References Barnett, A., "It's Safer to Fly," Risk Analysis, March 1992. Barnett, A. and M.K. Higgins, "Airline Safety: The Last Decade," Management Science, January 1989. ValuJet August 29, 1996 The Honorable William O. Lipinski Ranking Member, Subcommittee on Aviation Committee on Transportation and Infrastructure U.S. House of Representatives 2251 Rayburn House Office Building Washington, D.C. 20515 Re: June 25, 1996 Aviation Subcommittee Hearing Dear Representative Lipinski: At the June 25, 1996 hearing before the Subcommittee on Aviation, we discussed the maintenance manuals, work cards, and data sheets which inform SabreTech mechanics of the proper procedures for removing and disposing of oxygen generators from an MD-80 aircraft. As you requested, I am providing you, together with this letter, those documents for the hearing record and the written affidavit from a ValuJet employee who monitored SabreTech's work and the MD-80 aircraft. I have also attached the services agreement between ValuJet and SabreTech. I thought it would be useful to highlight in this letter the sections from these documents which are particularly responsive to your questions and the Subcommittee's inquiry. 1. McDonnell Douglas MD-80 Maintenance Manual. FAA regulations require SabreTech to utilize the McDonnell Douglas official Maintenance Manual when performing modifications to MD-80 aircraft. Specifically, chapter 35 provides: "This maintenance practice provides removal/installation procedures for the chemical oxygen generators." In addition to requiring the installation of safety caps (¶ 2(A)(2), at p. 201), the manual also mandates proper storage ("No oxygen generator (canister) is to be disposed of until it is initiated and chemical core is fully expended." Finally, it notes the "expended oxygen generator[s]... must be disposed of in accordance with local regulatory compliances and using authorized procedures, "¶2 (D)(1) & (2) (e), at pp. 204A-204B). 2. Material Safety Data Sheet. The McDonnell Douglas Maintenance Manual also requires Sabre Tech to refer to the material safety data sheet "(MSDS") of the oxygen generator's manufacturer. The MSDS provides, among other things, that (i) "generators must be spent prior to disposal," (emphasis in original), (ii) "the spent generators must be disposed of in accordance with all Federal and State regulations," and (iii) "it is the responsibility of the user [SabreTech] to comply with all Federal, State, and Local laws and regulations." (§ 13, p. 4; § 16, p. 5). 1800 Phoenix Boulevard / Suite 126/Atlanta, GA 30349 The Honorable William O. Lipinski 3. ValuJet Work Card 0069, ValuJet provided individual work cards to SabreTech that governed each modification to the MD-80 aircraft. Work card 0069, addressing the replacement of the oxygen generators, was actually drafted by McDonnell Douglas for ValuJet's use in the modifications. The work card contains in near-verbatim form the various warnings from chapter 35 of the MD-80 maintenance manual (e.g., activated generators produce temperatures of 500 degrees F), as well as instructions for the removal of the generators (e.g., safety caps must be installed prior to generator's removal). (It was these cards that SabreTech mechanics initialled as having installed safety caps on the generators, when, in fact, they failed to do so.) The work card also directed the SabreTech mechanics to chapter 35 of the MD-80 maintenance manual for guidance on the removal, storage, and disposition of the generators. 4. Affidavit of ValuJet Technical Representative. Richard D'Arcy was a ValuJet technical representative assigned to monitor SabreTech's modifications to the MD-80 aircraft. Mr. D'Arcy's May 20, 1996 Affidavit states that on three separate occasions, he indicated to Sabre Tech personnel, including managerial staff, that ValuJet did not want the outdated generators and they should be disposed of with the rest of SabreTech's hazardous waste. 5. Aircraft Maintenance Services Agreement. ValuJet and SabreTech entered into a services agreement whereby SabreTech provided maintenance and modifications to ValuJet aircraft. However, the services agreement explicitly provided that ValuJet would "have no supervision or control of [SabreTech's] employees engaged in providing the services hereunder" (¶ 8.30 at p. 9). Moreover, SabreTech warranted that all work provided to ValuJet would "be in accordance with the applicable standards, provisions, and stipulations of all pertinent Federal, State, and local laws, rules, regulations, and ordinances." (¶ 13.95 at p. 19). Thank you for your attention. Please feel free to include this letter in the hearing record prior to the attached documents, and please do not hesitate to contact me if you have any questions or need additional information. R MD-80 MAINTENANCE MANUAL CHEMICAL CYYGEN GENERATOR MAINTENANCE PRACTICES :. General A. This maintenance practice provides removal/installation B. C. D. Access to oxygen modules located in cabin attendant stations and lavatories is gained by inserting a small round pin shaped object through a hole in the module 2oor and pushing the latch release. Removal/installation procedures for all generators are Instructions for the storage (Ref. paragraph 2.C.) and aisposal (Ref. paragraph 2.D.) of generators are provided. Removal/Installation Chemici Oxygen Generator 2. A. Remove Generator WARNING: UNEXPENDED OX.GEN GENERATORS CONTAIN LIVE IGNITION NOTE: (1) Passenger overhead environmental panels contain unitized oxygen insert units. If generator is to be replaced in these units, remove and replace insert unit (Ref. 35-22-03). Manually open oxygen module door slowly, making certain that firing pin lanyards are free and will not pull firing pin on live generator. NOTE: Oxygen masks in forward attendant's modules will drop out if door is allowed to swing open (2) If generator has not been expended, install shipping cap on firing pin. (3) CAUTION: USE CAUTION NOT TO PULL OXYGEN GENERATOR FIRING Disconnect Ciriny pin lanyards from oxygen mask. EFFECTIVITY: JP ALL 35-22-01 THESE DATA SUBJECT TO RESTRICTIVE LEGEND ON TITLE PAGE. Page 201 Apr 1/91 |