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We began servicing N802VV and N803VV on February 5,

1996, and N830VV on February 13, 1996. On February 14, 1996, we

were first authorized to replace some oxygen generators that had exceeded their shelf life of 12 years. In the next few weeks, we ordered new generators from various vendors.

We were

subsequently authorized to remove and replace all cabin oxygen generators on N802VV and N803VV. Only a few needed to be replaced on N830VV.

Apparently,

In late April-early May, mechanics signed-off on the work cards indicating completion of the removal of the oxygen generators, including a representation that they had placed shipping caps on any removed, unexpended generators. removal of oxygen generators was a relatively rare task at SabreTech Miami. Based on our investigation, it would appear that no shipping caps were available at the time, and this procedure was not accomplished.

It appears, however, that the two mechanics who signed off the oxygen generator work cards, who were contract employees from separate companies, made a good-faith attempt to provide an equivalent level of safety. They either cut the lanyards or wrapped the lanyards and taped them around the generators, which is apparently how the new ones were secured when received. I have stated previously, however, that we cannot and will not tolerate any inaccurate representations on customer work order forms; these mechanics are no longer working at our Miami facility.

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In terms of precise numbers, it's still somewhat

unclear, but it would appear that six generators were removed

from N830VV, which were expended; 72 generators were removed from each of the other aircraft, N802VV and N803VV, for a total of 150 generators. After removal, the generators appear to have been stored in several cardboard boxes in a ValuJet-specific customer storage area.

On April 28, 1996, N830VV was redelivered to ValuJet. On May 1, 1996, N803VV was redelivered to ValuJet. On May 9 1996, N802VV was redelivered to ValuJet. In that same week, a SabreTech employee, apparently as part of an effort to straighten up the shop floor in advance of an inspection by a potential customer, prepared to return some of ValuJet's company materials. The return of ValuJet's company materials was standard procedure. On May 8, 1996, he redistributed the generators to equalize the number of generators in each box, placed bubble wrap on top, and sealed the boxes with tape. On May 10, 1996, the same clerk instructed another clerk to list the ValuJet company materials to be returned. In viewing the generators, this clerk saw the green "repairable" tag, which he apparently believed meant that the generators were empty and could be recharged.

Although this clerk appeared to know what the

generators were, he has told us that he did not know whether or not they were hazardous. At his instruction, the generators were listed as "5 boxes" "oxy canister" and on the following line "empty." The other company materials listed were a nose

wheel/tire assembly and two main tire assemblies.

Although the

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shipping ticket was dated May 10, 1996, apparently the driver was busy that day, and the materials were not returned until the next day. The driver drove along the interior service road, inside the airport restricted area, to the ValuJet ramp. He returned the company materials to a ValuJet employee, who signed for the goods and instructed our driver to place them on a baggage cart. Our employee then returned to our facility, and did not witness any further handling of the ValuJet-owned property.

In closing, Mr. Chairman, those are my observations and the facts to the best of my knowledge. We immediately initiated and continue to conduct our own internal investigation. I believe you know that we are cooperating fully with all of the formal investigations. The management and employees of SabreTech want to understand exactly what happened and take appropriate steps to further ensure the safety of the traveling public. That completes my prepared statement, Mr. Chairman. would be pleased to answer any questions you may have at this time.

Thank you.

I

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SabreTech

A Sabreliner Company

August 13, 1996

The Honorable John J. Duncan, Jr.

Chairman

Subcommittee on Aviation

Committee on Transportation and Infrastructure

2251 Rayburn House Office Building

Washington, D.C. 20515-6257

Dear Mr. Chairman:

Thank you again for the opportunity to testify before you on June 25, 1996 regarding the issues raised by the tragic crash of ValuJet Flight 592. We have filed today our corrections to the transcript of this proceeding. Please allow me to make three brief points for the record in response to the testimony and questions during this hearing.

First, Ranking Member Lipinski was correct in noting that ValuJet is ultimately
responsible for the performance of its maintenance. See 14 CFR §121.49 ("certificate holder
may make arrangements with another person for the performance of any maintenance...
[h]owever, this does not relieve the certificate holder of the responsibility"). Also, under Part
121, no airline employee may perform any assigned duties and responsibilities for the handling
or carriage of dangerous article unless "that person satisfactorily completed training regarding
the proper packaging, marking, labeling, and documentation of dangerous articles... and
instructions regarding compatibility, loading, storage, and handling characteristics." 14 CFR
§121.433a(a).

Second, recent reports in the media take issue with ValuJet's efforts to disclaim
responsibility for their loading of their hazardous company material on board their Flight 592.
As reported, ValuJet's own Hazardous Materials Training Manual states: "ValuJet Airlines
prohibits the carriage of hazardous materials on any aircraft," and that “[a]ll employees share in
the responsibility for preventing dangerous materials from being introduced on board our
aircraft." In a list of nine "common hidden hazards," that "should arouse your curiosity," the
first one mentioned is breathing apparatus cylinders. In contrast to ValuJet's House testimony on
June 25, its own manual unambiguously assigns responsibility: "It is the Airline
Representative's responsibility to know the contents of freight and COMAT shipments tendered
for shipments and to determine the acceptability of such commodities." Thus, ValuJet either

Sky Harbor International Airport 3737 East Bonanza Way Phoenix, AZ 85034 Phone 602-267-0660 Fax 602-273-8225

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knew or should have known about the dangerous nature of its own company materials that it loaded on board its aircraft.

Of course, since ValuJet was not authorized to carry hazardous materials, they should not have been placed on board the aircraft. During the hearing, ValuJet made much of the fact that Sabre Tech inaccurately stated that the oxygen canisters were "empty" when many were not, or that certain contract employees inaccurately stated that they had placed shipping caps on the canisters. The Sabre Tech ticket, however, clearly labeled the items as "Oxy canisters." Empty or full, oxygen canisters constitute a hazardous material. Again, according to ValuJet's own documents, these breathing apparatus "should arouse your curiosity," and should not have been placed aboard their aircraft. Unfortunately, neither their ramp agent nor the first officer, both of whom apparently reviewed the ticket that put them on notice of five boxes of oxygen canisters, did what they should have done--notify flight control and keep these hazardous items off the aircraft.

Third, regarding ValuJet's testimony that it warned Sabre Tech about the hazardous nature of its canisters and gave instructions for SabreTech to discharge and dispose of them as hazardous waste, this just is not true. The plain facts are that ValuJet's work order to Sabre Tech does not contain any instructions regarding the discharge or disposal of the generators. Indeed, in the over two months that the removed generators remained at SabreTech--in the daily presence of ValuJet personnel--ValuJet had ample opportunity to give clear, written instructions to Sabre Tech to discharge or dispose of the generators; it did not do so. No ValuJet document written before the crash contains any ValuJet instructions to SabreTech for discharge or disposal of the generators. And ValuJet's after-the-fact claims about warnings and instructions for discharge and disposal were categorically and immediately denied not only by Sabre Tech personnel, but also by ValuJet's own senior on-site technical representative.

Again, we commend the Committee for conducting this hearing in a highly professional and searching manner. We also commend the FAA and RSPA for moving quickly to prevent the carriage on board any passenger-carrying aircraft of any high-strength oxidizing substance, to increase staffing and training of its own hazardous materials personnel, and to insist on greater airline oversight of third-party maintenance. We all must await the results of the NTSB's hearing and probable cause determination. In the meantime, the key to effective and safe maintenance, whether performed in-house or by a third party, is clear communication.

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