07/01/96 Renato Lutz 10400 N. 77th Pl. Scottsdale, AZ 85258 Aviation Subcommittee 2251 Raymond Bldg. Washington D.C. 20515 Sir, In the past few weeks I watched once again the close scrutiny the FAA receives after a tragedy. I am one of those inspectors that Mr. Broderick had responsibility for. My 5 years in the agency and my previous background and education allow me to make some suggestions. The problems addressed by the committee are not simple ones and as you know, most complex problems have complex answers. Please consider the following: Require any FAR 121/135 certificate holders to charge a minimum amount for a passenger ticket per type of aircraft per hour operated. This money is to be used to perform a minimum amount of operations and maintenance training and certain percentage is to be used to operate the continuous maintenance and inspection program for that aircraft. For example if a B-727-200 is used as a baseline and requires X dollars per hour flown than a B-737-200 probably requires slightly less such as X x 0.95. Since deregulation has occurred the airlines are cutting each others throats. That's fine, few of us care if they make a profit. But most of us do care if they start cutting into safety. It doesn't matter what any CEO of any smaller carrier claims, the bottom line is that an American Air Lines or a United Air Lines, with all their resources, will always be safer than a Valujet with much more limited resources. As you all know, there are many other FAR 121 certificate holders who only operate 3 or 4 older B-727's and B-737's or DC10's etc. Some of them haul major sports teams. If any one of those crashes, it will make the Valujet crash look like it did not happen. In fact, it would easily overshadow a presidential aircraft crash or even an assassination. Look at O.J. Simpson. Need I say more? The government is laying to its citizens if we say that all FAR 121/135 certificate holders are equally safe. Lets level the playing field. If the above suggestion is not usable, lets establish a rating system as the movie industry has for its movies or the financial industry has for its bond ratings. Either the IG could rate them and publish the airlines ratings (they already have anyway) or better yet, may be the ATA would be willing to do it. In any case, this would be more favorable because then the consumer decides. They should be the ones who make the decision any way. May be the airlines could rate themselves as they do now with CASE evaluations. Establish probationary periods for all new start up certificates. I certificate a lot of certificate holders of all types. I have been involved in FAR 121/135 certifications in fact I am involved in several right now. I am also a principal inspector on FAR 121/135/145/147/etc. certificates. Once we issue a certificate it is very difficult to get back. A certificate holder may be up to speed the day they receive their certificate, but then they may drop off below the minimum level immediately there after as Valujet has. Even though they may be in violation, it takes much more effort to get the certificate back or hold it in suspension than it took to certificate the entity in the first place. A probationary period of 1 or 2 years would be extremely helpful. Of course this leads to the next problem. Restructure the FAA inspector pay system. Base it on merit not on complexity. If the above suggestion were implemented and it should be, then the inspector may not want to suspend or revoke the certificate because he/she may lose the amount of complexity required for the current pay grade. The current system is inherently crooked and a major conflict of interest. For example, if I am a principal inspector who has just certificated a FAR 121 carrier with 20 airplanes and they are way below minimums it is not in may interest to revoke their certificate because a 20 aircraft fleet allows me GS-14 pay. If this carrier runs out of business I may not have enough complexity to support may GS-14 and I may get reduced to a GS-13 pay as I should. Of course the good ol' boy network may not allow that to happen which is wrong in itself. If we base our pay on merit, then this conflict of interest does not occur and the public is better served. Merit is easily established. Merit is the performance of an individual as viewed by his team mates. In this case, the supervisors 25%, the peers 25%, the individual 25%, and the certificate holders 25%. As Mr. Steve Townes (President of SabreTech) said, whom I work with almost daily, "raise the standards of maintenance personnel". Lets stop treating them like oilers as they are known by arrogant pilots and lets raise them to the same levels as pilots. This would involve appropriate education levels, training levels, and recurrency training. Ratings for large aircraft may be an option. Of course this would also require the industry to pay commensurate salaries. The FAA FSDO's need to be run like a small business with global objectives set by HQ. The government can't move because of the layers of management who get in the way. Get rid of the Regions, distribute the specialists and support personnel amongst the FSDO's, and give each manager a budget to which strict adherence is required. A reward for moneys saved should be distributed amongst the employees who made it happen. The next fiscal budget should not be necessarily the same, and a manager should not get punished for not spending the entire budget as is status quo. Major budget decisions within the FSDO should be decided by a committee which consists of management and the employees. Local purchase is always encouraged. Lets stop the shotgun approach to safety solving. This process is soaked in human blood. What we need is a comprehensive review of all activities and processes by all people involved in this aviation business. I am sure that some one once before realized that oxygen generators, when stored in a mass, can produce enough thermal energy to create temperatures that will ignite most substances. Any one who has ever worked with epoxy knows this. Two or more substances mixed in small quantities that produce an exothermic chemical reaction when combined may generate temperatures of 300-400 degrees Celsius. The same substances mixed in large quantities can cause a fire or even an explosion. We need a system that allows knowledge like that to surface and to be reviewed and implemented. Finally, FAR 121.363 and 121.365 place all responsibility on the certificate holder. Few if any certificate holder programs, even those of large carriers, do not have adequate programs and systems that ensure that contractors perform in accordance with the certificate holders manuals. I know for a fact, and I can prove it, that some of the major carriers have nothing in their manuals that speaks about contracting out. For those who do have a section on the subject, it is usually very limited and ignored. It all cases marketing and accounting make the decisions in all carriers and most contractors. Those two levels meet but ops and the inspection or maintenance people are never asked how this transaction established by the bean counters should be executed. P.S. One of my favored speeches is that the FAA on behalf of the American public has given the operator the privilege to operate. I frequently give a clinic to the bean counter types that the company only exists because a certificate is hanging on the wall. A certificate that is highly regulated and can be removed permanently. I remind them that the pilots, mechanics, and flight attendants are the drivers and that every one else in the company is just there to support them in any way they can! I make sure that they understand that it is not the other way around in this business. It may be so in other endeavors. I also make sure that all of my operators understand that they are not my customer. They are my team mate. A team that works to produce a safe product. I tell them that the American public is my customer as well as theirs. This paragraph ought to be in every operation specification issued. Sincerely Penati lit I am writing to you on the following matter. I am enclosing herewith an article "LET US INTRODUCE A NEW MEASURE OF FLIGHTWORTHINES: PRIFETY-PRICE TIMES UNSAFETY". It is dedicated to the ValueJet 592 disaster, and proposes to introduce PRIFETY (a term which I coined specially for this purpose) to quantify the flightworthness. In particular, I propose that the newspapers would publish the FAA information on the (a) number of broken parts, (b) number of malfunctioning systems, (c) inadequate repairs, (d) number of canisters, (e) number of false reports, identified during the most recent week, for each airline, each week of the year. The sum of these numbers (or, may be, of additional measures of unsafety) will be utilized as an integral measure of unsafety. The price of the ticket times the unsafety plus one will constitute prifety. Having such an information published in newspapers may provide an additional impetus for the airlines to work to decrease the failure index, rather than just try to decrease the price. My thoughts, in this manuscript, were inspired by reading your comment (which is quoted in the manuscript):" IF VALUEJET WAS UNSAFE, WHY WASN'T IT GROUNDED SIX MONTHS AGO?". In my article I am trying to provide some common sense means towards the goal indicted in your question: Once the pertinent info is uniformly and regularly available, FAA will be grounding airlines more rigorously. I am looking forward to hearing from you at your earliest convenience. Sincerely yours, Teac Isaac Elishakoff IE/tp PS: I am simultaneously sending this article for possible publication in the Boca Raton Fort Lauderdale Davie Palm Beach Gardens Fort Pierce An Affirmative Action/Equal Opportunity Institution WRITTEN ESPECIALLY FOR THE "NEW YORK TIMES" July 3, 1996 Let Us Introduce A New Measure of Flightworthiness: Price Times Unsafety by Isaac Elishakoff Dr. I. Elishakoff is a Professor of Mechanical Engineering at Florida Atlantic University in Boca Raton. He is an author, co-author or co-editor of 15 books and over 200 papers on safety and reliability of structures, and effect of human error. |