Training and Work Performance Issues: Whose Responsibility is it?

By Thomas Sheckler

Many mechanics and repair station personnel have significant misunderstandings of the privileges and limitations of their certificates as related to their work performance and ultimate work product. For that matter, some aircraft maintenance organizations also experience confusion between individual privileges and limitations versus the organization’s duties (ratings, privileges, limitations, operation specifications, etc.), even though there may be large areas of overlap in responsibility. Often during discussion of these topics, members of the conversation tend to become polarized at one extreme or the other because of their own vested interests. The ill-informed and unsuspecting manager can become easily dragged along a futile ‘rabbit trail’ which may end in an unproductive contest of wills and ‘digging-in of heels.’ This scenario needs not occur. We, as supervisors, managers and directors, need to educate ourselves and define worker roles with specific expectations for performance. You don’t have to wait for a court date or letter of investigation from the FAA to get started in eliminating common workplace assumptions.

Issues of Confusion

There are too many issues to list in this article, but a few samples include:

•  My A&P certificate is protected since I work at a Part 145-certificated repair station; if something wrong happens, my personal certificate is never in jeopardy.

•  I’m forced to work on aircraft and/or articles using inferior tools owned by this repair station, since this has become a long-standing accepted norm; I don’t have a choice — I use only the resources available at the time.

•  Why should I pay for my own training to improve myself when I work for a manufacturer, repair station, air carrier or operator? It is not my job to better myself.

•  It’s the company’s duty to provide hearing and vision exams so that I may function at optimum performance levels when inspecting aircraft/articles.

•  My own time is my own business. It’s okay if I spend all day waterskiing on the lake and then go into night shift work already fatigued, despite current science correlating fatigue with human error events.

These are all good points to discuss at any local professional maintenance gathering or FAA Safety Team (FAASTeam) event. Bounce ideas off other maintenance managers/directors in similar organizations, and listen to others’ perspectives. You can learn a lot just by talking with and listening to peers within your industry. Note: what you may think should be ‘common sense’ may not be for others.

Become Better Educated:  “Accepted Industry Practices”

The first step is to study Title 14 of the Code of Federal Regulations thoroughly, particularly §§43.13, 65.81, 65.103, and Part 145 Repair Stations: Subparts C, D, and E, as applicable. Then, move on to studying any pertinent advisory circulars and industry best practices documentation that might be available. Don’t limit yourself to only aviation, but include policies enacted by other high-risk industries as well. “Performance rules” in Part 43 are a great place to start. Goal: to learn.

Re-examine your facility’s inventory of tooling and capabilities for all the work for which your station is rated. Scrutinize any special tool that might be suspect and validate its acceptance for use as a legitimate manufacturer alternate. Eliminate tools that consist of a ‘hodge-podge’ collection of parts ‘jerry-rigged’ for use. Check and confirm part numbers of special tooling to those listed in original equipment manufacturer’s manuals for special tools. Goal: to possess only acceptable tooling.

Inspect your organization’s work processes and policies. Look for documented standards for work performance. Think of the performance you expect from your technicians and repairpeople day in and day out at your facility. Begin to think of important expectations which are not specifically expressed in writing but should be. Jot down notes for further discussion and/or assessment for later review. Remember: any formal policy worth having should be spelled out, removing any vagueness or loopholes. Consider the possibility to refute an employee’s or customer’s claim of ignorance to some policy or issue which was never defined or expressed in writing. Goal: to define expectations.

Review all aspects of training your facility offers. Does all training reinforce and complement existing company policies relevant to the task being trained? Are the members who carryout on-the-job training good mentors who ‘go by the book’ every time? Goal: to ensure that training aligns with policy.

Look at your organization’s benefits and compensation packages critically, especially health insurance. If annual eye exams are available, is everyone who makes airworthiness decisions making use of this benefit yearly? Should it be a requirement to maintain authorization, qualification, and/or proficiency while working at your establishment? If so, then has this requirement been stipulated in an employee handbook or other formal company policy? It’s hard to enforce a rule that has never been written down. Goal: to account for worker condition and capability for quality work output.

Connect regularly with your working staff for valuable feedback. Be open to illumination of what is working and not working, and what tools/materials are sufficient and those that may be lacking. This small effort is also vital for employee buy-in, since you are demonstrating to them you are listening to their concerns. Try to move away from the old ‘us-versus-them’ mentality. Goal: too communicate with staff.

Define Roles and Specific Expectations:  “Privileges and Limitations”

What does it mean if an organization declares in its Repair Station Manual that it and its employees will always follow the FARs, OSHA, EPA and HAZMAT regulations, yet the organization never performs back checks of prior experience of “satisfactorily performed work” which occurred at an earlier date? Does §65.81 take the repair station ‘off the hook’ or is it still responsible for the work employees performed at its facility?

What does it mean for the individual who may be a shift leader (responsible for maintenance production) to simultaneously serve as a quality inspector (responsible for quality assurance) for work by his/her team? Could this be construed as a conflict of interest? What would it mean for a small team where no one has prior experience or training on a particular job at an earlier date? Who will perform the work? Who will inspect the work and approve it for return to service?

These questions can provide first-rate opportunities for the organization to begin demarcation of what actions are appropriate, not appropriate or unreasonable, thereby reducing uncertainty and unexpressed assumptions. Draft policies and procedures with rules that reaffirm the role of the organization and the roles of its employees, detailing both responsibility and accountability. Design methods to evaluate the success of said policies and procedures implementation periodically. Enforce these rules equally across the board. Make sure organizational leaders set the tone for responsibility and accountability. These kind of rules are not intended to take employee rights away from the workers, rather to provide more control of operations within the maintenance organization.

If your company will be accepting delivery of a new model or type of aircraft it has never had before, then come up with a plan beforehand. This plan should prevent role compromise at both the individual level and the organizational level. Consider OEM-recommended initial coursework for an employee for each shift. If the individuals selected will be the same ones conducting training for others, then it is crucial to choose these staff members carefully.

Ensure all training events demonstrate and complywith existing company policy guidelines on a consistent basis. All training (even on-the-job training) should be planned and deliberate, not by accident or happenstance. 

The manager of a maintenance organization needn’t bite off more than can he or she chewed. Begin at a general level of designing and implementing more defined company work policies that clearly lay down roles, responsibilities and expectations for both individuals and the organization. Make sure to get the word out to every worker so that no one slips through the crack. Update your policy manual and/or employee handbook periodically to reflect any significant changes in the your company’s work. Sometimes it’s okay to get out a magnifying glass to inspect a particular policy that may be a bit complicated, but avoid using a microscope!

This would be an excellent occasion to start integrating these new policies into the creation of a safety management system (SMS) and/or existing continuing analysis surveillance system (CASS). For smaller organizations, policy management, SMS, CASS, quality and reliability management can be woven into a single program of internal oversight. Why limit audits to merely safety, quality or reliability? Why not combine these efforts to reduce needless redundancy and lessen additional time expended toward these labors? Remember: everyone involved is a stakeholder, not just management personnel.

One other simple option is to utilize an existing credo or to create a specific code of conduct or mechanic’s creed, then have a formal signing event for universal agreement between workers and management staff. You may find that this endeavor, in whatever shape it takes, makes your maintenance organization run more smoothly when every improved policy item is spread open on the table, for all to see and to dispel rumors, myths and assumptions. 

Thomas Sheckler is president and senior consultant of Expert Aerospace Solutions LLC, a multi-disciplinary consulting agency specializing in aviation problem solving. EAS LLC engineers technical and nontechnical responses to issues like safety, compliance, training and quality interventions. Sheckler’s background includes aspects of flight and ground operations of fixed- and rotary-winged aircraft, having worked within several operational environments (i.e., Parts 91, 135, and 145, and military). He has undergraduate degrees in aircraft maintenance and aviation management and earned graduate degrees in system safety and human factors. As a former FAA aviation safety counselor (airworthiness), he continues to volunteer as a FAASTeam representative. Contact Sheckler by email at sheck1dd@hotmail.com.

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