Don't Let Them Shut You Down: Part 1

Don't Let Them Shut You Down: Part 1

Maintenance and Regulatory Compliance

Many maintenance organizations do not realize how they are affected by regulatory compliance. However, much of what Maintenance does has a direct affect on compliance with federal regulations and can cost the company millions of dollars if their actions cause an out-of-compliance situation.

Understanding this from within maintenance organizations varies from complete ignorance to maintenance by decree. The latter is a maintenance strategy that is defined by fear of the regulatory bodies and causes paralysis when trying to adopt proactive maintenance strategies. On both ends of the spectrum, reactive maintenance is the prevailing strategy and changing to a true proactive reliability program is very difficult. Regardless of their understanding of the regulations which governs their business, the maintenance program is most likely not mitigating equipment failures. This, therefore, leaves the organization open to risk and regulatory oversight.

New Regulations

When the unhappy constituents of a congressional district or local government entity call their representatives, it is often the starting point of new regulations. Specific events can also drive the government to draft new regulations or increase enforcement of existing ones. This call for action becomes, particularly, loud when people are hurt or killed because of corporate neglect.

It is important to understand how and why new regulations start because this understanding is the key to preventing further creation of new ones or heavy-handed enforcement of existing ones. Both of these things can be avoided if we as industrial professionals take a proactive approach.

There are many recent events that have caused significant news coverage and bad publicity for all of industry. Some events have led to congressional investigations. It is a bad day for maintenance and engineering when a CEO has to testify on Capitol Hill for a catastrophic equipment failure that affects the public. Maintenance has moved into the limelight, and is receiving public attention, perhaps for the first time in the history of “wrench turning”.

Case Studies

Many examples of maintenance culpability have been documented and reported on in the last several years. All of the events mentioned within many of the case studies written could have been avoided if a well-developed maintenance plan and reliability program were in place.

On April 4 2008, the FAA grounded Southwest Airlines 737-300 aircraft in order to perform airframe inspections. While there was no impact to the public in terms of safety, this event became high profile because of news reporting.



According to the investigation reports, Southwest had deferred several airframe inspections. These inspections were to identify cracks in the fuselage of a certain size. Upon closer examination of this case, it turns out that the inspection had been developed by Southwest and far exceeded the minimum requirements of Boeing. Even the FAA recognized this as a non-critical inspection and as such, issued a non-mandatory airworthiness bulletin.

“A progressive inspection for fuselage skin cracking was initially distributed to operators in the form of a "non-mandatory" Service Bulletin (SB) that provided "risk mitigation" actions that operators were encouraged to incorporate into their maintenance program. This Service Bulletin was based, in large part, on an inspection program developed by Southwest Airlines. …cracks in the fuselage skin on the Boeing 737 airplanes were identified and mitigated well before they could pose a safety of flight issue. …the FAA did not regard the skin cracking as an "immediate threat" to the safety of flight of the airplane.”

Even though the FAA deemed there to be NO Safety risk with these deferments, they fined Southwest Airlines $10MM and delayed thousands of passengers. The lesson to take away from this event is, “Do what you tell the regulators you are doing.”