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Overview of the Maintenance Mechanic Certification — General

Technician (by 14 CFR Section)


The Mechanic Certificate — Maintenance 65.3  Certification of Foreign Airmen Other Than
Technician Privileges and Limitations Flight Crewmembers
Since part 65 was covered only briefly in Chapter 12, it Normally, the FAA issues these certificates only to U.S.
was left for this chapter to develop it more completely. citizens or resident aliens residing in the United States.
Therefore, this chapter discusses the Federal Aviation However, on occasion if the FAA determines that the
Administration (FAA) regulation governing the certifi- issuance of a certificate to a person located outside of
cation of airmen other than flight crew members. This the United States is necessary for the operation and
chapter is based on the material contained in Title 14 continued airworthiness of a U.S.-registered civil air-
of the Code of Federal Regulations (14 CFR) part 65, craft, it will issue a certificate to that person, providing
which has the following subparts: they meet the necessary requirements.

• Subpart A — General 65.11  Application and Issue


• Subpart B — Air Traffic Control Operators Any person who meets the criteria for obtaining a
• Subpart C — Aircraft Dispatchers mechanic certificate must apply by means of a form
and in a manner prescribed by the Administrator. That
• Subpart D — Mechanics form is FAA Form 8610-2, Airman Certificate and/or
• Subpart E — Repairmen Rating Application. If a mechanic has had a certificate
• Subpart F — Parachute Riggers suspended, they may not apply for additional rat-
ings during the time of suspension. A revocation of a
This chapter will only focus on the certification of mechanic certificate prevents that person from apply-
maintenance technicians, and therefore subparts B, C, ing for a certificate within a period of 1 year after the
E, and F will not be addressed. revocation.
The FAA certifies two separate categories of mainte- 65.12  Offenses Involving Alcohol and Drugs
nance technicians, mechanic and repairman. Any person, who has been convicted of violating
The fundamental difference between these two is that federal or state statutes relating to drug offenses, can
the mechanic certificate is transportable, is issued to the be denied their application for a certificate or rating
technician based upon his or her training and knowl- up to 1 year after the date of conviction. The violation
edge, and is not dependent on the technician’s location. can be relating to any one or more of the following
Although the repairman certificate is also based upon actions: growing, processing, manufacturing, selling,
the training and knowledge of the technician, it is disposing, transporting, or importing narcotic drugs,
specifically issued to that technician while he or she is marijuana, depressants, or stimulants. They may also
employed at a distinct location of a specific company. face the suspension or revocation of any certificate that
This certificate carries a literal address where he or she they currently hold.
is authorized to work using his or her repairman skills.
65.13  Temporary Certificate
When the technician is no longer employed there, the
repairman certificate must be returned to the Flight A qualified applicant who successfully passes all
Standards District Office (FSDO) that issued it. required tests (a minimum score of 70 percent is
required) may be issued a temporary certificate, which

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is valid for not more than 120 days. During this time, also be suspended or revoked. Unacceptable conduct
the FAA will review the application and supplementary for written tests consists of:
documentation, and will issue the official certificate
and rating. • Copying or intentionally removing the test.
• Giving or receiving any part of a copy of the
65.14  Security Disqualification test.
This section was added following the terrorist attacks • Giving or receiving help during the test taking
of September 11, 2001. It basically states that anyone period.
determined by the TSA to be a security threat will
• Using any material or aid during the test taking
either have their application held if they are applying
period.
for a certificate, or have the certificate that they do
hold revoked. • Intentionally causing, assisting, or participating
in any of the previous acts.
65.15  Duration of Certificate
65.19  Retesting After Failure
Mechanics certificates are effective until they are sur-
rendered, suspended, or revoked. The difference in Should the mechanic or repairman fail to achieve
these terms can be summarized briefly this way: the required minimum passing grade, there are two
options they may consider when desiring to apply for
• Surrendered means given up voluntarily. retesting:
• Suspended means the FAA temporarily removed
• Wait a period of 30 days after the date of test
the certificate from the holder.
failure.
• Revoked means the FAA permanently removed
• Seek additional instruction in the subject matter
the certificate from the holder.
areas he or she failed, and provide a signed
65.16  Change of Name: Replacement of Lost or statement from the certificated technician
Destroyed Certificate providing the instruction.
If the technician changes his or her name, or is seek-
65.20  Applications, Certificates, Logbooks,  
ing a replacement certificate, an application must be Reports, and Records: Falsification,
submitted to the FAA at: Reproduction, or Alteration
Federal Aviation Administration In 14 CFR part 43, paragraphs 9 and 11, defines the
Airmen Certification Branch (AFS-760) requirements for a technician to make appropriate
P.O. Box 25082 entries in the maintenance/inspection records for the
Oklahoma City, OK 73125 work performed. This proper documentation is funda-
mental to safe and efficient operation of the U.S. civil
There is a charge for this service. aircraft fleet. Therefore, the FAA takes strong action
against those who would participate in the falsification
65.17  Test: General Procedure of those records. The following actions are the basis for
The FAA has designated certain persons to administer suspending or revoking any certificate or rating held
the tests associated with obtaining a mechanic certifi- by the person invoked:
cate. The minimum passing score for these tests is 70
percent. • Fraudulent or intentional false statement on an
application.
65.18  Written Tests: Cheating or Other • Fraudulent or intentional false statement in any
Unauthorized Content logbook, record, or report required to show
If the mechanic or repairmen applicant is determined compliance with any certificate requirements.
to be cheating, or otherwise involved in unauthorized • Any reproduction (for fraudulent purposes) of a
conduct, they are not eligible for any certificate or certificate or rating.
rating under this chapter for a period of 1 year. Fur-
thermore, current ratings the person already holds may • Any alteration of any certificate or rating under
this part.

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65.21  Change of Address Mechanic Certification —Specific
If the technician changes his or her address, the FAA (by 14 CFR Section)
(at the address shown below) must be notified in
65.71  Eligibility Requirements: General
writing within 30 days after the change of permanent
residence: The requirements for obtaining a mechanic certificate
are:
Federal Aviation Administration
Airmen Certification Branch (AFS-760) • Be at least 18 years of age.
P.O. Box 25082 • Be able to read, write, speak, and understand
Oklahoma City, OK 73125 the English language. (Note: If the applicant
does not meet this requirement and is employed
65.23  Refusal to Submit to a Drug or Alcohol Test outside the United States by a U.S. carrier, the
Any technician who refuses to submit to a drug test, certificate will be endorsed “valid only outside
which is required by 14 CFR part 121, appendix I or J, the United States.”)
is subject to denial by the FAA of any application for • Have passed all the required tests (written, oral,
additional certification or ratings, and suspension or and practical) within the preceding 24 months
revocation of any existing certificate or rating he or she from application.
currently holds. Appendix I of part 121 is titled Drug
Testing Program, and requires a urine sample from the • Possess and demonstrate the appropriate
employee. Appendix J is titled Alcohol Misuse Preven- knowledge and skill for the certificate rating
tion Program and requires that the employee submit to being sought.
a breath test. Each appendix contains a “Definitions” If a technician has one of the ratings, and desires to
section and a section titled “Employees who must be add the other, he/she must meet the requirements set
tested.” Persons involved with “Aircraft maintenance forth in section (§) 65.77, and take the written, oral,
or preventative maintenance duties” are listed in both and practical tests within 24 months.
appendices. There are various types (or rather times)
when testing is required. 65.73  Ratings
• Pre-employment The FAA recognizes two ratings, airframe and pow-
erplant, which may be obtained by a person upon suc-
• Periodic cessful application and testing. These may be attained
• Random either individually, or as a combined certificate.
• Post-accident
Any person holding an aircraft (A) or aircraft engine
• Testing based upon reasonable cause (E) certificate prior to June 15, 1952, and which was
• Return to duty testing valid on that date, may exchange it for the correspond-
• Follow-up testing ing current certificate. If both ratings were held, the
A & E certificate may be exchanged for an A & P.
The numerous test methods and the harsh penalty
imposed by the FAA on those who would involve them- 65.75  Knowledge Requirements
selves with these unauthorized substances, or abuse the Any applicant meeting the experience requirements
allowable use of alcohol indicates the concern that the listed in 65.77 must pass a written test (minimum
FAA has for the possible impairment of technicians. passing score of 70, reference §65.17) covering the
Aviation maintenance is a professional career choice construction and maintenance of aircraft. Applicable
that demands the highest caliber technical person portions of 14 CFR 43 and 91 are also included in the
to be capable of functioning at his or her maximum testing. Basic principles for the installation and main-
potential. There is no room in this profession for a tenance of propellers are included with the testing that
person to be involved with substance abuse. By doing is administered for the powerplant rating. Successful
so, the technician not only endangers themselves, but completion of the written test is required before the
their co-workers, and ultimately the customer who is candidate may apply for the oral and practical tests
expecting to have an airworthy aircraft delivered fol- identified in section 65.79.
lowing a maintenance activity.

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65.77  Experience Requirements manuals and/or instructions for continued airworthi-
Each mechanic applicant must have a certificate of ness for the task he or she is accomplishing.
completion from an FAA certified technician school
65.83  Recent Experience Requirements
(14 CFR part 147) or provide documented evidence of
a minimum of 18 months practical experience related to In addition to having the proper documentation, the
either airframe or powerplant maintenance (30 months mechanic is required by this regulation to have recent
required if applying for certification for both airframe and relevant work experience. Although, as it was
and powerplant). stated earlier in this chapter, the A & P certificate is
valid until it is surrendered, suspended, or revoked, it
65.79  Skill Requirements may not be exercised if the holder has not been actively
Oral and practical tests to determine the applicant’s working as a mechanic at least 6 of the preceding 24
basic knowledge and skills necessary for the certificate months. This activity can be any one of the following,
or rating sought are required to be completed after the or any combination of them:
applicant has successfully completed the written test. • Served as a mechanic under the certificate and
Minor repairs and minor alterations to propellers are rating
required to be demonstrated as part of the powerplant
rating. • Technically supervised other mechanics
• Supervised (in an executive capacity) the
65.80  Certificated Aviation Maintenance maintenance or alteration of an aircraft
Technician School Students
Whenever satisfactory evidence is shown to the FAA 65.85  Airframe Rating: Additional Privileges
that a student enrolled in an aviation maintenance A mechanic who holds an airframe rating may approve
training school certificated under part 147 is making and return to service an airframe, an appliance, or any
satisfactory progress, that student may take the oral related part after he or she has performed, supervised,
and practical tests required by paragraph 79, prior or inspected minor repairs or alterations. He or she
to completing the school (as required by paragraph may also perform the maintenance actions required
77) and prior to taking the written test required by for a major repair or alteration, and should initiate
paragraph 75. the appropriate form (FAA Form 337, Major Repair
and Alteration) associated with that work. However,
65.81  General Privileges and Limitations the return to service action must be accomplished by
Once a technician becomes a certificated mechanic, a certificated A & P technician holding an Inspection
he or she may perform or supervise the maintenance, Authorization (IA). (Refer to 14 CFR §65.95.) The
preventive maintenance, or alterations of an aircraft airframe mechanic is also authorized to perform the
or appliance (or part thereof) for which he or she is 100-hour inspection (if required per 14 CFR part 91
rated. However, he or she is not permitted to perform §91.409) on the airframe.
major repair or major alterations to propellers nor
accomplish any repair to or alteration of instruments. The FAA recently added a new category of aircraft
These activities are reserved for certificated repairmen called Light Sport. (Refer to 14 CFR part 21, §21.190.)
at an authorized repair station. Also, he or she may not A certificated Airframe technician can approve and
supervise the maintenance, preventive maintenance, or return to service the airframe after performing and
alteration of any aircraft or appliance (or part thereof) inspecting a major repair or major alteration. The work
for which he or she is rated, unless he or she has satis- must have been done on products that are not produced
factorily performed this work at an earlier date. This under FAA approval (i.e., are not type certificated)
is where the benefit of keeping an on the job training and must have been performed in accordance with
(OJT) log cannot be overemphasized. Whether the instructions developed by the manufacturer or person
technician attends a part 147 maintenance training acceptable to the FAA.
school or receives the required number of months as
practical experience, he or she has only scratched the 65.87  Powerplant Rating: Additional Privileges
surface of the tremendously complex world of aviation Similarly, a mechanic holding a powerplant rating has
maintenance. The technician must either work with the same limitations imposed regarding the powerplant
someone (like a shop mentor) or must perform the and propeller as the airframe technician has on the
task satisfactorily for the FAA. The certified mechanic airframe rating. He or she may perform and return to
must have and be able to comprehend the maintenance service minor repairs or alterations. He or she may also

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accomplish the work activities required for a major The minimum passing score for the computer test is 70
repair or alteration, but the work must be signed off for percent. If the applicant fails the test, retesting cannot
return to service by an IA. The privilege of perform- be attempted until a minimum of 90 days have elapsed
ing a 100-hour inspection (if required by part 91) on a from the failure date. Unlike the A & P test, there
powerplant or propeller is also authorized. is no reduction in this time if the applicant receives
additional training.
A certificated Powerplant technician can approve and
return to service a Light Sport powerplant or propeller 65.92  Inspection Authorization: Duration
after performing and inspecting a major repair or major An IA certificate expires on March 31 of each odd num-
alteration. The work must have been done on products bered year, but may only be exercised during the time
that are not produced under FAA approval (i.e., are not the technician holds a currently effective mechanic
type certificated) and must have been performed in certificate. The IA ceases to be effective if:
accordance with instructions developed by the manu-
facturer or person acceptable to the FAA. • The technician surrenders it, or it is suspended or
revoked.
65.89  Display of Certificate
• The technician no longer has a fixed base of
Once a technician receives his or her mechanic certifi- operations.
cate, the certificate must be kept in the immediate area
• The technician no longer has the required facilities
where he or she normally conducts work and exercises
equipment or inspection data available.
the privileges of the certificate. When requested, the
technician is required to present the certificate for Whenever the certificate is suspended or revoked, the
inspection to the FAA, or any authorized representa- technician must return it to the Administrator when
tion from the National Transportation Safety Board requested by the FAA to do so.
(NTSB), or any federal, state, or local law enforce-
ment officer. 65.93  Inspection Authorization: Renewal
An IA certificate may be renewed in one of the fol-
Inspection Authorization lowing ways each year the technician is seeking
(by 14 CFR Section) renewal:
65.91  Inspection Authorization • The performance of at least one annual inspection
An A & P mechanic who has held his or her certificate for each 90 days the technician has held the IA
for at least 3 years, and has been active for the last 2 rating.
years, may submit application using FAA Form 8610-1, • The performance of the inspections of at least
Mechanic’s Application for Inspection Authorization, two major repairs or alterations for each 90 days
to the FAA for consideration as an IA. In addition to the technician has held the IA rating. (Note: The
the preceding time requirements, the IA candidate inspections can be counted regardless of the
must have: approval or disapproval of the work.)
• A fixed base of operation where he or she can be • The performance (or supervision) and approval
located in person or by phone. of at least one progressive inspection.
• Available equipment, facilities, and inspection • The attendance and successful completion of a
data necessary to properly inspect the airframe, refresher course (acceptable to the Administrator)
powerplants, propeller, or any related part or that is at least 8 hours of instruction. This can be
appliance he or she will be approving for return either a single day seminar or a combination of
to service. individual classes acceptable to the Administrator.
Some seminars are sponsored by the FAA FSDOs
The applicant who meets all the above criteria must and are free; others are low cost. Private industry
then pass a written (computerized) test to determine also frequently conducts one-day sessions and
his or her ability to inspect the airworthiness of an usually charge for their efforts. Regardless of who
aircraft following either a major repair or alteration is conducting the seminar, it is usually an excellent
action or the performance of an annual or progressive way to accomplish renewal, learn about new
inspection. issues, and develop a network among peers.

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No renewal is required for someone who received the before beginning to exercise the privileges of an IA.
IA during the first quarter of the calendar year, since Although it is not required, good business etiquette and
the regulation states that anyone holding an IA for professional responsibility would suggest that a simi-
less than 90 days need not meet the preceding renewal lar letter be written to the responsible FAA principal
requirements. maintenance inspector (PMI) at the FSDO in the area
he or she is leaving.
It should be noted that regulations clearly state the
number of annual inspections and major repair or
alteration inspections required for renewal are for each
Ethics
90-day period and not in each 90-day period. Therefore, This is a tremendously broad and diverse area of
an IA could actually go 11 months without perform- study. It is also an area that is coming under more
ing any inspection activity relative to renewal. Then, scrutiny by consumers, individual watchdog groups,
in March he or she could conduct all four necessary and government review committees. Ethics, or more
annual inspections, or all eight 337-related inspections. appropriately the lack of ethics, has caused the loss of
The regulations do not provide for the mixing of any millions of dollars through fraudulent accounting prac-
of these renewal activities (i.e., two annual inspections tices, shoddy workmanship, etc. This chapter examines
and four Major Repair and Alteration forms). some definitions of ethics and some examples of poor
business ethics in order to raise the awareness of the
Another method of renewal is to meet with the FAA- technician to the importance of ethics.
assigned FSDO inspector who will determine that
the applicant possesses current knowledge of the The word “ethics” is actually a philosophical term that
applicable regulations and standards. Although this comes from the Greek word “ethos,” which means
is often considered the renewal method of last resort, character or custom. So, it is logical that a current
it should not be considered a negative experience. If definition of ethics is “the study of standards of conduct
the IA has been performing his or her activities in a and moral judgment.” Although situations involving
professional manner throughout the year, this session questionable ethics can exist wherever and whenever
can be considered a professional follow-up or consulta- business decisions are made, the scope of this discus-
tion. Proper IA-to-FSDO inspector interaction can be sion is limited to areas with which the technician will
enhanced with such a meeting. probably be associated.

65.95  Inspection Authorization: Privileges and A Scenario


Limitations The following incident illustrates one way that both
The IA may perform an annual inspection, or perform personal ethics and technician knowledge of regula-
or supervise a progressive inspection. He or she may tions can work together to provide him or her with
also approve for return to service any aircraft related the ability to make the right decision. Unfortunately,
part or appliance which has undergone a major repair others in that shop did not appear as concerned as the
or alteration (except aircraft maintained in accordance technician sharing the incident.
with a continuous airworthiness program operated
under part 121). A technician working for an airline was involved in
a situation that required a repair or replacement of a
The IA must keep his or her certificate available for fuselage ice shield. The computer inventory indicated
inspection by any one of the following persons: that a replacement part was in stock, so the technician
removed the damaged component. It was then found
• Aircraft owner
that the replacement part was not actually in stock. At
• A & P technician this point, a crucial decison was to be made: Can the
• FAA Administrator damaged item be reinstalled? The steps in properly
• Authorized representative of the NTSB documenting a maintenance event are to record the
removal of the damaged part, then document the instal-
• Any federal, state, local, or law enforcement lation of an airworthy part. Once the technician has
officer committed to removing the damaged part, it becomes
If the holder of an IA moves his or her fixed base of unairworthy and cannot be reinstalled regardless of its
operation, he or she must notify in writing the FSDO deferability in the minimum equipment list (MEL).
responsible for the location he or she is moving to,

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The actual sequence of events is as follows: had queried and believed a replacement part was
immediately available.
Significant impact damage to the ice shield was
observed and recorded. 3. The inspector was either unaware of regulatory
requirements or simply did not care.
The inspector reviewed and instructed the technician 4. The second technician was either unaware of
to replace the ice shield. regulatory requirements or simply did not care.
Availability of the replacement part was confirmed Final Observation
by computer.
The underlying company culture was apparently
The damaged part was removed, and the technician lacking concern for ethical decisions and regulatory
prepared the surface for the replacement part. compliance. An effective organizational culture should
always encourage ethical behavior and discourage
The new part was ordered from inventory, but the part unethical behavior. This means that not only does the
was not in stock. (Inventory Error) upper management of an organization say that they
conduct themselves ethically, they must do it con-
The inspector instructed the technician to reinstall the
sistently; employees, customers, vendors, and even
old one.
competitors should know this company has “high
The technician refused. ethical standards.”

The inspector instructed the technician to repair it. This latter issue may sometimes have painful con-
sequences, if the businesses are competing for a
The technician researched the structural repair manual customer’s business. The ethical company may esti-
(SRM) and found that the facility did not have the mate the maintenance activities to take 8 weeks and
proper facility authorization to repair the damaged quotes that time frame to the customer. The unethical
part. company may also know the work will take 8 weeks,
but tells the customer only 6 weeks, hoping to get the
The inspector told the technician to apply 5-minute job. Once the plane is “captured” and maintenance has
epoxy to the area, sand it down, and paint it. begun, explanations and excuses extend the original
The technician walked away. time estimate of 6 weeks to the actual 8 weeks or lon-
ger. Although the customer would be disappointed in
The inspector found someone else to compromise this situation, few customers would be able to remove
standards. The aircraft departed on time — illegal and an aircraft undergoing maintenance. This “bait and
unairworthy. switch” tactic is often used by unscrupulous companies
to get an aircraft into their shop no matter what it takes.
This happens more often than one would like, is prob- Although the shop’s retention of clients is frequently
ably overlooked by many people, and, unfortunately, very low, there always seem to be new ones willing to
might be considered standard operating procedure accept a shorter-than-normal turnaround time quote.
(SOP) for some maintenance facilities. It is the Often these same shops will underbid the job, and then
responsibility of the mechanic to follow regulations continually add extra costs as the work progresses.
and to question the actions of his or her supervisors if The technician is encouraged to avoid employment
the policy is to circumvent rules to make an on-time at maintenance facilities that do not think twice about
departure. trying to deceive the customer.
This incident provides some valuable insights into how Since companies are usually in business to make
day-to-day events can lead to pressure to produce and money, the “bottom line” mentality frequently drives
ultimately compromise the decision-making. management, and ultimately technician decisions.
1. The incident occurred while working for a com- But short-term, quick-fix solutions that focus only
mercial airline. The pressure for getting the aircraft on immediate financial success promote the idea that
in the air is tremendous in this environment. everything boils down to monetary gain. Ethical behav-
ior is not about monetary gain.
2. Inventory error added to the pressure. The damaged
part had been removed because the technician

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In addition to monetary gain, there are other common Some of the ethical conflicts that are evident in this
ways that unethical behavior is rationalized: situation are:

• Pretending that the behavior is not really unethical • Young engineer (newly hired) feels intimidated
or illegal by senior level engineer.
• Excusing the behavior by saying it is really in the • Early brake failure during development testing is
organization’s (or the technician’s) best interest excused away because “they are not representative
• Assuming the behavior is okay because no one of the final design.”
else would even be expected to find out about it • A company culture of intimidation and distrust.
• Expecting your superiors to support and protect Most of these conflicts could have easily occurred in
you if anything should go wrong (Gellerman the maintenance realm also, if the specifics are broad-
1986) ened, even a little.
This latter point often leads to a significant surprise • Change the word “engineer” to “maintenance
for the individual technician if he or she compromised technician.”
his or her standards at the encouragement of manage-
ment to get the job done. Should there be a problem • Instead of brake failure during development
with maintenance and subsequent airworthiness of testing, think of component test failure (with the
the aircraft, the very same managers or superiors who shop norm of “we don’t follow the manual on this
directed that technician to shortcut proper maintenance step; we have developed our own (unauthorized)
procedures would testify in court that they always procedure here.”)
encouraged their employees to work “by the book” and • The existence of a company culture of intimidation
never encouraged unauthorized shortcuts. and distrust transcends all lines of business.

Ultimately, every organization establishes a climate, or For a company to nurture a healthy ethical climate
culture regarding honesty, integrity, and ethical behav- and long-term success, the element of trust is funda-
ior. This corporate climate sets the tone for decision mental both inside and outside the organization. This
making at all levels and in all circumstances. This leads trust will boost employee morale, and usually boosts
to the second business example, the Aircraft Brake productivity and, therefore, profitability. It will also
Scandal. It is a classic case of both personal ethics and aid and enhance long-term business relationship with
“whistle blowing.” A brief review of the pertinent facts customers and vendors.
in the incident is as follows.
When differences of opinion do exist, ethical organiza-
A young engineering technician is in charge of con- tions pay close attention to those who are dissenting.
ducting the required qualification testing for a newly Those companies that are committed to promoting
designed brake and rotor system. An aggressive time an ethical climate will encourage rather than punish
schedule and an upper management mindset of not dialogue and debate about policies and practices.
wanting to hear bad news (i.e., the brakes are failing
tests), a senior engineer who is not willing to have his It is encouraging to note that more and more institu-
computations challenged, and a project manager who tions of learning, whether business schools or technical
states the brake will be qualified “no matter what,” colleges, are adding ethics courses into their required
ultimately lead to a congressional oversight hearing in curriculum. More and more organizations are develop-
1969. Along the way, the brake system is tested (and ing a corporate “code of ethics.” Some are using the
fails 14 times), no one wants to write the required test following seven-step checklist to help employees deal
report, low level employees seek legal advice, and the with an ethical decision:
aircraft suffers serious damage during landing while 1. Recognize and clarify the dilemma.
conducting initial flight testing, due to unsatisfactory
braking. 2. Get all the possible facts.
3. List options — all of them.

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4. Test each option by asking such questions as: Human Factors
— Is it legal?
FAA Involvement
— Is it right?
The FAA has had a formal involvement in this issue
— Is it beneficial? since 1988. That was the year the first Human Fac-
5. Make your decision. tors Issues in Aviation Maintenance and Inspection
6. Double check your decision by asking: National Conference was conducted, and that effort
reflects a working relationship between government
­­— How would I feel if my family found out research and industry activity. This yearly event
about this? includes airlines, suppliers, manufacturers, schools,
— How would I feel if my decision is printed in and government agencies. There is also an FAA website
the local newspaper? for human factors at http://hfskyway.faa.gov/ which is
7. Take action (Schermerhorn 1989). a tremendous resource.

Finally, the technician is encouraged to read the follow- Importance of Human Factors
ing code of ethics developed by Professional Aviation The greatest impact in aircraft safety in the future will
Maintenance Association (PAMA), Inc., and consider not come from improving the technology. Rather it
adopting it as their own. will be from educating the employee to recognize and
prevent human error. A review of accident related data
“As a certified technician, my performance is a indicates that approximately 75 – 80 percent of all avia-
public service and, as such, I have a responsibility tion accidents are the result of human error. Of those
to the United States Government and its citizens. I accidents, about 12 percent are maintenance related.
must ensure that all citizens have confidence in my Although pilot/co-pilot errors tend to have immediate
integrity, and that I will perform my work according and highly visible effects, maintenance errors tend to
to the highest principles of ethical conduct. Therefore, be more latent and less obvious. However, they can
I swear that I shall hold in sacred trust the rights and be just as lethal.
privileges conferred upon me as a certified technician.
The safety and lives of others are dependent on my Definitions of Human Factors
skill and judgment; therefore, I shall never knowingly Human factors is concerned with optimizing perfor-
subject others to risks which I would not be willing to mance … including reducing errors so that the highest
assume for myself, or those who are dear to me. level of safety is achieved and maintained.
“As a certified technician, I am aware that it is not — Ron LoFaro, PhD
possible to have knowledge and skill in every aspect FAA
of aviation maintenance for every airplane, so I pledge
that I will never undertake work or approve work which Human factors is the study of how people interact with
I believe to be beyond the limits of my knowledge. I their environments.
shall not allow any superior to persuade me to approve — FAA-H-8083-25,
aircraft or equipment as airworthy when there is doubt Pilot’s Handbook of Aeronautical Knowledge,
in my mind as to the validity of my action. Under no dated 2003
circumstances will I permit the offer of money or other Human factors are those elements that affect our
personal favors to influence me to act contrary to my behavior and performance, especially those that may
best judgment, nor to pass as airworthy aircraft or cause us to make errors.
equipment about which I am in doubt.
— Canadian Department of Defense (video)
“The responsibility that I have accepted as a certified
technician demands that I exercise my judgment on Our focus is on human factors as it relates to improper
the airworthiness of aircraft and equipment; therefore, actions. Note, however, that human factors exist in
I pledge unyielding adherence to these precepts for both proper and improper actions. [Figure 13-1] Since
the advancement of aviation and for the dignity of my improper actions usually result in human error, we
vocation.” should also define that term.

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Figure 13-1. Human factors exist in both proper and improper actions.

Human error is the unintentional act of performing a of fatigue on quality and productivity, it was not incor-
task incorrectly that can potentially degrade the system. porated into aviation until many years later.
There are three types of human error:
During WWII, “human factors” was more broadly
1. Omission: not performing an act or task. defined, and encompassed crew coordination and
2. Commission: accomplishing a task incorrectly. machine design. Flight crew management was studied,
and there was significant information gained about
3. Extraneous: performing a task not authorized.
group dynamics and stress. The Army Air Corp. even
There are also four consequences of human error: redesigned cockpit controls. But, unfortunately there
was no similar study conducted in maintenance opera-
1. Little or no effect. tions, and mechanics were generally seen as individual
2. Damage to equipment/hardware. contributors, and screened only for their technical
competency.
3. Personal injury.
4. Catastrophic. Unfortunately, all the “lessons learned” in the WWII
studies of group dynamics, and flight crew communica-
Brief History tion were seemingly forgotten after the war. Post WWII
Although Human Factors Management is sometimes aircrew studies continued to focus primarily on flight
thought of as a relatively “new” science, it can actually crews, especially pilot selection, simulator training,
be traced back to the early 1900s. (Refer to AC 120- and cockpit layout and design.
51A, Crew Resource Management (CRM) Training,
dated 1993.) During WWI, human factors was defined Subsequent studies of the technician focused on his
as individual skills and abilities. Most of that early or her individual competency, and included equip-
focus in aviation was on the pilot and his or her func- ment design (ergonomics). The Vietnam Conflict
tions. Specifically, things like technical proficiency, brought the quest for greater safety, and with that,
intelligence tests, and how “fearless” a volunteer came a systematic approach for error reduction.
was — were the important issues to consider. For the This increased attention brought both good and bad
next 20 years, these core factors guided the pilot selec- changes. It led to the “Zero Defects” quality programs
tion process. Although there was some learning that in maintenance and manufacturing. Generally, this had
occurred in British munitions plants about the effects a positive effect. However, it also led to “crackdown

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programs” which were one-way communication from A detailed review of aviation literature published
management (the infamous “my way or the highway” between 1976 and 1987 had very little to say about
approach). This concept is more dictatorial than maintenance. Out of 50 published articles, only 15
democratic, and typically had a long-term negative even mention maintenance. Most of these articles deal
effect on the company. This “crackdown” approach for with ergonomics, one article examines military engine
behavior control is based upon fear and punishment, design to “solider proof” the maintenance duties, and
which creates a problem. Errors are driven into hid- one U.S. Navy article advocated more management
ing, and then become apparent later, usually at a more control.
critical time (“Murphy’s Law”). Additional attempts to
develop “foolproof” equipment designs were added to As human factors awareness progressed, a “culture
the zero defect manufacturing goal and began to find change” occurred in U.S. carriers in the 1990s.
recognition in the maintenance world as well. Subse- Management behavior began to change; there were
quent efforts focused on effects of positive rather than practical applications of systems thinking; organiza-
negative motivators. The results of this effort were a tion structure was revised; and new strategy, policy,
reversal of the “crackdown” method, and motivation and values emerged. Virtually all of these involved
due to increased morale often improved maintenance communication and collaboration. One example is
safety performance. Studies have shown that motiva- from 1991, when Continental Airlines began “CRM
tion resulting from negative sources seldom achieved type” training in maintenance. Airline executives saw
the same effect. This led to a “Participative Manage- the importance of improving communication, team-
ment” style recognized by some U.S. industry and a work, and participative decision-making. A second
few airlines, but did not reach maintenance operations example is the United Airlines establishment of a
until much later. change in organization and the job of inspectors. They
remained more accessible during heavy maintenance
The Airline Deregulation (1978 –1988) effort had a and overhaul and stayed in closer communication with
profound effect upon the aviation community. Prior mechanics during normal repairs. The results were
to 1978, the airline industry was regulated by the fewer turnbacks and higher quality. A third example
Civil Aeronautics Act of 1938. This resulted in peace- is the Southwest Airlines developement of a strong
ful markets, stable routes, and consistent air fares. and clear organizational structure led by the CEO.
However, there was a downside consisting of two This resulted in open and positive communication
major problems: wasteful management practices and between maintenance and other departments. A final
excessively high wages compared to other comparable example is the TWA establishment of a new program
skilled-labor industries. The Airline Deregulation Act to improve communication between the maintenance
brought in competitive business practices, with routes trade union and maintenance management, resulting
and fares controlled by their profitability. This led to a in improved quality.
new style of airline management in which a CEO was
more of a business person and less knowledgeable of Current Approach
aviation. Existing airlines developed new routes and As mentioned earlier, the FAA itself has an increas-
added new kinds of service and style. Start-up airlines ing awareness and acceptance of “human factors”
brought other innovative ideas. The numerous mergers issues. In addition to the ACs already referenced, the
and acquisitions added an increasing pressure to focus FAA released in October 2005 an operator’s manual
on the financial bottom line. Doing more with less titled Human Factors in Aviation Maintenance. This
became the byline. In the 1980s, maintenance depart- manual was generated in response to the industry’s
ments were not immune to the pressures of mergers requests for a simple and manageable list of actions
and staff reductions. However, fleets were extremely to implement a maintenance human factors program,
reliable at that time, and significant savings were aided and is an excellent reference document for it. A team
by a reduction in number of maintenance technicians. of international industry experts chose the following
Other new ways of conducting business included six topics as necessary for a human factors program
leasing of aircraft and outsourcing of maintenance. A to be successful:
result of deregulation was change for the maintenance
programs (both personnel and departmental) and the 1. Event Investigation
pressure to produce and adjust. The problem, however, 2. Documentation
was that human factors for aviation maintenance was 3. Human Factors Training
still stuck in the 1960s model.
4. Shift/Task Turnover

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5. Fatigue Management 7. Lack of Resources: failure to use or acquire the
6. Sustaining and Justifying a Human Factors appropriate tools, equipment, information, and
Program procedures for the task.
8. Pressure: creating a sense of urgency or haste.
Probably the most well-known data associated with
reducing the negative impact of human factors is 9. Lack of Assertiveness: lack of positive commu-
the Dirty Dozen list of factors developed by Gordon nication of one’s ideas, wants, or needs.
DuPont from Transport Canada. [Figure 13-2] These 10. Stress: mental, emotional, or physical tension,
12 issues are: strain, or distress.
11. Lack of Awareness: failure to be alert or vigilant
1. Lack of Communication: lack of clear, direct
in observing.
statements and good, active listening skills.
12. Norms: informal work practices or unwritten rules
2. Complacency: self-satisfaction accompanied by
that are ccepted by the group.
a loss of awareness of the dangers.
3. Lack of Knowledge: lack of experience or training Subsequent to the development of the Dirty Dozen, the
for the task at hand. “Magnificent Seven” list of human factors issues was
4. Distraction: loss of focus, mental/emotional developed by DuPont, and focused on positive aspects.
confusion or disturbance, draw one’s attention These seven issues are:
away. 1. We work to accentuate the positive and eliminate
5. Lack of Teamwork: lack of working together to the negative.
achieve a common goal. 2. Safety is not a game because the price of losing is
6. Fatigue: weariness from labor or exertion, nervous too high.
exhaustion, temporary loss of power and ability to 3. Just for today — zero error.
respond.
4. We all do our part to prevent Murphy from hitting
the jackpot.
5. Our signature is our word and more precious than
DuPont’s Dirty Dozen gold.
1. Lack of Communication 6. We are all part of the team.
7. We always work with a safety net.
2. Complacency
Posters of the Dirty Dozen and the Magnificent Seven
3. Lack of Knowledge
are available for a fee from the Maintenance and
4. Distraction Ramp Safety Society (M.A.R.S.S.) located in British
Columbia, Canada.
5. Lack of Teamwork
Another major human factors tool for use in investiga-
6. Fatigue tion of maintenance problems is the Boeing developed
Maintenance Error Decision Aid (MEDA). This is
7. Lack of Resources
based on the idea that errors result from a series of
8. Pressure factors or incidents. The goal of using MEDA is to
investigate errors, understand root causes, and prevent
9. Lack of Assertiveness accidents, instead of simply placing blame on the main-
tenance personnel for the errors. Traditional efforts to
10. Stress
investigate errors are often designed to identify the
11. Lack of Awareness employee who made the error. In this situation, the
actual factors that contributed to the errors or accident
12. Norms remain unchanged, and the mistake is likely to recur.
In an effort to break this “blame and train” cycle,
Figure 13-2. The human factors in aircraft maintenance
MEDA investigators learn to look for the factors that
most commonly leading to accidents.
contributed to the error, instead of the employee who

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made the error. The MEDA concept is based on the nity to investigate errors. Those involved in the process
following three principles: may be intimidated by the attention coming from upper
management and various regulatory authorities.
• Positive employee intent (In other words,
maintenance technicians want to do the best job By using the MEDA process properly, the organization
possible and do not make intentional errors.) can investigate the factors that contributed to an error,
• Contribution of multiple factors (There is often discover exactly what led to that error, and fix those
a series of factors that contribute to an error.) factors. Successful implementation of MEDA will
allow the organization to avoid rework, lost revenue,
• Manageability of errors (Most of the factors that
and potentially dangerous situations related to events
contribute to an error can be managed.)
caused by maintenance errors.
When a company is willing to adopt these principles,
The “SHEL” model is another concept for investi-
then the MEDA process can be implemented to help
gating and evaluating maintenance errors. [Figure
the maintenance organization achieve the dual goals
13-3] As with other human factors tools, its goal is to
of identifying those factors that contribute to exist-
determine not only what the problem is, but where and
ing errors, and avoiding future errors. In creating this
why it exists. SHEL was initiated by Professor Elwyn
five-step process, Boeing initially worked with Brit-
Edwards (Professor Emeritus, Aston University, Bir-
ish Airways, Continental Airlines, United Airlines, a
mingham, U.K.) in 1972. It was later modified slightly
maintenance worker labor union, and the FAA. The
by the late Capt. Frank Hawkins, a Human Factors
five steps are:
consultant to KLM (Royal Dutch Airlines), in 1975.
1. Event: the maintenance organization must select The acronym SHEL represents:
which error that caused events will be investi-
• Software
gated.
• Hardware
2. Decision: was the event maintenance related? If
the answer is yes, then the MEDA investigation • Environment
continues. • Liveware
3. Investigation: using the MEDA results form,
the operator conducts an investigation to record
general information about the airplane — when the
maintenance and the event occurred, what event
SHEL
initiated the investigation, the error that caused the Software • Hardware • Environment • Liveware
event, the factors contributing to the error, and a

S
list of possible presentation strategies.
4. Prevention strategies: the operator reviews,
prioritizes, implements, and then tracks the process
improvements (prevention strategies) in order to (Procedures)
avoid or reduce the likelihood of similar errors in

H E
the future.
5. Feedback: the operator provides feedback to
the maintenance workplace so technicians know Worker
that changes have been made to the maintenance (Machines) (Ambient)
system as a result of this MEDA process.

L
The implantation and continuous use of MEDA is a
long-term commitment and not a “quick fix.” However,
airline operators and maintenance facilities frequently
decide to use the MEDA approach to investigate seri- (Personnel)
ous, high visibility events which have caused signifi-
cant cost to the company. The desire to do this is based
upon the potential “payback” of such an investigation. Figure 13-3. SHEL Model.
This may ultimately be counterproductive because a
highly visible event may not really be the best opportu-

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The model examines interaction with each of the four A good place to start researching would be the FAA’s
SHEL components, and does not consider interactions own website at http://hfskyway.faa.gov/. This site,
not involving human factors. titled “Human Factors on Aviation Maintenance and
Inspection (HFAMI)” provides access to products of
The term “software” is not referring to the common use the Federal Aviation Administration Flight Standards
of the term as applied to computer programs. Instead Service Human Factors in Aviation Maintenance and
it includes a broader view of manual layout, checklist Inspection Program. Many aviation maintenance indus-
layout, symbology, language (both technical and non- try trade magazines include a section or at least a page
technical), and computer programs. devoted to human factors. “The Human Factors and
Hardware includes such things as the location of com- Ergonomics Society” is a national organization com-
ponents, the accessibility of components and tooling. posed of 22 technical groups, including one devoted
to aerospace systems, which address both civilian and
Environment takes temperature, humidity, sound, light, military issues of safety and performance.
and time of day factors into account.
Professionalism
Liveware relates technician interaction with other
people, both on the job and off. These include manag- The aviation technician is the central figure in aviation
ers, peers, family, friends, and self. maintenance. From the day he or she sets out to become
a certificated technician per 14 CFR part 65 to the day
No discussion of human factors is complete without he or she retires or leaves the field, the technician must
reference to James Reasons’ Model of Accident Causa- be fully qualified as an aviation professional. This
tion. This diagram, which was introduced in 1990, and means the technician successfully blends technical
revised by Dr. Reason in 1993, is often referred to as the training with ethical thinking, and understands the
Swiss cheese model and shows how various “holes” in ramifications of the various aspects of human factors.
different systems must be aligned in order for an error Although the word “professionalism” is widely used,
to occur. Only when the holes are all aligned can the it is rarely defined. In fact, no single definition can
incident take place. encompass all of the qualifications and considerations
that must be present for true professionalism to exist.
There are two types of failure which can occur—active
Though not all inclusive, the following list provides
and latent. An active failure is one in which the effects
major considerations and qualifications that should be
are immediate. An example of this type would be an
included in the definition of professionalism.
aircraft slipping off one of the lifting jacks due to
improper placement by the technician. In this example, 1. Professionalism exists only when a service is
the aircraft jack is the approved item of ground support performed for someone or for the common good.
equipment, and it has been properly maintained.
2. Professionalism is achieved only after extended
A latent failure occurs as a result of a decision or training and preparation.
action made long before the incident or accident actu- 3. Professionalism is performance based on study
ally occurs. The consequences of such a decision may and research.
remain dormant for a long time. An example of a latent 4. Professionalism is reasoning logically and accu-
failure could also involve the aircraft slipping off a rately.
joint, but in this case it could be an unapproved jack
being used because funding had not been approved 5. Professionalism is making good judgment deci-
to purchase the correct ground support equipment sions.
(GSE). 6. Professionalism is not limiting actions and deci-
sions to standard patterns and practices.
The field of human factors, especially in aviation
7. Professionalism demands a code of ethics.
maintenance, is a growing field of study. This section
of this chapter has presented only a small segment of 8. Professionalism is being true to one’s values and
the numerous observations and presentations about the ethics and to those being served. Anything less
topic. If the technician desires to learn more, numerous than a sincere performance is quickly detected,
books exist and a review of Internet data will provide and immediately destroys effectiveness.
an abundant supply of information.

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