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DATEATTACHMENT 238300.10 CHG OIG

CHAPTER 126.  MONITORING PART 145 REPAIR STATIONS THAT ARE SUBSTANTIAL MAINTENANCE PROVIDERS, BEFORE, DURING, AND AFTER LABOR DISPUTE, STRIKE, OR BANKRUPTCY

SECTION 1.  BACKGROUND

1. PROGRAM TRACKING AND REPORTING SUBSYSTEM (PTRS) ACTIVITY CODES.

A.  Maintenance:  3644 (New)

B.  Avionics:  5634 (New)

3.  OBJECTIVE.  This chapter provides information and guidance to be used by inspectors when conducting surveillance of a domestic repair station and repair stations located out side the United States (air agency) before, during, and after a labor dispute, strike, or bankruptcy to ensure continued regulatory compliance.  A repair station in distress experiencing labor issues may be unable to meet financial obligations, and filing for bankruptcy protection may affect necessary maintenance and operational activities, thereby adversely impacting safety.  During these periods, Flight Standards Services (AFS) may require an increased and focused surveillance plan. In any case, the Federal Aviation Administration (FAA) should ensure that public safety is not jeopardized..

5.  GENERAL.  Safety is a concern when any of the above events cause disruption in air carrier substantial maintenance provider’s (repair station) operation.  The air agency/repair station is responsible for recognizing current or potential labor or financial problems that could adversely affect safe operations.  Repair station management should take a proactive role in these matters and not just react to events as they happen.  The repair station should communicate with its certificate-holding district office (CHDO) and keep them apprised of operational impacts.  Agency management should present a comprehensive brief to the principal inspector (PI) on how they will continue to operate and meet requirements using management personnel.  In some repair stations, certificated

repairmen are considered management and should not normally go out on strike.  In other repair stations, the repairmen might be considered part of the bargaining unit and may be affected by the strike.  In this case, the PI should verify that there are enough certificated personnel available to adequately supervise or perform maintenance as required by the workload.  Using the self-disclosure program, the repair station management should inform the CHDO of any significant safety-related findings that were identified through its monitoring and oversight programs.  The CHDO may learn of events leading to a labor dispute, strike, or bankruptcy from news media, normal surveillance, the public, other government entities, or other means.  Regardless of the source of information, the affected FAA office should initiate immediate action.  Since these problems may raise questions about an air agency’s ability to safely conduct operations, CHDO and PIs should be alert to indicators of financial problems and be ready to take immediate action if required.  

A.  Indicators.  One or more of the following indicators may show that a repair station operator is experiencing financial problems:

Requests for changes in training programs

Changes in the upkeep of equipment

Unrest among the work force

Trouble maintaining parts inventories, excessive back orders, COD-only basis with suppliers

Parts being purchased from non-accredited parts brokers data not current

Vol. 3

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