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Spring 2015 Issue 328

INSIDEA message from theALAE chairman

Occurrence reporting incivil aviation

View from down under

TECH

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3TECHLOG SPRING 2015

5 Editorial

6 ICAO – International standards andrecommended practices

8 A message from the ALEAChairman

10 Part-M and Part-145 interaction

13 Maintenance Safety Tip

16 AMFA takes a stand on safety

18 Improving maintenance standards

20 Aviation safety and the rights andrisks for licensed engineers

23 Occurrence reporting in civilaviation

24 View from down under

26 The stories of two great pilots

27 Letter

28 Short Reports

30 Association Notices

Objects of the AssociationTo promote the Professional Status of Association Members.

To represent Members in their workplaces.

To represent Members of the Association within the Industry.

To strive to improve the standards of safety in all aspects ofaircraft maintenance and operation.

The ALAE welcomes contributions to ‘The Tech Log’, butreserves the right to amend them where necessary. Allcontributions, whether they bear the names, initials orpseudonyms, are accepted on the understanding that the authoris responsible for the opinions expressed and that they do notnecessarily reflect or comply with those of the publisher oreditor. Although every care is taken, the publisher and editorcannot be held responsible for loss or damage to materialsubmitted. Whilst every care is taken to ensure contents areaccurate, the publisher and editor assume no responsibility forany effects arising from errors or omissions. Acceptance ofmaterial is not a guarantee of publication in any particular issue,since space is at a premium.

For more information on the following, please contact the Office Administrator: ALAE/Prospect, Flaxman House, Gogmore Lane, Chertsey, Surrey KT16 9JSTelephone: 01932 577007 Fax: 01932 565239Email: [email protected] Website: www.alae.org

When ALAE members call the telephone number above they willbe passed forward to the dedicated officer for their particular areaas per the breakdown previously advised to EC members.

Please inform the registered office above of any change of details,address, telephone number, etc as soon as possible to ensure youcontinue to receive your copy of ‘Tech Log’.

e-mail: [email protected]

‘Tech Log’ is published by MYPEC0113 257 9646 www.mypec.co.uk

Photography by Barry Swannand Garfield Moreton Photographyhttp://garfieldmoretonphotography.zenfolio.com

CONTENTS

Late May 15 B767 (PW) – B1/B2 (Theory) @ Bangkok ThailandJuly 15 B767 (PW) – B1/B2 (Practical) @ Bangkok ThailandJuly 15 B767 (PW4000) – B1/B2 Engine only diffs (Theory from

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16-18th June 15 B757 (PW2000) B1/B2 Engine only diffs (Theory from RR)@ East Midlands

19-21st June 15 B757 (PW2000) B1/B2 Engine only diffs (Theory from RR)@ East Midlands

22-24th June 15 B757 (PW2000) B1/B2 Engine only diffs (Practical fromRR) @ Ireland

27th July-4th Sept 15 B737 CL – B1/B2 (Theory) @ Manchester UK 7th-18th Sept 15 B737 CL – B1/B2 (Practical) @ UK28-31st July 15 B737 CL – B1/B2 Removal of Lims 1 (Theory)

@ Manchester UK26th Aug-4th Sept 15 B737 CL – B1/B2 Removal of Lims 9 (Theory)

@ Manchester UK28-31st July 15 & B737 CL – B1/B2 Removal of Lims 1+9 (Theory) 26th Aug-4th Sept 15 @ Manchester UK 21st Sept-2nd Oct 15 B737 NG – B1/B2 Differences from CL (Theory)

@ Manchester UK 12-16th and 26-30th B737 NG – B1/B2 (Practical) @ will be at Leeds or October 15 Manchester UK1st June-17th July 15 A330 – B1 (Theory) @ Brize Norton UK 6-10th July 15 A330 – B1 RR Engine only diffs (Theory from GE or PW)

@ Brize NortonRemoval of lims 1+9 available on this A330 training ** Contact us for more details

15-19th June 15 A330 GEN FAM @ Brize Norton UKJune/July 15 B737 NG – B1/B2 (Theory) @ Kula Lumpur Malaysia

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July/August 15 B737 NG – B1/B2 (Practical) @ Kula Lumpur Malaysia ** Contact us for more details

June 15 A310 – ‘C’ Licence Course @ Portugal ** Contact us for more details

Breaking News*STOP PRESS*CATTS is pleased to announce● CATTS is currently developing its

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More and more European airlines and maintenance

organisations are stretching the rules beyond breaking

point by abusing a note in Part-145.A.65 (b)3 that

states ‘Authorised personnel’ means personnel formally

authorised by the maintenance organisation approved

under Part-145 to sign-off tasks. ‘Authorised personnel’

are not necessarily ‘certifying staff ’.

This note is being miss represented and applied across

the whole of Part-145. MOE procedures are being

amended to allow maintenance to be performed and

“signed off ” by partially trained non-licensed personnel

without supervision or opportunity for certifying staff to

inspect.

This edition of Tech Log in part focuses on the active

move by industry to cut the cost of maintenance by

reducing the scope of licensed aircraft engineers and

increasing the status of the unlicensed mechanic. This

process change is being endorsed by several NAAs.

EASA, fully aware of the situation appear to be unable

or uninterested to act and put a stop to it.

In order to allow all readers to have the same base

understanding of the requirement, the first article in this

edition of Tech Log is an extract from the ICAO

annexes. This is where all aviation regulation has its

origin. The extract refers to licensing and is taken from

ICAO, Annex 1 chapter 4.2, Aircraft maintenance,

Requirements for the issue of the licence.

The closing paragraph of this section reads;

4.2.2.4 When a Contracting State authorises an

approved maintenance organisation to appoint non-

licensed personnel to exercise the privileges of 4.2.2, the

person appointed shall meet the requirements specified

in 4.2.1.

To get straight to the point; we can have sign off

personnel within a Part-145 maintenance organisation

that’s not an issue. If the work they perform however is

not being supervised or inspected by a licensed engineer,

then to all intent and purpose, their signature is a

certification of the maintenance performed. Therefore

and in accordance with ICAO Annex 1 chapter 4.2.2.4,

they would need to be trained to the same standard as

the licensed engineer. So not only are there serious

questions to be asked as to how such a system complies

with the Part-145.A.50 (a) requirement that ‘A

certificate of release to service shall be issued by

appropriately authorised certifying staff on behalf of the

organisation when it has been verified that all

maintenance ordered has been properly carried out’ but

also as to whether the sign off staff training syllabus is

equivalent to that of their licensed colleagues.

ALAE are very concerned.

Jon Harris, Editor – [email protected]

It is becoming common knowledge that the next move to dumbdown the effect and influence of the Licensed Engineer in lineand base maintenance is to remove him/her from the actualmaintenance task itself.

EDITORIAL

TECHLOG SPRING 20156

4.2 Aircraft maintenance (technician/engineer/ mechanic)4.2.1 Requirements for the issue of the licence4.2.1.1 Age The applicant shall be not less than 18years of age.4.2.1.2 Knowledge The applicant shall havedemonstrated a level of knowledge relevant to theprivileges to be granted and appropriate to theresponsibilities of an aircraft maintenance licence holder,in at least the following subjects:

Air law and airworthiness requirementsa) rules and regulations relevant to an aircraftmaintenance licence holder including applicableairworthiness requirements governing certification andcontinuing airworthiness of aircraft and approvedaircraft maintenance organisation and procedures;

Natural science and aircraft generalknowledgeb) basic mathematics; units of measurement;fundamental principles and theory of physics andchemistry applicable to aircraft maintenance;

Aircraft engineeringc) characteristics and applications of the materials ofaircraft construction including principles of constructionand functioning of aircraft structures, fasteningtechniques; powerplants and their associated systems;mechanical, fluid, electrical and electronic powersources; aircraft instrument and display systems; aircraftcontrol systems; and airborne navigation andcommunication systems;

Extract from Annex 1 to the Convention on InternationalCivil Aviation Personnel Licensing

ICAO – INTERNATIONALSTANDARDS ANDRECOMMENDED PRACTICES

7

Aircraft maintenanced) tasks required to ensure the continuing airworthinessof an aircraft including methods and procedures for theoverhaul, repair, inspection, replacement, modificationor defect rectification of aircraft structures, componentsand systems in accordance with the methods prescribedin the relevant Maintenance Manuals and the applicableStandards of airworthiness; and

Human performancee) human performance relevant to aircraft maintenance.Note. Guidance material to design training programmeson human performance can be found in the HumanFactors Training Manual (Doc 9683).

4.2.1.3 ExperienceThe applicant shall have had the following experience inthe inspection, servicing and maintenance of aircraft orits components:a) for the issue of a licence with privileges for theaircraft in its entirety, at least:

1) four years; or2) two years if the applicant has satisfactorilycompleted an approved training course; and

b) for the issue of a licence with privileges restricted inaccordance with 4.2.2.2 a) 2) or 3), a period of time thatwill enable a level of competency equivalent to thatrequired in a) to be attained, provided that this is notless than:

1) two years; or2) such a period as the State considers necessaryto provide an equivalent level of practicalexperience to applicants who have satisfactorilycompleted an approved training course.

4.2.1.4 TrainingRecommendation. The applicant should have completed a course of training appropriate to theprivileges to be granted.

Note. The Training Manual (Doc 7192), Part D-1,contains guidance material on a training course forapplicants for an aircraft maintenance licence.

4.2.1.5 Skill The applicant shall have demonstrated the ability toperform those functions applicable to the privileges tobe granted.

4.2.2 Privileges of the holder of the licenceand the conditions to be observed inexercising such privileges4.2.2.1 Subject to compliance with the requirementsspecified in 4.2.2.2 and 4.2.2.3, the privileges of the

holder of an aircraft maintenance licence shall be tocertify the aircraft or parts of the aircraft as airworthyafter an authorised repair, modification or installation ofa powerplant, accessory, instrument, and/or item ofequipment, and to sign a maintenance release followinginspection, maintenance operations and/or routineservicing.

4.2.2.2 The privileges of the holder of anaircraft maintenance licence specified in4.2.2.1 shall be exercised only:a) in respect of such:

1) aircraft as are entered on the licence in theirentirety either specifically or under broadcategories; or2) airframes and powerplants and aircraftsystems or components as are entered on thelicence either specifically or under broadcategories; and/or3) aircraft avionic systems or components as areentered on the licence either specifically orunder broad categories;

b) provided that the licence holder is familiar with allthe relevant information relating to the maintenanceand airworthiness of the particular aircraft for which thelicence holder is signing a Maintenance Release, or suchairframe, powerplant, aircraft system or component andaircraft avionic system or component which the licenceholder is certifying as being airworthy; andc) on condition that, within the preceding 24 months,the licence holder has either had experience in theinspection, servicing or maintenance of an aircraft orcomponents in accordance with the privileges grantedby the licence held for not less than six months, or hasmet the provision for the issue of a licence with theappropriate privileges, to the satisfaction of theLicensing Authority.

4.2.2.3 A Contracting State shall prescribethe scope of the privileges of the licenceholder in terms of the complexity of thetasks to which the certification relates.4.2.2.3.1 Recommendation. Details of the certificationprivileges should be endorsed on or attached to thelicence, either directly or by reference to anotherdocument issued by the Contracting State.

4.2.2.4 When a Contracting State authorisesan approved maintenance organisation toappoint non-licensed personnel to exercisethe privileges of 4.2.2, the person appointedshall meet the requirements specified in4.2.1.

TECHLOG SPRING 2015

8 TECHLOG SPRING 2015

EASA had announced a new working group (145.012

multiple/single release) to look at introducing a

common European approach to issuing a certificate of

release to service. The argument on the face of it made

sense as there were various release philosophies in use

throughout Europe and to ensure a common standard

there should only be one.

At the time ALAE made their views known

publically. These were an acceptance of the basic

premise (a common release methodology) but ALAE

did not accept the industry proposed solution which was

to move towards a company approval system, an

unlicensed system. The proposal was to use internally

approved but non-licensed staff with a much widened

scope. One of the more popular proposals was to allow

all maintenance to be performed by unlicensed staff,

unsupervised, with the role of Licensed Certifying Staff

reduced to checking paperwork and signing the CRS

after maintenance. The Licenced Engineer however

remaining accountable for the maintenance covered by

that release to service.

So what happened?ALAE decided upon an approach which retained the

Licensed Engineer and set to work. The ALAE team

successfully countered the original unlicensed proposals

and steered the working group to a decision which

retained the Licensed Engineer. This result was fully

supported by both ALAE and AEI but airline lobbying

managed to block its progression to Brussels thereby

preventing the decision becoming law. Instead EASA

issued an opinion (06/2010) within which they

maintained that change was needed but further work

was required before a rule change could be

implemented. The proposal was to take the benefit of

the work already performed during task 145.012 and

expand the scope of another planned working group,

M.029, in order to address simultaneously:

• the responsibilities of CAMOs and Part-145

organisations, and

• the procedures for maintenance, coordination, aircraft

release and airworthiness determination.

In other words, hand industry a second chance to

achieve their original goal.

EASA working group M.029 (CAMO/Part-145

responsibilities) was initiated and I myself was selected

as a group member. Parallel to this ALAE and AEI had

been lobbying EASA to clarify the role, responsibilities

and accountabilities of Licensed Support Staff within

base maintenance. This was due to the increasingly

worrying situation of the increased sign off scope being

issued to unlicensed mechanics. EASA finally agreed

and working group 145.024 was formed (Functions and

responsibilities of B1 and B2 support staff – link with

sign off ). ALAE also supplied a member for this

working group.

As both these working groups are still active we

remain bound by a confidentiality agreement. However

I can state that within both groups (145.024 and

M.029) it was just like being back in 145.012. We were

just confronted with more of the same. More attempts

to remove the requirement for the Licenced Engineer to

inspect any of the work carried out, whilst still

remaining responsible if any maintenance errors were

detected. Nevertheless we once again fought our corner,

A MESSAGE FROOn my election to the position of ALAEChairman back in 2006 I warned of amajor challenge about to confront allLicensed Aircraft Engineers.


kept safety paramount and ensured the continued use of

the Licensed Engineer. Both ALAE and AEI fully

support the outcomes these working groups delivered.

Now obviously that’s a very brief précis and of course a

lot more has happened over the past nine years than we

can mention here. I can say however that it has been a

long, hard and at times confrontational battle. That said,

ALAE delivered every step of the way. The industry and

for that matter, many regulators, would not shed a tear

if the Licence disappeared. Indeed removal of the

Licence has been a stated IATA goal since 1955. Yet

because of ALAE’s and AEI’s efforts, the Licence

remains in place.

It remains in place despite three working groups and

nine hard years of battle. It also remains in place

despite, at times, having to fight regulator apathy,

particularly from EASA. Not so much in

confrontational terms but in terms of there being a

regulatory void which is being fully manipulated by the

industry. Basically EASA often sit on their hands and

remain silent when we believe they should be more

proactive, particularly on clear safety issues. It seems we

do still have regulators, it’s just that they appear to be

unsure as to what they are regulating.

As a direct result of this weakness, the industry having

already experienced defeat three times, are now testing

regulator resolve by exploiting that regulatory void in

order to achieve their original goals. Goals which we all

know are usually cost driven to the exclusion of all else.

The latest development is that a major European

airline/maintenance organisation, has recently

introduced an NAA approved MOE, which details what

can only be described as a box ticking release to service

procedure. These revised procedures simply require the

Licenced Engineer to verify that the unlicensed

mechanics have signed off the work that was performed

without any physical verification by Licenced Engineers.

As an example the director responsible for maintenance

recently sent a directive to its Licensed Engineers saying

that: “With the release to service the (Licenced

Engineer) signs only that the correct person with the

correct rating had performed the job. He does not take

over responsibility for the job quality from the

unlicensed performing mechanic.” This reduces the task

of the Licensed Engineer to a purely administrative role

though they continue to bear the professional, civil and

criminal responsibility by virtue of execution of the CRS

for anything which may go wrong subsequently as a

result of the unverified maintenance.

Neither the NAA nor EASA have taken any action to

correct what legal experts and ALAE/AEI consider to

be a clearly illegal and non-compliant procedure.

Therefore a line in the sand has now been crossed.

ALAE will of course continue the battle. As long as

we are able to mount a challenge the Licence will stay.

It therefore important that Licensed Engineers continue

to support the one organisation which truly understand

the aviation industry. ALAE are happy to fight for

safety no matter how hard the battle. However we will

always only ever be as strong as our membership.

Membership costs less than the price of a pint per day.

Is that really too high a price to pay to keep the licence

thereby ensuring future generations benefit from the

safety critical work the Licensed Engineer performs

each day before every flight.

So don’t allow detractors tell you that ALAE don’t

make a difference. We do and we have. We are in this

position today because the industry is becoming

increasingly desperate to rid maintenance of the

Licensed Engineer but haven’t yet found a way around

ALAE and AEI. That’s the reality. Make no mistake,

the Licence would already be gone without our input.

So please ensure you let your colleagues know the

importance of what we do and our successes. But please

also ensure they read the letter published on page 27

and understand the consequences of not supporting

ALAE. Once it’s gone, be it ALAE or the Licence, it’s

gone for good.

M THE ALAE CHAIRMAN

The main ways you would most likely go about

obtaining such a car would be to purchase it brand new

from the manufacturer (Ford) via a dealer or through a

leasing agreement, or buy a second-hand Ford Focus

from a dealer or from a private individual.

Regardless of how you legally obtain your car, the car

should come with a service history document, various

user manuals and any other data pertinent to that car.

For a brand new car, once it leaves the manufacturer

(after you have personalised it with leather seats, air

conditioning or whatever takes your fancy), and

assuming the car has been built to the required

manufacturing standards, Ford is no longer responsible

for the roadworthiness of the car.

Once you are the proud owner of your new (or

second-hand) Ford Focus, YOU are required by law, as

the owner, to ensure that you take all precautions

necessary to ensure that your car remains roadworthy.

This means taking your car for its yearly MOT test

(Ministry of Transport test), ensuring the tyres’ treads

are within limit, repairing any lights or perhaps

replacing the exhaust if it appears faulty and so on.

There will also be some basic maintenance required

such as checking the engine oil regularly, replenishing it

when necessary, changing the engine water pump after

so many miles, etc. The owner’s manual for the car will

normally detail the basic maintenance requirements.

However, the key point here is that you, as the owner,

are responsible to ensure your car is roadworthy

regardless of how you decide to have your car

maintained and by whom.

When something goes wrong with the car or you need

to have it serviced or MOTed, you will take it to a

garage which will carry out your instructions. If the

10

The relationship between Part-M and Part-145 is based upon thefollowing simple concept:Imagine that you wished to purchase a Ford Focus car.

PART-M AND PART-145INTERACTION

TECHLOG SPRING 2015


garage mechanic discovers other problems with the car

whilst repairing what you have asked him to repair, he will

inform you, and you will decide how to proceed: either go

ahead with the repair or not, as you see fit. Some

individuals are competent enough to maintain their own

cars themselves, only sending it for an MOT once a year.

Regardless of how many scenarios and situations exist,

you, as the legal owner, still remain responsible for the

roadworthiness of your car.

The garage is certainly responsible for the quality of the

work that it carries out on your car, but the garage is

NOT responsible to tell you when the MOT is due, when

you need to get your car serviced and so on. As the owner,

you are wholly responsible to maintain the roadworthiness

of your car, to maintain your own service records, to keep

track of when MOT is due, to keep track of maintenance

actions carried out on the car etc.

The above description applies in exactly the same way to

civil aviation, be it private or commercial. The only

difference is that the machine to be operated and

maintained is often far larger and more complex than a

car, and there is a great deal more legislation and

regulations for it, since the safety required in air transport

operations and general aviation is of the utmost

importance by the very nature of the activity and the

amount of people one large aircraft can carry, in the case

of commercial air transport, for example.

It works in the following way:An air operator/owner decides to purchase an aircraft. If a

new aircraft, it will buy it directly from the manufacturer

and have it customised. The aircraft manufacturer, say

Airbus, will have designed and produced the aircraft to

exact standards as laid out in relevant EU regulations

derived from the new Basic Regulation described earlier in

Part 1. The design and manufacture of aircraft and aircraft

parts are regulated by Part-21 (annex I to the

Implementing Rules of Commission Regulation (EU) No.

748/2012 which relates to aerospace design and

manufacture) but we do not need to concern ourselves

with this here.

The moment the new aircraft has been handed over to

the air operator/owner, for instance a fictional Another

Airline UK, Airbus is no longer responsible for the

continuing airworthiness of that aircraft. It is only

responsible for the initial airworthiness: fresh off the

production line and safe to fly. It will however provide all

the documentation necessary for the maintenance of the

aircraft, the structural repairs, the various replacement

parts to purchase etc. The manufacturer will certainly be

available to sort out technical issues as required. However,

it will not be responsible for the continuing airworthiness

of the aircraft.

The continuing airworthiness of the aircraft is now

managed by the owner/operator of the new aircraft and

will be managed in accordance with Part-M regulations

annexed to Commission Regulation (EU) 1321/2014 as

discussed in Part 1 (regulations and requirements vary

depending on the size of the aircraft and its intended use

but knowing these is not necessary for the purpose of this

document. A commercial operator will be used for the

purpose of illustration).

When a commercial air operator is granted its air

operator certificate by the UK CAA, it is also

automatically granted a Part-M ‘Continuing

Airworthiness Management Organisation’ approval, or

‘CAMO approval’. This approval confers to the air

operator those privileges required to ensure all Part-M

regulations are implemented and the aircraft is kept

airworthy. The implementation of all Part-M regulations

is the responsibility of the air operator’s CAMO (this

continuing airworthiness management organisation is set

up by the commercial operator since it has received the

approval as part of its air operator certificate). Unlike

private aircraft owners, commercial air operators cannot

contract out independent continuing airworthiness

management organisations: they must establish their own.

The operator, as the owner of the aircraft, now makes

sure that its aircraft is airworthy (safe to fly) at all times it

is operating it. It must develop, in conjunction with the

CAA, a maintenance programme suitable to that aircraft

based on data from the manufacturer and must make sure

that this programme is followed. There are many other

actions under Part-M regulations that the owner must

take to ensure continuing airworthiness.

However, when the aircraft needs to be maintained or

needs to be repaired, what is the operator to do? It is at this

point that if it does not have its own in-house maintenance

organisation approved under Part-145 the operator takes its

aircraft to an organisation that has the engineering skills

and manpower to perform the required maintenance; in this

case, the ‘garage’ will be a maintenance organisation

approved under Part-145 to maintain specific aircraft.

Unlike an automobile garage, a Part-145 approved aircraft

maintenance organisation is made up of highly skilled

aircraft maintenance engineers and mechanics.

When a commercial air operator is grantedits air operator certificate by the UK CAA, itis also automatically granted a Part-M‘Continuing Airworthiness ManagementOrganisation’ approval, or ‘CAMO approval’.

The Part-145 approved maintenance

organisation will have been granted a

Part-145 approval for the required

aircraft types by the UK CAA in order

to operate as an approved aircraft

maintenance organisation. It will

employ appropriately approved and

licensed Part-66 aircraft maintenance

engineers to carry out the work as well

as trained mechanics. Only licensed engineers (trained

and qualified in accordance with the Part-66

requirements) who are not only licensed for the required

aircraft type but who have also been approved by the

Part-145 organisation are able to certify maintenance

(this means give the final seal of approval for each

maintenance job carried out).

In the same example with the car, the Part-145

maintenance organisation will carry out all maintenance

as requested by the operator. If some other defects are

found during a routine maintenance job, the

maintenance organisation will take note of this and

inform the operator’s CAMO (continuing airworthiness

management organisation or department). They will

advise on how to proceed and this additional

requirement will be requested by the operator as

deemed necessary.

Although the maintenance organisation is responsible

for the quality of its maintenance work, it is not

responsible for the management of the continuing

airworthiness of the aircraft. This responsibility is that

of the operator/owner as in the example with the Ford

Focus. The above principles would work in the same

way for an aircraft which is purchased second-hand

or leased.

It is important to understand that a commercial

operator simply cannot operate an aircraft fleet without

the services of a Part-145 approved maintenance

organisation (either in-house or contracted out).

Commercial transport aircraft and large aircraft, by law,

must be maintained by a Part-145 approved

maintenance organisation. Therefore, the value of such

an organisation cannot be underestimated.

Figure 1 shows a typical example of an Air Operator

Certificate together with its Continuing Airworthiness

Management Organisation (CAMO) approval, pursuant

to Part-M regulations.

A large air operator can often have its own Part-145

approval which means that it is permitted to maintain

its own aircraft as well as manage the continuing

airworthiness of the fleet. However, for smaller

operations, an air operator will usually contract out

the maintenance of the fleet to an approved

Part-145 organisation.

A similar arrangement can be implemented for

continuing airworthiness tasks. The effective

implementation of continuing airworthiness tasks

requires a large amount of personnel depending on how

many aircraft are owned. Tasks range from developing a

maintenance programme to keeping meticulous

technical records to maintaining an up-to-date technical

library with all the required data for each aircraft, etc.

Some commercial air operators may not have the

manpower or finance to carry out all these tasks by

themselves and they are, therefore, permitted to

subcontract some of the tasks to an outside organisation.

It must be noted that the term ‘subcontracted’ implies

that the subcontractor carrying out the tasks operates

under the quality system of the air operator and under

the operator’s CAMO approval for those tasks. This

differs from the term ‘contracted’ which implies the

contractor has its own quality system and is wholly

responsible for the final product. This would be the case

when the air operator contracts out the maintenance to

an approved Part-145 maintenance organisation.


Figure 1

Commercial Air Transport Operator(has been granted an Air Operator Certificate by the CAA)

Aircraft fleet is flown under EU Ops 1(operations) regulations (EU Ops 1 laysdown the regulations for commercial

air transport, including crewrequirements, airport requirements etc.)

Has a Part-M CAMO approval as partof its air operator certificate. Theoperator carries out all its own

continuing airworthiness tasks. It mayhowever, subcontract some continuing

airworthiness tasks to anotherorganisation.

Operator has a Part-145 approval. Itcarries out all maintenance on its own

fleet in accordance with Part-145regulations.

Figure 2


Another Airlines UK (AAUK)AAUK holds an air operatorcertificate and carries outaircraft operations in accordancewith civil aviation law.It contracts out the maintenanceof its fleet to an approved Part-145 organisation.It holds a Part-M ContinuingAirworthiness ManagementOrganisation (CAMO) approvalfrom the CAA and is entirelyresponsible for the airworthinessof its fleet.AAUK’s CAMO may either carryout all necessary continuingairworthiness tasks internally ormay subcontract some of itscontinuing airworthiness tasks toan organisation which providessuch services. (The serviceprovider does not need to hold aCAMO approval as it worksunder the airline’s quality systemand CAMO approval.)

Another MaintenanceOrganisation Ltd (AMO)AMO is an organisation whichholds a Part-145 approval tomaintain specific aircraft.It offers its maintenance servicesto airlines which requiremaintenance on their fleet. AMOcan only maintain those aircraftlisted on its Part-145 approval.AMO has its own QualityDepartment responsible for thequality system of its ownactivities and products.

Continuing airworthinesstasks service providerThe continuing airworthinesstasks carried out by thissubcontracted organisation forAAUK are subject to the qualitysystem of AAUK (the airline). Thework is carried under the CAMOapproval of the airline.

AAUK’s Part-M (CAMO) Quality Departmentoversees, by way of a quality audit system, allcontinuing airworthiness management activitiesincluding those which are subcontracted. It also hasa duty to assure itself that the Part-145 maintenanceorganisation is maintaining the operator’s aircraft upto the required standards.

Contracts its fleetmaintenance to anapproved Part-145

maintenanceorganisation

May subcontractsome of itscontinuing

airworthiness tasksto a suitableorganisation

Figure 3

Figure 2 shows how a commercial air

operator with a Part-M CAMO approval

and a Part-145 approval might work. If it

does not hold a Part-147 training

organisation approval, it would have to

send its engineers to such organisation for

maintenance training.

Figure 3 shows how a commercial air

operator with only a Part-M CAMO

approval (which comes with its air operator

certificate) and no Part-145 approval

would go about maintaining its aircraft

fleet and keeping it airworthy. (For non-

commercial operators/ owners, CAMO

arrangements can be different, but the

principles of maintenance and continuing

airworthiness remain the same. Please

consult the Part-M/Part-145 regulations

for a complete picture). Please note

that the names of the organisations

are fictional.

Delphine Ryan BSc MIET,

Aeronautical Engineer

According to Webster’s, trust is the ‘firm’ belief or

confidence in the honesty, reliability, justice, etc., of

another person or thing. When it comes to maintenance

and inspections, a question you should ask yourself is,

‘Do I trust or have confidence that the previous

maintenance or inspection was properly done?’ Sadly,

too many problems and accidents prove otherwise.

When removing and replacing a component, don’t

‘trust’ that it was properly installed previously. This is

especially true if a component requires bench tests,

clearance or tolerance checks prior to installation.

READ, UNDERSTAND, and FOLLOW the

manufacturer’s instructions and other Instructions for

Continued Airworthiness (ICA) rather than installing

as previously installed. We are human and as hard as we

try, we all make mistakes.

When it comes to inspections, carefully and

thoroughly inspect every item required by the

manufacturer’s inspection checklist rather than being

pressured to take shortcuts or cut corners. Do you have

the firm belief or confidence that all the covers and

panels were opened and/or removed and areas behind

insulation properly inspected during previous

inspections? The truth is, you don’t know for sure!

Here is a hypothetical example: Someone replaced

missing upholstery screws in an interior side panel. It

should be documented... but it might not be.

Nevertheless, was the screw too long and is it now

chaffing against a fluid line, hose, or electrical wire

behind that panel? You don’t know unless you inspect.

The ‘firm’ belief or confidence in reliability comes only

after YOU have performed maintenance and inspections

per manufacturer’s instructions and data.

Back in the ‘1980s, Ronald Reagan had a phrase he

used when dealing with the old Soviet Union: ‘Trust, but

Verify.’ Good advice for all of us!

FAA MAINTENANCESAFETY TIP-1209Who Do You Trust?

When it comes to inspections,carefully andthoroughlyinspect everyitem required by themanufacturer’sinspectionchecklist

July 30, 2014

Dear AMFA Members:

In the July edition of the Grapevine Newsletter we wrote extensively about AMFA’s safety initiative.

AMFA believes wholeheartedly that safety is our number one priority. We sincerely understand that our

craft’s relationship with the flying public is one of safety and dutifully stand by our mantra, ‘Safety in the

air begins with quality maintenance on the ground.’

To that end, this month, one of our members working for Southwest Airlines filed an AIR21 Whistle

Blower complaint against Southwest Airlines under 49 U.S.C §42121 with the United States Department

of Labor. In his complaint, the aircraft maintenance technician states that he was reprimanded for

reporting maintenance issues that his Base Manager and Manager of Maintenance deemed ‘working

outside of scope of assigned task.’ The complaint further states that he was advised two days later that any

further violations might result in ‘further disciplinary action,’ a message he states was ‘meant to intimidate

and dissuade mechanics from reporting similar discrepancies.

AMFA’s National Executive Council (NEC) fully supports the actions of this member, and we reiterate

our message from the newsletter: ‘If a manager asks you to deviate from maintenance standards, they are

asking you to violate federal law. AIR21 was enacted specifically to protect you and your job from any

retaliation for reporting any such violations.’

AMFA also supports your right to invoke AIR21. We urge you to be vigilant in reporting safety

violations and, most importantly, we urge you to never allow your professional obligations to be

deterred by intimidation tactics. It is your job and responsibility to keep our aircraft running safely for

the flying public.

The onus is now on Southwest Airlines executives to fully investigate these charges, and should

they find that the managers in question violated the law, take the proper steps to ensure this never

happens again.

We see this is as a perfect opportunity to work more closely with our represented carriers to create a

stronger safety culture, and the AMFA NEC hopes that Southwest Airlines will seize this opportunity.

Stay together and keep AMFA strong!

On behalf of the AMFA NEC,

Louie Key


AMFA TAKESA STAND ONSAFETY

Maybe a different licensing system overseen by a different regulator but some things are justthe same wherever you are. Our colleagues at AMFA (American Mechanics FraternalAssociation) followed up on a report that a licensed engineer was reprimanded for workingoutside the scope of his assigned task by documenting two cracks he discovered during aninspection. On this page you can read how it all started and on the following page what thecourt decided. ALAE can only congratulate AMFA on taking a stand for safety. Both articlesalso contain some good solid advice no matter where you work in the world. As AMFA proudlysays, ‘Safety in the air begins with quality maintenance on the ground.’

Louie Key, AMFA National Director


Southwest Airlines and a Southwest mechanic have

settled a ‘whistleblower’ case in which the mechanic said

the airline threatened to punish him for reporting

fuselage cracks that grounded a Southwest airplane.

Southwest on 16 January agreed to pay $35,000 in

attorney’s fees and expenses for mechanic Charles Hall,

who discovered the cracks as he was doing a maintenance

inspection on a Boeing 737-700 last July.

The carrier also promised not to punish Hall or anyone

who had backed him up in the dispute.

According to documents in the case, Hall was assigned

to do a ‘maintenance visit 1’ inspection on the airplane on

the evening of 2 July.

‘During his inspection, (Hall) discovered two cracks on

the aircraft’s fuselage and documented them,’ stated a 8

January order denying Southwest’s efforts to get a

summary judgment in its favour. ‘Discovery of these

cracks resulted in the aircraft being removed from service

to be repaired.’

On 5 July, Hall ‘was directed to attend a meeting to

discuss the issue of working outside the scope of his

assigned task,’ the order said.

The ‘letter of instruction’ that Southwest sent Hall said:

‘Please be aware that any further violations of MPM

(maintenance procedural manual) may result in further

disciplinary action.’

Hall on 22 July then filed a whistleblower complaint

under federal law that protects people who report aviation

safety issues.

Hall in mid-August was sent a second ‘letter of

instruction,’ dated 9 July, with no mention of disciplinary

actions.

After the US Department of Labour ruled against his

whistleblower complaint 27 August, Hall appealed to

an administrative law judge on 29 August. That judge,

Scott R. Morris, on 8 January ruled against Southwest’s

request for summary judgment that would throw out

the complaint.

“Mr. Hall asserted that the letter had the effect of

intimidating him and dissuading him and other

Southwest Airlines mechanics from reporting the

discovery of cracks, abnormalities, or defects out of fear of

reprisal discipline. Southwest Airlines provided little, if

any, evidence at this stage of the proceeding to rebut

these allegations,” Morris said in his order.

In Morris’ order, he said Hall in finding and reporting

the crack clearly engaged in protected activity, and

Southwest clearly knew that Hall was engaged in

protected activity.

Morris noted that Hall discovered the cracks as he

was checking the hydraulic system, part of the

maintenance procedure.

Hall was following Southwest’s ‘maintenance program

procedures when he completed non-routine cards,

identifying certain abnormalities with the aircraft that he

believed rendered the aircraft un-airworthy,’ Morris

wrote. ‘These abnormalities were verified by other

mechanics.’

Southwest in its defence said, “Hall got the letter of

instruction because he went outside the scope of his job

duties, not because he reported a safety issue, according to

the Morris order.” It also said, “it was important for

mechanics to do their assigned tasks. It further said that

Hall suffered no punishment as a result of the incident

and the subsequent letters and meeting.”

In a statement, Southwest reiterated its position as

outlined in Morris’ order. Said Southwest: “Southwest

issued a Letter of Instruction (LOI) to an Employee who

was performing duties outside of his work scope. An LOI

is not considered disciplinary action and is not retained in

a personnel file. Southwest explained the purpose of an

LOI to the Department of Labour and updated the LOI

so that the intent was clear. As such, the original

complaint was dismissed by the Department of Labor. In

the dismissal, the DOL investigator stated:

‘Consequently, this complaint is dismissed because

Complainant did not suffer an unfavourable personnel

action relative to his compensation, terms, benefits, and

privileges of employment.’ The Employee appealed the

DOL’s dismissal. In an effort to resolve the matter, both

parties settled which resulted in Southwest covering a

portion of the Employee’s attorney fees.”

Taken from this blog by Terry Maxon:

http://aviationblog.dallasnews.com/2015/02/southwe

st-airlines-pays-35000-to-settle-mechanics-

whistleblower-case.html/#comments

SOUTHWEST AIRLINES PAYS$35,000 TO SETTLE MECHANIC’S‘WHISTLEBLOWER’ CASE


The team is particularly looking at the following four areas;• Improving Supervision & Production Planning• Implementing a Safety Culture & ensuring Engineer Responsibility• Improving the effectiveness and adoption of Procedures/Processes/ Task Cards• Improving Competency assessment / Training & Induction

To assist the team, the CAA in conjunction with the ALAE has prepared thefollowing questions in an attempt to enable LAE’s and mechanics the opportunity toprovide data that CAA will use as part of their validation process. The information willbe viewed and assessed by a dedicated team from ALAE and a summary against eachquestion supplied to the CAA. Individual entries will not be divulged and if successfulfeedback and further questionnaires may be issued.

Supervision• Does your organisation have sufficient supervision to ensure all maintenance is carried

out in accordance with approved maintenance data?• Do the supervisors spend enough time in the hangar, at the aircraft or component

being maintained and with the team?• Are you clear what the terms of reference are for approaching supervisory staff for

advice and guidance?• Are the supervisors trained and knowledgeable on all types on which they

are supervising?• Has the level of supervision changed in the past five years (better or worse?)• Has the quality of the supervision changed in the past five years (better or worse?)• Do you believe that your organisation is good at assessing competency? If not, how

could it be improved?• Do you consider the induction training and assessment to be good? If not, what could

be improved?• If you could make a request regarding Supervision what would it be?

The CAA Airworthinessteam led by John McColl(Head of Airworthiness) isspending time analysingtheir audit and inspectionfindings to assist them intheir mission to improvesafety, and direct theirlimited resources to theareas that will make thegreatest difference. Part of this plan withinAirworthiness is tofurther improvemaintenance standards.

IMPROVINGMAINTENANCESTANDARDS

18


Human Factors• Do you believe that your organisation takes Human

Factor issues into account when planning theirmaintenance activity?

• Do you believe that the Human Factor training you receive adequately cover the subject for yourworking environment?

• What would make the Human Factor training morememorable and valuable?

Maintenance data• Is maintenance data easily available and current for

your current working environment?• When carrying out significant maintenance activities,

do you always have and use a copy of the MaintenanceManual?

• Is adequate training available for all methods ofmaintenance material presentation?

• Are problems with maintenance data actively pursuedby your organisation?

• If you could change something what would it be?

Planning/work load• Does your organisation adequately break down

maintenance tasks for certification purposes?• Do you believe that your organisation has sufficient

staff for the allocated work load?• Does your organisation plan for casualty aircraft during

a shift?• Are the handovers used by your organisation

satisfactory for the work carried out?• Are handovers face to face and written?• Does your organisation regularly use overtime to cover

planned packages of work?• Does your organisation regularly refuse/cancel leave

to ensure sufficient staff are available for planned work packages?

• Have you personally observed poor maintenancestandards that you consider to be related to planning?

• What 3 achievable things would you suggest toimprove planning and workload?

Scope of Licence/authorisation• Have you had your Licence/Authorisation for more

than 10 years?• Do you fully understand the limitations of your scope

of approval?• Do you understand the full scope of your authorisation?• Are you asked to certify for work you consider outside

the scope of your license?• Does your organisation routinely plan shift-rosters with

inappropriate licence cover for the intended workload• Is your quality department able to explain the privileges

of your licence and the corresponding scope ofauthorisation?

• Are you aware of the recent changes to Part-66 in

particular the expansion of the privileges for the B2 licence?

• Does your Quality department notify you when yourlicence is due for renewal?

• What 3 things could improve working effectivelywithin the constraints of your Licence/Authorisation?

Commercial pressures• Do you consider that you or your colleagues are put

under pressure to release components or aircraft withincomplete work or known defects?

• Do you believe that too many defects are entered in theTech Log on the last flight of the day as opposed towhen they are actually observed?

• Are you aware of defects being recorded in places otherthan the Tech Log? If so, where?

• Do you consider that the work load of the engineeringmanagement of your organisation ensures all requiredchanges to process and procedure can be addressed in areasonable timescale.

Licensing• Is your licence signed?• When your licence is returned by the Authority after

variation/renewal do you check to ensure it is correct.• Are you aware of your licences expiry date. (The CAA

no longer send out renewal notices)

Reporting Culture• Are you actively encouraged to report all issues?• Is the process for reporting issues clear and the forms

or equivalent readily available?• Do you believe that the safety culture in your

organisation is improving? If not, why not?• Do you believe that compliance with regulations and

standards is good? If not, why not?• What 3 things do you believe would further improve

the safety culture in your organisation?

Oversight• Do you believe that the internal quality assurance audit

process as applied today is effective in highlighting themajor issues?

• What 3 things would further improve the qualityassurance process?

• What 3 things would you suggest that the CAA could do differently as part of their oversight toimprove standards?


Releasing an aircraft to service is the single most

important function of a licensed engineer and it

represents confirmation by that engineer that he is

personally satisfied that all work done on the aircraft has

been performed satisfactorily in accordance with Part-145

of the Commission Regulation (EC) No 2042/2003. In

the event of a maintenance related accident after such

sign off; there will inevitably be an official accident

investigation, and, in most European States, a

simultaneous criminal investigation; particularly if the

accident has led to injury or death. The licensed engineer

will be the first in line in such an investigation and should

be aware of his legal position by way of precaution.

There are certain rights afforded to protect individuals

in most countries in the event they are implicated in

criminal investigations. Significant amongst these are the

rights to have a lawyer present in interviews by

investigators of criminal activities and to refuse to answer

questions in such interviews to avoid self-incrimination.

These rights are incorporated in the European

Convention on Human Rights. However, the application

of international and European law to aircraft accidents

significantly qualifies the protection afforded by the

Convention which shortfall can only be resolved by

international and European legislation. Until such

legislation is in place, individuals caught up in an official

investigation should consider their own rights to liberty

before fully cooperating with the investigating authorities.

Reliance on so-called ‘Just Culture’ concepts in this

context is misplaced.

At first sight the concerns expressed in this article may

seem misplaced. The provisions of Annex 13 to the

Chicago Convention of 1944 set out the rights of the

investigators to call for evidence and to interrogate

witnesses, all of which is subject to the overriding

proviso in Chapter 3.1 that ‘the sole objective of the

investigation of an accident or incident shall be the

prevention of accidents and incidents. It is not the

purpose of this activity to apportion blame or liability.’

Annex 13 finds its echo in Europe in recital 4 of the

Regulation (EU) No 996/2010: ‘the sole objective of

safety investigation should be the prevention of future

accidents and incidents without apportioning blame or

liability.’ The EU Regulation entitles investigators to call

and examine witnesses and to require them to furnish or

produce information or evidence relevant to the safety

investigation (Article 11(2)(f ). Article 23 requires

member states to ‘lay down the rules on penalties

applicable to infringements of this Regulation. The

penalties provided for shall be effective, proportionate

and dissuasive’. According to recital 35, penalties

should, in particular, ‘allow for the sanctioning of any

person who contrary to this Regulation... obstructs the

actions of a safety investigation authority... by refusing

to provide... material information and documents... or,

having knowledge of any occurrence of an accident

or serious incident, does not inform the relevant

authorities thereof.’

Clearly a thorough investigation of aviation accidents

is to be desired to secure it’s overriding purpose of

AVIATION SAFETY AND THE FOR LICENSED ENGINEERS

Sean Gates


preventing recurrence of such accidents and given

that blame is off the agenda.

However, and regrettably, accident investigations and

reports have a great deal to do with blame up to and

including criminal prosecution; so that the provisions

referred to above concerning the sanctity of the

investigation process and report cannot be relied on by

those implicated or interrogated in the investigation for

a number of reasons.

The Annexes to the Chicago Convention are not

deemed part of the Convention and are not, therefore,

subject to the rules governing enforcement of treaties

between states, so contracting states are not obliged to

implement or comply with the standards of an annex.

This is emphasised by Article 26 of the Convention

which provides that a State in which an accident to an

aircraft occurs... ‘will institute an enquiry into the

circumstances of the accident in accordance, insofar as

its laws permit, with the procedure (in Annex B).’

Article 14(3) of the Regulation which concerns

protection of sensitive safety information provides ‘the

administration of justice... may decide that the benefits

of the disclosure of the records... for any other purposes

permitted by way outweigh the adverse domestic and

international impact that such action may have on that

or any future safety investigation.’ By this means, the

overriding rights of judicial authorities as provided in

national law are acknowledged; effectively sanctioning

free access by prosecutors to the official investigation.

Given that prosecutors are entitled to such access to

the extent permitted under national law, one would

expect that the Annex and Regulation would similarly

protect the rights of individuals against self-

incrimination and to the benefit of Counsel. It is, after

all, the case that accident reports are routinely relied

upon, particularly in civil law countries as the definitive

guide to the factual circumstances giving rise to the

accident. The experience in Greece in connection with

the Helios accident in 2005; which included the

prosecution of the ground engineer who last worked on

the aircraft; underlines this. Defendants were convicted

even though material evidence as to causation was lost

by the investigation committee because the Appeal

Court treated the investigation itself as being conclusive

making any re-examination of the accident superfluous;

thereby depriving the Defendants from any effective

opportunity of challenging the report’s conclusions and

the opinions based on those conclusions.

Although the European Convention on Human

Rights preserves the rights of individuals not to self-

criminate, there are a number of derogations from that

right and in any event, since the accident investigators

are not judicial authorities, neither the right to remain

silent nor the right to Counsel can routinely be enforced

by reference to the provisions of the ECHR. To obviate

the hardship so caused there is, at least in the UK, an

understanding between the judicial authorities and the

AAIB (the body responsible for accident investigations)

enshrined in a Memorandum of Understanding of 2008

which stresses that ‘the public interest requires that

RIGHTS AND RISKS

Clearly a thorough investigation of aviationaccidents is to be desired to secure it’soverriding purpose of preventing recurrenceof such accidents and given that blame is offthe agenda.

safety considerations are of paramount importance, the

consequences of which may mean that the interests of

an AAIB investigation have to take precedence over the

criminal investigation.’ This does not, of course, entirely

replace the rights taken from those who are potential

accused but represents the high water mark so far as

that protection is concerned within Europe.

Plainly the absence of ordinary rights afforded to key

witnesses who may become suspects or accused in

criminal proceedings is a matter of very considerable

concern to those parties in the event of an accident as it

is or should be to all those who are post holders in any

affected organisation up to and including members of

the Board. This concern should be exacerbated by the

increased frequency with which criminal prosecutions

follow aircraft accidents; as in Valujet 1996, Concorde

2000, SAS 2001, DHL Bashkirian 2002, Helios

2005, and Spanair 2011, to name some of the more

recent cases.

Given the potential consequences of an accident

investigation to individuals and corporations, the

example given in the UK by the Civil Aviation

(Investigation of Air Accidents and Incidents)

Regulations 1996 at section 12(1) which provides:

‘no report which is required... to be published shall be

so published if, in the investigating inspector’s opinion,

it is likely to affect adversely the reputation of any

person, until the investigating inspector has:

(a) Where it appears to him to be practicable so to do,

served a notice under this Regulation upon that

person... and

(b) Made such changes to the report as he thinks fit

following his consideration of any representations

which may be made to him in accordance with

paragraph (3) below by or on behalf of the person

served with such notice’

should represent the minimum level of protection for

the rights of the individuals and the guarantee they need

to cooperate fully with investigators to advance the prime

purpose of securing and increasing safety in the industry.

A number of conclusions can be drawn from the state

of the law regarding accident investigations and recent

experiences. Principal among these must be that

anything said to accident investigators can and should

be expected to be used in criminal proceedings against

the interests of those making the statements and their

employers. Other than in the UK, there is no effective

opportunity for individuals to participate in or challenge

the findings of the accident report either within the

framework of the investigation itself or in subsequent

criminal proceedings. Criminal proceedings in Europe

are likely to be protracted over many years. The impact

of criminal proceedings on individuals is financially and

emotionally devastating, as it can also be on their

employers regardless of conviction or acquittal. This is

because of the time the proceedings take; their cost and

the mentally debilitating process of defending what are

quite often accusations that are unfounded, expensive to

challenge, and poorly understood by judges who are not

competent to comprehend complicated technical

matters. It would not be unusual in Europe for

competent criminal defence lawyers to charge €1million

per individual to defend criminal proceedings; and very

few criminal lawyers have ready access to the specialist

aviation expertise to support a technical defence. No

airline in Europe has adequate insurance to protect its

employees other than directors and officers against

criminal defence costs; though the European Regions

Airlines Association has issued a recommended practice

calling for protection from legal costs to form part of an

airlines disaster preparedness strategy.

The question plainly arises what can and should be

done to address these issues. From the perspective of

licensed engineers, an awareness of their exposure risk is

essential; and individuals need to identify sources of

support that may be available to them and tolls which

may be useful for their defence. What support does the

employer offer? Can any other source of financial and

technical support be identified? If the employer is one of

those which interprets a Part-145 CSR as purely a ‘tick-

box’ activity; that position should be documented and

available; as should the position of the national

authority with regard to the regulatory implications. A

defensive mindset needs to be adopted so that

responsibility is effectively allocated to those with

effective control.

Sean Gates, Senior partner

Gates Aviation Ltd

London


OCCURRENCE REPORTINGIN CIVIL AVIATION

Figure 1


Figure 2

Occurrence reporting is becoming more important as wemove from the current aviation safety system. The existingregulation framework is primarily a reactive system relyingon technological progress, the adoption of legislationoverseen by effective regulatory authorities, and detailedaccident investigations leading to recommendations forsafety improvements. However, whilst the ability to learnlessons from an accident is crucial, systems which areessentially reactive are showing their limits in being able todrive further improvements in the accident rate. As morethan 820 million passengers were carried by air in 2011 inthe European Union it can be demonstrated that airtransport is one of the safest forms of travel. However,while the accident rate has remained more or less stablesince 2004, the traffic is expected to almost double by2032. This could involve an increased number of accidentsand related fatalities. The EU is therefore faced with asignificant challenge if its aim is to continue to improvesafety and be the world leader in aviation safety asexpressed in the Transport White Paper 3.

(http://ec.europa.eu/transport/themes/strategies/doc/2011_white_paper/white-paper-illustrated-brochure_en.pdf )

The European Commission's proposal in order toimprove safety is an ambitious and comprehensive set ofregulations to move from principally reactive towards amore proactive and evidence based aviation safety system.To meet this challenge, the Commission proposesestablishing the appropriate environment to ensure that alloccurrences which endanger or could endanger aviationsafety are reported and collected. In order to achieve abetter reporting of occurrences the proposal includesprovisions ensuring the setting up of an appropriateenvironment to encourage aviation professionals to reportsafety related information by protecting them frompunishment except in cases of gross negligence. It alsoensures that the scope of mandatory reporting covers

major potential risks and that the appropriate means tocapture any safety threat are established with theestablishment of voluntary and Internal OccurrenceReporting Systems (IORS).

See figure 1 for an example of the EASA TechnicalOccurrence report form.

To ensure engineering personnel report not only MORs,but all occurrences which endanger or could endangeraviation safety, the culture of reporting in engineering willhave to be modified in order to develop a true picture ofthe real risks.

Self-reporting and/or reporting of a close colleague mayprove to be difficult to provision in the new rulestherefore leaving a gap in the requiredinformation for the system to deliver thebenefits and become the world leader inaviation safety.

However, alternatives are available for thosewho would prefer to report directly toALAE/AEI. AEI has recently introduced its ownsecure online reporting system. Members and non-members alike can use this completely confidentialsystem in order to raise important safety issues. AEI’sless formal system encourages reporting in order forAEI to report on general trends – see figure 2.

With the move to risk based oversight imminent,it is vitally important that we all make full use ofthe available reporting systems.

Hangar floor audits will be significantly reducedas the new system relies heavily on submittedreports. Therefore the only way to ensureregulators gain atrue picture of yourorganisation is by playingyour part and reporting as necessary.

Global conspiracy or just coincidence?In this edition of Tech Log there has been much

mentioned of what appears to be at best moves to

undermine the Licence whilst at worst remove the

requirement for it within Europe completely. What may

be less well known is a recent Australian aviation rule

change proposal which our colleagues at ALAEA

(Australian Licensed Aircraft Engineers Association)

challenged via parliament. CASA the Australian NAA

wanted to amend the regulations to enable unlicensed

but authorised personnel issue a certificate of release to

service for certain so called ‘specialist maintenance’ items.

The proposal was obviously extremely controversial

and worded in such a way there was a real fear that

safety would be undermined as there appeared to be no

limits as to the tasks, these specialist could perform.

From a Licensed Engineers perspective, understandably

more than unwelcome.

The situation appeared to suggest collusion between

Australian airlines and the regulator, CASA, in order to

dilute the effectiveness of the Licensed Engineer. To

many it seemed to be a well-crafted attempt by industry

drivers to reduce maintenance costs by introducing

cheap labour. It was of course sold as an advance in

world leading aviation maintenance work practices.

Whatever your view, the fact is, had the proposal got

through parliament, it would have enabled airlines and

MRO’s to employ cheap labour, supply them with

minimal training and then allow these so called

‘specialist certifying maintenance engineers’ to perform

and certify aircraft maintenance. Sounds familiar

doesn’t it.

Fortunately, our Australian colleagues were right on

the ball and immediately set about challenging the

proposal. A tremendous amount of groundwork was

carried out relating to certification responsibilities and

accountabilities in a global industry, as well

obtaining a legal opinion. This was ultimately relayed

to Nick Xenophon, an Australian MP who was

himself very concerned about the

consequences of the proposed

rule change.

VIEW FROMDOWN UNDER


Mr Xenophon opened the debate in parliament

by stating:

“I am moving to disallow these regulations today for

several reasons. Primarily, the impact of these

regulations is to reduce the safety of Australia’s aircraft

maintenance regime by transferring the authorisation to

certify airworthiness of aircraft from licenced engineers

to non-licenced and less-qualified people. The role of

licenced aircraft engineers is vital. They have a thorough

and sound knowledge of the aircraft as a whole they

know them nose to tail and back to front, and from

wing tip to wing tip. And, while the other individuals

who may work on specific areas of maintenance are

undoubtedly experts in their particular field, I am

concerned that they do not have the same

comprehensive ‘big picture’ knowledge as licensed

aircraft mechanical engineers.

This is an important issue about airline safety in this

nation. We do not want to see airline safety being

diminished. The regulations propose to have non-

licensed aircraft engineers to do certain types of

maintenance and to have certain powers. It is my view

that they should not have the authorisation to sign off

on the airworthiness or maintenance undertaken on

aircraft. I am concerned that the changes in these

regulations may put our aircraft maintenance systems

below the minimum global standard”.

After an extensive debate the senate voted narrowly to

dismiss the proposal.

The defeat of this government introduced bill drew a

very angry public response from the Australian deputy

prime minister, Mr Warren Truss who stated that:

“Labour’s decision to vote down the safety regulator's

considered position signals a dangerous departure from a

long-standing commitment from both side of politics to

allow the experts to determine safety issues”.

Mr Truss continued with: “Labour’s veto of this

measure sets back modernising Australia's aviation

safety maintenance and means that we are out-of-step

with major aviation industries in the US, Europe,

Canada and New Zealand. Aviation safety is not and

must not be allowed to become an industrial or political

issue. It must be above party politics and it certainly

should never be about what union a person undertaking

specialist aviation maintenance pays membership to”.

So there we have it. A government now on record as

stating that safety will be improved by allowing

unlicensed mechanics to issue certificates of release to

service. It’s also interesting to note the criticism directed

at our ALAEA colleagues and unions in general for

challenging the proposed rule amendment. Something

we believe to be absolutely right and proper in a

democratic society particularly when considers the

potential safety and legal implications the new system

would have encountered.

Unfortunately, all too often

today the average worker

seems to have

forgotten the

good work unions

and associations

perform. A sentiment

made by an anonymous

poster commenting on

the ongoing

development; “seems we

are in a world where it is

expedient to blame

unions and industrially

active staff for placing

roadblocks in the way of

unsafe laws and

practices”.

We would also like to

fully align with and

endorse a recent

statement made by

the ALAEA

President Paul Cousins:

“Your Executive tries to

ensure that the trust, honesty and integrity that we

expect of our members is reflected in our own

performance. It is not an easy path as many parts of the

industry we deal with simply don’t believe in safety and

airworthiness like we do. Unfortunately, all too often,

companies only pay lip service to what we hold dear.

However we remain focussed on trying to ensure what

they do is transparent and that they are kept

accountable”.

ALAE second that.


It is not an easy path as many parts of theindustry we deal with simply don’t believe insafety and airworthiness like we do.Unfortunately, all too often, companies onlypay lip service to what we hold dear.


When Navy fighter pilot and flight instructor Scott

Crossfield heard about the Bell Experimental Sonic XS-1

under construction in 1947, he wrote to its manufacturer

proposing that he be named its first test pilot; he offered

to fly it for free. Bell did not reply, but no matter: In 1950

Crossfield was hired by the National Advisory

Committee for Aeronautics and sent to Edwards Air

Force Base in California to fly the world’s hottest X-

planes, including the X-1, the tail-less Northrop X-4, the

Douglas D-558-I Skystreak and D-558-II Skyrocket, the

Convair XF-92A (which he pronounced ‘under-powered,

under-geared, underbraked, and overweight’), and the

Bell X-5. He made 100 rocket-plane flights in all. On

November 20, 1953, he took the D-558-II to Mach 2.04,

becoming the first pilot to fly at twice the speed of sound.

He gained a reputation as a pilot whose flights were

jinxed: On his first X-4 flight, he lost both engines; in the

Skyrocket, he flamed out; the windshield iced over in the

X-1. After a deadstick landing in a North American F-

100, he lost hydraulic pressure and the Super Sabre

slammed into a hangar wall. Forever after, Chuck Yeager

crowed, “The sonic wall was mine; the hangar wall

was Crossfield’s.”

Despite the many thrills at Edwards in the Golden

Age of X-Planes, Crossfield was seduced by an aircraft

on the North American drawing board. In 1955, he quit

the NACA and signed on with the manufacturer, where

he found his calling with the sinister-looking X-15.

Crossfield made the first eight flights of the X-15,

learning its idiosyncrasies, and logged another six after

NASA and Air Force pilots joined the program. On

flight number 4, the fuselage buckled right behind the

cockpit on landing, but he had his closest call on the

ground, while testing the XLR-99 engine in June 1960.

“I put the throttle in the stowed position and pressed

the reset switch,” Crossfield wrote in his autobiography

Always Another Dawn. “It was like pushing the plunger

on a dynamite detonator. X-15 number three blew up

with incredible force.” Fire engines rushed to extinguish

the blaze, and Crossfield was extracted from the cockpit.

“The only casualty was the crease in my trousers,” he

told reporters. “The firemen got them wet when they

sprayed the airplane with water.” You sure it was the

firemen? A reporter asked. Yes, he was sure, he said.

“I pictured the headline: ‘Space Ship Explodes; Pilot

Wets Pants.’”

After his Spitfire was shot down by a Focke-Wulf 190

over the Mediterranean in 1944, Hoover was captured

and spent 16 months in the Stalag Luft 1 prison in

Barth, Germany. He eventually escaped, appropriated an

Fw 190 (which, of course, he had never piloted), and

flew to safety in Holland. After the war Hoover signed

up to serve as an Army Air Forces test pilot, flying

captured German and Japanese aircraft. He became

buddies with Chuck Yeager; Hoover was Yeager’s

backup pilot in the Bell X-1 program, and he flew

chase in a Lockheed P-80 when Yeager first exceeded

Mach 1.

Hoover moved on to North American Aviation, where

he testflew the T-28 Trojan, FJ-2 Fury, AJ-1 Savage, F-

86 Sabre, and F-100 Super Sabre, and in the mid-1950s

he began flying North American aircraft, both civil and

military, at airshows. Many pilots called Hoover “the

greatest stick-and-rudder man who ever lived.” Hoover

is best known for the ‘energy management’ routine he

flew in a Shrike Commander, a twin-engine business

aircraft. This fluid demonstration ends with Hoover

shutting down both engines and executing a loop and an

eight-point hesitation slow roll as he heads back to the

runway. He touches down on one tire, then the other,

and coasts precisely to the runway centre.

Despite the numerous awards accorded him, Hoover

remains humble enough to laugh at himself. He notes in

his autobiography, Forever Flying, that in the 1950s,

after showing off his Bugatti racer to the

neighbourhood kids, he asked, “Well, what do you

think?” One youngster’s reply: “I think you’ve got the

biggest nose I’ve ever seen.”

THE STORIES OF TWO GREAT PILOTS

Scott Crossfield

Robert A Hoover

A look at the first pilot to fly twice the speed of sound and the manknown as ‘the pilot’s pilot’.

TECHLOG SPRING 2015


LETTER

We write to place on record our belief that the air

travelling public in Europe is exposed to an increasing

risk of injury. Our concern derives from the

inconsistent, and in some European countries,

inadequate, application by the individual national

authorities of safety regulations. The dilution of these

regulations by the authorities of those countries

presently represents an unacceptable risk of disaster.

The risk arises out of the regulations governing the

release to service of aircraft after they have undergone

maintenance. The rules promulgated by the

International Civil Aviation Organisation and approved

by the European Aviation Safety Agency (“EASA”) call

for work done on aircraft to be checked and signed off

by a licenced engineer whose responsibility it is to

certify that the aircraft is fit for service. The relevant

regulation (Part-145.A.50(a)) states ‘a Certificate of

Release to Service (CRS) shall be issued by

appropriately authorised staff on behalf of the

Organisation when it has been verified that all

maintenance ordered has been properly carried out’.

The administration of regulations within Europe is the

responsibility of the Civil Aviation Authority of each

European country. Their function is to approve the

procedures proposed by individual operators. The

European Aviation Safety Agency (EASA) periodically

audits each Authority to verify that the procedures they

have approved are in order.

We are advised by members that, in certain European

countries, Part-145 approved maintenance organisations

have obtained approval for a procedure for the release of

aircraft into service which effectively removes the

requirement for Part-66 qualified licensed staff to check

the work that has been undertaken by the organisations

mechanics. These revised procedures simply require the

licenced engineer to verify that the unlicensed

mechanics have signed off the work that was to be done.

The licenced engineers cannot physically inspect and

check. In the words of Part-145, there is no verification

the work has been properly carried out. This reduces the

task of the licensed engineer to a purely administrative

‘tick box’ exercise though he continues to bear the

professional, civil and criminal responsibility by virtue

of execution of the CRS for anything which may go

wrong subsequently as a result of the unsupervised

maintenance.

This procedure does not represent the verification

called for by Part-145 nor is it the custom and practice

of the industry. Instead it represents a departure from

that practice and a serious derogation from it. Such a

procedure cuts the operators costs by reducing the

amount of time that may be spent in maintenance;

particularly if the licenced engineer discovers work not

performed adequately. This in turn may lead to delays in

operation, some of which may give rise to the airline

suffering additional costs because of its strict liability

under the European regulation imposing liability on

carriers for delays. This should not be an adequate

reason for safety itself to be compromised.

It is not clear to us how the procedures adopted by the

national authorities we have mentioned can have

successfully been audited by EASA although there have

been suggestions that EASA itself is not adequately

funded or staffed. There is, however, no check on EASA’s

performance itself in this context. There is no effective

alternative for us to raise this issue other than by this

formal letter in which we hope to warn of the possible

consequences of the current dilution of safety regulations

within Europe. Of course we hope that that derogation

from Part-145 will not result in a fatal accident but

instead to a review of the audit procedure itself and of the

regulations of those States which we believe are currently

in breach of the regulations so as to return safety to the

heart of commercial aviation within Europe.

AEI has been receiving an ever increasing amount of evidence that licenceengineers are becoming persona non grata in some airlines and mro’s. Recentlya major operator introduced a new release to service procedure which AEIbelieves is both unsafe and non compliant. The situation could also leavelicensed engineers wide open to criminal prosecution through no fault of theirown. Therefore AEI has sought an independent legal view of the situation andsent this letter to Patrick Ky, the EASA executive director.

On November 16, 2013, a Piper PA-28-140 lost engine power shortly

after takeoff and crashed, resulting in a destroyed aircraft and a

seriously injured pilot. Why? Read on.

You are probably very familiar with the air ducts commonly referred

to as ‘SCAT’, ‘SCEET’, ‘CAT’, and ‘CEET’.’ You may have replaced

some on the aircraft engines you have worked. You might even keep a

ready supply on hand. Although we are not going to go into detail

about each duct here, we do caution you to ensure that the one you are

using is acceptable for the particular application intended. Beware!

Although it ‘looks like a duct’, ‘feels like a duct’, or ‘fits like a duct’, it

may not function like the ‘approved’ duct for your specific job.

Investigation revealed that the ‘SCAT’ duct installed as a carburettor

air inlet duct on the mishap PA-28-140 did not meet the specifications

of the air duct authorised and provided by Piper. The duct

COLLAPSED, thereby cutting off air flow to the engine.

An approved Piper inlet duct is engineered and designed to operate in

a vacuum of – 12 inches of HG (mercury), at temperatures between –

65 to +500 degrees Fahrenheit. The wire supporting the duct is .048

inches in diameter. Although the collapsed duct had the correct inside

diameter, the wall thickness was thinner and the wire size was several

thousandths less than the Piper duct.

We believe that “off the shelf ” ducts may be being used as a normal

replacement part instead of the authorised Piper carburettor air inlet

duct. We say this because there have been no approved carburettor air

inlets ducts ordered from Piper since 1999 even though the FAA

registry indicates there are over 5000 registered PA-28-140 aircraft.

What can you do to help prevent another accident? Well, if

applicable, check your fleet of PA-28-140 aircraft. Pass the word to the

owners and operators who fly these aircraft, as well as your AMT

colleagues that maintain these aircraft. The number one thing you can

do is always research the manufacturer’s manuals to validate you are

using approved replacement parts. Finally, never replace components

based on what was previously installed. Trust, but verify.

See Maintenance Safety Tip-1209, ‘Who do YOU Trust?’ published

August 2012. (See page 13.)

http://www.faasafety.gov/SPANS/noticeView.aspx?nid=4046.

TECHLOG SPRING 2015

SHORT REPORTS

28

One of the most commonthemes for Aviation Safety

Action Program (ASAP) Reports submittedfrom Aircraft Maintenance Technicians(AMTs) involve time constraints and pressure.It is not always a supervisor standing over ussaying, “get the job done now,” sometimes weas technicians put the pressure on ourselves.We need to realise this concept and correct theproblem where it exists. This is where the ideaof safety over schedule comes in to play.

The job we are hired for is to inspect, service,and repair the aircraft and then send it back inairworthy condition. We are the only ones thatcan deem the aircraft airworthy. We cannotbase our work on aircraft schedules. Thecompany is always trying to keep to theirschedule, and that is what they should try to dohowever, we have no control over tooling,parts, arrival times of aircraft in the case ofovernight work, or other unforeseencircumstances. Our job is to do the workaccording to the manuals, and return anairworthy product. If the aircraft is notfinished, the work will have to be rescheduled,cancelled, or it will just have to wait until the

correct procedures are accomplished. Do notrush, something as simple as paperwork notfilled out correctly can get you a Letter ofInvestigation (LOI).

In the case of an accident, there is morefinancial benefit to the company to adhere tothe policy of safety over schedule. It is alsomore beneficial to the AMT to preventthemselves from being hurt, receiving an LOI,possibly losing your job or worse. Of course,without being said it is always beneficial to our passengers.

Do we need another ASA Flight 261 tobecome safer? We all must take safety seriousand be proactive instead of reactive, and thisincludes the company. Make sure you do thingscorrectly, not quickly, and make sure you do theright thing even when no one is watching. Youwill never receive punishment for taking adelay on a turn or an originator if you aredoing maintenance according to the correctprocedure.

Another of the top human factors causes ofincidents are not using or reading technicalpublications and culture as affected byleadership. We have addressed the former in

past articles, but it serves to remind us that weneed to check the proper manuals each timewe perform maintenance and be aware ofupdates, read and sign, and make sure we havethe newest revisions at all times. The latter isalso a concept that we have discussed in thepast. Our culture needs to change, not onlyours, but also leadership’s. How can we assistthem in changing their culture? We need toreinforce our newly changed culture with eachother, and if questioned relay this tomanagement. We have done this last monthin meetings with the companies, explainingthis concept with our Safety Initiative. If you have not heard of this presentation,contact your local President or Safety andStandards Chairmen.

With all this being said, be aware of yoursurroundings, pay attention to safety, and haveall these concepts in your thoughts as youconduct maintenance. Familiarise yourselfwith our new Safety Initiative and we will allbe more efficient and safe in our jobs asprofessional AMTs.

David A. Brooks, National Safety &

Standards Director

SAFETY OVER SCHEDULE

FAA MAINTENANCESAFETY TIP-1203Is the duct ready for flight?


Is the safety profession uniquely incapable of renewing itself? For aprofession that is organised around the elimination, reduction andcontrol of risk, innovation can be a tall order.

Innovation means taking risk. It requires a critique and a questioningof assumptions that underlie our practices. Such a critique, suchquestioning, can be unwelcome. These are assumptions and practices,after all, that (many believe) have got us to where we are today, thatkeep many of us in business. Innovation is risky. It entails reputationalrisk, psychological risk, financial risk, practical risk even.

Safety innovation, then, is not just an oxymoron. It could be whatphilosophers call a performative fallacy. By stating itself, it denies thevery possibility of what it states. Safety and innovation do not worktogether, because innovation is per definition unsafe. Or at least it isseen as unsafe by all kinds of stakeholders.

Fear of innovation, of thinking and acting differently, has doggedhumanity forever. Yet humanity has always found ways to conquer thatfear. The European Enlightenment is an example of a wholesale shiftin intellectual thinking, lifting up the power and freedom of humanreasoning over hand-me-down truths from Church or Crown.Immanual Kant, one of the great Enlightenment thinkers, argued thatEnlightenment was our release from self-incurred tutelage. Tutelage isthe incapacity to use our own understanding without the guidance ofsomeone else or some institution. Tutelage is the ultimate run forintellectual cover, as one of my students Shawn Pruchnicki calls it.Tutelage means relinquishing your own brainpower and conform so as

to keep the peace, keep a job. But you also help keep bad ideas in place,keep dying strategies alive.

Crucially, Kant blamed not a lack of intellect for us submitting tosuch tutelage. He blamed a lack of determination; a lack of courage.His rallying cry for the Enlightenment became Sapere Aude, or ‘Dareto Think!’ Innovation depends on such courage. It depends on the freedom from constraint, on freedom from the shackles of a current paradigm.

It depends on a relentless curiosity, on an impatience ordissatisfaction even with what other people want us to know or do. Weare caught in a paradigm that has us confirm to each other what wethink we already know. This is how we train and educate vast cadres ofnew safety professionals. But innovation means thinking differentlyfrom what we think, from how we think. It means, as Michel Foucaultonce said, straying far afield of ourselves, seeing differently from howwe see. It means becoming free from ourselves. Dare to think!

But can safety professionals do that? There is, perhaps, somethingindelibly conservative about the safety profession it is a fieldcharacterised by a dogma of risk adversity, by an inclination to preservethat which we know (or hope or pray) still works for us. Daring tothink could mean playing with fire. It could mean biting the hand thatfeeds us. Perhaps taking risk is precisely what we do not want to do. Oris it?

Please help prove that we can dare to think, and change, too.Sidney Dekker http://www.sidneydekker.com/

Innovative and critical safety thinking www.safetydifferently.comCAN SAFETY RENEW ITSELF?

SHORT REPORTS

Licensed aircraft engineer, and member of theALAE Branch of Prospect, John Higgins wonhis protracted legal battle with his formeremployer British Airways for unfair dismissal.

John worked for British Airways as alicensed aircraft engineer for more than 27 years. But he was dismissed after an erroron a maintenance task, when he sought torepair a mistake by a colleague, on a day whenBA was very short staffed.

He appealed against the dismissal as he hadan exemplary career and BA had recorded theerror as having little or no airworthiness risk.But, although his appeal was successful,British Airways would only agree to reinstatehim as a mechanic, a position several gradeslower that would see him lose his status as alicensed aircraft engineer.

John resigned and pursued a claim of unfair

constructive dismissal with the support of theALAE Branch of Prospect and barristerLance Harris of Old Square Chambers whorepresented John at the hearing.

His case was heard in the Glasgow tribunalfrom 23-27 March. The tribunal agreed thatdemotion was such an extreme anddisproportionate sanction in thecircumstances that it amounted toconstructive dismissal.

Speaking after the ruling on Friday Johnsaid: “It is essential that any moves toundermine the status of the licensed aircraftengineer are opposed.

“I could not have done this without thesupport of the union’s Association ofLicensed Aircraft Engineers branch whichhas seen me through this very difficult time.”

Prospect full-time officer Malcolm Currie,

who along with union representative KeithRogers gave evidence to the tribunal, said:“Thank goodness John was a member ofProspect or he would have been left to try tofight this without any resources or support.It's so important for people to join a union.”

“If the employer had been successful indismissing John under these circumstancesthe effect would have been to inhibit otherengineers from reporting incidents to ensurethe industry is as safe as it possibly can be.”

Marion Scovell, head of Prospect Legal,said: “This is a great result. Constructiveunfair dismissal cases are very difficult to winbecause the law creates a very high hurdle forclaimants. In this case the tribunal found thatthe decision to demote Mr Higgins wasdisproportionate and I’m delighted that theyfound in his favour.”

PROSPECT MEMBER WINS UNFAIR DISMISSALCASE AGAINST BRITISH AIRWAYS


PERSONAL DETAILSPlease note that the Members’ migration ‘log in’ process

has now ceased. In order to gain access to the ALAE

website, Members’ only section and forum, please

update your details by logging onto the Prospect website

and selecting ‘first time log-in’ from the Members-only

menu at the top right-hand side of the page. The

process takes just a couple of minutes and will

automatically grant access to both the Prospect and

ALAE Members’ only area and, of course, the ALAE

forum. You will be required to enter your surname, post

code and Prospect membership number as printed on

the address label of your latest ‘Profile’ magazine. If you

should encounter any problems registering then please

contact our Chertsey office. It is well worthwhile

spending a few minutes in the Prospect Members’ only

area as you will be able to find out more information

on the additional services now available as a result of

the merger.

FREE WILL WRITING Prospect offers a free willing writing service to its

members in partnership with Slater & Gordon

solicitors. To make use of this service please log onto the

Prospect Members’ only area and you will find out more

under the legal services menu (www.prospect.org.uk).

LEGAL COVER Prospect’s LegalLine telephone number is

0800 328 7987 for all issues other than employment.

Employment issues are dealt with through your

Prospect full-time officer, John Ferrett

([email protected]).

PERSONAL DATAPlease help us to help you by ensuring your personal

information which we hold on our database is kept up

to date. With e-mail communication offering quick and

efficient access to information, a valid e-mail address

would help us tremendously whilst also keeping you

informed. It is also important that we know your

current home address and in particular, where you are

currently employed, as we need to know how many

Members we have in any specific company should we

make an application for recognition in that location.

Please take a couple of minutes to confirm that our

records are indeed current.

ASSOCIATION NOTICES

PROSPECT — THE VOICE OFTHOUSANDSProspect is a trade union with over 115,000 members

employed as specialists in defence, science and

technology, heritage, energy, agriculture, environment,

aviation and transport sectors. Prospect is run and

funded by members and exists to benefit their interests

in a variety of ways. Prospect negotiates terms and

conditions of employment, lobbies ministers from a

politically-neutral position, campaigns through the

media, represents members individually (right up to The

European Court of Justice) and provides relevant

commercial services to members.

Membership can be confidential if you wish, and you

can continue your membership beyond ALAE

employment. Of course, you may not expect to need our

support or representation; but neither did any of the

numerous members the union advises and represents in

difficulty each year!

Prospect are running a ‘Member recruit Member’

incentive and for every new member recruited there is a

reward for the recruiting member. If you have a

colleague who is not a member they can join easily on

line at the following link:

http://www.prospect.org.uk/becoming_a_member_or_re

p/member_get_member?_ts=50209

MEMBER’S INFORMATION PAGE

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