PAMA PROSE
BY DALE FORTON
ith the Dec. 7, 2011 crash of a Eurocopter AS350-B2 helicopter National Transportation Safety Board (NTSB) recommendations out they have put duty times for aviation maintenance professionals at the forefront. And of course their recommendation is limited to on-demand, fractional and all repair station operations, along with those involved with scheduled carriers. . Three items were recommended to the FAA from the NTSB. • establish duty time regulations for maintenance personnel in Parts 121, 135, 91 (K) and 145 that cover start time, workload, shift changes, circadian rhythms, adequate rest time and other factors;
Fatigue at the Forefront W
• encourage operators to implement best practices for conducting maintenance under Parts 121, 135 and 91 (K) that include use of work cards to detail maintenance tasks and other recording and verification of each task;
• and mandate maintenance personnel to receive initial and recurrent human factors training that cover human error causes such as fatigue.
DALE FORTON has worked in aviation for more than 32 years and as a licensed A&P Technician has been an active PAMA member for more than 26 of those years. For the past seven years he has served on the PAMA Board of Directors as vice chairman of the Board of Directors, Great Lakes Regional Director, Membership Committee Chairman, Governance Committee Chairman, and Strategic Planning Committee Chairman. Formerly a director of maintenance for 135,145, and 147 operations, he has also held positions as service manager, parts manager, technician, and director of product support. Dale has owned his own businesses as well.
PAMA was very happy when the FAA backed down from its interpretation of maintenance duty
time. Although we do believe strongly we need a regulation that covers the first bullet of the NTSB recommendation. Let me address the second and third bullets first. Encouragement by the FAA for the use of work
cards. This was a failure to follow procedures, 43.13 and the OEM maintenance manual. Which I believe was because of fatigue. I do not believe we can or ever will have a work card for every maintenance operation on an aircraft. But we can have procedures to safely make sure the work was completed correctly. Mandating human factors training is a good idea but so many A&P’s do not even take advantage
of IA renewals that are available locally. We believe this is a good idea but needs to have a broader scope than just human factors. Finally regarding fatigue. PAMA firmly believes that fatigue is an issue that maintenance technicians have to deal with constantly. The fact that the aircraft fly primarily during the day, necessitates nights and weekends be used for a majority of maintenance to be performed. And there are numerous factors that must be considered as a whole to have a viable fatigue prevention system. We agree with the statement the NTSB made on this point. Some of the other issues concern hours worked in a day. A technician might work three days in a
row of 16 hours each and become fatigued way before a six-day work-week ever became an issue. Additionally, a technician who normally works until mid-night might become fatigued after only 2 hours of overtime due to working past the time he would normally go to sleep. Additionally, what the person is doing or going through while off duty can play a large role in the
person’s ability to perform their duties safely. A technician, who works nights, could easily spend their day cutting down trees, or cultivating a garden or going through a divorce. Many of these tasks are more labor or mentally intensive than the actual aircraft maintenance. PAMA is working on this example we gave to the FAA. So this gives you an idea of what we are pursuing.
Maintenance Personnel Duty Hours A. All maintenance technicians are expected to manage their personal time so as to be well rested when they report for work.
B. Maintenance Technicians shall observe the duty time limitations as described in this section and shall not work when fatigued.
C. The following guidelines apply to any 24-hour period: • Maximum Duty Day – 14 hours (if work commences prior to 11:00 AM). • Duty Day – 12 hours (if work commences after 11:00 AM). • Rest Period – 10 hours. • Consecutive Days – 60 hours in a 7 day work week will require 24 hours off duty. 12 Consecutive Days worked will require 48 hours off.
PAMA would like to see organizations take this kind of multifaceted approach that blends as many of the fatigue causing factors, and prevents technicians from pushing themselves into unsafe working situations due to their personal desire to get the job done. Many of the large corporate flight departments have duty time requirements similar to these for their staffs. Our Technical committee is revising and adding to this suggestion above and will be offering a suggestion to the FAA that meets the NTSB suggestion as well. AM
38 Aviation Maintenance |
avm-mag.com | February / March 2013
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