Air Safety (Inside the FAA)
By David Amsden
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About this ebook
Air Safety (Inside the FAA) is written for anyone involved in aviation or who uses the air transportation system for travel. I disclose my extensive background in aviation to establish my qualifications for giving my opinions regarding many facets of the aviation industry, including regulatory oversight by the Federal Aviation Administration (FAA). I also include true experiences concerning my personal aviation maintenance and pilot endeavors, which have provided me with additional experience. I share stories of aviation accidents and incidents to show how the FAA’s Aviation Safety Inspectors perform their duties and make safety recommendation.
A couple of chapters deal with in-depth problems of existing regulations, including what I believe to be improper violations of aircraft mechanics working for airlines, the operation of unairworthy aircraft in revenue service, and the inadequate and useless program the FAA uses to perform it’s so called surveillance known as the Air Transportation Oversight System or ATOS for short.
In the process I hope to expose the contempt and abuse of FAA management that I feel undermines the trust given them by the public. I feel the only reason any safety in aviation exists today is because of the integrity of the FAA inspectors that go above and beyond the call of duty to keep the public safe in spite of management and all of the ridiculous FAA policies and procedures and bad interpretations of the regulations. I must not forget all the great mechanics, pilots, flight attendants, and support people in the airline industry that also have the integrity to do their best to make aviation safe for the public under the broken system in which they are forced to work.
David Amsden
I grew up in North Palm Beach, Florida where I was fortunate to enjoy surfing, boating, fishing, scuba diving, riding motorcycles, and racing cars at Palm Beach International Raceway. In 1968 I traveled with Cast C of the Up With People musical group, including a three months tour performing all over Italy. After returning to Florida I joined the United States Air Force as an aircraft mechanic, beginning a long career in aviation. During my active duty I spent some time in 1969 and 1970 in Vietnam and later was assigned to the 53rd Weather Reconnaissance Squadron’s Hurricane Hunters for two years in Puerto Rico. A few years after leaving active duty I joined the Air Force Reserves in 1977 as a C-130 Flight Engineer for three years. Then from 1980 to 1989 I managed maintenance bases for several freight airlines on large turbo prop and jet aircraft in Missouri, Utah, Arizona, and Texas until I was finally hired as an Aviation Safety Inspector with the Federal Aviation Administration at DFW Airport, Texas, until retirement in January of 2010. I currently live in Spring Hill, Florida and enjoy Caribbean cruises and scuba diving. My travels brought me to places in about 25 different countries and through parts of all 50 states, of which I lived for a time in 5 of them. I resided the longest in the Dallas/Fort Worth area of Texas and I can say I truly miss Texas, but I don’t miss the tornadoes.
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Air Safety (Inside the FAA) - David Amsden
Air Safety (Inside the FAA)
By
David L. Amsden
*****
PUBLISHED BY
David L. Amsden at Smashwords
Air Safety (Inside the FAA)
Copyright © 2013 by David L Amsden
All rights reserved. This book or any portion thereof may not be reproduced or used in any manner whatsoever without the express written permission of the publisher except for the use of brief quotations in a book review.
This ebook is licensed for your personal enjoyment only. This ebook may not be re-sold or given away to other people. If you would like to share this book with another person, please purchase an additional copy for each recipient. If you’re reading this ebook and did not purchase it, or it was not purchased for your use only, then please go to Smashwords.com and purchase your own copy. Thank you for respecting the hard work of this author.
Cover Photos are of the actual Allegro Airlines DC-9-14 aircraft after crash landing at Tampico, Mexico as described in Chapter 14.
Table of Contents
Dedication
Forward
Acronyms
Chapter 1 _ Background and Experience
Chapter 2 _ Thoughts to Ponder
Chapter 3 _ Bird Strike
Chapter 4 _ Near Gear-Up Landing
Chapter 5 _ Double Engine Flameout
Chapter 6 _ Near Mid Air Collision
Chapter 7 _ An Encounter with the FAA
Chapter 8 _ The FAA Mission
Chapter 9 _ An Inspector at Last
Chapter 10 _ How to Treat Inspectors
Chapter 11 _ Midair Collision
Chapter 12 _ Thunderstorm Penetration
Chapter 13 _ Airport Not in Sight
Chapter 14 _ Allegro Airlines Accident
Chapter 15 _ Crash of Air France Flight 447
Chapter 16 _ Air Traffic Control and Flight Standards
Chapter 17 _ Mechanics and Aircraft Maintenance
Chapter 18 _ Safety Recommendations and Major Concerns
Chapter 19 _ Air Transportation Oversight System
Chapter 20 _ Aging Aircraft Inspections
Chapter 21 _ Blue Ice or White Ice
Chapter 22 _ Pilots May Operate Unairworthy Aircraft
Chapter 23 _ Definition of Appliance
Chapter 24 _ Unapproved Aircraft Parts Make Aircraft Unairworthy
Chapter 25 _ Being a Whistleblower
Chapter 26 _ American Airlines and the FAA
Chapter 27 _ Flight Attendants
Dedication
I dedicate this book to the General Public and specifically to all the people who use the aviation transportation system. I would also like to recognize all the pilots and flight attendants that dedicate there lives and time in the day to day operation of aircraft along with the mechanics and ground support personnel that perform the long hours and hard work keeping them safe and flying. The real customers of the Federal Aviation Administration and all of government are you, the people. Don't ever let the government or any department thereof forget who they work for. They work for you!
Forward
I've had many interesting experiences in my life and more than once have thought about writing a book. After being retired from the Federal Aviation Administration (FAA) for a couple of years I began thinking more and more about sharing some of my experiences and thoughts.
For most of my life I have been involved in the aviation industry and had an interest in aircraft and flying. When I eventually became an Aviation Safety Inspector (ASI) I was proud, knowing I would now be able to make an impact on aviation to improve safety. I believed that was the primary job of FAA Flight Standards. Little did I know, safety was not always their biggest concern?
While working in the aviation industry I got to see first hand how aviation operators cut corners to save money, took chance after chance operating aircraft they knew were not airworthy and at times even questionable if they were safe to operate at all. There were times I had to put my job on the line when I would take a stand and say the aircraft wasn't operating until it was fixed properly. I knew it wasn't easy for me or for others to stand up to the companies they worked for, even risking their jobs. So it was important to me to have an opportunity to try to make a difference and work to improve aviation safety for all.
In this book, I hope to provide an overview of my personal impression of airlines and the FAA in general, aviation mechanics working in the air carrier environment, several serious safety concerns I discovered and could not get the FAA to act on, along with some short stories about accidents, incidents, and aviation issues I personally experienced.
My hope and intent is not to try to scare people, because in spite of everything I may say in here, I still believe aviation is the safest means of transportation, however, it could be much safer. I want to make the public aware of important safety issues that are not being addressed and my belief the FAA is improperly interpreting and using the regulations to violate individuals, instead of holding the airlines responsible for their actions, as they should to make aviation safer for everyone.
Acronyms
14 CFR - Title14 of the Code of Federal Regulations
49 USC - Title 49 of the United States Code
AC - Advisory Circular
AD - Airworthiness Directive
AMR-CMO - American Airlines Certificate Management Office
APAI - Assistant Principal Avionic Inspector
APMI - Assistant Principal Maintenance Inspector
APOI - Assistant Principal Operations Inspector
APPM - Assistant Partial Program Manager
ASAP - Aviation Safety Action Program
ATC - Air Traffic Control
ATOS - Air Transportation Oversight System
CAA - Civil Aviation Authority (used for any countries authority)
CAMP - Continuous Airworthiness Maintenance Program
CHDO - Certificate Holding District Office
CRM - Crew Resource Management
DER - Designated Engineering Representative
DFW - Dallas/Fort Worth
DGAC - French Direction General de l'Aviation, (the equivalent to the Federal Aviation Administration)
DME - Designated Maintenance Examiner
DOT - Department of Transportation
ECO - Engineering Change Order
EIR - Enforcement Investigative Report
EPI - Element Performance Inspection
ERT - Event Review Team
EWIS - Electrical Wiring Interconnect System (Aircraft)
FAA - Federal Aviation Administration
FM - Flight Manual
FOQA - Flight Operational Quality Assurance
FSIB - Flight Safety Information Bulletin
FSIMS - Flight Standards Information System
GMM - General Maintenance Manual
GPM - General Procedures Manual
HB - Handbook Bulletin
MEL - Minimum Equipment List
MMEL - Master Minimum Equipment List
NAA - National Aviation Authority
NTSB - National Transportation Safety Board
OEM - Original Equipment Manufacturer
PAI - Principal Avionics Inspector
Ops Spec - Operations Specifications
PAH - Parts Approval Holder
PC - Production Certificate
QA - Quality Assurance
QC - Quality Control
PC - Production Certificate
PHMSA - DOT Pipeline Hazardous Material Safety Administration (Formerly RSPA)
PIC - Pilot In Command
PMI - Principal Maintenance Inspector
PMA - Parts Manufacture Approval
PPM - Partial Program Manager
POI - Principal Operations Inspector
PTRS - Program Tracking and Reporting System
RII - Required Inspection Item
RSPA - DOT Research and Special Programs Administration
SAI - Safety Attribute Inspection
SIRS - Safety Information Reporting System
SPAS - Safety Performance Analysis System
STC - Supplemental Type Certificate
SWA-CMO - Southwest Airlines Certificate Management Office
TBD - To Be Determined
TSO - Technical Standard Order
TC - Type Certificate
ULD - Unit Load Device (an enclosed cargo container)
VSDR - Voluntary Self Disclosure Report
WFD - Widespread Fatigue Damage
Chapter 1
Background and Experience
What I have to say, will be somewhat controversial, but will be my professional opinions based on my own experience and conclusions I've developed over a lifetime spent mostly in aviation. I have some experience in general aviation, but most of my experience comes from heavy metal aircraft in the transport category.
I first became interested in aviation at about the age of 13, getting to feel the joy of flying, when a neighbor gave me a ride in a Cessna 172 aircraft at what is now called the Palm Beach International Airport (PBI) in West Palm Beach, Florida. At the time, I couldn't afford to continue with flying, but it didn't stop me from continuing to think about it.
At the age of 20, Vietnam was in full swing in 1968, and I found out I was due to be drafted, so I enlisted in the Air Force and went off to basic training at Lackland Air Force Base (AFB) in San Antonio, Texas. From there I attended a C-130/C-141 aircraft maintenance school at Sheppard AFB in Wichita Falls, Texas and after completion of my school I was assigned to the 314 Tactical Airlift Wing on C-130E aircraft located at Ching Chan Kang Air Base, in Taichung, on the west coast of Taiwan. I soon became a Crew Chief on a C-130E and on occasions went along on various missions in and out of Vietnam, Thailand, Korea, Japan, Okinawa, and the Philippines. I spent a couple of mouths at Cam Ranh Bay Air Base and a month at Tan Son Nuit Air Base in Vietnam maintaining my aircraft for the missions it flew in support of the war effort.
I left Taiwan in 1969; volunteering for reassignment to the 53 Weather Reconnaissance Squadron then located at Ramey AFB, outside of Aguadilla on the northwest corner of Puerto Rico. Again I was assigned as a Crew Chief, this time on a WC-130B Hurricane Hunter aircraft. During the hurricane season, the mission consisted of flying long 10 hour weather tracks over the Atlantic, Caribbean, and the Gulf of Mexico keeping track of storms and associated weather. In the winter we split up the squadron basing some of the aircraft at Patrick AFB, near Cocoa Beach, Florida to support Cape Canaveral's space program and another part of the squadron at Wiesbaden AFB just outside of Frankfurt, Germany to perform fog dispersal missions to keep the Frankfurt Airport open. To explain, Fog dispersal operations, they were performed during severe fog, or Zero Zero visibility. With the airports closed due to fog, the only requirement for our aircraft to take off was to be able to see two consecutive runway lights. Once airborne, our aircraft would fly up wind of the airport making back and forth passes while dropping ground up dry ice granules out the back of the aircraft, which would cause the fog to crystallize to the granules and fall to the ground like snow. This would open holes in the fog that would drift over the airport improving visibility so aircraft could then takeoff and land.
I was with the Hurricane Hunters for two years and spent the first winter season at Patrick AFB and the second winter In Germany. While I was at Patrick AFB, I had the opportunity to join the Patrick Aero Club and I learned to fly in a Cessna 152 and received my Private Pilot's Certificate. I managed to be one of the quickest students to go through the course. I began on the 31st of August and had my certificate in my hand on September 1st. I'm sure it has been done faster, but I thought 30 days was pretty good. When I got back to Ramey AFB, I continued flying in the Aero Club there, which had Piper Cherokee 140 aircraft.
After I left the Air Force in August of 1972, I returned to Florida and pretty much took a 5 year departure from aviation working various jobs such as managing a used car lot, designing, building, and installing screen enclosures, and interior decorating, along with taking a couple of aviation courses at Palm Beach Junior College.
In 1977, I found myself looking for work and I heard of an opportunity and joined the United States Air Force Reserve's 442nd Tactical Airlift Wing (TAW), 303rd Tactical Airlift Squadron (TAS) located at Richards-Gebaur AFB in Belton, Missouri, just south of Kansas City as a C-130E Flight Engineer. After completing Flight Engineer School at Little Rock AFB, Arkansas, I became a flight crew member. I spent the first year being what they called a reserve bum,
flying every mission I could take just to keep getting a pay check. It was like being a truck driver and having to keep on the road to get paid. The next two years I spent as a temporary Civil Service employee. The first year I was a full time Civilian Flight Engineer supporting the reserve training missions and the second working in the wing mailroom along with flying normal reserve missions. In 1979, I did get to spend a two week active duty mission at Howard AFB, in Panama, to support the Nicaragua evacuation during the Somoza uprising. That in it self would be another story.
While I was in the reserves at Richards-Gebaur AFB, I decided to study on my own and managed to obtain my FAA Airframe and Powerplant Mechanics certificate. I also began using my G.I. Bill taking more flying lessons from Kansas City Piper located in Olathe, Kansas, gaining my FAA Commercial Pilots certificate with instrument and multi-engine ratings. During this same period, I continued self-study and passed the written test and subsequent check-ride in a C-130E aircraft and obtained my FAA Flight Engineer Certificate with Turbo-Propeller rating.
I left the Air Force Reserves in 1980 and began my first civilian aviation job working as an aircraft mechanic at the old Fairfax Airport in Kansas City, Kansas. I began working with freight haulers and after my first job as a mechanic with Zantop Airlines I ended up running line maintenance stations for a number of freight airlines over the next eight years. I became a manager of all the maintenance stations for the airlines I subsequently worked for, except for my first job at Zantop and the short time I worked for Evergreen International Airlines at the Salt Lake City airport, where I worked as a line mechanic.
During those eight years after working in Kansas City, Kansas, I worked at Hill AFB in Clearfield, Utah; and at airports in Salt Lake City, Utah; Tucson and Phoenix, Arizona; El Paso, Texas; and Larado, Texas. Some of the airlines I worked full time for included Zantop Airlines, Fleming International Airlines, Cam Air, Evergreen International Airlines, TPI Airlines, Southern Air Transport, and Trans Continental Airlines. I attended many company schools and learned the systems and worked on Lockheed 188's, and C-130's, Boeing B-707's and B-727's, Douglas DC-6's and DC-8's and some drop in work on a few McDonnell Douglas MD-80 aircraft. I ended up with experience on reciprocating, turbo propeller, and jet aircraft and engines.
In September of 1989, while I was living in El Paso, Texas, I received a call from the Federal Aviation Administration (FAA) for a job interview as an Aviation Safety Inspector (ASI) at the Dallas/Fort Worth (DFW) airport, with the Flight Standards District Office (FSDO). I was soon hired and moved to Euless, Texas in the DFW area.
One thing the FAA provides is excellent training. I spent over 20 years in the FAA and attended many training classes, each being from a few days to two week long. The courses covered specific aviation subjects with three or more formal training classes required each year. I would estimate I've had hundreds of courses over my career, not including all the computer based and study on your own training courses.
To begin with, upon being hired by the FAA to be an Aviation Safety Inspector, you are sent off to the FAA Training Academy located at Will Rogers World Airport in Oklahoma City, Oklahoma for ten weeks of initial training. This covers much of the basics about the FAA. It is divided into several training blocks covering various subjects relating to the FAA, but mostly subjects specific to Flight Standards.
Some of the subject matter covered included FAA History, Organizational Structure, Reading and Writing for Technical Understanding, Oral Communications & Conflict Management Skills, Policies and Procedures, Rules and Regulations, Investigative Practices for Violations, Accidents, and Incidents, Preparation of Legal Cases, Case Law, National Transportation Safety Board (NTSB), Interviewing Techniques, Media Interaction and Control, Operation of Various Computer Programs used by the FAA, the FAA's Data Retrieval System for Airman and Aircraft Information, and other pertinent subjects.
After completion of initial training, you are assigned to an experienced inspector in the office and begin a period of mentoring. Each day you perform various duties by assisting the inspector in his duties. You go where that inspector goes and perform inspections, sit in meeting with aviation companies, work on investigations of violations and prepare reports and enter data from the inspections into the FAA's data base to document the daily work performed.
Each year you are assigned a number of formal training courses of one to two weeks duration for specialized required training for your specific specialty, depending on your assignment as an Operations, Maintenance, or Avionics Inspector. There were also a few Flight Attendant Inspectors, usually no more than one or two assigned to an office.
Some of the required formal training courses for my specialty as a maintenance inspector were Certification of Part 121 Air Carriers, Certification of Part 145 Repair Stations, Suspected Unapproved Parts, several Specific Aircraft Systems by Aircraft Make and Model, Emergency Evacuation and Survival Equipment, Aircraft Certification, Aircraft Airworthiness, Accident Investigation, International Civil Aviation Organization (ICAO), Principles of Composite Structure, Advance Composite Structure, Manufacturing of Parts, Corrosion Control, Non-Destructive Testing (each method are a week long for Visual Inspection, Radiographic Inspection, Ultra Sonic Inspection, Eddy Current Inspection, Magnetic Particle Inspection, and Dye Penetrant Inspection), Aging Aircraft, New Regulations, Aircraft Wiring, Hydrostatic Testing of Pressure Vessels, Major and Minor Alterations, Major and Minor Repairs, Aircraft Storage, Operations Specifications, Aerospace Medicine Relating to Accidents and Incidents, Environmental and Hazardous Materials, Weight and Balance, Load Planning, Air Cargo Operations, Aircraft Configuration, Propeller and Engine Accident Investigation, Rotorcraft Safety and Accident Investigation, Structures, Fire and Smoke Training, Parts and Material Storage, Airmen Certification, Designated Maintenance Examiner (DME), Designated Engineering Representative (DER), Quality Control (QC) and Quality Assurance (QA), Required Item Inspector (RII), Aerodynamics, Weather and Meteorology, Evaluation of Aviation Management, Maintenance Reliability Systems, Airworthiness Inspector Cockpit Enroute Inspection, Compliance and Enforcement Procedures, System Safety, Part 129 Geographic Inspector, Runway Safety, Human Factors in Accident Investigation, Safety Performance Analysis System (SPAS), MD-80 Systems, MD-11 and DC-10 Systems, B-727 Systems, B-767 Systems, Air Transportation Oversight System, Taxi 101, Inspection of Foreign Operated Aircraft, Aviation Safety Action Program, American Airlines Air Carrier Specific Training, Performance Management System, Structural Inspection Programs Evaluation, Security Awareness, Repairability of Structural Composites, Operations Safety System, Ground Deicing /Anti-icing, Foundations for Principal Inspectors, Nonessential Equipment and Furnishings List, Safety Issues Reporting System (SIRS), Aircraft Electrical Wiring Interconnect System (EWIS), Ethics Training, Fuel Tank System Ignition Prevention, and Widespread Fatigue Damage (WFD), among a few.
We also attended a lot of additional seminars and safety briefings along with a lot of reading and self study courses. The point is, there is never enough time or training to cover everything, but as an aviation safety inspector, we got an awful lot of good training in aviation.
Above and beyond FAA training, one of our many duties is to oversee the various training programs of the air carriers and repair stations assigned to us. We get a lot of additional undocumented training while sitting in observing various training classes provided by the aviation companies to their employees. Sometimes we actually enroll in an operator's course and get credit in our FAA files. These would mostly be for specific aircraft systems training, if we were assigned to surveillance and management of that particular fleet of aircraft. The best way to understand an operator's maintenance program is to attend their training classes. This would allow us to both observe and critique the classes and instructional processes while also learning their policies and procedures at the same time.
Without adequate training, an inspector would have a difficult time understanding all that is involved in the aviation industry. It takes a long time working in the industry to gain overall aviation experience, then it takes the rest of your life learning how to use all that experience and to make a difference in aviation safety.
During my first few years, I was the Assistant Principal Maintenance Inspector assigned to Buffalo Airways, Express One International Airlines, and Air Transport International Airlines (ATI).
I then moved to the Geographic International Team, later to become the DFW International Field Office (IFO) where I was assigned to regulatory oversight for Mexico and became a Principal Maintenance Inspector for several Mexican airlines that operated in and out of the United States, such as TAESA, Aero Executivo, Aviaxa, Aerolineas, and Allegro Airlines, to name a few, and I was also the Principal Maintenance Inspector for several FAA approved part 145 repair stations in Mexico such as Aeroelectronica, Chromalloy Neuevo Larado, Chromalloy Mexicali, Llantas, Turbinas, Servicios Aeros Estrella, Oxigeno, Matrix Aeronautica, and several others. At this same time I was also the Principal Maintenance Inspector for two large U.S. Part 145 repair stations, Dalfort Aviation located at Love Field in Dallas (the former Braniff Airlines Maintenance facility), and Chrysler Technologies located in Waco, Texas.
While assigned to Mexico in the IFO, I was also tasked to be trained by the Department of Transportation's (DOT) RASPA, which, at the time, was the office that performs all U.S. certification for hydrostatic testing facilities for pressure vessel testing. I was trained at both the U.S. Air facility in Pittsburg, Pennsylvania and the Delta Airlines facility in Atlanta, Georgia by Jim Jones, who at the time was the head of RASPA. The few FAA Inspectors chosen to perform DOT certification were Inspectors assigned to International FAA duties and strictly limited to only certify hydrostatic testing facilities outside of the United States; and for me it was only for facilities located in Mexico. I was one of very few FAA Inspectors that got to wear two hats, so to speak, one for the FAA and one for the DOT at the same time. I was, however, fortunate enough during my Mexico assignment to perform the initial certification of Oxigeno, a hydrostatic testing facility located in Mexico City.
After leaving the IFO, I spent one year assigned as a Geographic Inspector in the DFW FSDO, which means I was assigned oversight for surveillance of all operators, operating into and out of DFW Airport. I got to visit and fly with many airlines, observing both the Flight Crews in the cockpits and the Flight Attendants in the cabins performing their duties and observing their mechanics performing maintenance operations on the ground at various airports and