Aviation Safety: FAA Oversight of Aviation Repair Stations (Testimony,
05/07/98, GAO/T-RCED-98-188).

GAO discussed the Federal Aviation Administration's (FAA) oversight of
repair stations that maintain and repair aircraft and aircraft
components, focusing on: (1) the practice of using individual inspectors
in repair station inspections; (2) the condition of inspection
documentation; and (3) current FAA actions to improve the inspection
process.

GAO noted that: (1) FAA was meeting its goal of inspecting every repair
station at least once a year and 84 percent of the inspectors believed
that the overall compliance of repair stations was good or excellent;
(2) more than half of the inspectors said that there were areas of
compliance that repair stations could improve, such as ensuring that
their personnel receive training from all airlines for which they
perform work and have current maintenance manuals; (3) while FAA
typically relies on individual inspectors, the use of teams of
inspectors, particularly at large or complex repair stations, may be
more effective at identifying problems and are more liable to uncover
systemic and long-standing deficiencies; (4) because of insufficient
documentation, GAO was unable to determine how well FAA followed up to
ensure that the deficiencies found during the inspections were
corrected; (5) GAO was not able to assess how completely or quickly
repair stations were bringing themselves into compliance; (6) because
FAA does not tell its inspectors what documentation to keep, the
agency's ability to identify and react to trends is hampered; (7) FAA is
spending more than $30 million to develop a reporting system that, among
other things, is designed to enable the agency to apply its inspection
resources to address those areas that pose the greatest risk to aviation
safety; (8) as GAO has reported in the past, this goal will not be
achieved without significant improvements in the completeness of
inspection records; (9) since the May 1996 crash of a ValuJet DC-9 in
the Florida Everglades, FAA has announced new initiatives to upgrade the
oversight of repair stations; (10) these initiatives were directed at
clarifying and augmenting air carriers' oversight of repair stations,
not at ways in which FAA's own inspection resources could be better
utilized; (11) FAA has several other efforts under way that would have a
more direct bearing on its own inspection activities at repair stations;
(12) one effort would revise the regulations governing operations at
repair stations, and another would revise the regulations governing the
qualifications of repair station personnel; (13) the revision of the
regulations began in 1989 and has been repeatedly delayed; (14) the
third effort is the addition of more FAA inspectors, which should mean
that more resources can be devoted to inspecting repair stations; (15)
FAA has recently announced a major overhaul of its entire inspection
process; and (16) it is designed to systematize the process and ensure
consistency in inspections and in reporting the results of these
inspections so as to allow more efficient targeting of inspection
resources.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  T-RCED-98-188
     TITLE:  Aviation Safety: FAA Oversight of Aviation Repair Stations
      DATE:  05/07/98
   SUBJECT:  Inspection
             Aircraft maintenance
             Commercial aviation
             Transportation safety
             Aircraft accidents
             Air transportation operations
             Management information systems
             Human resources utilization
             Airline industry
IDENTIFIER:  FAA National Aviation Safety Inspection Program
             FAA Regional Aviation Safety Inspection Program
             FAA Program Tracking and Reporting Subsystem
             FAA Safety Performance Analysis System
             FAA Air Transportation Oversight System
             
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Cover
================================================================ COVER


Before the Subcommittee on Aviation, Committee on Commerce, Science,
and Transportation, U.S.  Senate

For Release
on Delivery
Expected at
2:15 p.m.  EDT
Thursday
May 7, 1998

AVIATION SAFETY - FAA OVERSIGHT OF
AVIATION REPAIR STATIONS

Statement of Gerald L.  Dillingham,
Associate Director, Transportation Issues,
Resources, Community, and Economic
Development Division

GAO/T-RCED-98-188

GAO/RCED-98-188t


(348103)


Abbreviations
=============================================================== ABBREV

  FAA -

============================================================ Chapter 0

Mr.  Chairman and Members of the Subcommittee: 

We appreciate the opportunity to testify on the Federal Aviation
Administration's (FAA) oversight of repair stations that maintain and
repair aircraft and aircraft components.  In recent years, FAA's
oversight of repair stations has become a matter of concern, in part
because the work performed by repair stations has been identified as
a factor in several aircraft accidents.  For example, the National
Transportation Safety Board determined that a fatigue fracture from
corrosion pits that were not discovered or properly repaired by a
repair station was the probable cause of a propeller loss on an
Atlantic Southeast Airlines Embraer-120 in August 1995.  The
propeller loss occurred at 18,000 feet, and the plane crashed during
an emergency landing, killing 8 and injuring 21 others on board. 

Last year, at the request of the Ranking Minority Member of this
Subcommittee and Senator Ron Wyden, we reported on FAA's oversight of
repair stations.\1 During our review, we observed operations at
repair stations in this country and overseas and reviewed the
inspection files for nearly 500 repair stations at FAA regional or
district offices.  We also surveyed inspectors responsible for repair
stations to obtain their views on how FAA's oversight could be
improved.  Our report discussed three main issues:  (1) the practice
of using individual inspectors in repair station inspections; (2) the
condition of inspection documentation; and (3) current FAA actions to
improve the inspection process. 

  -- FAA was meeting its goal of inspecting every repair station at
     least once a year and 84 percent of the inspectors believed that
     the overall compliance of repair stations was good or excellent. 
     However, more than half of the inspectors said that there were
     areas of compliance that repair stations could improve, such as
     ensuring that their personnel receive training from all airlines
     for which they perform work and have current maintenance
     manuals.  We also found that while FAA typically relies on
     individual inspectors, the use of teams of inspectors,
     particularly at large or complex repair stations, may be more
     effective at identifying problems and are more liable to uncover
     systemic and long-standing deficiencies. 

  -- Because of insufficient documentation, we were unable to
     determine how well FAA followed up to ensure that the
     deficiencies found during the inspections were corrected.  Thus,
     we were not able to assess how completely or quickly repair
     stations were bringing themselves into compliance.  Because FAA
     does not tell its inspectors what documentation to keep, the
     agency's ability to identify and react to trends is hampered. 
     FAA is spending more than $30 million to develop a reporting
     system that, among other things, is designed to enable the
     agency to apply its inspection resources to address those areas
     that pose the greatest risk to aviation safety.  As we have
     reported in the past, this goal will not be achieved without
     significant improvements in the completeness of inspection
     records. 

  -- Since the May 1996 crash of a ValuJet DC-9 in the Florida
     Everglades, FAA has announced new initiatives to upgrade the
     oversight of repair stations.  These initiatives were directed
     at clarifying and augmenting air carriers' oversight of repair
     stations, not at ways in which FAA's own inspection resources
     could be better utilized.  However, FAA has several other
     efforts under way that would have a more direct bearing on its
     own inspection activities at repair stations.  One effort would
     revise the regulations governing the operations at repair
     stations, and another would revise the regulations governing the
     qualifications of repair station personnel.  However, the
     revision of the regulations began in 1989 and has been
     repeatedly delayed.  The third effort is the addition of more
     FAA inspectors, which should mean that more resources can be
     devoted to inspecting repair stations.  Finally, FAA has
     recently announced a major overhaul of its entire inspection
     process.  This effort is scheduled to be implemented in the fall
     of 1998.  It is designed to systematize the process and ensure
     consistency in inspections and in reporting the results of these
     inspections so as to allow more efficient targeting of
     inspection resources. 


--------------------
\1 See Aviation Safety:  FAA Oversight of Repair Stations Needs
Improvement (GAO/RCED-98-21, Oct.  24, 1997). 


   TEAM INSPECTIONS VS. 
   INDIVIDUAL INSPECTIONS
---------------------------------------------------------- Chapter 0:1

FAA guidance prescribes an annual inspection to cover all aspects of
a repair station's operations, including the currency of technical
data, facilities, calibration of special tooling and equipment, and
inspection procedures, as well as to ensure that the repair station
is performing only the work that it has approval to do.  Most FAA
offices assign an individual inspector to conduct routine
surveillance at a repair station, even one that is large and complex,
rather than using a team of inspectors.  Most inspectors are
responsible for oversight at more than one repair station.  At the
FAA offices we visited, we examined the workloads of 98 inspectors
and found that, on average, they were responsible for 12 repair
stations each, although their individual workloads varied from 1 to
42 facilities of varying size and complexity.  The inspectors
assigned responsibility for repair stations are also assigned
oversight of other aviation activities such as air taxis,
agricultural operators, helicopter operators, and training schools
for pilots and mechanics. 

FAA uses teams for more comprehensive reviews of a few repair
stations through its National Aviation Safety Inspection Program or
its Regional Aviation Safety Inspection Program.\2 These special,
in-depth inspections are conducted at only a small portion of repair
stations.  In the past 4 years, an average of only 23 of these
inspections have been conducted annually at repair stations (less
than 1 percent of the repair stations performing work for air
carriers). 

From fiscal year 1993 through 1996, we found 16 repair stations that
were inspected by a single inspector and were also inspected by a
special team of inspectors during the same year.  The teams found a
total of 347 deficiencies, only 15 of which had been identified by
individual inspectors.  Many of the deficiencies the teams identified
were systemic and apparently long-standing, such as inadequate
training programs or poor quality control manuals.  Such deficiencies
were likely to have been present when the repair stations were
inspected earlier by individual inspectors. 

We believe that there are several reasons why team inspections
identify a higher proportion of the deficiencies that may exist in
the operation of large repair stations.  First, many FAA inspectors
responsible for conducting individual inspections said that, because
they have many competing demands on their time, their inspections of
repair stations may not be as thorough as they would like.  Second,
team inspections make use of checklists or other job aids to ensure
that all points are covered.  Although FAA's guidance requires
inspectors to address all aspects of repair stations' operations
during routine surveillance, it does not prescribe any checklist or
other means for assuring that all items are covered.  The lack of a
standardized approach for routine surveillance increases the
possibility that items will not be covered.  Finally, inspectors
believe team inspections help ensure that their judgments are
independent because most team members have no ongoing relationship
with the repair station.  By contrast, individual-inspector reviews
are conducted by personnel who have a continuing regulatory
responsibility for the facilities and, therefore, a continuing
working relationship with the repair station operator. 

A substantial number of the inspectors we surveyed supported the use
of team inspections.  We found that 71 percent of the inspectors
responding favored team inspections using district office staff as a
means to improve compliance, and 50 percent favored an increase in
National or Regional Aviation Safety Inspection Program inspections
staffed from other FAA offices.  We also found that some district
offices had already begun using locally based teams to perform
routine surveillance of large and complex repair stations.  Thus, in
our October 1997 report, we recommended that FAA expand the use of
locally based teams for repair station inspections, particularly for
those repair stations that are large or complex. 


--------------------
\2 FAA determines which facilities should receive additional
oversight through these comprehensive reviews, selecting them on the
basis of previous inspection results or the size and complexity of
operations. 


   FOLLOW-UP AND DOCUMENTATION OF
   INSPECTIONS
---------------------------------------------------------- Chapter 0:2

FAA's guidance is limited in specifying what documents pertaining to
inspections and follow-up need to be maintained.  We examined records
of 172 instances in which FAA sent deficiency letters to domestic
repair stations to determine if follow-up documentation was present. 
However, responses from the repair stations were not on file in about
one-fourth of these instances, and FAA's assessments of the adequacy
of the corrective actions taken by the repair stations were not on
file in about three-fourths of the instances.  We also examined
inspection results reported in FAA's Program Tracking and Reporting
Subsystem, a computerized reporting system, and found it to be less
complete than individual files on repair stations. 

Without better documentation, FAA cannot readily determine how
quickly and thoroughly repair stations are complying with
regulations.  Just as important, FAA cannot identify trends on repair
station performance in order to make informed decisions on how best
to apply its inspection resources to those areas posing the greatest
risk to aviation safety.  FAA is spending more than $30 million to
develop a system called the Safety Performance Analysis System, whose
intent is to help the agency identify safety-related risks and
establish priorities for its inspections.  It relies in part on the
current reporting subsystem, which contains the results of safety
inspections.  However, this system will not be fully implemented
until late 1999, and it will be of limited use if the documentation
on which it is based is inaccurate, incomplete, or outdated. 

We also found that FAA's documentation of inspections and follow-up
was better in its files for foreign repair stations than for domestic
repair stations, perhaps in part because under agency regulations,
foreign repair stations must renew their certification every 2 years. 
By comparison, domestic repair stations retain their certification
indefinitely unless they surrender it or FAA suspends or revokes it. 
Foreign repair stations appear to be correcting their deficiencies
quickly so that they qualify for certificate renewal.  The 34 FAA
inspectors that we interviewed who had conducted inspections of both
foreign and domestic repair stations were unanimous in concluding
that compliance occurred more quickly at foreign facilities.  They
attributed the quicker compliance to the renewal requirement and said
that it allowed them to spend less time on follow-up, freeing them
for other surveillance work.  However, we were unable to confirm
whether foreign repair stations achieve compliance more quickly than
domestic repair stations do, because of the poor documentation in
domestic repair station files. 

To address these problems, we recommended that FAA specify what
documentation should be maintained in its files to record complete
inspection results and follow-up actions, and that FAA monitor the
implementation of its strategy for improving the quality of data in
its new management information system.  FAA concurred with these
recommendations and has reported actions underway to implement them. 


   FAA ACTIONS UNDER WAY TO
   IMPROVE REPAIR STATION
   OVERSIGHT
---------------------------------------------------------- Chapter 0:3

FAA has several efforts under way that may hold potential for
improving its inspections of repair stations.  Two efforts involve
initiatives to change the regulations covering repair station
operations and the certification requirements for mechanics and
repairmen.  FAA acknowledges that the existing regulations do not
reflect many of the technological changes that have occurred in the
aviation industry in recent years.  The FAA inspectors we surveyed
strongly supported a comprehensive update of repair station
regulations as a way to improve repair stations' compliance.  Of the
inspectors we surveyed, 88 percent favored updating the regulations. 
This update, begun in 1989, has been repeatedly delayed and still
remains in process.  The most recent target--to have draft
regulations for comment published in the Federal Register during the
summer of 1997--was not met.  Similarly, the update of the
certification requirements for maintenance personnel has been
suspended since 1994.  Because of these long-standing delays,
completion of both updates may require additional attention on
management's part to help keep both efforts on track.  Our October
1997 report recommended that FAA expedite efforts to update
regulations pertaining to repair stations and establish and meet
schedules for completing the updates. 

A third effort involves increasing and training FAA's inspection
resources.  Since fiscal year 1995, FAA has been in the process of
adding more than 700 inspectors to its workforce who will, in part,
oversee repair stations.  Survey responses from current inspectors
indicated that the success of this effort will depend partly on the
qualifications of the new inspectors and on the training available to
all of those in the inspector ranks.  Specifically, 82 percent of the
inspectors we surveyed said that they strongly or generally favored
providing inspectors with maintenance and avionics training,
including hands-on training as a way to improve repair stations'
compliance with regulations. 

Another effort is FAA's new Air Transportation Oversight System. 
This system is intended to respond to problems in FAA's oversight
that have been pointed out in recent years by GAO, the Department of
Transportation's Inspector General, FAA's 90 Day Safety Review, and
others.  The goal of this new system is to target surveillance to
deal with risks identified through more systematic inspections. 
Phase I of the system is expected to be implemented in the fall. 
When fully implemented, this system will offer promise of significant
improvements in the way FAA conducts and tracks all of its
inspections, including those performed at repair stations.\3 However,
in its initial phase, the system will affect the oversight of only
the 10 largest air carriers and may not be fully applied to repair
stations for several years.  We will continue to monitor FAA's
progress in improving the effectiveness of its oversight in this
important area. 


--------------------
\3 It is unclear how the results of these inspections will be
integrated into the Safety Performance Analysis System currently
under development. 


-------------------------------------------------------- Chapter 0:3.1

Mr.  Chairman, this concludes our statement.  We would be pleased to
respond to questions at this time. 


*** End of document. ***