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Testimony of Frankm T. Gardner
Director Aviation Technical Department
Kreindler & Kreindlerreindler
101 Park Ave
New York, NY 10017-55900
before the
National Civil Aviation Review Commission
April 10, 1997


The Transportation Industry should look toward aviation as an example of the way to adapt to constantly changing techniques and methods in order to gain positive growth. Aviation safety is a direct reflection of established standards, working knowledge and practice of developed habits which are gained through a two-way communication flow between people working in various functions. In simple words, people working with people. The prime example of this is the way the F.A.A. should monitor its certificated A&P mechanics.
All modes of transportation move on the effect and actions of many. In order to maintain free flowing transportation, no one can be left out of the final recognized glories. The factors which adversely impact on our environment are increasing in number and complexity. The Transportation Industry must endure these changes in order to remain stable and continue to grow in today's environment.

Many years ago, an aviation firm printed a flyer which said in part:

"A salute to the person with scarred knuckles and a heavy box of well kept tools. Your hands brought the airplane from a frail beginning -- to its rightful place as the thundering giant of modern transportation. Your skill is an accepted guarantee of safety both for pilots and passengers. Faith in your ability is a strong shield against fear of those dangers that must lurk in the high places. You bear the burden of absolute and unquestioning trust. Not much of the glamor of aviation falls your way. But you are big enough to shrug that off and put your integrity on the line, every time an aircraft leaves the ground. You are saluted whenever you practice your skills. You are the backbone of aviation."

That salute is well-deserved to the unsung people working in the background of glory, who make the Transportation Industry move. We must never forget them or take it for granted that there will always be enough of them to serve. The task of assuring this raises the question of what must be done to forge the steady growth of A&P mechanics within the Aviation Industry. The F.A.A. holds a tight rein on licensed pilots. It keeps track of them through the medical examinations each pilot must take periodically. Pilots' physicals are required to comply with the Federal Aviation Regulations (F.A.R.'s). F.A.R. 61.3(c) - Medical Requirement for Pilot Certificate states: "No person may act as a pilot in command or in any other capacity as a required pilot flight crew member of an aircraft under a certificate issued to him unless he has an appropriate current medical certificate."

The F.A.A.'s Accident Prevention Safety (A.P.S.) program for pilots is very effective. This is directly attributed to the fact that the F.A.A. knows who, where and how many pilots are currently licensed.
Now let's look at the F.A.A.'s handle on licensed A&P mechanics. There isn't any! Neither the Aviation Industry or the F.A.A. knows how many active or alive A&P mechanics there are. The F.A.A. does have a file in the Record Section in Oklahoma City, Oklahoma that lists all mechanic certificates ever issued. This file records each A&P's name, address, ratings (A&P) and certificate number. However, this file is just that -- a file, It has no useful purpose since it cannot be used accurately to locate or count the active number of certified A&P mechanics. This file is not a helpful working tool for the Aviation Industry since A&P's are always being added but there is no method to delete them.

The F.A.A. has contact with the pilots through their scheduled medicals but once an A&P mechanic is licensed, the F.A.A. has no further contact with them. If the A&P has a change of address but does not contact the F.A.A., then the F.A.A. will never know about the move despite the fact that F.A.R. 65.21 Change of Address states: "Within thirty (30) days after any change in a mechanic's permanent mailing address, the holder of a certificate issued under this part shall notify the Department of Transportation, Federal Aviation Administration, Airman Certification Branch, Post Office Box 35082, Oklahoma City, Oklahoma 73125, in writing of the new address."

Question: What's the big fuss? What kind of dilemmas does this create?
Answer: How can A&P schools, those associated with aviation, the Boards of Education and aviation in general program future projections and growth when they do not have a starting figure on aviation mechanics?

It is easy to sit back and say we have a problem establishing and maintaining an accurate working tool for the Aviation Industry by not having a method of counting licensed A&P mechanics. It would be a task to get this handle, but not an overwhelming or considerably costly one.
Possible methods (which could be sent to the Department of Transportation's Federal Aviation Administration):

1. The F.A.A. could send a one-time mailer to all A&P's listed in the file at Oklahoma City, Oklahoma. The A&P's would be required to reply within a specified time frame.

(a) if no response is received -- revocation of that A&P license.
(b) if mail is returned -- revocation of that A&P license.
(c) These revoked certificates would then be published in an F.A.A. Advisory Circular (A.C.65) with a time frame for objections.

2. An addition to F.A.R. 65, subpart A, general referring to an addition to Advisory Circular (A.C. 65). This A.C. 65 should be a form to be completed by the licensed A&P mechanics showing their current data. It should be mailed to the Department of Transportation, Federal Aviation Administration, Airman Certification Branch, Post Office Box 25082, Oklahoma City, Oklahoma 73125. This A.C. 65 would have to be completed every four (4) years. If no report is received, the certificate would be revoked and the A&P mechanic's name would be added to the Revocation List, Advisory Circular A.C.65.
Explanation of the F.A.A. Advisory Circular system:

The F.A.A. issues advisory circulars to inform the aviation public in a systematic way of non-regulatory material of interest. Unless incorporated into a regulation, the contents of an advisory circular are not binding. Advisory circulars are issued in a numbered subject system corresponding to the subject areas of the Federal Aviation Regulations. In the case of the A&P mechanic certificated under F.A.R. 65, the advisory circular would be numbered A.C. 65.

An advisory circular is issued to provide guidance and information in the designated subject area or to show a method acceptable to the F.A.A. for complying with a related Federal Aviation Administration regulation.
What basically does it entail to obtain an F.A.A. A&P mechanic's license under F.A.R. 65?
The applicant for a mechanic's certificate must present either an appropriate graduation certificate or certificate of completion from a certificated aviation maintenance technician school or at least thirty (30) months of practical experience concurrently performing the duties appropriate to both the airframe and powerplant (A&P) ratings.

The applicant must then pass a written test covering the construction and maintenance of airframes and engines. It includes the basic principles on installation, modifications, inspection and requires knowledge of the appropriate F.A.R.'s covering airmen and aircraft maintenance.

The applicant must then pass an oral and practical test for both the airframe and powerplant ratings. These tests cover basic skill in performing practical projects on the subjects covered on the written tests.
When the applicant has successfully completed all these stringent requirements the F.A.A. issues an aircraft mechanic license with airframe and powerplant ratings and assigns this certificate a number. This certificate is then placed in the file at Oklahoma City, Oklahoma.

When the F.A.A. presents this certificate the new A&P mechanic must take the mechanic's creed.
"UPON MY HONOR, I swear that I shall hold in sacred trust the rights and privileges conferred upon me as a certificated mechanic. Knowing full well that the safety and lives of others are dependent upon my skill and judgment, I shall never knowingly subject others to risks which I would not be willing to assume for myself, or for those dear to me.

"IN DISCHARGING this trust, I pledge myself never to undertake work or approve work which I feel to be beyond the limits of my knowledge; nor shall I allow any non-certificated superior to persuade me to approve aircraft or equipment as airworthy against my better judgment; nor shall I permit my judgment to be influenced by money or other personal gain; nor shall I pass as airworthy aircraft or equipment about which I am in doubt, either as a result of direct inspection or uncertainty regarding the ability of others who have worked on it to accomplish their work satisfactorily.

"I REALIZE the grave responsibility which is mine as a certificated airman, to exercise my judgment on the airworthiness of aircraft and equipment. I, therefore, pledge unyielding adherence to these precepts for the advancement of aviation and for the dignity of my vocation."

While F.A.A. certificated A&P mechanics are working under their license they are required by the F.A.R.'s to report to the F.A.A.'s Service Difficulty Program. This program is an information system providing assistance to the Aviation Industry as well as the F.A.A. in identifying and resolving aircraft problems encountered during service. The program provides for the collection and dissemination of aircraft service information to improve service reliability of aeronautical products. The Service Difficulty Program's objective is to bring about the prompt and appropriate correction of conditions negatively affecting the continued airworthiness of aeronautical products. Submitted reports are vital to the effectiveness of the program.
F.A.A. certificated A&P mechanics must keep themselves current with the ever-changing Federal Aviation Regulations and Airworthiness Directives. Airthworthiness Directives, primary safety functions of the F.A.A., are used to correct unsafe conditions found in an aircraft, aircraft engine, propeller or appliance. When such conditions are found, they are likely to exist or develop in other products of similar design. These unsafe conditions may be because of design defects, maintenance or operational causes.

Airworthiness Directives define the authority and responsibility of the Federal Aviation Administration for administering the necessary corrective actions. Airworthiness Directives are the media used to notify F.A.A. certificated A&P mechanics of unsafe conditions and to specify the conditions under which the certificated products may continue to be operated.

The F.A.A. certificated A&P mechanic must maintain a currency with the F.A.A.'s published Aviation Airworthiness Alerts. The Aviation Airworthiness Alerts provide a common communication channel through which the aviation community can economically interchange service experience and thereby cooperate in the improvement of aeronautical product durability, reliability and safety.

The F.A.A. recently formed committees composed of members of the Transportation Industry to rewrite the Federal Aviation Regulation F.A.R. 65, that basically governs the A&P mechanic. Therefore, this would be the time for the addition to F.A.R. 65 to be written into subpart A general, making the report to the F.A.A. by certificated A&P mechanics through Advisory Circular A.C. 65 mandatory.
Why the need for established control on behalf of the F.A.A. for the certificated A&P mechanic? It's a simple one-word answer -- SAFETY.

Safety is the key and primary word in all modes of transportation. Would any vehicle move if the odds for safety were not in its favor? All assets must be covered to ensure the most reliable avenues have been checked and secured.

The F.A.A.'s certificated A&P mechanics are a prime example of people working in the background of glory, who instill and maintain this maximum level of efficiency and safety into the Transportation Industry. However, if A&P mechanics, who are held at the apex of safety in the Transportation Industry, are not properly monitored, what of the non-certificated background heroes in other areas of the Transportation Industry? Since the Transportation Industry as a whole is not in the fortunate position as the F.A.A. in controlling its safety support numbers, how can it establish this control?

A one-word answer: AWARENESS.

Awareness that does not just spotlight glory positions like pilots, engineers, captains, drivers, etc. that move the Transportation Industry. Clerical agents, purchasers, suppliers, etc. must be included in this new-found awareness.

What has now developed?

Another one word answer: A-TEAM.

A team of workers moving together as a vehicle's frame, engine and drive mechanism, all working in controlled unison to achieve a destination uneventful and safely.
What can the Transportation Industry do to achieve this?

This is not a one-word answer.

Every mode of transportation is individually molded to its own procedures of operation. Every mode of transportation -- its participating organizations and everyone affiliated with it -- must play their part to establish programs so that every vital part of a well functioning unit is controlled or included in the end result.
And what are the end results?

There are no end results -- because there is no end!

We must transform the fundamentals of today's accomplishments into simple terms to describe an action that could be termed "personal satisfaction." Unlike energy which can neither be created or destroyed, personal satisfaction CAN be created and it CAN be destroyed. It can be created through positive recognition. And conversely, it can be destroyed with through uncaring, unconcerned attitudes.

Considering the vast number of people directly and indirectly linked to the Transportation Industry, one must wonder how their flow of motion is channelled correctly to achieve a safe final destination. One answer might be a unique form of team work in which groups of workers at one time would work independently and at another time would work jointly with other groups of workers -- but at all times, all the workers would be working for the good of the industry.

What a wonderful achievement this would be! And the attainment of this goal should be acknowledged, nurtured, protected and never taken for granted.

The Transportation Industry, if dissected, would probably prove to be the largest of all industries. It would be hard to find any poslition that is not involved with this marvelously functioning machine.

The Transportation Industry should look toward aviation as an example of the way to adapt to constantly changing techniques and methods in order to gain positive growth. Aviation safety is a direct reflection of established standards, working knowledge and practice of developed habits which are gained through a two-way communication flow between people working in various functions. In simple words, people working with people. The prime example of this is the way the F.A.A. should monitor its certificated A&P mechanics.
To reinforce the need of recognizing unsung heroes, I quote from an unknown Alaskan:

"Through the history of world aviation many names have come to the fore. . . .
Great deeds of the past in our memory will last, as they're joined by more and more. . . .
"When man first started his labor in his quest
to conquer the sky,
he was designer, mechanic and pilot
and he built a machine that would fly . . . .
But somehow the order got twisted,
and then in the public's eye
the only man that could be seen
was the man who knew how to fly . . . .

"The pilot was everyone's hero,
he was brave, he was bold, he was grand,
as he stood by his battered old biplane
with his goggles and helmet in hand . . . .
To be sure, these pilots all earned it.
To fly you have to have guts . . . .
And they blazed their names in the hall of fame on wings with baling wire struts . . .

"But for each of these flying heroes
there were thousands of little renown,
and these were the men who worked on the planes
but kept their feet on the ground . . . .
We all know the name of Lindbergh,
and we've read of his flight to fame . . . .
But think, if you can, of his maintenance man, can you remember his name?

"And think of our wartime heroes. . . .
Can you tell me the names of their crew chiefs?
A thousand to one you cannot . . . .

"Now pilots are highly trained people,
and wings are not easily won . . . .
But without the work of the maintenance man
our pilots would march with a gun . . . .
So when you see mighty aircraft
as they mark their way through the air,
the grease-stained man with the wrench in his hand is the man who put them there . . . ."

All modes of transportation move on the effect and actions of many. In order to maintain free flowing transportation, no one can be left out of the final recognized glories. The factors which adversely impact on our environment are increasing in number and complexity. The Transportation Industry must endure these changes in order to remain stable and continue to grow in today's environment.

# # # #


Frank T. Gardner
1175 York Avenue
New York, NY 10021


Investigate commercial and private plane accidents on behalf of victims and their families. Liaison with government regulatory agencies, media, expert witnesses and testing laboratories. During 35 years with the CAA/FAA responsible for investigating aircraft accidents and incidents. Conducted aircraft and component evaluations, special inspections and Air-Carrier proving flights. Conducted authorized inspection meetings and accident prevention programs. Certificated or added ratings to repair stations and air-carriers. Developed programs to enhance aviation safety.


1995 to Present
Kreindler & Kreindler
100 Park Avenue
New York, NY 10017-5590

Director, Aviation Technical Department. Working on behalf of the victims and their families, investigate commercial and private plane accidents including PanAm Flight 103, Avianca Flight 052 and TWA Flight 800. Conduct wreckage inspections. Coordinate the liaison with government agencies, media, expert witnesses and testing laboratories.
CFR Title 14 FAA FAR 183 - Designated Airworthiness
Representative (DAR 27-FS-EA); FAA - Authorized
Inspector (IA) FAR 65

Electronic Media Interviews re TWA Flight 800
DATELINE - NBC 10/22/96
DATELINE - NBC 3/30/97

1988 to 1994
Aviation Consultant. Specialized in aircraft accident investigation primarily with Kreindler & Kreindler.
CFR Title 14 FAA FAR 183 - Designated Airworthiness Representative (DAR 27-FS-EA); FAA - Authorized Inspector (IA) FAR 65


1971 to 1987 (Retired)
Federal Aviation Administration
Eastern Region, Flight Standards Division
Teterboro, NJ (1975 to 1987), Philadelphia, PA (1971 to 1975)

Aviation Safety Inspector/Airworthiness (Grade GS-14). Responsible for
investigation of aircraft accidents and incidents and filing enforcement actions. Full charge of certificate responsibility for over 80 repair stations, 30 Air-Carrier operators (FAR 135/121 monitoring American Eagle Command Airways. Evaluated applicants for FAA certification and ratings of Air-Carriers, Repair Stations, Airframe and Powerplant Mechanic Schools, A&P Mechanics, Parachute Lofts, Parachute Riggers, Aircraft and Components, Aircraft, Industrial and Executive Operators. Gave expert testimony at legal proceedings related to aircraft accidents.

1969 to 1971
Federal Aviation Administration
Flight Standards Division, Aircraft Management Branch
JFK Airport, Jamaica, NY

Aircraft Specialist (Grade GS-11). Responsible for providing highest level of airworthiness in both aircraft and avionics maintenance. Planned aircraft maintenance schedules on agency and leased aircraft; revised schedules to meet operational require-ments; developed projected aircraft maintenance schedules to conform with the aircraft maintenance section workload.

1964 to 1969
Federal Aviation Administration
Technical Center (NAFEC)
Atlantic City, NJ

Aircraft Production Control Specialist (Grade GS-9). Provided technical and administrative maintenance services to private, commercial and foreign aircraft. Responsible for verifying that all maintenance on aircraft adhered to FAA regulations. Debriefed pilots to insure that aircraft logbooks accurately reflected the maintenance discrepancies.

1957 to 1964 Federal Aviation Administration
Eastern Region, Flight Standards Division
JFK Airport, Jamaica, NY

Lead A&P Mechanic (Grade WS-11). Supervised licensed mechanics in correction of pilot complaints. Administered engine replacement, electrical trouble-shooting, repair to accident damage, airframe and systems modifications and installation of new equipment. Responsible for assignment of tasks to individual mechanics.


1956 to 1957
TWA and Riddle Airlines
JFK Airport, Jamaica, NY

A&P Mechanic. Analyzed and corrected engine malfunctions, removed and installed engines. Performed general aircraft maintenance and repairs including inspection and adjustment to components, replacement and rigging of control surfaces and fuel systems.

1952 to 1956 - U.S. Air Force. (Served in the U.S. and European Theater as A&P Mechanic and Flight Engineer. Honorable discharge.)

Associate in Art Degree, Borough of Manhattan Community College of the City of New York, 1971. Majored in Government Administration. All courses were directed toward a strong administrative background with special emphasis on government procedural practices, labor relations, management and finance.

Aviation Safety Inspector's Credential FAA Form 110A
A&P License 1333771
FAA Authorized Inspector (IA)
Parachute Riggers License MCG 12326698
FCC Restricted Radio 2E2528
FAA Designated Airworthiness Representative - DAR 27-FS-EA

Wings Club, New York City
Westchester Aircraft Maintenance Association (WAMA)
Professional Aircraft Maintenance Association (PAMA)
Aviation Hall of Fame of New Jersey
FAA Flight Standards Retirees, Inc.

FAA Quality Performance Awards - 1969, 1974, 1978, 1984, 1985
Washington, D.C. Roundtable Association Award for Government
Participation in Education - 1987
FAA Aviation Training 1992-1993



  1. A&E Mechanic, Sheppard AFB, Texas
  2. A&E Specialist, Sheppard AFB, Texas
  3. B-26 Flight Engineer Light Bomber Specialist, Loan AFB, France
  4. C-46 A&E Cargo Specialist, Floyd Bennett NAS, Brooklyn, New York
  5. Jet Aircraft & Engine, Floyd Bennett NAS, Brooklyn, New York
  6. Jet Canopy and Seat Ejection, Amarillo, Texas
  7. Aircraft Weight and Balance, Chanute, Illinois
  8. CAA Aircraft Mechanic, New York Board of Education, Brooklyn, New York
  9. US Department of Interior Bureau of Mines, First Aid, FAA Regional Office
  10. Radiological Monitoring Course for Instructors, EITC, Brooklyn, New York
  11. Aircraft Gas Turbine Compressor, Garrett Corporation Airesearch, Phoenix, Arizona
  12. Queenair 80 Beechcraft, Beech Aircraft Corporation, Wichita, Kansas
  13. Management II, FAA Regional Office
  14. Management of Personnel Division, FAA Regional Office
  15. Letter Writing, FAA Regional Office
  16. Emergency Relationships Orientation, FAA, NAFEC, Atlantic City, New Jersey
  17. Piloting, Seamanship and Small Boat Handling, Absecon Island Power Squadron, Atlantic City, New Jersey
  18. Associate in Arts Degree in Government Administration (Liberal Arts) Borough of Manhattan Community College of the City University of New York
  19. 21603 General Aviation Maintenance Indoctrination at FAA
    Academy 2/9/72-3/14/72
  20. Flight Standards Inspectors Conference Workshop, Atlantic
    City, New Jersey 7/17/72-7/28/72
  21. US Department of Agriculture Forest Service, Missoula, Montana - Smoke Jumper, Parachute Rigger 2/24/74-3/9/74
  22. 22502 Non-Destructive Testing at FAA Academy 9/9/74-9/20/74
  23. 21828 Air Taxi Certification and Surveillance 11/3/75- 11/14/75
  24. 14007 DOT Directed Study - Introduction to Foreign Service 1976
  25. 21811 General Aviation Aircraft Alterations 6/18/76
  26. 01507 Compliance and Enforcement Procedures 9/23/77
  27. 22501 Fundamentals of Aircraft Structures 2/16/79
  28. FAA-Maintenance Airman Standardization Airworthiness
    Section Examinations Standards Branch, Flight Standards National Field Office, Teterboro, New Jersey 7/79
  29. 21812 General Purpose Helicopter 1/2/80
  30. 21840 DC-9 Airframe & Powerplant Maintenance & Inspection
  31. FAA-Surveillance Refresher Seminar for Airworthiness Inspectors. Aircraft Maintenance Division AWS-300, Philadelphia, Pennsylvania 11/84
  32. FAA-General Electric Factory Course. CT7 Turboprop Engine - Aircraft Engine Business Group, Technical Operation, Lynn, Massachusetts 9/85
  33. FAA-Enforcement Information System, Eastern Regional Office
  34. 28403 FAA-3 Maintenance Steering Group. MSG-3 (Aircraft
    Maintenance Training. Boeing Commercial Airplane Company, Seattle Washington 4/86
  35. FAA-Federal Personnel Management
  36. FAA-Seminar in Labor Relations
  37. FAA-Region and Urban Problems
  38. FAA-Social Psychology
  39. FAA-Federal Government Organization and Operation
  40. FAA-Federal Administrative Practices
  41. FAA-Federal Financial Management
  42. FAA-Federal Procurement Practices
  43. FAA-Law for the Federal Manager
  44. FAA- Management for Supervisors
  45. FAA-Management of Personnel Functions
  46. FAA-Effective Writing
  47. FAA-FAR 183 - Designated Airworthiness Representative (DAR27-FS-EA) - early renewal, recurrent training every two years from 1988
  48. FAA-FAR 65 - Authorized Inspector (IA) - yearly renewal, recurrent training yearly from 1985
  49. Continuously attend FAA, WAMA, PAMA, Wings Club and various other aviation organizations' education seminars