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Testimony of John A. Lewis
Operations Manager
Professional Aviation Maintenance Association (PAMA)
636 Eye Street, NW
Washington, DC 20001
before the
National Civil Aviation Review Commission
October 8, 1997

My name is John A. Lewis, Operations Manager of the Professional Aviation Maintenance Association (PAMA). We are located at 636 Eye Street, NW in Washington, DC, 20001. PAMA is a professional association whose purpose is to support and represent individual aviation maintenance technicians, presently known in the regulations as "Airframe and Powerplant Mechanics." PAMA was formed in 1972, 25 years ago, by far-sighted individuals who saw the need for banding together to promote, educate, and represent the aviation maintenance professional. Our membership of some 5,000 includes mechanics from general aviation, corporate aviation, and the airlines. We maintain the nation's fleet of aircraft-from the largest to the smallest.

The primary goal of the individual aviation maintenance technician is safety, and this is why I am here today.

Our members are proud that we are an integral part of the world's safest aviation system. We know and understand the importance and responsibility of what we do. My goal today is to help you better understand how we fit into the safety system and to inform you of some of our issues, challenges, and goals. I will offer several suggestions to make this safe system even safer.

There are four things needed for every successful flight. First, is a well-designed aircraft that has been tested and found safe. The second is adequate fuel to take you successfully to the intended destination and a little farther. Third is a pilot who knows the way, is well trained, and has sufficient experience. Lastly is well maintained aircraft that will not fail. Admittedly, there are numerous other supporting elements also important to safe flight, but at its very basic level, Aviation still comes down to design, fuel, operations, and maintenance.

Most aviation mechanics, and I will refer to them from now on as Aviation Maintenance Technicians or AMTs, work under harsh and demanding conditions. The entry-level pay is very low compared to many other fields with comparable skill and experience requirements. We are subject to the wind and weather, the regulations, inconsistent FAA oversight, employers who pay a lot of attention to the bottom line, parts systems, manufacturer's instructions, and a host of other vagaries. We maintain, repair and overhaul the aircraft you fly.

The term Aviation Maintenance Technician-AMT-is embodied in a proposed regulation currently winding its way through the regulatory labyrinth within the FAA. This proposed regulation is called Federal Aviation Regulations Part 66 and it affects us in a number of ways. With the enactment of this regulations, our job title will change from "airframe and powerplant mechanic" or "A&P" to "Aviation Maintenance Technician." It will become more challenging to become a licensed AMT and the FAA will be required to maintain a current registry of active AMTs. The proposed regulation has been under consideration and active development for over 10 years. PAMA has been involved throughout this 10-year process, most recently through the ARAC (Aviation Rulemaking Advisory Committee). We are awaiting the release of a Notice for Proposed Rulemaking (NPRM) for the proposed FAR Part 66.

The final development of the proposed rule was the product of the Aviation Rulemaking Advisory Committee (ARAC). It contains some controversial elements that were not resolved during the process. I know you are all familiar with ARAC. We believe it is a good process and with a few process improvements could be even better. It is not without its problems, but involving the aviation community in rulemaking is preferable to the past when the FAA only listened to well placed advocates.

There are two governing factors in the proposed FAR Part 66 rule that affect safety and AMTs. The first is a new requirement for recurrent training. For years, the maintenance community has debated whether to require recurrent training, how much should it be, and what should it cover . The ARAC could not come to a consensus, primarily because of the budgetary implications of requiring such training. One segment of the aviation community views the continued training as an unwarranted expense in a time of rising costs. The airlines view it as a necessary expense. So the aviation community was and is split.

PAMA is unequivocally in favor of recurrent training for all AMT's maintaining aircraft. Just as you, in your profession, continue to receive some manner of training, whether required or not, most professional AMTs obtain recurrent or inservice training. Either our employers require it, the fast pace of technology requires it, or our own desire for professional improvement requires it with improved safety as our focus want the rules to require it.

The need for continuing education in a changing technical environment is hardly debatable. Of course, we need to continue to discuss how the training is implemented and how much and what training must be required. There is no doubt that additional training will make the system safer. There must be a minimum amount of standard training and it must be required of all active AMT's maintaining aircraft. If you set the bar (level), we will exceed it.

The education and training requirements to maintain aircraft is extensive. To become licensed AMTs, we must receive approximately two and a half years of classroom and practical training in all facets of aviation maintenance. This training is conducted by the approximately 200 FAA-approved schools and universities nationwide. We are skilled at pneumatics, hydraulics, metals, engines (both piston and turbine), electronics, fluids, metal fabrication, wood, fabric, math, science, English, physics, the regulations, and a host of other subjects. Before we can practice our trade we must pass nine tests-three written, three practical, and three oral. At the conclusion of this education and certification process, we are granted the authority to return an aircraft to service or, in lay terms, turn it over to the pilot as safe to fly. Beyond this, the FAA places restrictions on us to ensure we do not have this authority right out of school or without reasonable levels of experience. At least once, we must have done the work before or operated under the supervision of someone who has.

The lack of a requirement for continuing inservice training for all AMT's is a big void in the regulations. This commission must stress the need for it to the leaders responsible within the FAA.

The second major area affecting safety is the lack of a census of licensed AMTs. The FAA issues us a certificate and then does not maintain the records. The database of AMTs in Oklahoma City is so out of date that the FAA has no idea who, where, or what we are doing. For instance, if you ask the Administrator to show how many active AMTs there are out there fixing aircraft, they will tell you they have 329,000 licensed mechanics on their books. This includes Orville and Wilbur Wright and a few others that will never lift a wrench again. Our estimate is that only 120,000 licensed AMTs work on aircraft regularly.

The lack of a valid database is not acceptable. The FAA has a duty to maintain a current list of active aviation maintenance technicians. This duty goes hand-in-hand with the requirement to license. The FAA blames a budgetary shortage for not maintaining the database. I believe it is something more fundamental. The FAA often has trouble implementing a new policy unless the safety issue is patently obvious. Unfortunately, this means that many safety issues must lead to a death before they are addressed. I believe that a database of active AMTs has not yet materialized because you cannot yet show a direct link to a specific number of fatalities.

Knowing who is working on the nation's aircraft is a basic function of the licensing process. Today, the FAA cannot tell you if convicted drug dealers, sociopaths, or international terrorists are maintaining the aircraft you fly on. Apart from these security concerns, the FAA does not have the ability to disseminate technical safety information to every active AMT. Let me give you an example of why the database is necessary. Recently an airliner was brought down by packing oxygen generators in an unapproved way. Since that time, I have been told that after all the publicity as many as 15 additional incidents of improperly shipped oxygen generators have occurred. The FAA should have sent warnings to every active AMT, but they cannot reach them directly.

The proposed Part 66 calls for a re-registration of aviation maintenance technicians, but this rule has been under development for a score of years. A number of FAA administrators committed to PAMA that the database would be kept current. But, to date, not one has had the ability to carry out that promise. If this item is not in the FAA budget, I hope you agree with me about the necessity for a good current census and database.

Thank you for the opportunity to talk with you today. I have summarized two areas of potential safety improvement. They are not earth shaking, but both affect fundamental areas of safety. Again they are, recurrent training for all AMT's and the ability to send safety information to every active AMT. PAMA is prepared to assist you with the development of proposed regulatory language to implement these initiatives.

Again, we appreciate the opportunity to talk with you today.