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Testimony of John A. Lewis
Professional Aviation Maintenance Association (PAMA)
636 Eye Street, NW
Washington, DC 20001
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
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
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
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.