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Safety’s Hazard
By Scott Skola


Safety and helicopter maintenance have had a long – and interesting – relationship.  During the past two decades, safety has played an ever-increasing role and is now one of the primary influences on each and every task mechanics perform.

But can too much initiative in the name of safety have a more negative than positive effect in a maintenance environment?  Can safety actually become a hazard? 

"What you talk’n bout, Willis?”

No, this is not about removing basic safety procedures, nor regressing to the old days of bathing in MEK, or working 48 hours straight to change an S-76 transmission.  This topic focuses on the current shift to apply abstract safety initiatives directly into aircraft maintenance procedures. 

Somewhere along the line when it came to safety policies, or of late, Safety Management Systems (SMS), maintenance operations became grouped with the rest of the company instead of remaining with flight operations.  This opened the door for flight-critical maintenance operations to be influenced by a company’s general industrial safety policies, customer-developed standards, and other third party initiatives. 

One result of this shift has been the increase in safety documentation and procedures mechanics are required to use during aircraft maintenance.  While these new initiatives are a positive force in theory, their sheer volume is starting to mitigate the actual maintenance task more than the hazards associated with that task. 

Unfortunately, most people assume that anything labeled “safety” is good and therefore should not be questioned — anyone with a differing opinion risks being labeled a rebel or not a team player.  Even for those SMS programs that have an established two-way dialogue policy, or “stop work” policy, it can be difficult to communicate these emerging conflicts to those not involved

However, time is running out.  With Safety Management Systems soon approaching regulatory status, it is imperative that we open a positive, information-based dialogue about the relationship between maintenance and safety before our maintenance operations are once again lost in the transition.

Growing Trend

To illustrate this shift we only need to compare the work environments of mechanics and pilots.  In the past, a pilot simply performed his duties with his hands on the controls, his flight manual and company manuals close by, and a basic flight plan.  Within this same time period a mechanic stood at the aircraft, wrench in hand with the maintenance and company manuals at his side, ready to perform his assigned tasks.

Fast forward to today where the cockpit environment has remained basically the same.  Except for a few more buttons to push, it’s still the pilot, his two manuals, and the act of flying the aircraft.  On the other hand, we find the mechanic is still in the maintenance office reviewing the SMS manuals and the customer-required maintenance task forms, while waiting for the maintenance computer to download the required Job Safety Assessments (JSA). 

Now, with the appropriate maintenance manual, company maintenance manual, company SMS manual, customer task form, JSAs, and company safety notices in hand, the mechanic can approach the aircraft.  And once he gathers his maintenance gloves and bump helmet he might actually be able to start his assigned tasks.

So what the heck happened?

The Confusion

When we apply an informal safety analysis to our maintenance operations, we encounter an unbalanced assessment when compared to flight operations.  To start, I don’t recall hearing about or reading about an upswing in industry-wide maintenance related incidents, or an increased risk of maintenance related errors and omissions.  Yet, there has been a tenfold increase in the amount of preparation mechanics must undergo in order to perform their tasks safely.

What makes it even more confusing is that a majority of these additional safety procedures are already covered in most manufacturer maintenance manuals or, in some cases, the company manuals.  So why generate duplicate, and often conflicting, additional maintenance requirements when there is no risk history?  The standard answer: safety protocol.

If that is true then why don’t we have pilots review a JSA on enhanced operational control or inadvertent IMC prior to each flight?  Or, why isn’t proper flight planning included in the SMS manual?  Or, why aren’t pilots required to use flight helmets, nomex, and gloves in all flight operations?  All of which have been topics in numerous public discussions, along with a well-documented risk history. The standard answer: cockpit distraction.

Yet, it’s not distracting in aircraft maintenance operations?

The question now is how do we transfer our maintenance operations from the current industrial-safety level to the flight-safety level that oversees flight operations.  Simple, we troubleshoot it just like any other discrepancy, by first defining the situation.

The Basics

In terms of actual work, the main difference between flight operations and maintenance is the ability of pilots to accomplish their work tasks (flying) within a controlled environment.  As a matter of fact, in 1981 the FAA enacted FAR 121.542 and FAR 135.100, better known as the Sterile Cockpit Rule, to ensure that only essential activities were undertaken during critical stages of flight.  This effectively allows the pilot to concentrate on his main task (flying the aircraft) free of unnecessary distractions.

In contrast, mechanics work in an uncontrolled environment.  With no regulatory oversight, our work environment has become ever increasingly cluttered with redundant requirements, non-maintenance procedures, and other distractions that would be more appropriate in a general industrial setting rather than in a flight-critical maintenance function. 

One option to curb this non-regulatory path of influence on maintenance safety oversight, and regain our “sterile” environment, is the use of a fundamental safety tool: risk assessment.

Risk Management

At the core of most safety programs is some form of risk management that identifies and quantifies the different levels of risk exposure.  Each perceived risk is assessed and, if needed, an appropriate barrier is developed to mitigate that risk.

Our very own helicopter industry would not exist in its present form without managed and acceptable risks.  For example, nearly every certified rotorcraft cannot perform 100% of its duties without entering the shaded area of its height verses velocity performance chart at some point.  However, on a daily basis the majority of the industry operates their aircraft within this area. 

Why?  Because it was determined to be an acceptable risk.  This risk is even supported by specific regulations that allow pilots to transition through these terminal performance areas: FAR 91.9(d) and FAR 136.13(b).  So it is important to understand that while there may be risks in our maintenance operations, these risks can be mitigated without an overabundance of initiatives that only further distance the mechanic from the most important item – the actual work on the aircraft. 

Taking Corrective Action

Following the FAA’s lead, we could call this process the Sterile Maintenance Rule.  To start with, amend existing SMS programs so that the applicable aircraft manufacturer’s documentation is the foundation for all safety requirements during the performance of maintenance on the aircraft.  The manufacturers have done an outstanding job of documenting the potential hazards involved in maintaining their aircraft, and it would be a disservice not to use those warnings, cautions, and notes.

The second tier of maintenance safety initiatives should be the company maintenance manual.  It should reflect all company-initiated modifications, additions, and substitutions – with their associated safety requirements – to the manufacturer’s documentation.   References to other supporting maintenance documents like ASBs, STCs, TBs, internal safety alerts, customer task cards, etc. should also be included in the appropriate sections.  For large diverse fleets, a separate company manual can be generated for each specific model, maintenance manual, and/or manufacturer.

If an SMS program mandates JSAs, then initiate one JSA that references adherence to factory and company maintenance manual safety instructions.  This JSA could be affixed to the outside cover of each manual to ensure its review.    

And this is where it should stop.  Keeping all pertinent safety and maintenance information in a simple, concise, and organized system promotes safety in itself by reducing the chances of a mechanic missing an item in a system that is spread out over numerous locations and formats.

Ideally, a final action would be to standardize the entire maintenance operation.  Nothing will promote a safer working environment better than removing the individual learning curves a mechanic faces when moving between maintenance locations and departments.  While this particular initiative is always met with the dreaded “cost” stigma, it begs to ask: Can a company truly afford to put a “price” on safety, when the entire industry has made safety its new battle cry?  

To sum up, I believe increased levels of safety awareness, and the resulting safety initiatives, are a good thing.  But as with all good things, too much can also create problems.  A striking example is the Macondo Prospect blowout and oil spill in April 2010.  The companies involved were among the most safety conscious and structured entities in the world, yet they suffered one of the most tragic events in recent history.  Unfortunately, the only discussions on avoiding a repeat of this event appear to revolve around adding more levels of safety initiatives, instead of correcting the existing ones. 

I think as mechanics we must insist that all safety-related initiatives be secondary to our main responsibility of performing maintenance on the aircraft.   And unless the current trend is altered, we may find ourselves victim to the very same safety initiatives put in place to protect us.

About the author: Scott has worked in various maintenance positions at a major helicopter operator for over 31 years.  When not working his scheduled seven-day hitch, he provides technical writing and research services through his business TEK Aviation LLC, and can be contacted at tekaviation@cox.net


 

Posted in: Safety

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