Pencil Rectification

[Gorgons]

Hypothetical situation and question, a small 703 company has an AME they call the base engineer, works alone or sometimes with an apprentice. Base engineer is responsible for one aircraft that is based there. The company has a cash flow problem and the usual credit problems that come along with it. Availability of parts is sometimes skectchy and continually putting band-aids on what should be permenant fixes eventually wears the AME down. Inspections are due but you don't have what you need to do it properly, pressure from above to do what you can to keep the bird flying is constant. Eventually the AME completely caves and starts signing off inspections and work that wasn't actually performed to keep the boss off his back even though it wasn't a situation created by the AME. AME did what he did expecting the parts would eventually get purchased, show up and the work would get done. Fast forward a few months and questions start getting asked, pilots are getting uncomfortable because they have suspicions as to whats happening and customers start hearing rumours and partial conversations between pilots. Those questions lead to more questions and the base engineer ends up getting fired by the PRM for rectifying inspections and such with a pencil instead of tools and parts. AME's from another base get involved and a couple days later the aircraft that was removed from service by the PRM is returned to service and as far as everybody is concerned everything that should have been done is now done and all is good.

Question

Is the company legally obligated to report a situation like this to Transport Canada or can they keep it an internal matter and ensentially sweep it under the rug?

[Troubleshot]

Hypothetical situation and question, a small 703 company has an AME they call the base engineer, works alone or sometimes with an apprentice. Base engineer is responsible for one aircraft that is based there. The company has a cash flow problem and the usual credit problems that come along with it. Availability of parts is sometimes skectchy and continually putting band-aids on what should be permenant fixes eventually wears the AME down. Inspections are due but you don't have what you need to do it properly, pressure from above to do what you can to keep the bird flying is constant. Eventually the AME completely caves and starts signing off inspections and work that wasn't actually performed to keep the boss off his back even though it wasn't a situation created by the AME. AME did what he did expecting the parts would eventually get purchased, show up and the work would get done. Fast forward a few months and questions start getting asked, pilots are getting uncomfortable because they have suspicions as to whats happening and customers start hearing rumours and partial conversations between pilots. Those questions lead to more questions and the base engineer ends up getting fired by the PRM for rectifying inspections and such with a pencil instead of tools and parts. AME's from another base get involved and a couple days later the aircraft that was removed from service by the PRM is returned to service and as far as everybody is concerned everything that should have been done is now done and all is good.

Question

Is the company legally obligated to report a situation like this to Transport Canada or can they keep it an internal matter and ensentially sweep it under the rug?

Oh it will be reported alright, problem is, none of the said discrepancies will be the fault of the shady company/PRM...the company will portray that the issue all along was due to the pen-whipping AME and they caught him in the act. Then they can show TC that the problem has been rectified by dismissing the employee...problem solved. The AME should have just quit or have gone to TC right away, cause if he kicks up a stink now he just looks like a disgruntled employee and has zero credibility.

Never forget that these shady operators know how to play the greasy game and prey on good natured people to help them grab every dollar. Pilots, AME's , hangar space, fuel, etc...will all get screwed over, just a matter of time.

The AME that got canned should just view it as a blessing in disguise that he didn't help produce a smoking hole while there. These sort of practices will catch up to the operator but not until they squeeze every last dollar outta the joint.

[Gorgons]

I can see where your coming from and your answer is most likely how a slimy operator would handle it but I'm more interested in knowing if there is a reg that covers this type of situation. Does anybody know if there is anything that makes reporting such an incident mandatory? Or can a company just put a lid on it and keep it an internal matter?

[CID]

So how is it that the operator is "slimy" in this scenario but the AME is a victim and just "caved"? Sorry, but they are both slimy. If you are an AME and start pencil whipping inspections, you are a dangerous individual. I don't care what the circumstances were. You are slimy and probably in the wrong profession.

Having said that, there are certainly many slimy operators out there that will exploit weak minded or slimy pilots and mechanics. If the company is under SMS, there is a better chance of management taking a fall in these cases but if the company hasn't adopted SMS, the AME in this case is all by him/herself.

[Gorgons]

Was never my intention to paint the AME as a victim, he would be making a choice, one that comprimised his and the industries integrity. Arguably a criminal act... In this scenario what makes the operator slimy is they would happily throw an employee under the bus when they are equally but not blatantly complicate, only acted, perhaps literally once questions were being asked. In the picture I painted there is no SMS, its a 703 operation. Still no answer as to whether there is a mandatory requirement to report it to Transport Canada?

[robertw]

703 operators are required to have their maintenance done by an AMO. You wouldn't have a "Base Engineer" working strictly for an operator doing maintenance on company aircraft. That AME would have to be working under an AMO.

AMO's are governed by CAR 573. CAR 573.09 requires that an AMO has a quality assurance system that audits the AMO processes. The 703 operator is supposed to have a quality assurance system required by CAR 706.07 for the same purposes. These systems are supposed to be the regulations that would require reporting of this situation. Once a company reports in their own QA system, TCCA will eventually find out about it when they come for a PVI. The first thing they ask for is the audit records and QA findings.

As far as I know, there is no specific regulation that says you must report XYZ to TCCA if you become aware of an issue like that. It is the responsibility of the operator to ensure that maintenance is being done as per the aircraft maintenance schedule.

Also +1 to CID's comments.

[CID]

Just to be clear, 703 can be SMS. Keystone Air, an airline in Manitoba which currently has its OC suspended is a 703 SMS operator.

[Gorgons]

Just as 703 can operate to 705 standards, one can always choice to exceed the standards. Also for clarity, currently there is no requirement for a 703 to employ an SMS program. So all the drift aside the answer seems to be no, there is no requirement for the operator to report the incident to Transport. And if the operator is also an AMO he also has influence over the QA, good likelihood the issues don't get caught in an audit or documented. Thanks for the responses.

[robertw]

No, I think you're wrong. There is a requirement and it is found in CAR 573.09 and CAR 706.07. If the QA system is not recording and rectifying findings, which do make it back to TCCA during PVI time, they are contravening those CAR's.

There is no regulation that says that you must march into your local TCCA office and report contraventions of regulations though if that's what you're looking for.

[NeverBlue]

Call Transport and tell them???

...maybe at the same time you could call the police and tell them you speed once in a while...and then maybe revenue Canada and tell them your accountant is writing off expenses that they shouldn't be...

[Darkwing Duck]

There has to be a paper trail of some sort that the Base Manager / AME is not able to fudge, such as receipts for purchased parts that were replaced for example. If the work was "done" but no receipt for said replaced parts from Acme Aviation Parts Warehouse then some of the blame would have to be placed back to the ownership / operator.

[dashx]

Eventually the AME completely caves and starts signing off inspections and work that wasn't actually performed to keep the boss off his back even though it wasn't a situation created by the AME

So the AME created another situation. A situation that he was responsible for.


You are not there to appease your PRM or the pilot or the customer. You are there to make sure nobody gets killed due to "caving in"........

But that's just my version of reality.

Words just words.........