July 19, 2017
After many months of work there has been a change in the Aviation Safety Action Program (ASAP) Memorandum of Understanding (MOU) at Southwest Airlines (SWA). Our ASAP came under 14 CFR, part 121 and AC 120-66A as an air carrier engaged in passenger operations within the United States. Our Program’s initial MOU was signed on September 27, 2001, and the only modification made to the MOU since was the addition of AMFA when we were elected as the bargaining agent for the Aircraft Maintenance Technicians (AMTs) and Appearance Technicians.
Several years ago the FAA updated the AC to AC 120-66B, but we did not update our MOU at that time. Over the last couple of years, the FAA has studied updating to AC 120-66C, but the timeline for completion of this anticipated revision remains unknown. The FAA has informed SWA, AMFA, and the IBT that we must update to AC 120-66B to be in line with the rest of the industry. Most of the changes are internal working and reporting processes and procedures that will bring a 16 year old process up-to-date.
Changes You May Notice
The primary change AMTs will notice is in the reporting timeline.We were required by the FAA to go from five (5) days to the industry standard three (3) days to file the online report from when you make your initial phone call.
The Event Review Committee (ERC) will begin to use a decision making tool called “Just Culture” to assist in making the determination of report acceptance.This is good for those represented as it removes any personality issues and decisions are based on a decision flow matrix.We have reviewed some of our past troublesome reports using this system and they flow nicely, and we have determined that those reports would have most likely been accepted.
Some of the new terminology used reflects the current industry standard, like “intentional disregard for safety” may be replaced by “reckless behavior.”
The question has been raised as to why the AMFA membership did not have the opportunity to vote on this change. We are required to be in compliance with rules and regulations set forth by the FAA and, therefore, we do not vote on mandated changes to the AC. We do, however, vote on whether or not we participate in the Program.
Not All Reports Submitted will be Handled Through ASAP
There are some reported issued that are outside of the jurisdiction of ASAP to issue corrective action. Items like broken ladders, reports involving other departments of SWA (such as Ground Ops), and facility type issues are issues that cannot be processed through the ASAP. We are limited to making recommendations. By referring a non-14 CFR regulatory items to the Safety Reporting System (SRS) it goes to director level where a resolution is required. When using the SRS, the reporter has the ability to remain anonymous by checking the applicable box when you file a report. Should an AMFA member file a report that the ERC decides is best to forward into SRS, the AMFA ERC member will file the report. They will then notify the member of the SRS tracking number and update the member with any action to correct the issue.
National Safety and Standards Director