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Compliance Reminder: Non-Compliance Awareness
Sep 19, 2017

September 19, 2017

On July 13, 2017, Southwest terminated an Aviation Maintenance Technician (AMT) for deviating from “all required procedures included in MT 735-00-01.” 

The letter of termination indicates that the Company relied on surveillance tape to determine that the AMT may have allowed a second mechanic to sign for work that the AMT had performed:  “security video evidences that a second AMT did not enter the area of the flight crew oxygen cylinder and therefore, required processes and/or procedures of MT 735-00-01 were not completed.”

Based on this single incident, Southwest justified the AMT’s termination in the following terms:

Southwest Airlines expects its Aircraft Maintenance Technicians to follow policies and procedures to ensure the safety of our customers and employees.  Based on the aforementioned conduct, which has led to Southwest Airlines losing confidence in your judgment and ability to properly follow regulations, policy and procedures, your employment with Southwest Airlines is terminated.

Disclosures to the FAA have also led to the AMT’s receipt of a Letter of Investigation.

The unfortunate AMT in question is one of several of your fellow aircraft mechanics Southwest has terminated in the recent months for alleged non-compliance with documented maintenance procedures. 

All members are urged to carefully review maintenance documentation applicable to O2 bottle installation.  This installation requires a sign-off for verification by a second AMT confirming the O2 supply valve is open and safety wire has been performed.  The Aircraft Maintenance Manual (AMM) gives removal and installation procedures and should always be consulted when remove and replace or servicing of any O2 bottle. Wholly aside from written SWA company policy and procedures, every AMT has both the right and obligation to perform maintenance in accordance with the standards embodied in our maintenance manuals. When we say “obligation,” we refer to Federal Aviation Regulations (FARs) that mandate that all aircraft maintenance must be performed using the “methods, techniques, and practices” prescribed in applicable maintenance manuals.  14 CFR § 43.13(a).  The FARs further stipulate that maintenance work be properly documented. Reference 14 CFR § 121.701(a) which states:

“Each person who takes action in the case of a reported or observed failure or malfunction of an airframe, engine, propeller, or appliance that is critical to the safety of flight shall make, or have made, a record of that action in the airplane's maintenance log.”

As confirmed by these recent incidents, Southwest uses video surveillance to enforce its compliance policies and has apparently shared videotape with the FAA. We believe that our members recognize their moral and legal obligation to perform their maintenance work in a manner that complies with the FARSs and all applicable maintenance manuals; however, no one is perfect all the time.

A memorandum was distributed to all SWA Technical Operations employees on January 3, 2017, that concerned the reporting of potential non-compliance. As a licensed Airframe and Powerplant Technician you have the right to protect yourself and your license by utilizing the Aviation Safety Action Program (ASAP). We are all human and mistakes can happen, so take every precaution to avoid them, but know that AMFA’s involvement with ASAP is to utilize a non-punitive program to ensure the continued safety of flight where our AMTs are concerned.  All AMTs should become familiar with the ASAP process, particularly now that it has been forcefully brought to our attention that our momentary lapses may be recorded and used to terminate our jobs and revoke our licenses.

In closing, please remember to stay focused on the job you are performing and task at hand. Do not let the distractions of everyday life re-direct your attention away from what is happening in front of you. Please use the buddy system to help each other remain compliant. It is extremely important to watch out for ourselves and each other, that’s the essence of being in a Union.

We all need to ensure that each of us is able to return home each day to the families we love and support. 

In Solidarity,

Scott King
National Safety & Standards Director

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