Motorblog

Maintenance Entropy and Southwest Airlines

President, SUCCESS by DESIGN
Executive Director, Institute of Electrical Motor Diagnostics, Inc.
Member National Writers Union (UAW Local 1981) and International Federation of Journalists

Yes, here we are again with Maintenance Entropy at its worst.  With an unprecedented period of aircraft safety and the pressure to cut costs, why shouldn’t airlines look to cutting aircraft maintenance, the FAA become complacent on inspections, and US Department of Transportation reports on concerns with outsourced and uncertified facilities and personnel working on aircraft be ignored.  Then, when things go wrong, all the warnings consciously avoided, point fingers and refuse to be accountable for really, really bad decisions.

We see this within industrial and commercial maintenance organizations where costs are cut in an effort to increase profitability; early retirement of experienced personnel without transferring knowledge; ceasing successful programs because there is no additional benefit without understanding sustainment; and, other such things as focusing on ‘wrench time’ as a metric.  Yes, it is time to start revisiting and slaughtering a few ‘sacred cows’ related to how we think about maintenance and how the so called leaders of our industry are setting us back against progress.  I have been subtly stating the obvious for some time.  Now, something serious has occurred that makes my warnings outlined in previous newsletters and ‘Physical Asset Management for the Executive’ seem to be prophesy rather than concern.

On June 9, 2005, a PBS interview focusing on several of the aircraft industry reports I have identified in the past entitled ‘The Cost of Safety’ was conducted.  The interviewer was Margret Warner discussing a number of issues identified in several reports prompted by the ‘Safety Oversight of an Air Carrier Industry in Transition,’ by the Department of Transportation’s Inspector General.  “The Federal Aviation Administration’s safety inspectors are not keeping pace with the new risks posed by cost-cutting throughout the airline industry.  That’s the word from the Transportation Department’s inspector general in a report publicly released yesterday.”

At the time, the following statement was made by one of the interviewee’s, reporter Sara Goo, “And I should say that in context, you know, we are going through an unprecedented level of aviation safety in this country, where we haven’t had a major accident, a fatal passenger accident in the past three years.” The focus, at this point, was on how the FAA was not closely watching work sent to third party vendors and was focusing 90% of its inspections during the day, at just the airline repair stations, when most maintenance is performed overnight.  The primary focus on the changes, how things are occurring, and cost cutting was amazing in the interview, which led into the second half, an interview with Marion Blakey, head of FAA.

To paraphrase the interview (http://www.pbs.org/newshour/bb/transportation/jan-june05/faa_6-09.html), Margret Warner points out, “I’ll give you one example, there was one of the new carriers, there are no names mentioned, but one of the five new carriers, one year it added 60 percent to its personnel and 60 percent to its routes, three times the number of destinations, cut maintenance by 14 percent.  But none of that had been factored in, the IG says, as a risk factor, wasn’t seen as a risk factor by the FAA.” Ms. Blakey pointed out that “I think it’s fundamentally flawed.” And then points out, “And it’s about analyzing the data to see what the data tell us about where there really is a risk.” She also goes on to continue to point out that there has not been a fatal problem and that the IG uses ‘anecdotal evidence.’ I will definitely point out that the IG reports do specifically use anecdotes to support the other data that they present.  The fact that “… looking at the way we’re applying resources [referring to the significant reduction of FAA inspectors coming up], looking at the fact that when you go across the board, we’re looking at computer data; we are looking at a vastly larger amount of information than we ever had in recent years.”

However, the data that the FAA is using for risk analysis involves trusting that accurate data is making it into the computers and is even being reported in the first place.  As I have pointed out in the past, depending on the location and the incentives for entering the data, the accuracy of such data must be brought into question without auditing.  In effect, the FAA’s administrator’s answer to each of the issues was either that the assumption is flawed or referring to the fact that no one had died lately.

So, I downloaded the FAA’s reporting on delays related to everything and focused on several of the specific incidences that I was involved in.  Particularly the Northwest Airlines aircraft where the maintainers had failed to fully attach the rear cone on one aircraft and United Airline’s issue with ‘inspection hatches on the left engine.’ I was unable to find details on either incident, as well as numerous other issues.  I did find outlines as to ‘maintenance related costs and delays.’

Now we fast forward the complacency concerning aircraft maintenance to present day issues.  Most notably last week in an almost buried news story concerning significant fines against Southwest Airlines concerning their lack of performing critical safety inspections on 46 aging aircraft.  These inspections focused on checking for fuselage fractures on the aircraft, which stemmed from a number of incidences including the 1988 Aloha Airlines failure that killed a flight attendant when a portion of the top of the aircraft came away during flight.  Southwest’s immediate response?  “We assure our customers that this was never a safety of flight issue.”

So, that should mean that NONE of the aircraft had structural issues?  Especially after Southwest also stated, “The FAA penalty is related to one of many routine and redundant inspections on our aircraft fleet involving an extremely small area in one of the many overlapping inspections.  These inspections were designed to detect early signs of skin cracking.” [St. Louis Business Journal, March 7, 2008].  This also re-enforces the idea that there should be zero cracking, right?

According to the NBC4.com article of March 7, 2008, “FAA Fines Southwest Airlines $10.2M for Safety Violations,” four of the planes had 4 inch cracks requiring immediate repair and an additional six that had the start of cracking.  Let’s see, that would be 22.7% of all the affected aircraft!!  I suppose that would be close to zero.

I suppose then that this must be a recent issue and possibly upper management wasn’t aware.  Especially after three Southwest Airlines employees were put on paid leave during the investigation and the FAA put the blame on one inspector (at this time, two FAA inspectors have been given ‘Whistle-Blower’ status protection during Congressional hearings on the matter).  Well, as it turns out, the problem started out with 46 aircraft in which mandated inspections were not performed that was reported to the FAA in March, 2007, corrective action outlined and the FAA agreed to the corrective actions in April, 2007.  Reports had been provided to the upper levels of FAA and the CEO of Southwest was involved in the issue.  However, those same planes continued to perform service: “The FAA Alleges that from June 18, 2006 to March 14, 2007, Southwest operated 46 Boeing 737 airplanes on 59,791 flights that did not comply with the FAA Airworthiness Directive (AD) that requires repetitive inspections of certain areas of the planes to detect fatigue cracking.” Southwest claimed that they were in compliance and the FAA stated, “that after Southwest Airlines discovered that it had failed to accomplish the required repetitive inspections, between March 15, 2007, and March 23, 2007, it continued to operate those same 46 airplanes on an additional 1,451 flights.” [CNNMoney.com, March 7, 2008, ‘Southwest Responds to FAA Allegations’]

“Southwest Chief Executive Gary Kelly had said Tuesday he was concerned by findings from an internal investigation into the missed inspections.  He announced that the Dallas-based company had placed three employees on paid leave while it investigated the situation.”… “Acting FAA Administrator Robert A. Sturgell called the events ‘a twofold breakdown in the aviation system.’ – first, Southwest’s failure to properly inspect its planes; and the FAA’s failure to ground the jets as ‘at least one FAA inspector looked the other way.’” [CNNMoney.com, March 12, 2008, ‘Southwest Grounds 41 Planes on Safety Concerns’] However, these types of actions are often the result of management policy, written or in action.  For instance, the Inspector General’s report on Northwest Airlines when Northwest executives blocked an FAA inspector from their facilities due to the fact that he was constantly bringing up concerns with how maintenance was being performed.  When his immediate management would not correct the issues, he sent a report further up the chain and was promptly transferred to another location until he contacted the Inspector General who investigated and discovered that his concerns were correct.  The FAA inspector was returned to the Northwest facility.  However, the amount of trouble this caused definitely sent a message.

Following taking 8% of their aircraft out of service and having to cancel about 4% of flights last Wednesday, Southwest stated, “other such service operations could occur in coming days because of the ‘ongoing internal review of Southwest’s maintenance programs, policies, and procedures.’” [CNNMoney.com, March 13, 2008, ‘Southwest Back to Normal Operations’] This all represents interruption of service, interruption of other inspections and maintenance schedule, and an impact on Southwest shares of 4.1%, or $0.51/share to $11.89/share following the report.  It appears that the $10.2M had some level of impact of drawing attention to complacency in maintenance.  However, the issue is being handled as a financial versus maintenance/safety issue with those responsible ducking for cover.  However, the FAA maintenance inspections do not have the same teeth as other safety programs such as OSHA, which holds the ownership and management of an organization directly responsible for employee safety.  Why do we not have the same conditions with aircraft?  Wouldn’t you expect that maintenance, reliability and customer safety would play a higher role if the owners/managers were held personally responsible?

In the meantime, with companies that we need to trust for our safety in flights standing behind the idea that there has not recently been a fatal incident that should drive them to focus on maintenance/safety issues, even with the rapidly rising number of sometimes reported maintenance issues that I have outlined for over two years, this situation is going to become worse.  Basically, I am predicting a catastrophic failure of the system in which there will be numerous deaths prior to any action being taken on this subject.  In the meantime, the FAA and many of the airlines seem to be content with testing the waters of risking our health and safety as a numbers game, politics and cost cutting riding the luxury of the present ‘random failure’ incident of nothing negative… yet.

However, bridge inspections went the same route until the collapse of the bridge in Minnesota, it was assumed that because no incidences had occurred that those responsible for the maintenance/repair budgets could ignore failing inspection reports until a few of those who trusted to the safety of those routes died.  There is simply no excuse, the warning signs are there as they are with our facilities and production equipment.

While the impacts are not always fatal in our industrial and facility maintenance programs, they do have impacts on our economy and the viability/profitability of the organization.  In order to mitigate the damage of maintenance complacency and maintenance entropy, it will require a corporate reliability and maintenance strategy.  A properly applied program does not negatively impact profitability, but instead allows the organization to run to capacity, with the strength and type of R&M program impacting that capacity.

In our next newsletter, we are going to start exposing a number of practices that are holding us back at the ground floor.  Many of these practices are espoused by a growing number of maintenance consultants, but will kill our programs because while they seem to ‘make sense’ they fly against true logic and the understanding of the corporate system.  One of the worst of the culprits is something known as ‘wrench time.’ Watch next week and I will explain why.

Until then.

Sincerely,
Howard W Penrose, Ph.D., CMRP
President, SUCCESS by DESIGN Reliability Services
Executive Director, Institute of Electrical Motor Diagnostics, Inc.
Member National Writers Union (UAW Local 1981) and International Federation of Journalists