433
1 considerably, and I started working on taking on project
2 management for some of the engineering projects that were
3 going on, DPFMS installation, things of that nature. I
4 started running those as project manager and basically that
5 launched into the engineering department development.
6 Q Okay, thank you. Could you please describe your
7 professional qualifications for the position that you held
8 at the time of the accident, i.e., director of engineering?
9 A Yes, I've attended the University of Cincinnati
10 electronic course at the University of Cincinnati, and most
11 of my experience came from working with manufacturers, STC
12 holders, STC developers, engineering firms. At the time
13 Emery was dependent upon outside engineering firms to
14 develop STCs, and I can't recall how many projects I oversaw
15 as project manager -- that's basically the background for
16 that.
17 Q That's fine. Could you please identify any
18 special qualifications that were required by Emery at that
19 time?
20 A For?
21 Q For the position of director of engineering?
22 A I believe they were management -- prior
23 management experience, -- I can't really recall all of them.
24 Q Are you a current A&P?
25 A Yes, sir.
Executive Court Reporters
(301) 565-0064
434
1 Q What position, by title, did you report to while
2 acting as the director of engineering?
3 A Vice president of technical services.
4 Q And what positions, by title, reported to you as
5 the director of engineering?
6 A I had systems, structures, power plants and
7 avionics engineers reporting to me. The manager of
8 reliability, at the time it was Robert Peck, and the manager
9 of technical publications.
10 Q Okay, thank you. Could you please describe your
11 major duties and responsibilities as the director of
12 engineering?
13 A Major duties and responsibilities, mostly was
14 coordination of activities below me and then gaining
15 funding, analyzing the industry to see what was the next --
16 you know, the next big AD, not the smaller ADs, but larger
17 ADs -- aging aircraft things, when they shut down the Omega
18 system -- that was a -- you track those type of things and -
19 - around the world, to make sure that Emery was poised to
20 have the funding and the components, and have a project in
21 place to take care of those things, such as TCAS and things
22 like that. So it was kind of divided between managing the
23 processes and the people, and looking ahead to see what was
24 going to be required.
25 Q Alright. As the director of engineering, were
Executive Court Reporters
(301) 565-0064
435
1 you responsible for monitoring aircraft technical problems
2 in order to minimize their impact on operational performance
3 and maintenance?
4 A The reliability, yes.
5 Q As the director of engineering, were you
6 ultimately responsible for submitting changes to the
7 maintenance and inspection programs?
8 A The reliability -- the MRB, the maintenance
9 reliability board -- that's where the changes were
10 introduced. I'm not sure if I'm answering your question.
11 Q Were you ultimately responsible for submitting
12 changes to the maintenance inspection programs since the
13 manager of reliability reported directly to you? Were you
14 ultimately responsible for these functions?
15 A No, it was not a sole function to put those
16 changes into the maintenance program. It was a board
17 function.
18 Q Which would reside within the engineering
19 department?
20 A The maintenance reliability board consisted of
21 department heads. Any changes to the maintenance program,
22 there'd be a recommendation that would be -- you want me to
23 describe the process, real short?
24 Q That would be great.
25 A Okay. Reliability would analyze the incoming
Executive Court Reporters
(301) 565-0064
436
1 data. If there was a trend spotted for some sort of
2 negative impact, irregardless of what it was, a review of
3 the work decks, all the work cards, would be reviewed to see
4 where -- if that activity was taken -- if there was -- say
5 it was a seat lubrication. We were having problems with the
6 seats, the maintenance of the seats, jamming of the seats.
7 We found in some of the cards where the seats were being
8 lubricated, but we felt that either the lubrication was not
9 correct or we had a better lubricant out there, or that
10 maybe it wasn't frequent enough, reliability would propose a
11 change via a work card -- either an additional work card or
12 editing a work card. That card then would be presented
13 before the MRB to be voted upon, based on all the
14 information. And if it was adopted it would be then sent to
15 the FAA for approval.
16 Q Okay, thank you. Try to rephrase this a little
17 bit. What about changes to the maintenance program itself?
18 Maintenance manuals? Illustrated parts catalog, et cetera?
19 Wouldn't that reside within the tech ... group?
20 A Yes.
21 Q Which falls under engineering?
22 A Yes, sir, it did.
23 Q So there would be some type of cognizant
24 authority over the programs that were put forth?
25 A Yes.
Executive Court Reporters
(301) 565-0064
437
1 Q Alright, thank you. Would it be appropriate to
2 say that as the director of engineering, you were
3 responsible for initiating engineering changes as necessary,
4 to insure the continued airworthiness of Emery's fleet of
5 DC-8 aircraft?
6 A Yes.
7 Q Could you briefly describe your involvement with
8 this accident investigation?
9 A The night of the accident I was called at home at
10 around midnight. I --
11 Q Not quite that much detail, sorry. Which group
12 you were a member of and major functions you performed to
13 date?
14 A Member of the group's going to be a little
15 difficult. I started out with you, as you know, and I
16 believe that group was called the systems instructors group.
17 Q Air worthiness group.
18 A Okay, if it's all under the air worthiness group.
19 That's the group I've been with since the day of the
20 accident.
21 Q Okay, but initially you supported on scene
22 activities?
23 A Yes, I did.
24 Q And then approximately a year later, when we
25 reconvened the air worthiness group, you were present in ...
Executive Court Reporters
(301) 565-0064
438
1 A Yes, I was.
2 Q And follow up testing at Emery.
3 A I was not there for the follow up testing at
4 Emery.
5 Q Okay. My error there, thanks. Could you please
6 identify when you left Emery and why you decided to leave
7 the company?
8 A I left in June of 2000 to pursue an opportunity
9 to work and build a start up airline.
10 Q When were you rehired by Emery? And in what
11 capacity do you now serve the company?
12 A I serve the company -- I'm basically being
13 retained to help with different projects within Emery.
14 Throughout the course of this, because they wanted
15 continuity with the accident investigation, I was brought in
16 several times when there were events taking place regarding
17 the investigation, to assist and to maintain that sense of
18 continuity.
19 Q Okay, thank you. I'd like to shift my focus now
20 to the D-check that was performed at Tennessee Technical
21 Services, and in doing so discuss several of the issues
22 pertaining to the maintenance instructions provided by
23 Emery.
24 Mr. Robbins, was it standard practice at Emery
25 for engineering to write simple or generic work procedures
Executive Court Reporters
(301) 565-0064
439
1 that referred maintenance personnel to the applicable
2 maintenance manual for the detailed work scope?
3 A You're asking about the format of the work cards?
4 Q Yes, essentially.
5 A That was the -- that was the format -- that --
6 I'm not sure if I -- could you restate the question?
7 Q Was it essentially a standard practice at Emery
8 for engineering to write simpler, generic procedures that
9 would refer the mechanic or maintenance personnel to the
10 specific or appropriate maintenance manual?
11 A I don't think there was an effort to write
12 generic cards. I think there was an effort to give as much
13 detail on the cards as possible, given the diversity of the
14 fleet.
15 Q Okay, thank you. Can you describe how
16 maintenance personnel at Emery or its various repair
17 facilities were expected to determine the applicable or
18 effective maintenance manual or illustrated parts catalog
19 reference to be utilized when performing maintenance and/or
20 inspection tasks in accordance with Emery's maintenance
21 program?
22 A Sure. The process is very simple in practice.
23 There's two methods to begin with on identifying what
24 aircraft you have by serial number. Emery produced an
25 aircraft directory which showed the aircraft tail number,
Executive Court Reporters
(301) 565-0064
440
1 and all the associated other numbers -- fuselage number,
2 manufacture date, original operator, different codes for
3 IPC. That sheet was distributed widely and published --
4 updated whenever necessary, whenever an aircraft came on or
5 left certificate.
6 In that case, you could just pick up the serial
7 number off of that -- off of that directory. If that's not
8 available, say it was stuck out on the line somewhere, on
9 the aircraft cabin entry door there was a placard that would
10 give the serial number. That serial number -- you just need
11 that serial number, you go to the front of the maintenance
12 manual and in that introduction to the maintenance manual,
13 there is a list of the serial numbers. Adjacent to the
14 serial numbers is the applicable code -- this is a general
15 description of it -- I would have to walk through it -- but
16 that serial number is associated with a code in the case of
17 a maintenance manual, code 1, code 2.
18 Once you've established what the code is,
19 anywhere in the maintenance manual that you go, as long as
20 you stay within the confines of that manual, that code is
21 applicable for that aircraft.
22 Q In other words, if you did not have the proper
23 maintenance manual in hand at that time, in search of a
24 particular serial number that should be contained in that
25 manual, would you be able to -- you would not be able to
Executive Court Reporters
(301) 565-0064
441
1 find the applicable instruction for that aircraft, is that
2 correct?
3 A If the --
4 Q Let me try to rephrase that here. I think I
5 understood your response. What i'm saying is how would you
6 determine or how would maintenance personnel determine which
7 manual they need to refer to in order that they determine
8 the proper code effectivity, and therefore proper chapters?
9 A Well, in the course of this hearing there's been
10 a lot of talk about Emery's manuals, United's manuals,
11 Douglas manuals, and I'd like to, if I can, try to clear up
12 that premise first and maybe help people understand.
13 Q Sure.
14 A The Emery manuals are all the manuals that Emery
15 uses. Okay? Within that set of Emery manuals, there are
16 various manuals in there. One of the manuals that is in
17 there is the original -- I shouldn't say the original, but
18 the published Douglas maintenance manuals. That would be
19 one of the documents that you could go to, and in fact, if
20 you had virtually any of the aircraft, their tail numbers --
21 excuse me, their serial numbers would be listed in that
22 document. Does that answer your question?
23 Q So essentially you're saying a maintenance person
24 could refer to a -- the master maintenance manual for the
25 DC-8 fleet, and therefore determine within Emery's fleet,
Executive Court Reporters
(301) 565-0064
442
1 which particular maintenance manual they should refer to.
2 A As a starting point, yes, and depending on what
3 that maintenance activity or action was that you
4 specifically were looking for, that would be your starting
5 point. Yes.
6 Q Okay, thank you. In your opinion, as the former
7 director of engineering, when would it be appropriate for
8 maintenance personnel to refer to the master Douglas DC-8
9 maintenance manual or illustrated parts catalog, assuming
10 that the respective manual from the previous operator is
11 available and effective for that aircraft?
12 A It's a judgement call, but let me say this about
13 that comment. In the Douglas master maintenance manual, if
14 you follow the proper code and you get to a maintenance
15 activity, or let's say the maintenance action or activity
16 that you're looking for isn't in there, then you would have
17 to go to the previous operator's manual, and I'd like to
18 give you a brief description, or scenario if I could?
19 Q Sure.
20 A When Douglas built the aircraft, there is a post-
21 production or excuse me -- pre-production options are
22 installed in the aircraft. So as the airplane comes out of
23 Douglas, that aircraft has certain systems on it that may or
24 may not be relative to another aircraft. All those changes
25 are put into the Douglas maintenance manual, and there's a
Executive Court Reporters
(301) 565-0064
443
1 code assigned, and you find that code, just the way I
2 described before.
3 After the aircraft departs the factory, it goes
4 to the initial operator, they may or may not modify the
5 aircraft further. In most cases, these aircraft were
6 modified by the initial operator, and in that course, some
7 of the operators elected to update Douglas with the
8 information so that that manual was current. There was no
9 requirement to do that, but some of them elected to devise
10 and build their own in-house manual. Okay?
11 So once again -- I'll go back and answer your
12 question again, I go to the maintenance manual, I'm looking
13 for a specific maintenance activity, but I can't find one
14 that matches my aircraft in the master. Okay? I have no
15 option. I have to go to the previous operator. That's one
16 way of doing it. That's a fairly simple -- at least I hope
17 it's a fairly simple operation.
18 Q Let me try to rephrase my question. Maybe I
19 asked it incorrectly. Let's say you're working on a
20 particular aircraft, looking for a particular procedure.
21 Let's say you wanted to do some troubleshooting, say,
22 ailerons. And the particular chapter from that previous
23 operator -- it's a previous operator's aircraft -- did not
24 have a specific chapter related to that maintenance. Would
25 it be appropriate to go to a different -- the master
Executive Court Reporters
(301) 565-0064
444
1 maintenance manual? Or where else for technical data for
2 that troubleshooting?
3 A It's possible to do that, yes.
4 Q Would you be concerned if maintenance or
5 inspection personnel utilized the original equipment
6 manufacturer's maintenance manual in lieu of the maintenance
7 manual effective for that particular aircraft or system?
8 A No, if, in my opinion, in my experience with the
9 aircraft, if the -- most of the changes that I'm describing
10 are differences in aircraft or avionics related, there's
11 very, very few changes to the mechanical operation of the
12 aircraft. That's significant because in the avionics world,
13 I could go to a chapter in a maintenance manual and see that
14 the part doesn't even exist in the aircraft. My original
15 operator's manual will have that equipment. In a mechanical
16 sense, there's virtually no differences in these aircraft.
17 There may be some differences in the way you adjust certain
18 things, given -- I think we've talked about the United
19 versus the Douglas -- but to answer your question, would it
20 bother me? You'd have to give me a particular instance.
21 Q You just mentioned a moment ago that Emery
22 Worldwide Airlines operated a fairly diverse fleet with
23 aircraft, talking DC-8s dating back 40 years since
24 production, operated by not one or two, but probably several
25 various operators each. How do you know, as the director of
Executive Court Reporters
(301) 565-0064
445
1 engineering, or how do you expect maintenance or inspection
2 personnel to realize or recognize that a particular aircraft
3 may not have been modified in certain areas of maintenance
4 and therefore, that they are utilizing the proper
5 procedures? What if there had been maintenance that ...
6 reamed bushings for flight controls, et cetera, that might
7 have been improved or added to that maintenance manual? If
8 your maintenance personnel do not look into those manuals
9 and refer to a generic one not applicable to that aircraft,
10 wouldn't you be concerned for that?
11 A Well, if you were revising the manuals for
12 certain things like what you're talking about, the -- much
13 in the same way Tennessee Tech handled their revisions,
14 there's a circle around the chapter that's affected with a
15 revision. So there's -- it's a fairly straight forward
16 process, and maybe I'm not doing it justice, but the
17 possibilities of getting any wrong procedure, based on a
18 change in the case of these manuals, is very, very slim.l
19 Q I think the other point of my question would be
20 that in your response you indicated that you wouldn't be
21 concerned, at least outside the areas of avionics, because
22 you feel these aircraft are fairly similar.
23 A What I hope I left you with is that given the
24 specific topic, I'm ont overly concerned about it, but give
25 me a specific topic and I would like to address that
Executive Court Reporters
(301) 565-0064
446
1 individually, as to whether I would think that would be a
2 problem or not.
3 Q Okay, why don't we move on at this point here.
4 I'll try to keep that in the back of my mind while I'm
5 asking the questions here, and if I come upon a good
6 example, maybe I'll use it.
7 A Okay.
8 Q Could you explain how engineering was typically
9 informed of problems with existing work cards and/or their
10 associated maintenance procedures?
11 A You say how or?
12 Q Yes, how?
13 A Specifically, I'm not absolutely certain. I can
14 recall a couple of times when the manager of tech pubs was
15 approached by an individual, or maybe a phone call, and one
16 of the cards was questioned about its content or they wanted
17 to change to make it read better, something along those
18 lines. There was an official process which -- there was a
19 request for change document which should have been filled
20 out, and generally speaking, the people that wanted the
21 changes either didn't feel that they were -- it was that
22 necessary or didn't want to take the time to fill out the
23 form, but very few of those changes came through that
24 process. But that was the official way to bring about a
25 change in the maintenance work cards.
Executive Court Reporters
(301) 565-0064
447
1 Q If that process was utilized in accordance with
2 your maintenance policy and procedures manual, wouldn't the
3 engineering department be involved in the review of those
4 requests?
5 A Sure.
6 Q Prior to the time of the accident, were you aware
7 of any problems associated with the D-check work cards
8 identified within Exhibit 7-K, 7-Kilo, i.e., work card
9 number 3103, 3502, 3504, or 06?
10 A 3502?
11 Q Yes, all exhibits within Exhibit 7-K. 3103,
12 excuse me.
13 A No, I'm not aware with any problems with the
14 cards themselves.
15 Q Okay. According to the revision date block
16 identified on each of the work cards noted, these
17 maintenance procedures had not been revised since 1992,
18 therefore would it be fair to state that Emery was not aware
19 of any problems associated with these D-check procedures
20 since the time of the latest revision?
21 A The D-check cards are -- the D-checks are very --
22 very spaced out on these aircraft, and they don't get used
23 very often. That would be an indication of why the revision
24 date is from '92, which is a fairly long time ago.
25 Q Are you implying that for D-checks -- basically
Executive Court Reporters
(301) 565-0064
448
1 just let me ask a question. How often would you review the
2 work packages for, say, a D-check?
3 A If during the course of gathering reliability
4 data we felt that something needed to be addressed in the D-
5 check, it would be taken care of at that point or be
6 addressed or looked at in the D-check work cards or by
7 request for revision or request for change on the cards,
8 would be the times that we would look at it. Otherwise, and
9 as I said, the time frame between D-checks is fairly
10 lengthy, and therefore they don't get a lot of exercise.
11 And that same point, when an issue is brought before
12 reliability as a chronic problem, a D-check is not usually -
13 - at least in my experience, it's not really the best place
14 to attack a problem because it is so far out that it would
15 take you a long time to get the fleet changed or fixed or
16 modified or whatever would take place.
17 Q So what would be your philosophy on handling
18 problems that might arise when the aircraft comes in the D-
19 check? Are you suggesting that you would just wait until
20 the problem arises and deals with it as it comes up?
21 A I'm saying that the work cards were approved and
22 they were working documents. I was not aware, and I was not
23 informed of any problems or request for changes on these
24 cards by any party.
25 Q Okay, thank you. Could you please explain how
Executive Court Reporters
(301) 565-0064
449
1 engineering would track nonroutine maintenance items that
2 originated due to findings noted during the performance of
3 scheduled maintenance or inspection tasks?
4 A Reliability based its data off of pilot reports,
5 maintenance reports. In the case of nonroutines, there
6 would be maintenance items were tracked as a separate set
7 because there were -- a lot of the nonroutines are -- I'll
8 say cosmetic, or possibly cosmetic, or ball mat, trays --
9 roller trays, those type of problems are logged on
10 nonroutines. It's not something typically that would get
11 the attention of reliability to change a -- make a change in
12 a program to correct. So those items were tracked a little
13 bit differently than the pilot reports.
14 Q Okay, thank you. Could you explain why
15 nonroutine maintenance items identified during scheduled
16 maintenance were not recorded or entered on the applicable
17 work card that prompted the initial maintenance inspection
18 activity?
19 A Could you say that again, please?
20 Q Yes. Could you explain why nonroutine
21 maintenance items that would arise, or that identified
22 during scheduled maintenance were not recorded, i.e.,
23 entered - basically linked to the applicable work card that
24 prompted the initial maintenance or inspection task?
25 A Why they're not entered on the log page?
Executive Court Reporters
(301) 565-0064
450
1 Q Right. If you have a work card, for example, and
2 I'll just reference the same Exhibit since it should still
3 be out, Exhibit 7-K, the first card, doesn't matter, any
4 page, the work cards themselves have no block to enter any
5 nonroutine or any discrepancies noted during this
6 inspection, or maintenance activity. And I was just asking
7 why.
8 A Are you -- is this two questions? Are you asking
9 me why it's not put in the log book, or are you asking me
10 why the cards don't reflect a nonroutine?
11 Q No, I'm just asking if you can explain why the
12 nonroutines that are written during an inspection or
13 maintenance task, are not linked to the original work card
14 that led to that finding?
15 A Well, in the case of the C's and D checks, I
16 believe they are, by task. In the lower checks, the B-
17 checks, particularly, there's --
18 Q Please refer to Exhibit 7-K.
19 A Yes.
20 Q Page one, pick any page. Is there any block on
21 that particular work card that you're looking at -- I'm
22 looking at card 3103 -- for maintenance or inspection
23 personnel to enter any such nonroutines for any
24 discrepancies noted during this task?
25 A No, the nonroutine is linked to the card, not the
Executive Court Reporters
(301) 565-0064
451
1 card linked to the nonroutine.
2 Q Okay. Now, I'm asking, can you explain why?
3 A No, I cannot.
4 Q Do you think it would be beneficial, if you were
5 doing extensive maintenance and during a D-check, let's say
6 modifications to the nose structure, where you have cards or
7 procedures, work orders that engineering had put together --
8 A Those would be treated differently.
9 Q Okay.
10 A Those are generated off of routine inspections.
11 The nonroutines, specifically with regards to Exhibit 7-K,
12 would be corroded rivets, missing glare shield trim -- those
13 type of items -- paint missing -- those kinds of things
14 would be picked up -- I'm not specifically targeting these,
15 but those are the types of items that you would see coming
16 out of a nonroutine generated from a routine work card.
17 Modifications to the aircraft -- those are treated entirely
18 different. Those are documented. They're not even -- they
19 would never have a nonroutine -- to my knowledge, they
20 wouldn't have a nonroutine associated with them, unless it
21 was some side work or the facility that was doing the
22 modification required a nonroutine in order to do the job.
23 Q Is there a link between the nonroutines and the
24 work cards that originated that finding anywhere else, since
25 it's not on the work card?
Executive Court Reporters
(301) 565-0064
452
1 A It's -- it's on the nonroutine that goes back to
2 the work card.
3 Q So essentially you're stating on the nonroutine
4 there's a reference back to the particular inspection task,
5 i.e., work card?
6 A I believe so, yes.
7 Q Okay, thank you. Please refer once again to the
8 D-check work cards identified within Exhibit 7-K. Could you
9 explain the rationale behind the note found on each of the
10 work cards, i.e., "Use applicable DC-8 maintenance manual,
11 chapter 27, when performing this card."
12 A The rationale behind that?
13 Q Yes.
14 A As we were talking earlier about the coding
15 system in the Douglas maintenance manual, and once again
16 I'll refer to the diversity of the fleet, that Chapter 27 is
17 -- that's the ATA spec 27, main flight controls, will get
18 you to a section in the maintenance manual. Within that
19 section, given different codes -- Flying Tigers, United,
20 SAS, KLM -- those different effectivity codes -- this
21 particular task that's listed on this card may be 2730-7.
22 It might be 2730-4. Rather than try to -- and this gets to
23 the question I answered about the generic nature of the
24 statement -- in order to research the entire fleet -- and
25 remember the fleet changes -- these cards would be nearly
Executive Court Reporters
(301) 565-0064
453
1 impossible to maintain, and the main reason is because of
2 the lengthy approval process to get them through the FAA if
3 you make even an editorial change, that card goes through
4 the FAA for them to look at.
5 Q Therefore, in your opinion, would it be standard
6 practice for engineering to utilize this type of generic
7 reference?
8 A Again, I don't think there's a conscious effort
9 to be generic. It's --
10 Q Well, let me rephrase this. Let's say you have
11 an inspection card or work card, let's pick one of these out
12 of seven -- let's say work card, on page three, work card
13 number 3504.
14 A Okay.
15 Q Looks to be a total of 12 line items or tasks on
16 this specific procedure.
17 A I think there's ten, but go ahead.
18 Q It carries over onto page four.
19 A Oh. Okay.
20 Q The title of the card, "Install right elevator
21 assembly". Recorded check date, November 4, 1999 -- and
22 we're going to get into this a little bit further detail a
23 little bit later here, but in essence this card was opened
24 two, three weeks. A lot of different people could be
25 working on this -- personnel at different times, different
Executive Court Reporters
(301) 565-0064
454
1 shifts. Is it very effective, economically, for Emery to
2 require the maintenance personnel -- everybody who touches
3 this card, to do the research that you just identified?
4 Wouldn't it be better for engineering to specify the
5 appropriate procedures to be utilized?
6 A Now, as I said, when that aircraft would in this
7 case, go into heavy maintenance, the code that's used for
8 that aircraft would remain constant throughout the check.
9 And this work card is basically a work step card, and as the
10 mechanic, in this case, in the heavy check facility,
11 accomplished this task, the design of the card is to use, in
12 a kind of a broad sense, and use number two, "Hoist overhaul
13 elevator into position. Install eyeball -- and I can't make
14 out the rest of it, but that's a step that's defined maybe
15 in more detail in the maintenance manual. The reason why
16 this has got a step that is brought out to a signator or
17 signing block is so that Emery can be assured that the step
18 was accomplished as it's listed in this work card.
19 Q Let me try to be a little more specific here.
20 The question is not accounting for the various steps in any
21 given particular card. My concern, question, would be more
22 related to ensuring that maintenance inspection personnel,
23 when conducting a certain task or work card, are utilizing
24 the proper procedures that identify the correct installation
25 process for that particular effectivity, whether or not it's
Executive Court Reporters
(301) 565-0064
455
1 different from serial number 1, 2, 3, et cetera.
2 A You're asking -- if I get your question right,
3 you're asking whether or not this is an effective card in
4 order to insure that the maintenance facility is using the
5 proper effectivity?
6 Q No, sir, I'm not. I'm asking how engineering can
7 insure that maintenance or inspection personnel source the
8 appropriate maintenance manual, utilizing or referring to a
9 reference such as that listed on this work card or any of
10 these work cards. How can you be assured, in engineering,
11 that maintenance or inspection personnel go to the correct
12 manual?
13 A Well, based on my experience as a mechanic on
14 these aircraft, the process that you use to select the
15 proper manuals steers you in the right direction. It's a --
16 as I said, it's a fairly simple process. It's about the
17 same as going to the auto parts store and picking up
18 replacement headlight for your car. You could be in the
19 wrong aisle that sells fan belts, but you go to the aisle
20 where it says lights, and that's kind of chapter 27. What
21 type of light do you have is going to be given to you by a
22 number. That would be the code. I mean it's a fairly
23 straight forward process.
24 Q I would agree, and the question is not based upon
25 the lack of understanding from the Safety Board's
Executive Court Reporters
(301) 565-0064
456
1 perspective, but more based upon the assurance that the
2 maintenance or inspection personnel that are doing work in
3 association with this card, or any other card, actually
4 source and utilize the appropriate maintenance manual?
5 A I -- I'm going to have to say i don't know.
6 Q Was it standard practice for the engineering
7 department to include supplemental instructions on work
8 cards, i.e., the information that was important to the
9 maintenance or inspections to be performed, however, that
10 did not exist within the applicable maintenance manual
11 reference?
12 A Can you give me a specific instance?
13 Q Hold on one second. You want a specific one with
14 an Emery work card or --
15 A I need to understand and see what you're talking
16 about -- supplemental information --
17 Q Well, let's just say generally, you're in
18 engineering today, you're engineer, structural engineer
19 assembled a work card for an upcoming D check where you want
20 to inspect a ... elevator assembly. Let's say this is
21 related to the CPC program -- it doesn't really matter. And
22 in that card you identify, you know, in line with these
23 various work cards within Exhibit 7-K, a standard reference
24 to utilize the appropriate maintenance manual. And let's
25 say that for the purposes of this scenario that the
Executive Court Reporters
(301) 565-0064
457
1 inspection that you want is a very thorough inspection,
2 string D check, you actually want to require that
3 maintenance remove the elevator for example, let's say
4 disassemble the leading edge, look for corrosion.
5 On the work card itself you might have a generic
6 reference such as these in Exhibit 7-K, saying use the
7 applicable maintenance manual.
8 A Can I stop you at this point?
9 Q Sure.
10 A And can we use a different scenario than CPCP
11 because that -- you're getting into --
12 Q Forget I mentioned CPCP programs. We're going to
13 use the same example, your engineer is writing a card for
14 upcoming D check to pull off an elevator, to remove the
15 leading edge, to do an inspection for corrosion. The
16 applicable work card that's finally signed off by
17 engineering, by Emery, and issued for this particular work
18 to be performed includes a generic statement indicating
19 refer to the applicable maintenance manual, and therefore
20 there is no specific reference to a maintenance manual
21 reference, and generic work steps, essentially stating
22 remove elevator, disconnect leading edge, perform inspection
23 for corrosion. Reassemble. Reinstall. And that's
24 essentially the content on the work card itself.
25 Now, let's take this scenario to another step.
Executive Court Reporters
(301) 565-0064
458
1 Let's say the applicable maintenance manual is manual one.
2 Chapter 27 -- doesn't matter. For this applicable work --
3 and let's say this particular aircraft, in this particular
4 instance, we have a new mechanic, a new inspector that's
5 involved with this work card or this procedure that's
6 expected. They, for whatever reason, incorrectly identify
7 the manual that they feel they should be using, and in doing
8 so follow a procedure for removal, installation -- doesn't
9 matter, take your pick -- and they inadvertently cause
10 damage to the aircraft, injure somebody, miss an area of
11 vital inspection.
12 So once again, my question would be, not related
13 to the process of identifying what the applicable
14 maintenance manual would be for a particular serialized
15 aircraft while in D-check, C-check, B-check, doesn't
16 matter -- my question is, are you concerned from an
17 engineering standpoint that there might be individuals out
18 there that might be challenged due to work load issues,
19 might be newer personnel -- for whatever reason -- might
20 incorrectly identify the applicable maintenance procedures
21 and thereby miss something, inadvertently cause something
22 that might affect the safety of flight?
23 A The concern regarding the possible misuse or
24 incorrect use of the manual is mitigated because, in my
25 opinion, personally, that the facility that's using the
Executive Court Reporters
(301) 565-0064
459
1 maintenance manual has been certified by the FAA and has
2 been found to be competent and capable of identifying the
3 correct manuals and using the processes in those manuals to
4 perform maintenance on a given aircraft. And they are given
5 that capability, certified by the FAA to perform that
6 maintenance. I understand there may still be some gray area
7 about --
8 Q That's fine. Now let's continue the scenario
9 back to this question. We're in the same set of conditions
10 here. The initial question was, was it standard practice
11 for the engineering department to include supplemental
12 instructions on work cards, essentially for those cases
13 where the appropriate maintenance manual, let's say the
14 individual has it in hand, he's got the applicable
15 maintenance manual. But for whatever reason, this specific
16 reference is missing a vital step, or due to past
17 experience, whether it be an incident, economic reasons or
18 otherwise, engineering or that appropriate operator has to
19 determine that we need to supplement the information that's
20 in this maintenance manual, and for whatever reason they
21 have not already gone through the revision process for that
22 appropriate manual. Would engineering at Emery, include the
23 necessary supplemental information on that specific work
24 card? Is that a standard practice?
25 A In my experience, we had a form called a request
Executive Court Reporters
(301) 565-0064
460
1 for technical services for the engineering department. And
2 I hope I'm answering your question, but in that form,
3 anybody --
4 Q Let me -- I hate to interrupt but we're to stay
5 on topic here. We've already gone through that at this
6 point here.
7 A But this is a different process, this is just a -
8 - this is just identification of a problem, and I don't care
9 where it was -- a problem on a line, problem with heavy
10 check, problem with the type of information needed,
11 clarification from a technical standpoint -- that request
12 for technical services would come to engineering and we
13 would resolve it internally, and I'm not aware of that
14 process being used in this context. In other words, I'm
15 saying I've never seen, to my knowledge, I've never had that
16 happen to me.
17 Q Okay, so process aside, what I was really asking
18 about is if engineering had already made the determination -
19 - I didn't care about the process -- but had made the
20 determination, had recognized that a particular procedure
21 that the company knew was going to be an upcoming procedure
22 or maintenance task, inspection, and you had an existing
23 work card -- so in other words, somebody has made a request
24 at some point, now it's up to engineering at this point, and
25 now this aircraft is scheduled in for D-check next week.
Executive Court Reporters
(301) 565-0064
461
1 Would you ever include that type of supplemental information
2 on the work card itself, such that maintenance or inspection
3 personnel would be apprised of the additional cautionary
4 information they require?
5 A Given the specifics that you've given me, such as
6 what's going in the check next week, it would be impossible
7 to adapt that into a work card in that time frame, because
8 of the approval process. Now it may be part -- and I'm only
9 speculating based on what I'm understanding you to say, but
10 there's a work scope sheet that goes with the aircraft that
11 is in some cases it's revised as the check progresses and
12 possibly that avenue may be taken. I'm not -- and if you're
13 asking whether I knew or whether engineering knew if there
14 was a problem with the card would we address it before it
15 went out, the answer to that question is yes, given time and
16 authority and the MRB voted on that change, yes, absolutely.
17 Q Just keep in mind this example is just off the
18 top of my head, so a week time frame is --
19 A Well, -- okay, that's why I needed specifics.
20 Q Let me follow onto a comment to your response,
21 then. Let's say you are pressed for time and due to the
22 cumbersome revision process for your program at Emery, we
23 still have the same aircraft coming in, scheduled for a D-
24 check, and you recognized at the engineering level or the
25 maintenance level that there was a discrepancy in the
Executive Court Reporters
(301) 565-0064
462
1 program -- in a card -- in a reference, and wanted to get
2 out this additional necessary information to maintenance or
3 inspection personnel. How would you do that?
4 A If it was brought to my attention like that that
5 there was a deficiency in the cards, I knew there was a
6 problem or there would be a problem, I would expedite a
7 change to the card, hand walk it through the MRB and in the
8 case of -- when the certificate moved to Cincinnati, I would
9 if I had to, drive to Cincinnati, meet with the PMI, express
10 the concern about expediting the card and the approval
11 process and bring it back to prevent any damage or any
12 problems to the aircraft.
13 Q Alright, thank you. Let's refer back to Exhibit
14 7-K once again. Parties keep these out --
15 A I never left it.
16 Q And let's take a look at D-check work card number
17 3103, it should be page one, lower right hand corner. The
18 card is titled, "Remove the right hand elevator and tabs."
19 Could you please read the check date noted on the work card?
20 A Check date was September 7, 1999.
21 Q Would you expect the date entered on this work
22 card to accurately reflect when each of the work steps
23 associated with this work card were actually accomplished?
24 A I'm not sure. I'm not sure what prompts the date
25 to be put on the card, whether it's when it goes into work,
Executive Court Reporters
(301) 565-0064
463
1 out of work, some time in between. I really couldn't answer
2 on that.
3 Q I guess essentially what I'm asking is this
4 particular card only has three items, it's a pretty easy
5 card. We have a final check date -- I'm assuming this is
6 the date that this card is signed off as being completed in
7 its entirety. There's really no way to tell on this card if
8 item one was performed last month, item two last week and
9 item three today. Is that correct?
10 A That is correct.
11 Q Do you have any concerns regarding that from an
12 engineering standpoint? Not necessarily on this particular
13 card, but cards that might be more involved?
14 A From an engineering standpoint? Sure. The 145
15 maintenance facility is hired to basically manage the
16 process and to insure certain quality is built into the
17 product. In the management of that process, this is a tool
18 for Emery to use to insure that all steps were complied
19 with. The management of that process, whether step one was
20 done last week and step two was done this week -- as long as
21 the steps were accomplished, and they were accomplished in
22 accordance with the applicable maintenance manual, I don't
23 necessarily have a problem unless there's some expiration
24 dates, or there's some work conflict that happens with the
25 check. I don't specifically have a concern about the
Executive Court Reporters
(301) 565-0064
464
1 timing.
2 Q How can you be assured that there is no work
3 conflict with an extended card, say a procedure that's open
4 three, four weeks?
5 A I have had, in the course of some C-checks, prior
6 to the engineering department, the maintenance reps on site,
7 they would kind of initiate a process to say, you know,
8 these two things -- you shouldn't have these two together.
9 If there was a problem with the flow of the work via the
10 work cards, or if a facility was having a hard time
11 accomplishing the work cards because of the way that they
12 were ordered or written, or distributed -- anything of that
13 nature, that would come back through the maintenance reps.
14 We would try to identify -- and again, this did not happen
15 since I was he director of engineering, but I have been
16 witness to the process. They would come back, there would
17 be some dialogue between the heavy maintenance provider,
18 Emery's heavy maintenance group, and tech pubs to decide
19 what can be done about managing the process better, either
20 by changing the cards or by some other fashion.
21 Q Okay. During previous testimony, Mr. Hall
22 described steps that Tennessee Technical Services have taken
23 in the past to insure that their maintenance personnel
24 performed an adequate turnover of maintenance activities
25 that extend beyond one work shift. I think this pertains
Executive Court Reporters
(301) 565-0064
465
1 directly to this discussion here and the subject at hand.
2 Can you explain how Emery's maintenance program meets the
3 manual requirements of Federal Aviation Part 121.369?
4 A Is that an Exhibit?
5 Q Subpart B, step 9. Yes, that would be an Exhibit
6 7-T. I'll give you a couple minutes to find that.
7 A You say 7-Tango?
8 Q Yes, and I plan on reading the appropriate
9 section here. 7-Tango, pages six and seven.
10 A Okay, found it.
11 Q Six and seven.
12 A Pages six and seven?
13 Q Right. 121.369, subpart B, step 9. My question
14 being, can you explain how Emery's maintenance program meets
15 the manual requirements of this particular FAR, specifically
16 that the certificate holder's manual contain the procedures
17 to insure that required inspections, other maintenance,
18 preventive maintenance or alterations that are not completed
19 as a result of shift changes or similar work interruptions
20 are properly completed before the aircraft is returned to
21 service? In other words, once again we're referring to a
22 card that might be opened, detailed work package might be
23 open -- for two months if it's in D-check.
24 A Right. Prior to selecting any heavy maintenance
25 provider, there's an audit conducted on that facility. The
Executive Court Reporters
(301) 565-0064
466
1 audit is there to insure that they comply with all the
2 applicable regs -- and I'm stepping outside of my area of
3 expertise, but I know that I have seen -- I've seen the
4 audit paperwork. I know that some of these things in here
5 are addressed as to whether they're satisfactory or
6 unsatisfactory procedure at the facility. I'll have to
7 refer -- I don't have the document in front of me --
8 Q Well, I'm really more interested in just your
9 concern from an engineering standpoint, as the director of
10 engineering. Essentially Mr. Hall, yesterday, testified
11 that, if I recall correctly, TTS put in place a system, for
12 whatever reason, and keep in mind they are working to
13 Emery's Part 121 maintenance program, but for whatever
14 reason, felt it necessary to supplement that program with
15 in-house instructions whereby, for those types of cards in
16 this instance, where there would be shift changeovers, they
17 would attach maintenance manual procedures et cetera, and
18 stamp off each individual step, et cetera.
19 Obviously, that amount of detail is not in any of
20 these work cards that we're talking about that we're
21 concerned with today, and I'm just -- I'm just curious. The
22 question once again would be, how can Emery insure that a
23 repair station, TTS or otherwise, actually fulfills the
24 entire intent to the scope of a particular maintenance
25 action or inspection, especially one that is so drawn out
Executive Court Reporters
(301) 565-0064
467
1 that might be open two, three, four weeks?
2 A That's the job of the card, I would agree.
3 Q Let's move on.
4 A Okay.
5 Q Please refer to Exhibit 7-K again, pages three,
6 four and five. Once again we're talking about work cards
7 number 3504, top right hand corner on page three and four,
8 and work card number 3506 on the bottom of the page.
9 Wouldn't you agree that based upon the completion dates
10 recorded on these cards, and the fact that the cards are
11 worked in conjunction with one another, that work card 3504
12 remained open for more than two weeks?
13 A In conjunction -- you're saying that both these
14 cards were worked in conjunction with each other?
15 Q Yes, if you refer to page six --
16 A Yes, I see that.
17 Q Okay.
18 A And you're asking?
19 Q Essentially to confirm that the work that was
20 initiated on work card 3504 was initiated at some point on
21 or before November 4, 1999, but was not completed until
22 November 4, 1999. Excuse me, the first date should have
23 been October 14, '99, and was not completed until November
24 4, 1999.
25 A Again, I have to say that I don't know Tennessee
Executive Court Reporters
(301) 565-0064
468
1 Tech's procedures on what initiates someone to put a date in
2 that block, so I have no idea of the activity behind these
3 two cards marrying up.
4 Q Keep in mind, the questions I'm asking are from
5 an engineering standpoint, and I, myself, as an engineer,
6 I'm more interested in the procedure here, the mechanics of
7 the system here. What you're indicating here is, and I
8 realize that we haven't stopped, and if necessary we can so
9 you can read through these two cards and think about this
10 for a minute, but I'd have to say that I know myself,
11 Captain McGill, first couple times we went through these
12 cards, it is quite confusing to see when you first key in on
13 these approval dates, how, when you're performing work card
14 3504, which is installation of the right elevator assembly
15 procedures, and then refer to 3506, functionally check the
16 right elevator and tab, something which must happen after
17 the elevators are obviously installed, how then the
18 completion date on that work card can be at an earlier date?
19 And I know the answer at this point, so I'm not asking for
20 that.
21 A You're asking if it's a concern -- an engineering
22 concern?
23 Q Essentially that's where I was going, but
24 initially the question was, essentially by looking at these
25 two dates and realizing that they're worked in conjunction,
Executive Court Reporters
(301) 565-0064
469
1 realizing the work scope that a) you have to install these
2 elevators before you can do a functional check, check ... et
3 cetera, that yes, this work card 3504 had to have been open
4 for two and a half weeks or more. And then leading up to
5 your response, yes, would you as the director of
6 engineering, be concerned that you don't have an appropriate
7 turnover process or something in place?
8 A I would have to review Tennessee Tech's specific
9 turnover process to see if it was a concern. Engineering
10 typically does not get involved with the auditing process.
11 Once the cards are --
12 Q Excuse me. I'm not asking about an auditing
13 process. I'm talking from an engineering standpoint, now.
14 Engineering at Emery has developed these cards --
15 A Right.
16 Q -- but we're not talking about TTS or any other
17 vendor's turnover policy or in house procedures,
18 supplemental or otherwise, to the operator's 121 maintenance
19 program. I'm only discussing, and really only require
20 responses to the work cards from Emery, and Emery's
21 perspective pertaining to the content of these work cards.
22 Are you concerned, from an engineering standpoint, for those
23 maintenance items, inspection or otherwise, for which cards
24 are open for extended periods that that maintenance may or
25 may not -- essentially that maintenance might be missed due
Executive Court Reporters
(301) 565-0064
470
1 to the signoffs on these cards.
2 A If they follow the applicable maintenance manual
3 in its entirety, there should be no problems with these
4 cards.
5 Q Would you agree that would only be the case if
6 the work card itself is adequate --
7 A No --
8 Q Could you explain your reasons why?
9 A The work card is not meant to be the document
10 used to perform the maintenance. It's a direction to the
11 applicable maintenance manual. The work card is used to --
12 for Emery to document that the steps listed were performed.
13 Q Once again, this gets back a few minutes ago to
14 the discussion about supplemental instructions. I think you
15 would have to admit that any of us working in the aviation
16 have stumbled across, whether we specialize in avionics
17 systems, structures, power plants -- doesn't matter, the
18 maintenance manual is not infallible, neither is the
19 illustrated parts catalog. Member Goglia mentioned that
20 earlier. I don't think I've ever picked up an illustrated
21 parts catalog and not been able to find a mistake on the
22 page I'm looking at.
23 If the work cards merely refer to a maintenance
24 procedure, and as you previously indicated, there's a
25 lengthy period, still undefined, between the review of these
Executive Court Reporters
(301) 565-0064
471
1 D-check packages, which would include not only the scope of
2 the specific verbiage included within the work card itself,
3 but also that of the applicable maintenance manuals or other
4 technical data, how can you be assured that maintenance or
5 inspection personnel are going to perform the task properly?
6 Even if they have the appropriate manuals, how are you going
7 to be assured, when the cards are open this long, that
8 they've step by step completed the appropriate tasks, that
9 they haven't missed a bolt, or a safety, or a security?
10 A The only answer I can give you is to witness it
11 myself step by step, that's it. That's the only way I can
12 be absolutely certain that every step is accomplished is to
13 witness it myself. Outside of that, I -- I'm -- and maybe
14 I'm missing your point, but I don't understand -- these are
15 steps, this is what the cards are designed, straight out of
16 the parent document, which is the Douglas tech, that's used
17 to validate these steps were taken.
18 And I realize there are errors in the maintenance
19 manual and the IPC and the wiring diagrams and -- there's
20 errors, there are typos, there's issues with every
21 maintenance manual I've ever seen. They're human errors.
22 If I was to try to duplicate that process on this card, I'm
23 just as likely to introduce the same human errors or
24 different ones.
25 Q Wouldn't you agree that one of the roles of
Executive Court Reporters
(301) 565-0064
472
1 engineering would be to ... mitigate the number of human
2 errors that are out there --
3 A Yes.
4 Q -- and therefore being very specific? Alright,
5 thank you. I got a little bit off track here, but, could
6 you refer back to line item two on the same card?
7 A Card 3504, item two.
8 Q Actually, I'm not sure if I'm not a little bit
9 out of sequence here or not here. Let's just back up here.
10 Refer to card 3103, so it's page one. Could you please read
11 line item two?
12 A "Remove right hand elevator control tab. Bag and
13 attach all parts to tab."
14 Q Okay, thank you. Could you also confirm that the
15 two remaining steps on this work card, i.e., line items one
16 and three, include similar instructions regarding the
17 retention of hardware during the removal of the right hand
18 elevator and gear tab?
19 A Yes.
20 Q Okay, thank you. According to the records
21 associated with the accident aircraft on September 9, 1999,
22 Tennessee Technical Services performed a receipt inspection
23 of the right hand elevator that was ultimately installed on
24 November 8079 Uniform. For the record, this occurred two
25 days following the removal of the existing right hand
Executive Court Reporters
(301) 565-0064
473
1 elevator, in accordance with work card number 3103. Once
2 again, the check date assigned was 7 September 99 on work
3 card 3103. Therefore, is it safe to assume that in planning
4 for this particular D-check, Emery intended to replace the
5 elevator and tabs removed from the aircraft with overhaul
6 flight controls?
7 A I can't speak to what -- I didn't get involved
8 with the heavy maintenance planning process.
9 Q Do you happen to recall when the aircraft entered
10 the TTS facility for its D-check? Roughly?
11 A October -- I'm taking a guess, I don't know.
12 Q Can you refer back to card 3103 and look at the
13 accomplishment date for the --
14 A Okay, September, sorry.
15 Q Okay, so at least September, and departed D-check
16 November 19th. Was the engineering department aware that
17 the elevator assemblies on this aircraft were to be replaced
18 in lieu of overhaul?
19 A Specifically, no.
20 Q I guess this is essentially the same question I
21 just asked here. If not, can you explain why not? Why
22 wasn't engineering made aware of these plans so that you
23 could have included supplemental maintenance instructions on
24 the work card related to the retention of hardware and
25 disposition of the flight controls? So once again, we're
Executive Court Reporters
(301) 565-0064
474
1 referring to card 3103.
2 A And your question why the card stipulates to bag
3 all parts?
4 Q More or less. Well, essentially, to summarize
5 the trend of events, November 8079 Uniform entered TTS for
6 D-check. For whatever reason, existing elevator flight
7 controls, including tabs, both sides, would be removed and
8 would be replaced with overhaul units. Card number 3103,
9 within the Exhibit here, handles the directed maintenance
10 procedures for TTS to follow during that removal process.
11 It's fairly basic here. We've just gone through, really
12 only care about item two at this point, but all three steps
13 indicate bag and attach all parts to the elevator.
14 And therefore, my question is, since Emery, not
15 necessarily yourself, but somebody within Emery was
16 cognizant of the fact that these elevators would be
17 ultimately replaced with overhauled units, don't you think
18 it would have been appropriate to provide supplemental
19 instructions on this card or otherwise, such that TTS could
20 do something differently with these parts that had been
21 removed during the performance of card number 3103? For
22 whatever reason, the decision was that the overhauled flight
23 controls would --
24 A Well, the step tells you, "bag and attach all
25 parts to the tab" which is removed and sent out, so the
Executive Court Reporters
(301) 565-0064
475
1 parts don't exist at Tennessee Tech anymore, they would have
2 to use new parts.
3 Q Okay, thank you. We'll come back to this in a
4 minute. Please revert to the same Exhibit, page two. Work
5 card number 3502, titled "Install right elevator tabs". Can
6 you explain why there are five inspector stamps, including
7 what appears to be two stamps for step five, when the work
8 card merely requires inspections related to steps one and
9 five?
10 A No.
11 Q Based on the information recorded on this work
12 card, can you determine who was actually responsible for the
13 maintenance and inspection tasks identified? This question
14 goes beyond identifying inspector stamp or an A&P
15 certificate number, and refers specifically to those line
16 items where there are multiple stamps or signatures.
17 A No, not on this copy, no. I may be able to if I
18 really studied it, but it would be difficult.
19 Q Copy aside, assuming you had the original before
20 you now, would you be concerned from an engineering
21 standpoint if you had two inspector stamps in one block,
22 which are clearly distinct, two different individuals looked
23 at something. Why did that happen? What were the findings?
24 Did the first individual note something he was concerned
25 with that was ultimately resolved by the second?
Executive Court Reporters
(301) 565-0064
476
1 A In -- in my years as a mechanic, I have seen many
2 instances where people have used RII authority signatures
3 and inspector stamps outside the confines of what's required
4 by the procedures because they felt this was a critical
5 step, and I'll be honest with you, sometimes it's a matter
6 of just laziness that rather than go look at the proper
7 documents to see whether or not it's required, you put a
8 stamp. It's the safe thing to do. You put a stamp on
9 there. I can't tell you why this was like this. I can tell
10 you -- am I concerned about it? Does it make me concerned
11 that I had two inspectors instead of one looking at this? I
12 don't think so.
13 Q Aren't you really referring to a normal
14 maintenance task that possibly somebody has stamped off as
15 an inspector in addition to the requirement, the sole
16 requirement for the maintenance individual to sign off?
17 That's totally different than the question at hand.
18 The question would be referring to item number five, which
19 requires an inspector's stamp, and there are two inspectors
20 stamps. So my question once again would be, are you
21 concerned that there's not something else evident or that
22 transpired during the performance of this inspection,
23 "Inspector verify control and gear tab installation and
24 security."
25 A First all, this is a normal maintenance task, or
Executive Court Reporters
(301) 565-0064
477
1 whatever way you phrased it. This is a routine card, okay,
2 first. Second of all, I'm not that concerned that I had two
3 sets of eyes instead of one required. This would not cause
4 me concern except for divergence from procedures at the
5 facility, if you want to be honest about it.
6 Q That's exactly where I'm at. How can you be
7 assured, from a quality standpoint, from an engineering
8 standpoint, that we don't have a deviation here? That
9 something hasn't occurred that should have, or should have
10 that shouldn't have?
11 A Short of witnessing it myself, I cannot.
12 Q Do you not think that's part of engineering's
13 responsibility in putting together these programs?
14 A You're asking me if the result of two people
15 making a stamp on a card that clearly calls for one in the
16 development stage, if I'm concerned at the development
17 stage? I'm kind of confused, I think.
18 Q I think we all are here, but hold on. My next
19 question was going to be how do you prevent additional sign
20 offs such as these, but it doesn't appear that you're
21 concerned with that, so --
22 A I don't want to give the impression that I'm not
23 concerned. It's that I don't have any control over the
24 process unless I'm physically there. If you're going to ask
25 me if these cards are perfect, no, they're not. They are an
Executive Court Reporters
(301) 565-0064
478
1 evolution process, and I'm sure MSG-3 would provide better
2 cards. In fact, Emery was going in that direction.
3 Q Excuse me, a few minutes ago you said you didn't
4 want to get into MSG-3 and the CPCP program --
5 A Well, the reason I said that before is because
6 this MSG-2 type card does not include corrosion and SIDS
7 (ph) and things of that nature. MSG-3 does. That's why I -
8 - there's a significant change between the two, MSG-2 and
9 MSG-3, and that's -- and it wasn't that I didn't want to get
10 into it, it was that there was a -- from my perspective, it
11 was a difficult analogy to comment on.
12 Q Alright, as previously noted, work card number
13 3502, once again, page two of the same Exhibit, includes the
14 following note: "Use the applicable DC-8 maintenance manual,
15 Chapter 27". For the record, could you identify the
16 applicable maintenance manual that maintenance personnel
17 should have utilized when accomplishing this task?
18 A Can I?
19 Q Yes.
20 A Using the aircraft tail number, yes, I could.
21 Q No, today before you, here. It's one of the
22 Exhibits that's entered. You've indicated before that
23 you've been a party to the investigation. I know you've
24 been involved with the air worthiness group findings to
25 date. This is an area you should be intimately familiar
Executive Court Reporters
(301) 565-0064
479
1 with.
2 A Yes. I know which code it is, at least I'm
3 pretty sure, but --
4 Q Alright, please note for future reference for the
5 record, that DC-8 maintenance manual Chapter 27- 32-06 from
6 Exhibit 7-L is the appropriate maintenance manual procedure
7 for this tail number. Could you please refer to Exhibit 7-
8 L? Do you have the Exhibit before you now?
9 A Yes, I do.
10 Q Could you identify the revision date on the
11 bottom right corner of the applicable instructions?
12 A First page?
13 Q Yes.
14 A September 9, 1986.
15 Q Okay, thank you. Now referring back to work card
16 number 3502, could you please read step three for the
17 record?
18 A 3502?
19 Q Yes, found on page two.
20 A Card one --
21 Q There's only one card there. Card one of one.
22 It's five steps.
23 A Step two?
24 Q Please read step three.
25 A Three. "Install overhauled elevator control tab
Executive Court Reporters
(301) 565-0064
480
1 to elevator."
2 Q Okay, thank you. Can you explain how engineering
3 expected maintenance personnel to correctly identify and
4 source the parts, including hardware, required for this
5 installation, when as previously noted, work card number
6 3103 instructed maintenance personnel to bag and attach all
7 parts to those flight control surfaces that were previously
8 removed?
9 A You're asking how they were supposed to get the
10 hardware to do the installation?
11 Q That's correct.
12 A Go to the IPC.
13 Q Why would you -- or can you list off, from the
14 top of your head, what parts would be needed to -- what
15 we're talking about here -- install right elevator tabs. So
16 control tab, gear tab. Can you list -- are you familiar
17 with all the components, all the hardware that would be
18 necessary?
19 A To be quoted at it? No.
20 Q Generally?
21 A I mean there's --
22 Q Why would you expect maintenance personnel, once
23 again, for a card -- some of these cards have been opened,
24 are open for extended periods, it's not uncustomary for that
25 to be the case -- why would you expect -- why would you have
Executive Court Reporters
(301) 565-0064
481
1 an engineering department? Why would you expect maintenance
2 personnel for each individual that touches this card has to
3 work on this, has to go back to the maintenance manual, to
4 the IPC to identify what parts are necessary? What if there
5 was --
6 A It doesn't take two weeks to hang an elevator, or
7 a control tab. That process would require hardware to
8 attach it. You would have to go to the IPC to get the
9 hardware, attach the tab or the elevator at that point.
10 Now, after that happens, there could be a two week interval
11 where there's no activity because they're doing other cards.
12 That doesn't mean that every mechanic who walks by it or
13 looks at the card is going to the maintenance manual or the
14 IPC or the stores to get hardware. That's not the case.
15 Q Keep in mind, the reason we are here today, at
16 least one of the major reasons we are here today is to a
17 missing bolt. Now obviously, the Safety Board has not made
18 final determinations yet regarding probable cause for the
19 accident, however, I have to believe that everybody in this
20 room that's intimately familiar with the investigation
21 findings to date -- it's a matter of public record --
22 realize that we have a missing bolt on the right elevator
23 control tab, push rod attachment to the crank fitting for
24 elevator control tab. Wouldn't you agree that work card
25 3502 for this particular accident aircraft, which is titled
Executive Court Reporters
(301) 565-0064
482
1 "Install right elevator tabs", step three, "install
2 overhauled elevator control tab to elevator" has any bearing
3 on why we're here today? And isn't the hardware that's
4 required to install the control tabs the subject of
5 discussion? Isn't that why we're here? And therefore,
6 wouldn't the identification, proper identification of what
7 should or should not be installed, and whether or not it
8 should be safetied, be discussed here?
9 A Yes, it should.
10 Q You're essentially indicating that these parts
11 were removed, they were shipped out because the elevators
12 were shipped out. I guess I would contend, from an
13 engineering standpoint, that that would be a poor practice.
14 A Perhaps it's being shipped out so that they don't
15 use old hardware to reinstall the new elevator.
16 Q Alright, let's move on. Can you explain why the
17 work card does not indicate the required hardware to be
18 installed during this installation, and once again, I'm
19 referring specifically to work card 3502, step three,
20 "Install overhauled elevator control tabs to the elevator" -
21 - and if you know, this is for the right side only.
22 A The reason why it doesn't indicate it is because
23 this is formatted in accordance with the government's
24 original documents and MSG-2 processes.
25 Q And I'll finish your answer, based on previous
Executive Court Reporters
(301) 565-0064
483
1 testimony you've given a couple times, the work card refers
2 back to the appropriate maintenance manual procedures, is
3 that correct?
4 A Yes, it does.
5 Q Okay, thank you. I'm going to jump ahead here a
6 little bit here, and in the interest of trying to save some
7 time, but I would suggest you refer to Exhibit 7-L again,
8 and the question being since the applicable Emery
9 maintenance manual instructions, i.e., 27- 32-06, found in
10 Exhibit 7-L that was to be used during this installation did
11 not clearly identify the hardware to be utilized, can you
12 explain how the engineering department expected maintenance
13 personnel to correctly identify, install and secure the
14 necessary hardware?
15 A The lower side of that card, under C, referenced
16 procedures, it does list the illustrated parts catalog on
17 that front card.
18 Q Excuse me, can you say that again?
19 A Yes. Under two, special tools and materials,
20 there's reference procedures, C, 2a, is reference to the
21 illustrated parts catalog.
22 Q Which, if you refer to the last page of Exhibit
23 7-L is attached to this procedure?
24 A Okay.
25 Q Let me ask once again, -- let me back up I guess
Executive Court Reporters
(301) 565-0064
484
1 we're not going to save time here. Could you identify
2 anywhere within this specific Exhibit, maintenance manual
3 Chapter 27-3206, would you please identify the hardware
4 required to connect the right elevator control tab push rod
5 to control tab crank fitting attachment?
6 A All the parts?
7 Q Yes, please.
8 A I could -- you want me to analyze each part or do
9 you want me to just give you a general answer?
10 Q I thought I led this question enough. For the
11 life of me, I can't find dick in this manual.
12 A If pages six and seven don't show the required
13 parts, then it's not here.
14 Q Well, I think we need to establish this for the
15 record, so I'd ask you to take a few minutes reading with
16 you this maintenance manual procedure.
17 CHAIRMAN GOGLIA: Certainly. Why don't we take a
18 15 minute break while the witness, who doesn't get a break,
19 prepares.
20 MR. PUDWILL: Thank you, Mr. Chairman.
21 (Whereupon, a 15 minute recess off the record was
22 taken.)
23 CHAIRMAN GOGLIA: Continue.
24 MR. PUDWILL: Thank you, Mr. Chairman.
25 BY MR. PUDWILL:
Executive Court Reporters
(301) 565-0064
485
1 Q Once again, we were viewing Exhibit 7-L, which is
2 the applicable maintenance instructions that should have
3 been utilized, I'm assuming were utilized, to install the
4 right elevator control tab. Mr. Robbins, can you confirm
5 now whether or not this Exhibit, this maintenance manual
6 procedure identifies the required hardware at the pushrod
7 control tab crank fitting at the attachment?
8 A It's missing a part.
9 Q Can you be more specific?
10 A Yes, it's missing a cotter pin.
11 Q Walk me through your findings here.
12 A The nearest I can tell --
13 Q Please refer to the appropriate page.
14 A I'm on page six.
15 Q Okay, let me back and ask one question first.
16 Did you find any mention made of the hardware to be
17 installed at this location and the verbiage -- the work
18 steps leading up to the illustrated parts catalog?
19 A I wasn't asked to do that, I don't think. You
20 asked about the parts.
21 Q Well, the intent was to identify whether or not
22 the hardware required for this installation is identified
23 anywhere within this reference. The illustrated parts
24 catalog is part of this chapter, 27-3206. Let me walk you
25 through it. Let's go to page two. Specifically, step
Executive Court Reporters
(301) 565-0064
486
1 three, removal and installation. See this maintenance
2 procedure could be used for either.
3 Proceed to page three, subpart D near the bottom
4 of the page, step two. "Connect tab pushrod to tab crank
5 and secure." Do you have the same step before you?
6 A Yes, I'm there.
7 Q Do you see any mention made of hardware required
8 at this location in the verbiage on D-3?
9 A No.
10 Q At D-2, I'm sorry.
11 A D-2, no, I do not.
12 Q Okay --
13 A Except for the reference to secure, but that's
14 not a part.
15 Q Just for the record to speed this up, then, the
16 hardware required is not identified anywhere within this
17 chapter within the verbiage, the maintenance instructions
18 themselves. So therefore that leaves the illustrated parts
19 catalog. Can you walk us now through the findings that you
20 have referring to the figure on page 1001 or page six of
21 this Exhibit?
22 A Stand by one -- if you can give me just a second.
23 Q Sure.
24 A Okay, can you go to page six, you said.
25 Q Yes, sir.
Executive Court Reporters
(301) 565-0064
487
1 A Okay, I'm there.
2 Q You started to indicate that everything was
3 depicted other than the cotter pin. Can you explain what
4 you mean?
5 A Item 10 on page seven is a cotter pin. It's only
6 listed on the Exhibit page six in one place, and that's the
7 forward part of the control push rod.
8 Q Okay. But still, using this Exhibit, this
9 maintenance manual reference, this illustrated parts
10 catalog, once again, page 1001, which depicts figure 1001 of
11 this installation. Do you -- can you identify for the
12 record where the tab crank fitting is located?
13 A The lower right hand corner.
14 Q It's kind of hard to miss. It's labeled as such.
15 Can you see where the push rod attaches to this crank
16 fitting, just above that nomenclature?
17 A Yes, I can.
18 Q Can you confirm that is the bolt we are talking
19 about here today, correct?
20 A That is correct.
21 Q Is there a reference on this figure indicating
22 what hardware is required for this installation?
23 A Not on this figure, no. If I can interject a
24 bit?
25 Q The question is, can you identify anywhere on
Executive Court Reporters
(301) 565-0064
488
1 this Exhibit, on this figure or the associated parts list on
2 the next page, the hardware for this installation?
3 A If I knew what an AM 310-5 nut looked like, in
4 other words, was it castellated (ph), fiberlocked (ph), or
5 some other type of nut? If it was a castellated (ph) nut,
6 that would be a very good clue that a cotter pin was
7 required to safety, however it's not listed on figure six or
8 page six of this Exhibit.
9 Q Excuse me, can you please explain why you're
10 referring to item eight?
11 A Maybe I'm -- item eight is -- if you look on page
12 six, above where it says inboard hinge bolt --
13 Q Right.
14 A It lists items eight, seven and six.
15 Q Correct.
16 A Eight is a nut.
17 Q I would not disagree with you there.
18 A If it's a castellated (ph) nut, that would be --
19 the only reason you use a -- you only use a castellated (ph)
20 nut in conjunction with a cotter pin, but as I pointed out,
21 the figure on page six does not indicate an item 10 or
22 cotter pin to be installed.
23 Q Let's back up a little bit here. Emery's
24 engineering department issued a fleet campaign directive.
25 We have several Exhibits in here, I don't think it pays at
Executive Court Reporters
(301) 565-0064
489
1 this time to refer to the particular Exhibit, but we can if
2 necessary -- the one off the top of my head would be Exhibit
3 7-M, which is, I believe, A-27-8, "Perform a fleet-wide
4 campaign directive to inspect Emery's fleet of DC-8 aircraft
5 for proper hardware, proper installation, orientation, et
6 cetera at the -- at this installation at the control tab
7 crank fitting." Once again, we're talking about where the
8 push rod attaches to the crank fitting.
9 Item six, seven, and eight that you were
10 referring to, refer to the inboard hinge bolt, which
11 attaches -- this is the inboard hinge fitting for the
12 control tab. Item six, seven, and eight do not refer to --
13 A I see what you're saying, the push rod link.
14 Q Correct. This was identified previously through
15 the comments process, received by Emery in response to the
16 air worthiness factual report, essentially that hey, yes,
17 this procedure does identify the hardware for this location,
18 item six, seven and eight, and as pointed out at that time,
19 item six, seven, and eight, once again refer to the inboard
20 hinge bolt. So therefore, could you now confirm or would
21 you agree that this procedure, Chapter 27-3206, which is
22 referenced on work card 3502, as the applicable procedure,
23 nowhere within identifies the proper hardware to be
24 installed, orientation of that hardware, whether or not that
25 hardware should be secured, and if so, how, at this time.
Executive Court Reporters
(301) 565-0064
490
1 A The card refers you to the applicable manual. In
2 this case, this manual is deficient in those items.
3 Q Thank you. Isn't it also true that the Douglas
4 Aircraft Company DC-8 master maintenance manual and
5 illustrated parts catalog also lack this information?
6 A Do you have a reference?
7 Q I can produce one here. Hold on one second.
8 I'll refer to and say it's 7-A, it'll just take me a minute
9 to find the page -- page number. Alright, my memory is
10 partially here, it's been a while ago. There is a reference
11 in Exhibit 7-Alpha that I have in the back of my mind. It
12 does not identify the specific reference, however let me
13 read the paragraph. It's found on page 19.
14 It says, "A review of the DC-8 master maintenance
15 manual and illustrated parts catalog applicable to Chapter
16 27 revealed similar findings, i.e., no reference to the
17 hardware required to install the control tab push rod to the
18 tab crank fitting. However, as previously indicated, a
19 review of the DC-8 overhaul manual ..." -- I'll give you one
20 of my questions here -- "Chapter 27-16-1 did reveal the
21 hardware required at this location."
22 So, to answer your question, I do not have the
23 reference before me here, but it -- suffice it to say -- has
24 been established that the Douglas Company master maintenance
25 manual and illustrated parts catalog, at least at the time
Executive Court Reporters
(301) 565-0064
491
1 of the accident, also was lacking in the fact that it did
2 not depict this hardware, or describe this hardware.
3 Moving along here --
4 A Can I -- can I ask a question?
5 Q Yes.
6 A If I may? On Exhibit 7-L --
7 Q Yes, sir.
8 A -- page seven, item one, where it listed the tab
9 assemblies for the elevator, have those been researched to
10 see if the push rod and attaching hardware come as part of
11 that assembly?
12 Q I don't recall at this point after two years.
13 A Okay. That's the same with the Douglas master.
14 I'm assuming that it also references an assembly.
15 Q Once again, I don't recall at this time here.
16 A Okay.
17 Q But the bottom line would be that as just
18 established, neither the work card nor the applicable
19 maintenance manual, Chapter 27-3206 describe the hardware to
20 be required for this installation. Is that correct?
21 A I don't want to sound evasive, but without
22 looking at what those parts, those assemblies consist of,
23 I -- I can't answer that they don't. I can only say that
24 the items listed, in their individual -- the individual
25 parts don't show the hardware, but I don't know about the
Executive Court Reporters
(301) 565-0064
492
1 assembly.
2 Q Okay, that's fine. No problem. Why don't we
3 refer now to -- we'll come back to this now in a second --
4 why don't we refer to the fleet campaign directive found in
5 Exhibit 7-M. Come at this from a little bit different angle
6 here. Once again, for the record, this fleet campaign
7 directive was issued by Emery to perform an inspection of
8 the pushrod installation -- complete pushrod installation,
9 so both at the fore and aft end of the pushrod, based on the
10 best ... findings to date at that time.
11 CHAIRMAN GOGLIA: Mr. Pudwill, will you hold on
12 for one second.
13 MR. PUDWILL: Sure.
14 CHAIRMAN GOGLIA: Since you're going to go on to
15 the FCD. Would the witness please pull out 17-D, 7-M, I
16 believe you have in front of you, and 17-E.
17 THE WITNESS: 17-Delta and who?
18 CHAIRMAN GOGLIA: Echo.
19 THE WITNESS: All 17.
20 CHAIRMAN GOGLIA: We'll provide you with one.
21 THE WITNESS: I don't have 17 -- all's I've got
22 is seven.
23 CHAIRMAN GOGLIA: Mr. Pudwill, I planned on
24 getting into this area in a few minutes, whenever it came
25 back -- those three documents, so I would like to start -- I
Executive Court Reporters
(301) 565-0064
493
1 have some questions with them, and then I'll turn it back to
2 you.
3 MR. PUDWILL: Would you mind going ahead with
4 that? I need to review this fleet campaign directive,
5 anyway.
6 CHAIRMAN GOGLIA: Okay, thank you. You have 17-D
7 and E?
8 THE WITNESS: Yes.
9 CHAIRMAN GOGLIA: And 7-M?
10 THE WITNESS: Yes, I have all three.
11 CHAIRMAN GOGLIA: Okay. Would you take 17-D
12 first.
13 THE WITNESS: I have it.
14 CHAIRMAN GOGLIA: Okay. Are these documents
15 prepared by the engineering department? Are they originated
16 in the engineering?
17 THE WITNESS: I wasn't there at the time of the
18 distribution of this, but typically they would be. They
19 would come out of the engineering department.
20 CHAIRMAN GOGLIA: Okay, and they're numbered from
21 the top right hand side, in this particular case, 7-M -- I
22 mean 17-D is A-27-7, is that correct?
23 THE WITNESS: That's correct.
24 CHAIRMAN GOGLIA: And it was issued when?
25 THE WITNESS: 2/16/01.
Executive Court Reporters
(301) 565-0064
494
1 CHAIRMAN GOGLIA: Okay. And if you would
2 continue on the pages two, three, and four. The following
3 three pages. And in the introduction, would you read that?
4 I'll read it aloud for everybody.
5 "Due to the possibility of incorrectly installed
6 parts on the elevator push-pull rod assembly, an inspection
7 of the rod assembly is called for. This FCD inspects the
8 rod ends for proper installation of the bolt, washer, nut,
9 and cotter pin."
10 I have a question for you. Do you know that this
11 was done? It says all -- the whole fleet?
12 THE WITNESS: Do I know that it was complied with
13 on the entire fleet?
14 CHAIRMAN GOGLIA: Yes. Yes or no?
15 THE WITNESS: Well, I believe -- I wasn't there
16 at the time. I believe I saw a list with all the aircraft
17 complied with, but I can't be certain.
18 CHAIRMAN GOGLIA: And do you recall ever seeing
19 what the outcome of that was?
20 THE WITNESS: I only saw the document.
21 CHAIRMAN GOGLIA: Okay. Now, if you would take
22 7-M. And again flip to the cover page. And it's A-27-8.
23 And it's essentially a month later by the date, is that
24 correct?
25 THE WITNESS: That is correct.
Executive Court Reporters
(301) 565-0064
495
1 CHAIRMAN GOGLIA: And now in this campaign, it's
2 expanded.
3 THE WITNESS: Yes, it is.
4 CHAIRMAN GOGLIA: What kind of -- to your mind,
5 as the head of engineering, an engineering person, what
6 would drive the engineering department or the maintenance
7 department to expand this inspection?
8 THE WITNESS: Sometimes when you -- and I kind of
9 know the history of the origin of 27-7 -- okay, I was
10 involved somewhat with the investigation at Tennessee Tech
11 when we saw some items that we didn't like. And I'll give
12 you the real world scenario. There's times when you get a
13 lot of -- if you publish something, and this has happened to
14 me countless times, you publish something, the instant it
15 hits the street, mechanics call from all over pointing out
16 discrepancies and punctuation, spelling of words,
17 information missing. There's lots of reasons why it may be
18 expanded or reissued to facilitate everybody's questions.
19 And I'm speaking in a general term. I don't know that
20 that's what happened here.
21 CHAIRMAN GOGLIA: And you don't know why they
22 would include the opposite end of the push-pull rod?
23 THE WITNESS: I have -- I don't know.
24 CHAIRMAN GOGLIA: Okay. And then if you would
25 look at 17-E. And this one is 27-8, r... and it is a --
Executive Court Reporters
(301) 565-0064
496
1 one week later, 3/22/01. And now we add a clearance check.
2 So inside of 30 days, we have a fleet campaign directive
3 issued, reissued, reissued again, expanded and expanded
4 twice. I have concerns that things were being found that
5 drove maintenance and engineering departments to expand the
6 look.
7 THE WITNESS: I don't know that that's the case,
8 however, in similar situations I can -- as I said, I have
9 some familiarity with the first original 27-7 -- because of
10 the seriousness of the nature of the topic, there was a rush
11 to get this out so that at least people were out there
12 looking at the general area to see if there was a problem.
13 Thirty days later, there's a reissue that's expanded from
14 four pages to 11, and I'm assuming this is to -- in my
15 experience -- this is done in response to feedback from line
16 mechanics, maintenance control people who look at these and
17 research them, find other documents or -- possibly finding,
18 not necessarily problems in the field, but conflicts between
19 the content of the FCD and what they're actually seeing on
20 the aircraft. And by conflicts I mean that because of the
21 speed or the urgency to get the initial one out, there's a
22 possibility that it wasn't researched as thoroughly as it
23 could have been, given -- you know, if it wasn't such a
24 serious and wanted to get some immediacy out of it.
25 CHAIRMAN GOGLIA: Can I draw your attention back
Executive Court Reporters
(301) 565-0064
497
1 to 17-D?
2 THE WITNESS: 17-D?
3 CHAIRMAN GOGLIA: Dog. Correct. The first FCD
4 that was issued on February 17, 1991 -- I mean 2001 -- and
5 on the left hand side of the page, in the second line down,
6 "Complete the entire fleet no later than February 26th". So
7 this campaign was done or nearly done before this next one
8 was issued. But you have no recollection, or no direct
9 knowledge of the findings?
10 THE WITNESS: As I saw -- I saw the document
11 briefly. I didn't analyze the document, no.
12 CHAIRMAN GOGLIA: Okay, Mr. Pudwill, are you
13 ready to continue?
14 MR. PUDWILL: Yes, I am, Mr. Chairman.
15 BY MR. PUDWILL:
16 Q While we're on the subject matter, I am referring
17 of the three, to Exhibit 17-Echo.
18 A Which version is that?
19 Q That's eight. 27-8, revision one.
20 A Okay.
21 Q One little quick general question. Can you
22 identify the signature in the approved by space on page 1 of
23 11?
24 A It looks like Edward Jones.
25 Q Can you identify who that would be?
Executive Court Reporters
(301) 565-0064
498
1 A At the time, he might have been the director of
2 quality control or the manager of quality control.
3 Q Wouldn't this document originate within the
4 engineering department?
5 A Origination, yes. An FCD is -- in the Emery
6 context, an FCD is treated different than say an EO.
7 Q Wouldn't you have reviewed this document at that
8 time, after whoever had prepared it?
9 A As I said, I wasn't there at the time, but I
10 would assume that it was reviewed by engineering.
11 Q I'm sorry, I might be missing something here.
12 This was -- oh, essentially can you -- I'll just ask, was
13 this before or after you left the company?
14 A After.
15 Q Okay, thanks. Please refer to page 2 of 11. And
16 right in the middle of the page, it's materials.
17 A Yes.
18 Q It identifies the hardware here. So I'm not
19 asking for you know, those numbers -- I can't expect anybody
20 to remember that, but essentially would you agree that we
21 have a bolt, a washer, nut, and cotter pin required at this
22 installation?
23 A Yes.
24 Q Two each. Okay, now I'm referring specifically
25 to the control tab attachment at this point right now?
Executive Court Reporters
(301) 565-0064
499
1 A Are we in the FCD document?
2 Q Yes, we are.
3 A Okay.
4 Q And just for confirmation of that, flip forward
5 to page nine of 11, and it shows a figure, depicting both
6 the fore and aft ends of this push rod. And once again, I
7 recognize that this can be corrective ... check both ends,
8 but I'm really just trying to confine comments to the
9 accident location at this point, so the attachment at the
10 rear of the push rod to the control tab push rod, and would
11 you agree that you have a bolt, nut, washer and cotter pin
12 depicted in the upper right hand corner, which would be at
13 the tab crank fitting?
14 A Beginning with item 24, is that what that arrow -
15 - is that the area we're talking about?
16 Q Yes, item 24.
17 A Yes, it appears to be a bolt, washer, nut and a
18 cotter pin.
19 Q Okay, thank you. Now, please refer back to
20 Exhibit 7-L, keep that Exhibit 17-Echo available. Compare
21 that figure, if you will, to figure 1001 on page six of the
22 Exhibit, which is page 1001 of maintenance manual Chapter
23 27-3206. Do you see now that item six, seven, and eight,
24 which refer once again to the inboard hinge bolt are in a
25 different location?
Executive Court Reporters
(301) 565-0064
500
1 A Yes, I agreed before.
2 Q Okay, and therefore now, can we make the
3 assertion that this maintenance manual reference, which is
4 applicable for the accident aircraft, and once again that
5 TTS was expected to utilize during the performance of work
6 card 3502 found in Exhibit 7-K, would essentially be
7 inadequate in that it did not define the hardware at this
8 location?
9 A This particular maintenance manual does not
10 depict the hardware.
11 Q Alright, thank you. Next question was going to
12 be identify source of technical data available to Emery
13 personnel and their contract providers that clearly depicts
14 this hardware by part number, to be installed when
15 connecting the control tab and push rod --
16 A Which document are we on right now?
17 Q I was just going off my notes here.
18 A I'm sorry.
19 Q This -- if you paid attention, you heard ... we
20 already answered this when we referred back to Exhibit 7-
21 Alpha, but essentially, the question was if you could
22 identify a source of technical data that would have been
23 available to TTS at the time, and of course the answer has
24 already been revealed, the ... factual report and the answer
25 that I was looking for was the overhaul manual, chapter 27-
Executive Court Reporters
(301) 565-0064
501
1 16-1, figure two. And once again, that's Exhibit 7-Alpha,
2 Section 8.2, page 16.
3 To my knowledge, that's the only location that
4 the Safety Board was able to identify the hardware for this
5 installation other than for the drawings provided by
6 Douglas, which I'm assuming TTS did not have available.
7 A On those, I'll take your word, but again, I have
8 to state without knowing what parts consist of -- what's
9 consisting in the parts of an assembly that's listed in the
10 IPC, I'm -- you know, that -- there's a spot there that may
11 be -- there may be something in the assembly listing on the
12 IPC that includes these parts.
13 Q Okay, but --
14 A By far what I'm saying is there's exploded views,
15 and then there's things that come as a set, such as, you
16 know, black boxes and things of that nature. The box itself
17 has a part number, which is an assembled bunch of
18 transistors and what not. The IPC wouldn't necessarily list
19 the transistors. The overhaul manual might, but the IPC
20 would not. So again, I'm interjecting, and it's only a
21 question that I have looking at what you've provided, that
22 the assemblies would have to be reviewed to see what they
23 contain.
24 Q Wouldn't the illustrated parts catalog that's
25 found on pages 1001 and 1002 of maintenance manual Chapter
Executive Court Reporters
(301) 565-0064
502
1 27-3206 be the applicable illustrated parts catalog for this
2 installation, and therefore shouldn't this procedure, this
3 illustrated parts catalog, include this information?
4 A Include what? I'm sorry, I didn't hear that.
5 Q Identification of the hardware to be installed.
6 A Once again, there's many components on the
7 aircraft, Kevin, that are made up of multiple parts. The
8 higher assembly gets the part number.
9 Q Okay, in the case of -- you know, a lot of these
10 mechanical components, all kinds of components, there's --
11 those are assemblies of multiple parts, sometimes thousands
12 of parts, with the parent part number is what you get out of
13 the IPC. The components that comprise that part number are
14 only listed in the overhaul manual for that particular part,
15 and I'm only caution because I've been working with these
16 aircraft for many years, and sometimes these assemblies --
17 sometimes are where the supposed or the apparent missing
18 parts exist in the assembly itself.
19 MR. PUDWILL: Mr. Chairman, do you mind if I take
20 a minute to confer with my colleagues here?
21 CHAIRMAN GOGLIA: No, in fact I have a couple
22 questions that I can ask right now.
23 MR. PUDWILL: I appreciate that, thank you.
24 CHAIRMAN GOGLIA: Mr. Robbins, when did you leave
25 Emery? What was the date?
Executive Court Reporters
(301) 565-0064
503
1 THE WITNESS: June -- the end of June 2000.
2 CHAIRMAN GOGLIA: Okay, and where were you in
3 1999 in the organization?
4 THE WITNESS: I was director of engineering. The
5 spring of '99, April, May, something like that.
6 CHAIRMAN GOGLIA: And what were you doing before
7 that?
8 THE WITNESS: Manager of maintenance training.
9 CHAIRMAN GOGLIA: And about how long?
10 THE WITNESS: Six years.
11 CHAIRMAN GOGLIA: There is a number of concerns
12 been voiced by the pilot group about problems with Emery and
13 concerns -- concerns they have about Emery's maintenance in
14 that period of time. Have you heard those?
15 THE WITNESS: I've seen some report in the
16 newspaper, in the local paper.
17 CHAIRMAN GOGLIA: Okay, and did you, as part of
18 your normal duties and especially in the spring of '99, did
19 you ever have access to somebody from the flight ops side
20 bring to you any of the debriefs that the Captain fills out?
21 THE WITNESS: Yes, I saw a couple, a few.
22 CHAIRMAN GOGLIA: And did any of those raise
23 concerns to you about the allegations or concerns that the
24 flight crews were having about the performance of the
25 maintenance department?
Executive Court Reporters
(301) 565-0064
504
1 THE WITNESS: Yes, in fact, I can recall taking
2 an initiative and doing some research by myself to see if
3 they were founded, and I'll be very honest with you, in each
4 case that I tried to track down evidence of somebody --
5 whatever the allegation was, I can't recall off the top of
6 my head -- but in each case, I could not find substantiation
7 to support the claim.
8 In a lot of cases what I saw was disagreements
9 over -- in some cases, disagreements over the use of the
10 MEL. There's a phrase in the MEL that says something to the
11 effect that you can defer it if the time and material
12 doesn't -- it's going to interfere with the schedule or
13 something along those lines, I can't be sure. That's a
14 point of contention. I mean my -- the mechanic in me says I
15 want to fix the airplane, but sometimes I just literally
16 can't because I don't have the parts available, possibly the
17 tooling, or the time to get the airplane out to make the
18 scheduled departure.
19 The flight ops people, obviously want to fly the
20 aircraft. That's their job. That's what they do. There's
21 almost an inherent conflict whenever you have an aircraft
22 that's got a component broken. And those sometimes depend
23 on people's -- the tempers get a little short when they've
24 been up for -- away from home for a few days. Mechanics
25 don't always have the most gifted way of explaining things
Executive Court Reporters
(301) 565-0064
505
1 to air crew. There's lots of reasons why there may be a rub
2 in the cockpit which manifests itself into an alleged report
3 of something else. And as I said, in the instances that I
4 took the initiative and tracked these things down, when it
5 got down to the end game, there was -- there was really
6 nothing there but a disagreement that maybe got out of hand
7 a little bit.
8 I'm not saying that there's never a chance of any
9 of this stuff happening. I'm saying in my personal
10 experience, that's what I came to.
11 CHAIRMAN GOGLIA: And I am familiar with the
12 phraseology in the MEL that you're talking about that allows
13 that difference of opinion to exist, and in the course of
14 your duties, did you ever feel any obligation that company
15 policy should be clear in that area and try to initiate some
16 action?
17 THE WITNESS: I think it's very clear, the
18 verbiage. It's the application. You know, the line gets
19 crossed when the air crew wants to leave -- or I should say
20 the air crew wants everything to work on the airplane, and I
21 don't blame them. You know, everybody would like to fly an
22 aircraft with 100 percent of the components working.
23 Maintenance would like to provide that in almost all cases.
24 It's when those two oppose each other, that's where the
25 conflict comes.
Executive Court Reporters
(301) 565-0064