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aerotech777
Topic Author
Posts: 97
Joined: Sat Aug 15, 2009 3:53 pm

Safety Hazards In/Around Aircraft

Mon Sep 07, 2020 8:05 pm

As you know working on and around airplane in hangar or flight line can present safety hazards. I am not talking about safety hazard caused by vehicles and equipment around aircraft in the ramp or in the hangar, but the powered or active (electric power on, hydraulic, pneumatic...etc) aircraft itself. If my memory is good the AMM included some warnings in old aircraft (such 737-200 and 727), but there were no procedures to deactivate the aircraft systems. For example as ex AMT especially inside the hangar, we have to put a note on cockpit, open circuit breakers, communicate with other employees, or most importantly disconnect a connector for example of hydraulic pumps as extra precaution if we are working on hydraulic system or flight controls.

It seems Boeing have system or process to deactivate aircraft systems in order to prevent/reduce the safety risks on or around active or powered airplane according to the link below. There is Boeing system/process called LOTO (lockout, tagout, and tryout) in order to comply with U.S Occupational Safety and Health Administration (OSHA) regulations. Boeing link:

https://www.boeing.com/commercial/aerom ... 2014q4.pdf

a) Does your airline/aircraft operator has a similar safety policy/process (LOTO) when employees are working on/around powered airplane?

b) Does your airline/aircraft operator has his own (internal) safety policy/process (similar to LOTO), or it is related to government regulations that airline/aircraft operator must comply with?

As an ex AMT we had some relatively serious injuries in the workplace (not in our crew) and if my memory is good:
-One employee get sucked into JT8D engine (737-200). As as you might know this engine is fitted with IGV (inlet guide vanes). So the employee was lucky (no death). The result will be totally different if it was high bypass engine (big fan) and no IGV as in the current engines.
-One employee get strucked by spoiler on the head (the guy had surgery on neck/vertebrate).
-One employee was hit and thrown by accidentally inflated door escape slide inside the airplane.

The article mentioned examples of safety hazards. As AMTs we know at a certain degree (some know more and some know less) the safety hazards on/around aircraft.
c) Based in your experience and opinion what are the most serious and important safety hazards while working on/around the aircraft (besides the known hazards such flight control, landing gear (test), running engine?
Please give some examples of accidents/incidents if they happened?

d) In your opinion what are the devices/items that aircraft manufacturers (Boeing, Airbus....etc) can add to aircraft in order to reduce the hazards for employees working on/around aircraft?

e) Does Airbus (in the assembly line) has system/process to deactivate aircraft systems in order to reduce safety hazards on/around airplane? Does Airbus AMM include
procedures to deactivate aircraft systems?

Feedback appreciated.
 
aerotech777
Topic Author
Posts: 97
Joined: Sat Aug 15, 2009 3:53 pm

Re: Safety Hazards In/Around Aircraft

Tue Sep 15, 2020 7:03 pm

Press Release – FAA Proposes $210,000 Civil Penalty Against Alaska Airlines

For Immediate Release

May 3, 2012
Contact: Allen Kenitzer or Mike Fergus
Phone: (425) 227-2004

SEATTLE – The Federal Aviation Administration is proposing a civil penalty of $210,000 against Alaska Airlines of Seattle for allegedly failing to properly document and tag deactivated systems and equipment before making repairs.

The FAA alleged that on 10 occasions between June 19, 2010, and January 13, 2011, Alaska performed maintenance on six of its Boeing 737 airplanes but failed to comply with the required alternative deactivation procedures. Specifically, the airline allegedly failed to document the alternative actions it took, and failed to install the appropriate danger tag. These requirements are safety measures designed to reduce hazards to technicians during maintenance and to prevent potential damage to the aircraft and onboard systems.

Alaska Airlines has 30 days from receipt of the civil penalty letter to respond to the agency.


This is quote on May 3, 2012 from this link: https://www.faa.gov/news/press_releases ... wsId=13513

I thought reducing hazards to prevent potential work injuries is the duty of OSHA. Why FAA get involved on this matter? Why not OSHA?

Feedback appreciated.
 
GalaxyFlyer
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Re: Safety Hazards In/Around Aircraft

Tue Sep 15, 2020 9:20 pm

It’s, by law, the FAA’s jurisdiction, that’s why. Airside, airplanes, all FAA, OHSA has no jurisdiction.
 
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fr8mech
Posts: 8070
Joined: Mon Sep 26, 2005 9:00 am

Re: Safety Hazards In/Around Aircraft

Wed Sep 16, 2020 3:13 am

GalaxyFlyer wrote:
It’s, by law, the FAA’s jurisdiction, that’s why. Airside, airplanes, all FAA, OHSA has no jurisdiction.


Nope, we see OSHA on the airside all the time.

aerotech777 wrote:
Why FAA get involved on this matter?


Where are the instructions for LOTO located? They are in the AMM. If you don't follow the instructions in the AMM for LOTO, you're in violation of the FAR's.

If you have policies or procedures in your GMM, GPP, GOM, whatever, for LOTO and you're not folloing those procedures, you're in violation of the FAR's.
When seconds count, the police are minutes away, or may not come at all.
It’s hard to win an argument with a smart person, but it’s damn near impossible to win an argument with a stupid person. ~B. Murray
Ego Bibere Capulus, Ut Aliis Sit Vivere
 
GalaxyFlyer
Posts: 6229
Joined: Fri Jan 01, 2016 4:44 am

Re: Safety Hazards In/Around Aircraft

Wed Sep 16, 2020 3:28 am

Interesting, I was told that the FAA has exclusive jurisdiction on the airside. Wrong, I guess.

But,

https://www.osha.gov/laws-regs/standard ... 1990-11-14
 
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fr8mech
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Re: Safety Hazards In/Around Aircraft

Wed Sep 16, 2020 4:04 am

GalaxyFlyer wrote:
Interesting, I was told that the FAA has exclusive jurisdiction on the airside. Wrong, I guess.

But,

https://www.osha.gov/laws-regs/standard ... 1990-11-14


Interesting, but it's also 30 years old, and I have personally provided responses to out Health & Safety folks for response to OSHA complaints.
When seconds count, the police are minutes away, or may not come at all.
It’s hard to win an argument with a smart person, but it’s damn near impossible to win an argument with a stupid person. ~B. Murray
Ego Bibere Capulus, Ut Aliis Sit Vivere
 
flipdewaf
Posts: 3640
Joined: Thu Jul 20, 2006 6:28 am

Re: Safety Hazards In/Around Aircraft

Wed Sep 16, 2020 4:00 pm

I would guess that like in the UK the FAA regs apply when the aircraft is in motion (or more properly doors closed) and that the maintenance procedure probably has to be approved by the FAA or an approved FAA third party provider.

The OSHA (Equivocal to the HSE in the UK) has a far broader reach but less specified in terms of actions and puts the onus on the people performing the tasks (both management and shop floor) to demonstrate that the procedure is suitable. It is effectively deemed suitable by the nature that Boeing (for example) being the experts and therefore the de-facto authority describing the tasks means that those by default pass the OSHA (HSE) test however that isn't the end. The OSHA requirements likely outflank those of the FAA in terms of risk assessing the potential hazards and looking at other risks within the area and for the actions being taken including things like suitability of the person for the task, environmental conditions including things like the floor condition, the temperature, the tiredness of the person, their potential mental state.

Fred
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aerotech777
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Posts: 97
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Re: Safety Hazards In/Around Aircraft

Sat Sep 19, 2020 5:02 pm

Where are the instructions for LOTO located? They are in the AMM. If you don't follow the instructions in the AMM for LOTO, you're in violation of the FAR's.

If you have policies or procedures in your GMM, GPP, GOM, whatever, for LOTO and you're not folloing those procedures, you're in violation of the FAR's.

What are GMM, GPP, GOM? Are these FAA approved LOTO manuals?

It’s, by law, the FAA’s jurisdiction, that’s why. Airside, airplanes, all FAA, OHSA has no jurisdiction.

It seems that OSHA has limited authority over the working conditions of the flight attendants even in flight according to this extract from the following link:
https://www.osha.gov/dep/letters/040120 ... mbers.html

SUBJECT: Applicability of Certain OSHA Standards to Cabin Crew Members on Aircraft in Operation

The purpose of this memorandum is to inform you that OSHA now has limited authority over the working conditions of cabin crew members (e.g., flight attendants) while they are onboard aircraft in operation. Beginning March 26, 2014, OSHA will apply its standards for noise, hazard communication and bloodborne pathogens to the working conditions of cabin crew members (but not flight deck crew) on aircraft in operation. OSHA and the airlines have agreed that the airlines may implement modified training programs to comply with the training components of these standards until January 1, 2015, at which time their training programs will have to include in-person training sessions for all OSHA-required training.


The hazards mentioned in this policy are: noise, hazard communication and bloodborne pathogens.
What they referring by mentioned "bloodborne pathogens" (infectious microorganisms in human blood): are they referring to the risk of recirculated air in the cabin (HEPA filters) or some injuries (skin cut)?
What they mean by hazards communication?

Pilot are also exposed to noise. Why pilots are included in this policy?

Feedback appreciated.
 
aerotech777
Topic Author
Posts: 97
Joined: Sat Aug 15, 2009 3:53 pm

Re: Safety Hazards In/Around Aircraft

Sat Sep 19, 2020 5:35 pm

Pilot are also exposed to noise. Why pilots are NOT included in this policy? mea culpa.
 
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fr8mech
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Joined: Mon Sep 26, 2005 9:00 am

Re: Safety Hazards In/Around Aircraft

Sat Sep 19, 2020 8:54 pm

aerotech777 wrote:
What are GMM, GPP, GOM? Are these FAA approved LOTO manuals?


General Maintenance Manual, General Policies and Procedures Manual, Ground Operations Manual. These are Some of the different manuals, among many others, that operators use to govern their maintenance and ground operations. They are FAA approved and violating the procedures in those manuals can result in FAA enforcement action.

Our GMM talks about LOTO, so failure to perform LOTO, could result in enforcement action.
aerotech777 wrote:
Where are the instructions for LOTO located? They are in the AMM. If you don't follow the instructions in the AMM for LOTO, you're in violation of the FAR's.

aerotech777 wrote:
What they referring by mentioned "bloodborne pathogens"


These have been interpreted to mean any bodily liquids that can carry infectious pathogens. HEPA type stuff would be “airborne pathogens”.
When seconds count, the police are minutes away, or may not come at all.
It’s hard to win an argument with a smart person, but it’s damn near impossible to win an argument with a stupid person. ~B. Murray
Ego Bibere Capulus, Ut Aliis Sit Vivere
 
flipdewaf
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Joined: Thu Jul 20, 2006 6:28 am

Re: Safety Hazards In/Around Aircraft

Sun Sep 20, 2020 3:09 pm

aerotech777 wrote:

The hazards mentioned in this policy are: noise, hazard communication and bloodborne pathogens.
What they referring by mentioned "bloodborne pathogens" (infectious microorganisms in human blood): are they referring to the risk of recirculated air in the cabin (HEPA filters) or some injuries (skin cut)?
What they mean by hazards communication?


Generally this refers to how one deals with bodily fluids and particularly those can transfer diseases, think hepatitis and HIV. The fluids are generally urine, faeces, seamen, blood and vomit. There should be plans in place to minimise exposure and spill response plans similar to chemical spills.

If someone needs to replace some jig that has got damaged through someone being sick in flight then appropriate protection and procedures should be provided for the situation regarding the vomit which I wouldn’t expect to be provided by Boeing.

The same would apply for working on the lavatory systems.

There would need to be procedures and systems in place to prevent people cutting themselves and dealing with it if they do. Imagine Dave is HIV+ and cuts himself removing a bolt and there is blood left on it then James has a go and does the same thing....

Fred


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aerotech777
Topic Author
Posts: 97
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Re: Safety Hazards In/Around Aircraft

Wed Sep 30, 2020 6:02 pm

General Maintenance Manual, General Policies and Procedures Manual, Ground Operations Manual. These are Some of the different manuals, among many others, that operators use to govern their maintenance and ground operations. They are FAA approved and violating the procedures in those manuals can result in FAA enforcement action.

Our GMM talks about LOTO, so failure to perform LOTO, could result in enforcement action


It seems that Boeing uses certain lockout devices for LOTO such circuit breaker collars, lock, and tag to deactivate aircraft systems as it shows in this link:
https://www.boeing.com/commercial/aerom ... 2014q4.pdf

In the link below it shows also some lockout devices
https://www.google.com/search?q=loto+in ... yJYpFEVHOM

If I am not mistaken, the AMM does not mention the procedure and the lockout devices that AMTs must to use to deactivate aircraft systems. fr8mech said that GMM (General Maintenance Manual) talk about LOTO.

a) fr8mech and other AMTs, what kind of lockout devices do you use in your airline/aircraft operator?

b) fr8mech and other AMTs, do you have certain way or approved procedure to lockout aircraft system?

Feedback appreciated.
 
gregorygoodwin
Posts: 66
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Re: Safety Hazards In/Around Aircraft

Wed Sep 30, 2020 9:29 pm

Here at FDX, we have a LOTO system that is laid out in our General Maintenance Manuel. When we bring a ship into the hangar for maintenance we have a crew that does what is called a pre-dock. This is when a lot of the systems are inactivated and circuit breakers are pulled and tagged. If during the maintenance visit, if you need to power up hydraulics and a flight control is to be moved, a manager and/or lead mechanic must be present and do a clearance check to prevent an accident. If you are going to do a repair, such as a structural or composite repair, it is up to the technician to be safe, such as putting a lock-out device on a spoiler, and letting others know. It is imperative that the techs know the idiosyncrasies of the aircraft they are working on. For example, on the 767-300F there is no easy way to disconnect spoilers and flaps. If you decide to lower flaps to gain access to something , you must be aware that slats are going to deploy and if the inboard engine cowls are full open you will hit them. It's the little details that get forgotten or overlooked that quickly cause grief.
 
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fr8mech
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Re: Safety Hazards In/Around Aircraft

Thu Oct 01, 2020 12:53 am

aerotech777 wrote:
If I am not mistaken, the AMM does not mention the procedure and the lockout devices that AMTs must to use to deactivate aircraft systems.

I'm not sure where you get that idea. The AMM has several instances where it instructs the AMT to make a system safe, or deactivate it to prevent injury or damage.

aerotech777 wrote:
a) fr8mech and other AMTs, what kind of lockout devices do you use in your airline/aircraft operator?


We use c/b collars, tags, placards, lock-out fixtures, tooling called out in the AMM. Sometimes it's just a matter of tagging the external power receptacle.

aerotech777 wrote:
b) fr8mech and other AMTs, do you have certain way or approved procedure to lockout aircraft system?


Yes, the AMM provides the procedures. In the absence of instructions in the AMM, then the GMM provides general guidance. In the end, it comes down to common sense and communication.
When seconds count, the police are minutes away, or may not come at all.
It’s hard to win an argument with a smart person, but it’s damn near impossible to win an argument with a stupid person. ~B. Murray
Ego Bibere Capulus, Ut Aliis Sit Vivere

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