FAA’S OVERSIGHT OF AMERICAN AIRLINES’ 

MAINTENANCE PROGRAMS

Federal Aviation Administration

Report Number: AV-2010-042

Date Issued: February 16, 2010
U.S. Department of

Memorandum

Transportation

Office of the Secretary

of Transportation

Office of Inspector General

Subject: ACTION: FAA’s Oversight of American Airlines’

Maintenance Programs

Federal Aviation Administration

Report Number AV-2010-042

Date: February 16, 2010

From: Lou E. Dixon

Assistant Inspector General 

 for Aviation and Special Program Audits

Reply to 

Attn. of: JA-10

To: Federal Aviation Administrator

American Airlines, one of the world’s largest passenger airlines, has not 

experienced a fatal accident in 8 years. Despite this safety record, we received a 

complaint in February 2008 alleging that the overall operational reliability of the 

airline’s aircraft had diminished and that previously reliable aircraft systems were 

regularly failing. Specifically, the complaint included 10 maintenance-related 

allegations and highlighted several incidents, including 3 flights that the 

complainant alleged had experienced cockpit windshield failures. The complaint 

also included allegations of unacceptably high levels of maintenance deferrals, 

performance of required aircraft inspections by non-qualified personnel, and 

failure to perform inspections called for in an aircraft manufacturer’s service 

bulletin.

The complainant also sent the allegations to the Federal Aviation Administration 

(FAA). FAA Headquarters forwarded the allegations to its American Airlines 

Certificate Management Office (CMO) in Fort Worth, Texas, for investigation.

Given the seriousness of these allegations, we assessed (1) FAA’s oversight of 

American Airlines’ maintenance program and identified any underlying 

weaknesses and (2) FAA’s response to the allegations. We conducted this audit in 

accordance with generally accepted government auditing standards between June 

2008 and December 2009. Exhibit A details our audit scope and methodology. 

Exhibit B lists the entities we visited or contacted.
2

RESULTS IN BRIEF

FAA’s oversight of American Airlines’ maintenance program lacks the rigor 

needed to identify the types of weaknesses alleged by the complainant—at least 

four of which were confirmed and have potential safety implications.

• First, we confirmed the allegation that American Airlines’ maintenance-related 

events have increased. Further, the National Transportation Safety Board 

(NTSB) recently found that American’s Continuing Analysis and Surveillance 

System (CASS)—a system intended to monitor and analyze the performance 

and effectiveness of a carrier’s inspection and maintenance programs—failed 

to detect repeated maintenance discrepancies, which, if found, could have 

prevented an in-flight engine fire that occurred in September 2007. However, 

during a 2-year period between 2005 and 2007, FAA did not perform required 

routine surveillance of American’s CASS and reliability programs—two key 

systems for monitoring carriers’ maintenance programs. While FAA reviewed 

the carrier’s policies and procedures governing the two systems, it did not 

determine whether the carrier actually followed them. 

• Second, we confirmed the allegation that maintenance deferrals increased

significantly. From 2004 through the first 5 months of 2008, American’s 

number of open maintenance deferrals increased by 32 percent, from an 

average of 298 per day to an average of 394 per day. Despite this increase, 

FAA only tracked the number of deferrals but did not identify the types of 

aircraft parts being deferred or the causes of the deferrals. As a result, FAA 

inspectors missed opportunities to identify potential fleet-wide maintenance 

issues and put corrective action plans in place.

• Third, we confirmed the allegation that American was not following 

procedures for required maintenance inspections. We found that FAA has not 

taken appropriate action to address American’s longstanding failure to comply

with required maintenance inspection procedures. In late 2005, FAA initiated 

a System Analysis Team, which made 35 recommendations to improve 

American’s compliance, but corrective actions for the team’s recommendations 

made in 2006 are still not complete.

1

 1 According to American officials, as of December 2009, they have implemented the majority of the System Analysis 

Team’s recommendations to improve compliance with RII requirements, with one remaining to be implemented in 

April 2010.

In December 2007, inspections of repairs 

made to the aircraft damaged during an in-flight engine fire were performed by 

a technician whose qualifications had expired—a deficiency that was not 

discovered until the aircraft was ready to depart with passengers. Following 

this incident, FAA requested that American submit a comprehensive corrective 

action plan within 20 days. In September 2008—9 months after FAA’s 
3

request—American submitted its plan and is continuing its efforts to 

implement FAA’s 2006 recommendations.

• Finally, we confirmed the allegation that American did not implement a 

Boeing service bulletin2

To assess the February 2008 allegations, FAA undertook two reviews. One 

review was conducted by the CMO for American about 1 month after the 

allegations were submitted. The other review was conducted by FAA inspectors 

from outside the CMO utilizing an Internal Assistance Capability (IAC) process to 

independently review the February 2008 safety allegations.

alerting carriers to problems with aircraft windshield 

heating systems that could cause the windshield to crack or shatter if left 

uncorrected. FAA did not identify process weaknesses in American’s 

maintenance and engineering programs that resulted in the carrier’s failure to 

perform planned inspections of Boeing 757 windshield heating systems. 

Further, FAA has yet to finalize and issue an airworthiness directive that would 

require carriers to address the windshield heating problem—a recommendation 

NTSB made in 2004.

3

Based on our findings, we are making several recommendations to enhance FAA’s 

oversight in key maintenance areas at American and improve its processes for 

assessing safety allegations. 

However, neither 

review was comprehensive. The CMO’s review of mechanical reliability focused 

on only one of the nine systems alleged to have experienced decreased reliability. 

The independent review did not include work at the air carrier. Instead, the review

was performed hastily over 1 weekend and focused on the work already performed 

by the CMO, such as inspection reports filed by CMO inspectors. As a result, the 

IAC team reached a number of the same faulty conclusions made by the CMO. 

Additionally, the IAC’s June 2008 recommendations have not been acted upon 

because, according to CMO managers, they did not receive a copy of the IAC’s 

final report until June 2009.

BACKGROUND

In 1998, FAA implemented the Air Transportation Oversight System (ATOS), a 

data-driven, risk-based approach to air carrier safety oversight. ATOS was 

designed to shift inspectors away from the inspection method they had used for 

over 30 years, which focused on whether air carriers were complying with 

regulations, to an approach that proactively assessed risks within air carriers’ 

 2 Implementing the service bulletin was not required. However, service bulletins often highlight safety issues that lead 

to the issuance of an airworthiness directive. 3 The IAC was developed in response to an OIG recommendation: OIG Report Number AV-2007-080, “FAA’s 

Actions Taken To Address Unsafe Maintenance Practices at Northwest Airlines,” September 28, 2007. OIG reports 

are available on our website: www.oig.dot.gov.
4

maintenance and operations systems. Under ATOS, FAA inspectors are to use 

data analysis to focus their inspections on areas that pose the greatest safety risks 

and to shift the focus of those inspections in response to changing conditions 

within air carriers’ operations. 

CASS and reliability are two of the key air carrier systems that inspectors assess 

under ATOS. FAA regulations require some air carriers to have a CASS to assess

maintenance performed on the carrier’s aircraft.

4

The February 2008 complaint raised serious questions about the effectiveness of 

American’s CASS and FAA’s oversight of the air carrier’s maintenance program. 

Specifically, the complaint included 10 maintenance-related allegations that 

indicated an overall deterioration in the airline’s operational reliability. The 

complainant’s 10 allegations are listed below. 

 Although not required, air 

carriers may have an FAA-approved reliability program, which monitors failure 

rates of aircraft components with the goal of achieving improved operational 

performance. Air carrier personnel enter reliability program data into CASS for 

monitoring the effectiveness of air carriers’ inspection and maintenance programs. 

FAA inspectors are responsible for determining whether these maintenance and 

monitoring systems are working effectively through routine ATOS surveillance. 

 4 Maintenance may be performed in-house or by other entities, such as contract facilities.

February 28, 2008, Allegations Against American Airlines

• Maintenance-related delays, cancellations, and diversions have increased.

• Minimum Equipment List (MEL) deferrals have increased, and MEL authority has 

been abused.

• A Boeing service bulletin that could have prevented some cockpit windshield 

failures was not implemented.

• Certain Functional Check Flights (post-maintenance test flights) were eliminated.

• Maintenance check intervals were changed, resulting in fewer maintenance 

checks.

• Spare parts inventories were reduced.

• Required inspections of an aircraft repaired after a September 2007 engine fire 

were performed by a non-qualified mechanic.

• Computerized maintenance records were inadequate.

• Maintenance records were not transparent.

• Retribution was taken against personnel who have reported maintenance 

problems.
5

In March 2008, FAA’s CMO for American—which is responsible for overseeing 

American’s maintenance and flight operations—initiated a review to look into the 

allegations. 

FAA OVERSIGHT WAS INADEQUATE TO IDENTIFY 

WEAKNESSES IN AMERICAN’S MAINTENANCE OPERATIONS 

FAA’s oversight of American’s maintenance operations was inadequate to identify 

the types of problems described in the February 2008 allegations. First, FAA did 

not conduct all required routine inspections of American’s CASS and reliability 

programs and failed to identify weaknesses in these critical safeguards. Second, 

FAA did not determine reasons behind increased maintenance deferrals at 

American, although such deferrals could have significant safety implications or 

indicate financial difficulty at the carrier. Third, FAA has not held American 

accountable for addressing longstanding problems with required maintenance 

inspections. Finally, FAA did not identify internal process failures that led to 

American’s inadequate response to Boeing’s service bulletin.

FAA Did Not Perform Comprehensive Surveillance of American’s 

CASS and Reliability Programs

ATOS requires inspectors to evaluate carriers’ CASS and reliability programs—

from both a policy and implementation standpoint. These routine reviews are 

intended to ensure that air carriers comply with regulatory requirements and that 

their operations and maintenance programs are working effectively. FAA’s 

guidance specifically calls for ATOS inspections at least once every 6 months and 

a policy review at least once every 5 years. However, during a 2-year period 

between 2005 and 2007, CMO inspectors did not perform the required semiannual 

inspections of American’s CASS and reliability programs. They only conducted a 

policy review, which disclosed a lack of procedures in American’s CASS and 

reliability programs to identify root causes of identified maintenance problems as 

well as inconsistencies between the airline’s CASS manual and other internal 

guidance.

5

The potential consequences of a poorly performing CASS were demonstrated in 

April 2009 when the NTSB determined that American’s CASS failed to detect 

According to CMO officials, they did not perform the semiannual 

inspections because the carrier was making changes to its CASS and reliability 

programs in response to FAA findings. Yet, given the problems identified in its 

policy review, the CMO would have been prudent to comply with ATOS 

requirements and conduct semiannual inspections of the carrier’s CASS and 

reliability programs.

 5 American officials advised us that they have improved the carrier’s CASS program, including adding root cause 

analysis procedures. In addition, they are rewriting the CASS manual and all maintenance manuals, which are 

planned for completion in 2010.
6

repeated maintenance discrepancies, which contributed to the September 2007 inflight engine fire on American Airlines flight 1400 (see figure 1).

6

Specifically, in the 13 days prior 

to the flight, the aircraft’s left 

engine air turbine starter valve 

had been replaced six times in an 

effort to address an ongoing 

problem with starting the engine 

using normal procedures. None 

of the valve replacements solved 

the engine start problem, and the 

repeated failures to address the 

issue were not recognized by the 

airline’s CASS personnel. 

According to the NTSB, if these 

maintenance discrepancies had 

been found, the engine fire could 

have been prevented. 

 

The NTSB recommended that American evaluate and correct deficiencies in its 

CASS. American officials have completed their internal review and are preparing 

a response to the NTSB.

While we did not identify any immediate safety-of-flight issues, our analysis of 

maintenance-related incidents at American Airlines found that the carrier’s overall 

operational reliability has decreased since 2004, which increases the risk of serious 

incidents. The rate of operational events across all fleets—including cancellations, 

in-flight diversions, and other delays—rose from 3.9 events per 100 departures in 

January 2004 to 5.8 events per 100 departures in December 2008. In June 2008, 

the CMO inspected American’s CASS and concluded that American had improved 

its event analysis by including day-to-day operational events, rather than just

events that the airline deemed to be “significant.” Despite this improvement, 

inspectors expressed concern that American’s CASS audit division was 

understaffed in relation to the complexity and size of the airline.

7

The CMO inspectors for American also performed reliability inspections in early 

2008 but disagreed with the complainant’s allegation that operational reliability 

 6 In September 2007, an engine fire forced an emergency landing of an American Airlines MD-80 soon after its 

departure from Lambert-St. Louis International Airport. The fire damaged the hydraulic system, rendering the 

plane’s rudder inoperable, and the nose landing gear failed to extend during the first landing attempt. A second 

attempt was successful, and none of the 143 people onboard were injured. However, the plane sustained substantial 

structural damage. 7 According to American officials, the carrier has added nine auditors and plans to add four CASS analysts in 2010.

Figure 1. American Airlines September 2007 

In-Flight Engine Fire

Source: NTSB
7

had decreased. The CMO’s conclusion, however, was based on limited 

inspections of American’s MD-80s and A-300s, which account for only half of 

American’s aircraft in its six8 fleets and exclude American’s Boeing 757 fleet, the 

carrier’s second-largest with 124 aircraft. Further, inspectors did not review 

automated reliability data that American provides to the CMO on a regular basis,9

and principal inspectors did not analyze or reconcile differences in inspection 

results. For example, inspection records for the MD-80 and A-300 show that one 

inspector identified problems with the carrier’s CASS and reliability systems 

while the other concluded there were no problems. Ultimately, the CMO reviewed 

the performance of only one of the nine mechanical systems that the complainant 

alleged were failing at an increasing rate—the MD-80 nose landing gear—which 

experienced 27 failure-to-retract events in 2008, compared to 8 in 2005.

10

Finally, FAA assessed the allegation that American Airlines had reduced the 

number of Functional Check Flights (FCF)

 Based 

on this limited review, the CMO concluded that American’s fleet-wide operational 

reliability had not decreased. In contrast, we found that operational reliability had 

decreased for all nine systems, which included hydraulics, electrics, flight 

controls, and the MD-80 nose landing gear.

11

FAA Did Not Perform Comprehensive Analyses of Maintenance 

Deferrals 

it performs and that this action had 

resulted in increased numbers of mechanical failures following heavy 

maintenance. However, FAA’s assessment lacked the rigor needed to verify or 

refute the allegation. While Federal Aviation Regulations require an FCF 

program, FAA lacks guidance detailing what attributes a properly functioning FCF 

program should contain, according to FAA inspectors. The inspectors added the 

FCF program to their risk management action plan but noted that they struggled 

with how to proceed with their inspections and that guidance would be helpful in 

performing their oversight duties. We verified that American has reduced the 

number of FCFs it performs on its Boeing 767 fleet but were unable to determine 

if this negatively affected aircraft mechanical reliability. 

FAA guidance recommends that safety inspectors monitor the number of 

Minimum Equipment List (MEL) deferrals. MELs list the instruments and 

equipment that may be inoperative without jeopardizing the safety of the aircraft. 

This allows a carrier to continue to operate the aircraft provided it makes the 

repairs within a certain number of days. While FAA prescribes the number of 

 8 American retired its A-300 fleet in late August 2009. 9 We also determined that inspectors were not regularly reviewing these automated data as part of their risk

assessments and routine surveillance. 10 According to American officials, the carrier made multiple maintenance program changes in response to the MD-80 

nose landing gear issue, which resulted in significantly improved performance in the first quarter of 2009. 11 A Functional Check Flight is a test flight of an aircraft performed after major airframe maintenance to ensure that the 

aircraft is functioning normally.
8

days an air carrier can defer maintenance for each listed component, there is no 

limit on the number of MEL deferrals a carrier can have. An increase in deferrals 

does not necessarily indicate an increased safety risk, but analyses of trends and 

the types of deferrals can uncover fleet-wide maintenance issues or potential 

financial difficulty, which can have safety implications if the carrier forgoes 

needed maintenance to remain viable. While CMO inspectors track the number of 

maintenance deferrals across American’s fleet, inspectors have not analyzed trends 

or monitored the types of components being deferred. 

As alleged by the complainant, we confirmed that the number of open fleet-wide 

MEL deferrals increased by 32 percent between 2004 and the first 5 months of 

2008, from an average of 298 per day to an average of 394 per day (see figure 2). 

On a per-aircraft basis for this period, the number of average open MELs per 

aircraft rose from 0.42 per aircraft to 0.60 per aircraft.12

Figure 2. Average Daily Open MELs, January 2004 to May 2008

Source: OIG analysis of FAA data

Since January 2007, American has submitted at least 13 self-disclosures regarding 

improper use or issuance of an MEL. Instances of misuse included deferring 

maintenance on a navigational component that was not listed in an MEL and 

 12 Since May 2008, the number of maintenance deferrals has trended downward. In November 2009, the number of 

average open fleet-wide was 254 per day, or 0.42 per aircraft (just under the 2004 level).

0

50

100

150

200

250

300

350

400

450

500

Jan-04

Apr-04

Jul-04

Oct-04

Jan-05

Apr-05

Jul-05

Oct-05

Jan-06

Apr-06

Jul-06

Oct-06

Jan-07

Apr-07

Jul-07

Oct-07

Jan-08

Apr-08

Date

MELs

0.00

0.10

0.20

0.30

0.40

0.50

0.60

0.70

0.80

MELs per aircraft

MELS

MELS per Aircraft
9

therefore could not legally be deferred. FAA has several open enforcement 

investigations regarding MEL authority and, in August 2008, proposed a civil 

penalty of $4.1 million against American for inappropriate use of an MEL to 

return an aircraft to service.

13

In March 2008, the principal maintenance inspector reported to senior FAA 

managers on the CMO’s response to the MEL allegations and indicated that the 

complainant did not provide any substantiating data to support the claim of MEL 

abuse. Consequently, the CMO did not assess this allegation or inspect 

American’s MEL program.14

FAA Has Not Held American Accountable for Addressing 

Longstanding Problems with Required Maintenance Inspections

 However, in April 2008, FAA identified American’s 

MEL program as one of the programs that was 2 years overdue for an inspection. 

CMO inspectors completed the inspection in May 2008—almost 7 years since the 

previous inspection. 

FAA has also failed to require American Airlines to comply with procedures for 

required inspection items (RII).

15 Mechanics performing RII inspections must 

complete biannual training on current policies and procedures to maintain their

authorization to perform these inspections. However, American has a history of 

noncompliance with RII requirements. For example, in 2007, American selfdisclosed nine noncompliances—three disclosures involved expired technician 

qualifications, and six disclosures related to RII inspections that were not 

conducted.

16 In late 2005, FAA and air carrier representatives initiated a System 

Analysis Team (SAT)17

Despite the SAT’s numerous recommendations, we confirmed the allegation that 

an American Airlines technician with an expired authorization performed an RII 

inspection on the fire-damaged MD-80 after mechanics had performed significant 

repairs on the aircraft.

to correct American’s failure to comply with RII 

inspection requirements. In May 2006, the SAT made 35 recommendations, 

including promptly notifying employees whose qualifications are about to expire.

18

 13 American officials disagreed with FAA’s proposed penalty. As of December 2009, the case remains open.

 American did not discover the RII noncompliance until 

the aircraft had been returned to service and was at a gate ready to depart with 

14 The CMO is required to inspect a carrier’s MEL policies and procedures every 5 years. 15 Required inspection items are mandatory maintenance activities that, due to their importance to the overall 

airworthiness of the aircraft, must be independently inspected by a specially trained inspector after the work is 

completed. 16 The self-disclosure program is intended to encourage data-sharing between FAA and air carriers to identify and 

address safety issues. 17 A System Analysis Team is a group of FAA and air carrier personnel that FAA CMO management can establish 

when it determines that a practice or process in place at an airline should be reviewed. Upon completing the review, 

the team makes recommendations for improvement. 18 The complainant alleged that repeat maintenance discrepancies may have led to the September 2007 in-flight fire. 

We did not perform a detailed review of this allegation since it was part of an ongoing NTSB investigation.
10

passengers. American self-disclosed this noncompliance to FAA in December 

2007. Following American’s self-disclosure, FAA requested that American 

submit a comprehensive corrective action plan within 20 days.19

American has taken some steps to address compliance with RII requirements, such 

as implementing an electronic notification system to warn mechanics when their 

authorization to perform inspections is about to expire. According to American 

Airlines officials, as of December 2009, they have implemented the majority of 

the SAT's recommendations to improve compliance with RII requirements, with 

one remaining to be implemented in April 2010.

 FAA granted 

American an extension, and in September 2008—9 months after the selfdisclosure—American submitted its plan, which proposed addressing the incident 

by counseling and retraining the mechanic involved. 

According to FAA’s principal maintenance inspector, FAA will continue to 

monitor American’s compliance with RII requirements until it is satisfied that a 

long-term corrective action is in place. To date, however, FAA’s actions have not 

elicited confidence that its oversight is sufficient. For example, in response to the 

RII allegation, the CMO assigned 1 inspector to review only 1 MD-80 aircraft—

even though the MD-80 fleet is American’s largest, with 279 aircraft.

FAA Did Not Identify Internal Process Weaknesses at American that 

Led to the Carrier’s Failure To Perform Needed Inspections

FAA did not identify process weaknesses in American’s maintenance and 

engineering programs that resulted in the carrier’s failure to perform planned 

inspections of Boeing 757 windshield heating systems. In 2006, Boeing issued a 

service bulletin alerting carriers to a problem with a windshield heating 

component on its 757 aircraft and instructed air carriers on procedures for 

correcting the problem. Left uncorrected, the component could overheat, cause 

smoke to enter the cockpit, and crack or shatter the aircraft’s cockpit windshield. 

Although American took steps to implement the inspections, neither FAA nor the 

carrier ensured the mechanics performed the work. For example:

• The engineer responsible for drafting the engineering change order—which is 

required to issue work cards to mechanics—left the company, and the order 

was never released. Without the order, American personnel could not issue

work cards instructing mechanics to perform the work. The CMO incorrectly 

concluded, however, that American cancelled the order because it opposed the 

replacement windshields called for in the service bulletin.

 19 FAA can accept self-disclosures and absolve carriers of any penalty if the carriers develop a comprehensive solution 

to keep reported safety problems from recurring.
11

• According to American officials, its engineers verbally requested in 2006 that 

quality assurance representatives inspect the Boeing 757’s windshield heat 

components as they came in for maintenance. However, the engineers did not 

document the request or inspection results, so we were unable to verify that the 

inspections were performed.

Implementing the service bulletin was not required, and, according to Boeing 

officials, correcting the identified problem would not have prevented a 

January 2008 incident as the complainant alleged. This incident involved an 

American Boeing 757 making an emergency landing after the cockpit filled with 

smoke and the inner pane of the co-pilot’s windshield shattered, blocking 

visibility.

20

Since the January 2008 incident and subsequent February 2008 allegations, 

American and FAA have initiated or taken actions to address windshield heating 

system concerns (see figure 3).

 However, service bulletins often highlight safety issues that lead to 

the issuance of an airworthiness directive. While an airworthiness directive has 

not been issued, Boeing stated that the bulletin did have safety implications based 

on prior incidents and that all air carriers were expected to comply. Yet, as of 

January 2008, American had not performed planned inspections of Boeing 757 

windshield heating systems.

 20 The January 2008 flight landed safely, but the cockpit crew was treated for injuries from the shattered glass. 
12

Figure 3. Air Carrier, FAA, and CMO Actions Taken in Response to Cockpit 

Windshield Heating Concerns

February 2008 March 2008 May 2008 September 2008

American Airlines actions are highlighted in blue.

FAA (Headquarters and CMO) actions are highlighted in yellow.

Note: As of December 2009, American Airlines officials told us that the carrier had completed 61 percent of the windshield 

replacements.

The effectiveness of FAA’s actions, however, is unclear. For example, despite the 

number and proximity of reported incidents21 involving problems with 

windshields and American’s failure to release an engineering change order for the 

windshields, FAA concluded that increased oversight was not warranted. 

Consequently, FAA inspectors were unaware of the process failures that led to 

American’s failure to perform the windshield inspections recommended by 

Boeing. FAA’s failure to complete other actions—including issuance of an 

airworthiness directive—further exacerbates risks. Specifically, as early as 2004, 

the NTSB recommended that FAA issue a directive to address the windshield 

heating problem on Boeing 747, 757, 767, and 777 aircraft. However, FAA did 

not propose the directive until March 2008, nearly 4 years later. FAA officials 

stated the delay was partly due to the need to obtain technical data from Boeing on 

other aircraft in addition to the 757.

 21 In February 2008, two additional unscheduled American landings occurred due to windshield failures—one on a 

Boeing 737 and one on a 757.

American inspects 

windshield heat 

components per 

Boeing service 

bulletin.

FAA CMO initiates 

inspections of windshield 

failures on American’s 737, 

757, 767, and 777 fleets. 

The CMO did not identify 

process failures in 

American’s engineering 

department. One 757 

inspection remains 

incomplete.

Then Acting FAA 

Administrator states in a 

memorandum that an 

airworthiness directive

requiring air carriers to 

comply with the service 

bulletin will be issued by 

July 31, 2008. As of 

December 2009, FAA had

not issued the airworthiness 

directive.

American elects to replace all 

of its Boeing 757 windshields 

with those produced by a 

manufacturer that airline 

officials told us has proven 

more reliable.

FAA proposes to 

issue an 

airworthiness 

directive

requiring carriers 

to implement the 

Boeing service 

bulletin.
13

FAA’S INDEPENDENT REVIEW OF ALLEGATIONS WAS NOT 

COMPREHENSIVE

As we recommended in September 2007, FAA developed an IAC process to 

independently review safety allegations. FAA assembled an IAC team to assess

the CMO’s response to the maintenance allegations. The team met on May 31 and 

June 1, 2008—the weekend before we began our audit at the FAA CMO. In its 2-

day assessment, the team identified problems with the thoroughness of the CMO’s 

review, such as not resolving differences of opinion between two inspectors on the 

airline’s reliability. However, the team’s review focused on the work already 

performed by the CMO, such as inspection reports filed by CMO inspectors, and 

did not conduct independent work at the air carrier. As a result, the IAC team 

reached a number of the same faulty conclusions made by the CMO, including that

American had knowingly cancelled its engineering change order to address aircraft 

windshield problems. In addition, the IAC team did not review 4 of the 

complainant’s 10 allegations, including the allegation regarding MEL abuse. A 

more comprehensive review—one that included work at the carrier—would likely 

have enabled the team to better determine the sufficiency and accuracy of the 

CMO’s inspections as well as the validity of the complainant’s allegations.

In June 2008, we recommended that FAA establish an independent organization to 

investigate safety issues identified by FAA employees. In response, FAA 

established a new organization in its Office of Chief Counsel to carry out these 

responsibilities. While we are still assessing whether this action addresses our 

concerns, we have questions about the extent to which the new office will 

coordinate IAC’s safety-related independent reviews to maximize the 

effectiveness of the independent review process and avoid unnecessary delays in 

taking needed actions. For example, CMO managers did not act on the IAC’s 

June 2008 recommendations because they did not receive a copy of the report until 

June 2009. According to FAA officials, the Agency has not decided whether IAC 

reviews will be coordinated through this new organization.

CONCLUSION

Although various factors underlie each of American Airlines’ maintenance-related 

events, a lack of adequate FAA oversight is a critical thread. This raises

significant concerns about potential maintenance weaknesses going uncorrected—

not just at American but at other air carriers. FAA’s failure to assess carriers’ 

maintenance programs, identify root causes of maintenance deferrals, ensure 

properly trained mechanics perform RII inspections, and ensure carriers promptly 

respond to recommendations and service bulletins escalates these concerns. 

Additional action is needed from FAA to enhance its routine oversight of air 
14

carriers, including American, and improve the Agency’s processes for assessing 

industry-wide safety allegations.

RECOMMENDATIONS

We recommend that FAA:

1. Begin a review of American’s CASS and reliability system to ensure that 

problems are identified and needed improvements are made. These steps 

should include a review of why American’s CASS did not detect repeat 

maintenance discrepancies that led to an in-flight fire in September 2007. 

2. Conduct comprehensive inspections of the allegations regarding operational 

reliability, MELs, RII requirements, and windshield inspections. 

Specifically, require inspectors to:

a. assess operational reliability for all fleets and the nine systems mentioned 

in the allegations;

b. evaluate American’s use of its MEL authority and potential MEL abuse;

c. ensure American corrects deficiencies with required maintenance 

inspections identified in the 2006 SAT report and carrier self-disclosures, 

including problems with mechanics’ expired RII qualifications; and 

d. verify that American is identifying and correcting problems with 

windshield heat components and that controls are in place to prevent 

internal engineering and maintenance process failures.

3. Improve data analyses by requiring the CMO analyst and inspectors to 

regularly and thoroughly review available operational reliability data, track 

the types of maintenance items that are deferred, closely monitor trends in 

maintenance deferrals, and identify reasons for any significant negative 

changes in reliability or increases in deferrals.

4. Issue the proposed airworthiness directive that would require implementation 

of the Boeing service bulletin on repairs to windshield heating components 

on 757s.

5. Improve the independent review process by:

a. performing verification work at air carriers rather than just reviewing 

FAA inspection records and ensuring that the review results are shared 

with the office under review.
15

b. coordinating all safety-related independent reviews conducted using the 

IAC process through its new Office of Audits and Evaluations.

6. Determine why FAA’s oversight did not identify the weaknesses discussed 

in this report and whether these are Agency-wide issues or limited to 

American’s CMO.

AGENCY COMMENTS AND OFFICE OF INSPECTOR GENERAL 

RESPONSE

We provided our draft report to FAA on December 22, 2009, and received its 

formal response on February 1, 2010. American Airlines officials also reviewed 

our draft report and requested that we include information on actions they have 

taken in response to the issues we found. We have updated the report where 

appropriate. FAA concurred with recommendations 1 through 5 and partially 

concurred with recommendation 6. We are requesting additional information from 

FAA on recommendations 1, 2, 3, and 6 to ensure actions taken or planned are 

well supported and fully responsive. FAA’s response is included in its entirety as 

an appendix to this report. 

In summary, FAA claimed that it had already identified most of the issues found 

in our report through its own oversight processes and that no further action was 

necessary on many of the issues. However, we take exception to this assertion 

based on the following points. First, actions are still underway, and the 

effectiveness of these actions as well as those FAA has completed is still 

uncertain. Second, FAA has not completed its national assessments to address the 

issues we identified that were potentially cross-cutting or industry-wide. Finally, 

it is important to point out that where FAA has taken action, it only did so after we 

briefed Agency officials on the need for them; therefore, we will remain vigilant in 

overseeing FAA’s implementation.

Regarding recommendation 1, FAA responded that the events surrounding flight 

1400 (in-flight engine fire in 2007) were not due to CASS issues. Based on 

American Airlines,’ the NTSB’s, and our observations, we disagree with this 

assertion. Specifically, both American Airlines and the NTSB agreed that changes 

to American’s CASS were needed since failures in American’s maintenance 

program led to this incident. In response to the NTSB’s recommendations, 

American officials took several actions to improve CASS, including improved 

oversight and tracking of repeat maintenance items and improved communication 

between their maintenance operations control and CASS departments. 

FAA asserted that no further actions are needed to address recommendations 1, 2, 

and 6. However, recognizing that many of the actions are still underway, we are 
16

requesting supporting documentation to validate that these issues are fully 

addressed. Specifically, we request that FAA provide: 

• Actions taken or planned to monitor American Airlines’ changes to its CASS 

made in response to the NTSB’s flight 1400 recommendations. 

(Recommendation 1)

• The final results of its ACEP review of American Airlines, including the 

comparative analysis of ACEP findings versus those found in routine 

surveillance. (Recommendations 1, 2, and 6)

• Actions taken or planned to assess overall deterioration in operational 

reliability at American across all fleets and the nine systems mentioned in the 

allegations. (Recommendation 2.a.)

• Actions taken or planned to address the internal process failures we identified 

at American that led to the failure to perform planned inspections.

(Recommendation 2.d.)

Finally, while FAA fully concurred with recommendation 3, we are also 

requesting information to verify that the new data analysis process being 

developed by the CMO will include a review of operational reliability data and 

types of maintenance items deferred, as we recommended.

ACTIONS REQUIRED

FAA’s planned actions and target dates for recommendations 4 and 5 are 

responsive, and we consider these recommendations addressed but open pending 

completion. In accordance with Department of Transportation 8000.1C, we 

request that FAA provide, within 30 days of this report, additional and clarifying 

information for recommendations 1, 2 (2.a and 2.d), 3, and 6. We appreciate the 

courtesies and cooperation of FAA and American Airlines representatives during 

this audit. If you have any questions concerning this report, please contact me at 

(202) 366-0500 or Robin Koch, Program Director, at (404) 562-3770.

#

cc: Assistant Administrator for Financial Services and Chief Financial Officer

 FAA Associate Administrator for Aviation Safety

 Director of Flight Standards Service

 Martin Gertel, M-100

Anthony Williams, ABU-100
Exhibit A. Scope and Methodology

17

EXHIBIT A. SCOPE AND METHODOLOGY

We conducted this audit in accordance with generally accepted government 

auditing standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence that provides a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that the 

evidence obtained provides a reasonable basis for our findings and conclusions 

based on our audit objectives. We conducted this review between June 2008 and 

December 2009. We used the following scope and methodology in conducting 

this review. 

To assess FAA’s oversight of American Airlines’ maintenance program, identify 

any underlying weaknesses, and evaluate FAA’s response to the allegations, we 

performed audit work at FAA Headquarters and FAA’s Certificate Management 

Office for American Airlines in Fort Worth, TX. We interviewed FAA inspectors 

and the operations research analyst and analyzed inspection data from FAA 

inspection databases to determine the validity of the allegations. We obtained 

inspection reports from these data sources to identify strengths and weaknesses in 

FAA’s surveillance of American Airlines as related to the allegations in the 

complaint. We also reviewed the IAC team’s final report and interviewed team 

members. 

While we did not perform an audit of American Airlines, we did assess FAA’s 

oversight by interviewing officials at American Airlines’ headquarters in Fort 

Worth, TX. In addition, we performed work at American Airlines’ largest 

maintenance base in Tulsa, OK. We reviewed American Airlines’ fleet reliability 

data and interviewed American Airlines’ maintenance and engineering personnel. 

We also reviewed NTSB findings and recommendations concerning maintenance 

at American.

We interviewed industry safety experts (e.g., NTSB) to obtain their opinions on 

the windshield heating issue and contacted appropriate Boeing Commercial 

Airplane Company representatives regarding service bulletin processes to 

determine their view of the importance of the service bulletin related to windshield 

heating units on certain models of Boeing aircraft.
Exhibit B. Entities Visited or Contacted

18

EXHIBIT B. ENTITIES VISITED OR CONTACTED 

Federal Aviation Administration (FAA) 

Headquarters: 

Flight Standards Service Washington, DC 

Certificate Management Offices (CMO): 

American Airlines CMO Fort Worth, TX 

Air Carrier 

American Airlines Headquarters Fort Worth, TX

American Airlines Maintenance & Engineering Facility Tulsa, OK

Other Industry Representatives or Organizations

Allied Pilots Association (APA) Fort Worth, TX

Transport Workers Union (TWU) Tulsa, OK

National Transportation Safety Board (NTSB) Washington, DC

The Boeing Commercial Airplane Company Seattle, WA
Exhibit C. Major Contributors to This Report

19

EXHIBIT C. MAJOR CONTRIBUTORS TO THIS REPORT 

Robin Koch Program Director

Name Title

Marshall Jackson Project Manager

Christopher Frank Senior Auditor

Travis Wiley Analyst

Doneliya Deneva Auditor

Karen Sloan Communications Officer 

Andrea Nossaman Writer/Editor
Appendix. Agency Comments

20

APPENDIX. AGENCY COMMENTS

Federal Aviation 

Administration 

Memorandum

Date: February 1, 2010

To: Lou Dixon, Assistant Inspector General for Aviation and Special Program 

Audits

From: Ramesh K. Punwani, Assistant Administrator for Financial Services/CFO

Prepared by: Anthony Williams, x79000

Subject: OIG Draft Report: FAA’s Oversight of American Airlines Maintenance

Programs

Safety is at the heart of the Federal Aviation Administration's (FAA) mission, and every day

thousands of inspectors around the country work to identify and ensure that appropriate action is 

taken to address safety issues on air carriers large and small. Our system of maintenance 

oversight is multifaceted and looks at both specific problems and seeks to identify trends 

characteristic of systemic issues. The agency requires carriers to take action and make corrections 

and does not hesitate to level civil penalties to further effect change in maintenance practices. In 

fact, over the last 24 months the Agency's routine oversight has resulted in around $4.4 million in 

proposed civil penalties related to American Airline's maintenance programs.

The FAA's oversight of safety programs at American Airlines resulted in the implementation of 

strong and effective measures in ten specific areas of the air carrier's maintenance program. After 

careful review of the Office of Inspector General's (OIG) draft report, FAA has determined that 

the issues identified in the report are largely the same items that the FAA previously documented 

using its safety oversight processes. While not described in the OIG report, the actions on these 

measures have either been completed or are underway. The FAA will continue to ensure the 

carrier fully and effectively completes the actions through enhanced oversight by its American 

Airlines Certificate Management Team (CMT).

The FAA launched an Air Carrier Evaluation Program (ACEP) of American Airlines last year as 

a result of routine oversight by the CMT, which found problems with the carrier's airworthiness 

directive compliance. The ACEP revealed many of the same weaknesses detailed in the OIG 

audit, including: a high number of open maintenance deferrals; airworthiness directive 

compliance and management; and handling of engineering, major repairs, and alterations. FAA 

has been working to ensure the carrier elevates its maintenance practices and makes needed 

changes, including overhauling its Continuing Analysis and Surveillance System (CASS).
Appendix. Agency Comments

21

FAA's evaluation of American Airlines also clarified some areas where the Agency's 

maintenance oversight could be further strengthened. As a result, the Agency initiated three

actions that will enhance oversight of all carriers. First, FAA launched a national Air Carrier

Evaluation Program that uses a risk-based targeting process to make certain all part 121 air

carriers are evaluated by national teams on a recurring basis. Second, FAA is using the new

Corrective Action Tracking Tool (CATT) in the Air Transportation Oversight System (ATOS) 

software to track timely, effective completion of corrective actions. CMT managers and 

inspectors are required to use this tool to document required corrective actions so the FAA knows 

they were completed by the air carrier on time. Finally, the Flight Standards Evaluation Program 

(FSEP) is auditing FAA field offices to make sure they are operating according to national 

procedure. 

As noted above, the FAA has taken a number of actions that are responsive to the findings and 

recommendations in the OIG report. However, we appreciate the recommendations enumerated 

by the OIG, and believe they further support FAA's previous findings and corrective actions. The 

IG’s efforts continue to provide a positive contribution to our continuous efforts to further 

strengthen and fine tune our approach to safety oversight.

OIG Recommendation 1: Begin a review of American's CASS and reliability system to ensure 

that problems are identified and needed improvements are made. These steps should include a 

review of why American's CASS did not detect repeat maintenance discrepancies that led to an 

in-flight fire in September 2007.

FAA Response: Concur. FAA initiated efforts, based on the findings from the CMT and the

ACEP as indicated above, which have already resulted in significant improvements to American 

Airlines' CASS. This includes enhanced CASS program staffing at the airline, revised and 

improved CASS guidance, and improved information systems.

While FAA continues to closely monitor the effectiveness of American Airlines' actions with

respect to its CASS program, it is important to recognize that CASS is intended to provide a

strategic tool to help airlines identify trends that may lead to safety issues and is not intended to 

be a tactical tool capable of addressing individual component failures. While the complainant's 

allegations led OIG to focus on the accident involving American Airlines flight 1400 as a failure 

of American Airlines' CASS, FAA's review of maintenance records indicate that the systems 

performance issues involved in the accident would not typically be identified through CASS as a 

chronic problem. Specifically, FAA's review identified an error in the National Transportation 

Safety Board's (NTSB) data. While NTSB's data indicated the errant start valve was changed six 

times, further review indicates it was actually changed four times and the third valve operated 

normally for 25 flights over the course of seven days. The fourth valve failed after installation 

and was deferred the very next flight (flight 1400). This performance would not typically be 

flagged as an issue by the CASS program. As a result of the changes already implemented, and 

the data error issue, no further action is necessary to address American Airlines' CASS with 

regard to the issues surrounding flight 1400.

Nonetheless, FAA recognized the need to take action to address the type of situation that arose 

surrounding flight 1400. As a result, since this accident, the American Airlines CMT's oversight 

has led to improvements in American's FAA approved Reliability Program. These improvements 

include automated web-based reporting, standardization of product team activity reports, 

automated mean-time-between-unscheduled-removal reporting, FAA sponsored system analysis 
Appendix. Agency Comments

22

team (SAT), development and deployment of a web-based chronic aircraft reliability analysis 

tool, and the establishment of a dedicated reliability engineering group under separate company 

management.

OIG Recommendation 2: Conduct comprehensive inspections of the allegations regarding

operational reliability, MELs, RII requirements, and windshield inspections. Specifically,

require inspectors to:

a. assess operational reliability for all fleets and the nine systems mentioned in the 

allegations;

b. evaluate American’s use of its MEL authority and potential MEL abuse;

c. ensure American corrects deficiencies with required maintenance inspections 

identified in the 2006 SAT report and carrier self-disclosures, including problems 

with mechanics’ expired RII qualifications; and 

d. verify that American is identifying and correcting problems with windshield heat 

components and that controls are in place to prevent internal engineering and 

maintenance process failures.

FAA Response: Concur.

a. assess operational reliability for all fleets and the nine systems mentioned in the 

allegations;

The February 2008 complaint focused on a degradation of operational reliability for all fleets to 

include recordable in-flight events involving smoke/fire, landing gear, engines, fuel, hydraulics, 

electrics, radar, flight controls and air conditioning/pressurization. The only specific examples of 

reliability degradation cited by the complainant focused on MD-80 nose gear retraction failures, 

B-757 windshield failures, and an A300 yaw damper problem. Through a series of surveillance 

activities, the CMT assessed performance of the above mentioned systems and determined 

problems existed in the MD-80 nose gear retraction system, the B-757 windshield heat system, 

and an isolated, single event involving an A300 yaw damper malfunction.

The CMT's oversight led American to implement nose landing gear strut pressure checks on a

monthly basis as well as strut fluid changes on a 14 month interval starting in April 2007. Since 

American flight 1400 in September 2007, American Airlines has implemented additional 

maintenance program changes to improve MD-80 nose landing gear retract system performance. 

These program improvements include improved spray deflector repair requirements and 

additional landing gear strut visual inspections. These changes far exceed the original equipment 

manufacturer recommended requirements.

The B-757 windshield heat issue is discussed in paragraph d below. The A300 yaw damper

issue was investigated and the FAA determined American correctly diagnosed and repaired the 

malfunction. As a result, while the CMT will continue to conduct careful surveillance of

American Airlines' management of maintenance issues, no further action is necessary to address 

this recommendation.

b. evaluate American's use of its MEL authority and potential MEL abuse;

FAA conducted an evaluation of MEL authority and its implementation at American and found 

that multiple American Airlines' initiatives reduced open minimum equipment list (MEL) to 
Appendix. Agency Comments

23

approximately 354 in January 2009, with a further reduction to 254 by November 2009. 

According to the Air Transport Association (ATA), the industry averages approximately 0.5 open 

MELs per aircraft per day. Based on American Airlines' November 2009 data, American 

averaged 0.42 open MELs per aircraft per day, slightly below industry averages.

CMT assessments of American Airlines' MEL management since September 2007 concluded

that American's MEL process design and performance is satisfactory. Further, two design

assessments completed since 2007 identified deficiencies that have been addressed through

program revisions. The latest design and performance assessments, conducted during the ACEP 

in the third and fourth quarters of fiscal year 2009, identified items of concern in performance 

which were evaluated and found acceptable. As a result, while the CMT will continue to conduct 

careful surveillance of MEL management, no further action is necessary to address this 

recommendation.

c. ensure American corrects deficiencies with required maintenance inspections 

identified in the 2006 SAT report and carrier self-disclosures, including problems 

with mechanics' expired RII qualifications;

The required inspection items (RII) SAT initiated in January 2006 made 35 recommendations for 

program improvements. Following completion of the SAT in April 2006, the team continued as a 

collaborative working group (American Airlines management, Transport Workers Union, and 

FAA) until July 2008 to address the recommendations. American implemented numerous 

corrective measures, which include increased awareness of RII requirements, training, and 

system improvements. Of the 35 RII program recommendations produced by the SAT, the airline 

has incorporated 22, the working group determined 12 did not provide value to the process, and 

one will be implemented by April 2010.

The comprehensive fixes put in place by American Airlines can be seen in a significant reduction 

in RII events over the last three years. Major program improvements include identification of RII 

tasks in the aircraft maintenance manuals, restrictions on temporary RII authorizations, 

confirmation and critical items check policies were eliminated to avoid confusion with the RII 

program, a personalized "expired qualification" notice displayed when the employee signs on to 

the corporate website, a monthly "training dashboard" distributed system wide, annual RII 

awareness training regardless of RII authorization, and a monthly expired-qualifications report 

distributed system wide. The third quarter 2009 ACEP confirmed RII system design, and its 

performance was affirmed one month later. As a result, while the CMT will continue to conduct 

careful surveillance of these issues, no further action is necessary to address this 

recommendation.

d. verify that American is identifying and correcting problems with windshield heat 

components and that controls are in place to prevent internal engineering and 

maintenance process failures.

American Airlines' engineering analysis demonstrated that the failures were due to design 

deficiencies which would not be addressed by Boeing service bulletins 757-30-19 and 

757-30-20. Recognizing this shortcoming, American opted to replace all of the suspect window 

assemblies with new windows from a different manufacturer. American has completed more than 

75% of these replacements. American's efforts in this arena go well beyond Boeing's 

recommendations and there have been no additional instances of windshield failure in this 
Appendix. Agency Comments

24

manner since this event in early 2008. As a result, while the CMT will continue to conduct 

careful surveillance of this issue, no further action is necessary to address this recommendation.

OIG Recommendation 3: Improve data analyses by requiring the CMO analyst and inspectors

to regularly and thoroughly review available operational reliability data, track the types of

maintenance items that are deferred, closely monitor trends in maintenance deferrals, and identify 

reasons for any significant negative changes in reliability or increases in deferrals.

FAA Response: Concur. The American Airlines CMT manager will establish a local process to 

gather and analyze data in order to better identify adverse trends in American's operation. This

process will specifically focus on MEL rates, delays, cancellations, MEL extensions, and 

maintenance escalations.

A quarterly report of the data will be generated by the American Airlines unit operations

research analyst. This report will be issued to the Principal Inspectors (PIs) and Partial Program 

Managers (PPMs). The PIs and PPMs will review the data looking for adverse trends that may 

warrant special targeted surveillance in order to reverse these adverse trends.

Preventive Action Request (PAR) P-10-81 was generated to create this process for inclusion in 

the American CMT's quality manual. This process will be in place and the first report produced 

no later than June 2010.

OIG Recommendation 4: Issue the proposed airworthiness directive that would require

implementation of the Boeing service bulletin on repairs to windshield heating components on

757s.

FAA Response: Concur. On March 5, 2008, the FAA issued notice of proposed rulemaking

(NPRM) 2008-NM-038-AD to address reports of window heat system malfunctions on Boeing

models 757, 767, and 777 airplanes, causing electrical arcing. Specifically, the NPRM addressed

the lower electrical connectors of the windshields. We received extensive comments during the

NPRM comment period. We are currently reviewing the NPRM comments and expect to issue

the final rule before the end of February 2010.

Although an Airworthiness Directive for the B-757 windshield failures has not been issued,

American Airlines revised its maintenance program to replace all B-757 windshields with the

PPG products outlined in the service bulletin. As stated above, American Airlines is 75%

complete on B-757 windshield replacement. The American Airlines CMT will conduct follow-up

reviews to ensure 100% completion.

OIG Recommendation 5: Improve the independent review process by:

a.performing verification work at air carriers rather than just reviewing FAA inspection 

records and ensuring that the review results are shared with the office under review;

b.coordinating all safety-related independent reviews conducted using the IAC process 

through its new Office of Audits and Evaluations.

FAA Response: Concur. FAA will revise its independent review process to include verification 

of work performed, in addition to reviewing FAA inspection records. We will also revise our 

independent review process to ensure the results of the review are shared with the office under 

review so that all safety concerns are addressed in a timely manner. These revisions will be 
Appendix. Agency Comments

25

incorporated into the Flight Standards Service (AFS) Internal Assistance Capability Document 

by June 30, 2010.

Flight Standards Service (AFS) Internal Assistance Capability (IAC) is devoted to fact finding,

assessing, and making recommendations on matters of special interest to AFS top leadership.

While AFS will continue to direct and manage this process, the FAA believes the Office of Audit

and Evaluation (AAE) can add value to the process by performing quality assurance functions

with respect to IAC results and reviews. Accordingly, effective immediately, AAE will review

final reports from IAC reviews for accuracy and completeness. AAE will also evaluate whether

the IAC review was fair and followed established AFS processes. These new responsibilities are

consistent with AAE's role to coordinate and provide independent quality control of certain

investigations and to assess whether investigations and resolutions are fair, impartial and in

conformance with established processes.

OIG Recommendation 6: Determine why FAA's oversight did not identify the weaknesses

discussed in this report and whether these are Agency-wide issues or limited to American's 

CMO.

FAA Response: Partially concur. As described above, FAA's oversight identified many of the

weaknesses discussed in this report. For example, FAA's American Airlines CMT and the

ACEP review of American Airlines identified discrepancies requiring corrective action in the

following areas:

• required inspection items;

• MEL/configuration deviation list;

• AD management;

• engineering/major repairs and alterations;

• continuous analysis and surveillance;

• weight and balance program;

• extended operations (ETOPS);

• carry-on baggage;

• training of station personnel; and

• station facilities.

The ACEP evaluation of American Airlines took place from April to September 2009 and 

warrants discussion in the OIG report as ACEP evaluations are an important part of the FAA's 

oversight of part 121 air carriers. Furthermore, routine surveillance conducted by the American 

Airlines CMT discovered many of the weaknesses discussed in the report. In many cases, 

American Airlines failed to complete corrective actions in a timely and effective manner. We 

implemented a new software tool to help us make sure that airline performance improves in this 

regard (see below).

Overall, FAA initiated the following actions to strengthen its oversight of all air carriers:

1. We are supplementing routine surveillance with a national air carrier evaluation 

program. The national ACEP program uses a risk-based targeting process and ensures 

that all part 121 air carriers will be evaluated by national teams on a recurring basis. A 

component of the national program will be a comparative analysis of ACEP findings 
Appendix. Agency Comments

26

versus those discovered during routine surveillance. Where statistically significant 

differences exist, further analysis will seek root causes that result in system 

improvements such as changes to data collection tools, handbook guidance, or training 

curricula.

2. We are following up on air carrier corrective actions using a new software tool. We 

deployed the Corrective Action Tracking Tool (CATT) in our ATOS software to track 

timely, effective completion of corrective actions. CMT managers and principal 

inspectors must use the CATT to document corrective actions required of air carriers and 

to ensure that actions are completed in a timely manner.

3. We are ensuring that inspectors follow FAA policy. In addition to the national ACEP 

program, the FSEP is being used to assess whether FAA offices operate according to

national policy. The objective of this program is to audit our offices to determine if they 

are providing surveillance and analysis of the ATOS program for performance and 

effectiveness and are implementing corrective action of any deficiency. This initiative 

was beta tested in July 2009. It was used effectively on an audit in November 2009. It is 

scheduled for five more audits through 2nd quarter of fiscal year 2010 and approximately 

14 total audits for the fiscal year.

As a result, while FAA will continue along these and other lines to ensure that it provides useful 

and effective safety oversight to the nation's air carriers, no further action is necessary to address 

this recommendation.