ACTIONS TAKEN TO ADDRESS 

ALLEGATIONS OF UNSAFE MAINTENANCE 

PRACTICES AT NORTHWEST AIRLINES

Federal Aviation Administration 

Report Number: AV-2007-080 

Date Issued: September 28, 2007 
U.S. Department of 

Memorandum

Transportation 

Office of the Secretary 

of Transportation 

Office of Inspector General 

Subject: ACTION: Actions Taken To Address Allegations 

of Unsafe Maintenance Practices at 

Northwest Airlines 

Federal Aviation Administration 

Report Number AV-2007-080 

Date: September 28, 2007 

From: David A. Dobbs 

Principal Assistant Inspector General 

 for Auditing and Evaluation 

Reply to 

Attn. of: JA-1 

To: Acting Federal Aviation Administrator 

This report presents the results of our audit of the Federal Aviation 

Administration’s (FAA) actions taken to address allegations of unsafe 

maintenance practices at Northwest Airlines (Northwest). These allegations were 

reported by an FAA Aviation Safety Inspector (the complainant) assigned to 

FAA’s Northwest Airlines Certificate Management Office (CMO) in 

Bloomington, Minnesota. 

The complainant alleged that Northwest’s actions during the aircraft mechanics’ 

strike—initiated against the airline on August 20, 2005—created a public safety 

risk. Specifically, the complainant alleged that Northwest’s replacement 

mechanics and management personnel transferred into maintenance roles were not 

appropriately trained and that processes involving receipt of aircraft parts were 

improperly conducted. The complainant contacted then Minnesota Senator Mark 

Dayton, who requested that FAA and the Office of Inspector General (OIG) 

evaluate the validity of these allegations. 

To avoid duplicative efforts, we monitored FAA’s review processes and results to 

evaluate both FAA’s response to the complainant and the validity of the 

allegations. To accomplish this objective, we interviewed the complainant, 

accompanied FAA review team members as observers during their on-site work, 

and met extensively with FAA officials to review the conclusions they developed 

and planned to report. 
 2

In addition, our investigative staff interviewed CMO inspectors and managers, 

who also expressed a desire to discuss problems related to the CMO’s oversight. 

We provided a summary of the concerns identified during these interviews to FAA 

Headquarters in October 2005. We also briefed Senator Dayton and his staff on 

our audit and investigative results in October 2005. Exhibit A contains further 

details on our scope and methodology. Exhibit B provides details on the results of 

our investigative staff interviews. 

BACKGROUND 

In August 2005, approximately 4,400 Northwest Airlines mechanics went on 

strike. Northwest replaced these mechanics with a combination of management 

representatives, newly hired mechanics, and contract mechanics. FAA responded 

to the strike by sending its inspectors to perform focused oversight in locations 

where Northwest had major operations. FAA management reported that 

Northwest continued to operate safely despite the mechanics’ strike. 

However, on August 22, 2005, an FAA inspector performing oversight at 

Northwest expressed concerns that Northwest had not adequately trained its 

replacement mechanics for their new responsibilities and that it had made other 

changes that negatively affected its operations. For example, the complainant 

stated that the parts receiving procedures had been changed to speed up 

processing, but that these changes had resulted in a more limited review of 

repaired parts. The inspector submitted his concerns to FAA in the form of a 

safety recommendation and filed a complaint about Northwest’s operations and 

FAA’s oversight with Senator Mark Dayton’s office. 

At the same time, Northwest officials complained to the CMO that the 

complainant’s conduct was interfering with Northwest operations. On 

August 29, 2005, Northwest management officials notified the CMO that it would 

no longer permit the complainant to have unescorted access to Northwest 

facilities. According to Northwest officials, the complainant had displayed 

disruptive and unprofessional behavior in his interactions with Northwest 

employees and vendors. As a result of these complaints, CMO managers 

reassigned the complainant to office duties and restricted him from performing 

oversight on Northwest Airline premises. 

Our investigative staff reviewed the validity of Northwest’s allegations as well as 

the propriety of actions that CMO management had taken against the complainant 

in response to these allegations. Generally, we could not conclude that 

Northwest’s concerns were baseless or fabricated. We determined that Northwest 

had documented complaints about the inspector going back many years. 
 3

According to Northwest, FAA’s response to its prior complaints about the 

inspector had not been effectively handled. 

However, the airline’s August 29, 2005, letter of complaint came within days of 

the beginning of the mechanics’ strike. The letter also followed several inspection 

findings identified by the complainant criticizing Northwest’s operations. The 

CMO’s reassignment of the complainant in response to the airline’s complaints 

removed a highly experienced inspector from on-sight duties when Northwest’s 

operations were most affected by labor problems. We encouraged the CMO to 

establish a “clean slate” with the complainant and provide him with training and 

feedback so he could address concerns about his interactions with Northwest 

officials and function as an effective aviation safety inspector. Further, while 

there may have been merit to some of the airline’s concerns with the complainant, 

it was incumbent upon FAA to determine the validity of the complainant’s safety 

concerns about Northwest’s operations. 

RESULTS IN BRIEF 

In reviewing FAA’s actions to investigate the complainant’s safety concerns, we 

determined that FAA needs better procedures for responding to and resolving 

safety complaints identified by its inspectors. Currently, FAA does not require 

that internal allegations about safety oversight be investigated by staff independent 

of the office where the complaint is generated. It also does not require that review 

results be published or that, where appropriate, involved staff be held accountable 

for remedying any identified problems. Circumstances surrounding FAA’s 

handling of safety allegations at Northwest underscore the need for FAA to 

develop better review processes. 

On September 7, 2005, FAA dispatched a three-member inspection team to review 

inspector allegations of unsafe maintenance practices and FAA’s oversight of 

Northwest. We accompanied FAA on this review and immediately identified 

concerns with the composition of the review team and the team’s review 

procedures. Two of the three FAA review team members were from the Great 

Lakes regional office in Des Plaines, Illinois. The Manager of the Northwest 

CMO, where the complainant works, reports directly to the Division Manager in 

the Great Lakes office. The complainant questioned whether team members from 

the Great Lakes office would be objective in their review. 

We encouraged FAA to use team members that were not associated with the 

Northwest CMO to prevent any questions about the impartiality of the review 

team. However, FAA’s Director of Flight Standards Service advised us that the 

review was a regional office responsibility. Therefore, he declined to change the 
 4

team members, stating that one of them was an experienced office manager from 

another region. 

FAA’s first review team did not thoroughly review the complainant’s 

allegations. Once on site at the CMO and Northwest offices in September 2005, 

FAA’s team performed a very limited review of the complainant’s allegations. In 

August and September of 2005, FAA inspectors responsible for oversight of 

Northwest’s operations identified at least 121 findings related to replacement 

mechanics’ lack of knowledge or ability to properly complete maintenance tasks 

and maintenance documentation. Even though the review team was aware of 

these findings, the team’s only action to examine the complainant’s allegation that 

replacement mechanics were not properly trained was a review of the mechanics’ 

training files. 

The team did not conduct independent observations of replacement mechanics 

actually performing maintenance tasks and did not assess the 121 inspection 

findings in its review of mechanic training. Nevertheless, in November 2005, 

FAA reported that Northwest had revised the training program that technicians 

had to complete before performing maintenance tasks while unsupervised. This 

action confirmed that the complainant’s concerns about mechanic training were 

valid and helped to ensure that Northwest continued to operate safely. 

From September 2005 to December 2005, we met extensively with FAA and 

encouraged a more comprehensive review of the complainant’s allegations. 

During the same period, our office was receiving calls from Northwest employees 

related to concerns about Northwest operations. During interviews with CMO 

personnel, OIG investigative staff determined that other inspectors performing 

oversight of Northwest also shared the complainant’s concerns (see exhibit B). 

Specifically, these inspectors stated that replacement workers were not receiving 

proper training and were not properly addressing technical problems as they arose. 

They also stated that CMO management discouraged the use of civil penalties, 

thus leading to ineffective oversight of the carrier. We provided FAA with a 

summary of these inspectors’ concerns in October 2005. As a result, FAA formed 

a second review team to follow up on these issues. 

FAA performed a second review but did not properly respond to the 

complainant or ensure that the CMO took corrective action for identified 

deficiencies. In November 2005, FAA agreed to initiate a second review to 

follow up on our concerns regarding its first review and other inspectors’ concerns 

expressed to our investigative staff. This review was performed by a more 

independent team consisting of representatives from FAA Headquarters and other 

regions. Although the review validated more of the concerns identified by the 

complainant, FAA did not use the results to ensure that the CMO took action to 

resolve identified problems. 
 5

More importantly, despite finding that the complainant had valid concerns, FAA 

issued a letter to the complainant in February 2006 indicating that all of his safety 

recommendations lacked merit. For example, the complainant recommended that 

Northwest revise its mechanic training program. Even though the CMO directed 

Northwest to revise the program, FAA Headquarters advised the complainant that 

this recommendation was a subjective, unsupported opinion. This created the 

appearance that FAA had determined the complainant’s allegations had merit and 

that corrective action by Northwest was necessary but did not want its written 

response to acknowledge the validity of the concerns. 

The CMO initiated several actions against Northwest requiring that it correct 

problems identified by FAA inspectors. For example, FAA wrote a letter of 

correction to Northwest for inappropriately changing its parts receiving procedures 

and required that the carrier correct this problem. FAA’s decision to issue the 

letter of correction validated another of the complainant’s allegations. However, 

FAA never formally issued the full results of the reviews it conducted with 

recommendations to the CMO for improving its oversight at Northwest. Our 

recommendations for improving FAA’s review procedures are listed on page 8. 

FINDING 

FAA Needs To Develop Better Procedures for Investigating and 

Resolving Inspector Safety Recommendations and Concerns 

FAA established a process for performing increased oversight of Northwest 

operations when the mechanics’ strike began, and more than 800 FAA inspections 

were completed within the first 2 months of the strike. FAA also took steps to 

require that Northwest enhance its training program for replacement mechanics to 

ensure that the airline continued to operate safely. However, when one of its 

inspectors raised safety concerns, FAA did not demonstrate a willingness to 

thoroughly review and address the issues that the complainant identified. In fact, 

FAA informed the complainant that all of his concerns lacked merit, even though 

its own reviews of the allegations determined that some of the issues, such as 

problems with replacement mechanic training, were valid. 

FAA’s review process had significant shortcomings. Specifically, FAA did not 

conduct comprehensive, objective reviews; release a report of its findings showing 

how it resolved the complainant’s concerns; or hold the CMO accountable for 

correcting the safety and oversight deficiencies identified by its review teams and 

our investigative staff. To promote greater information sharing and the Agency’s 

commitment to safety, FAA needs to develop better processes for responding to 

inspector concerns. 
 6

FAA Did Not Objectively Review and Respond to the Complainant’s Safety 

Recommendation 

In August 2005 and again in October 2005, the complainant submitted 

recommendations to FAA’s Office of Accident Investigation, which is responsible 

for administering FAA’s Safety Recommendation Program. This program is used 

to identify and correct safety deficiencies in the National Airspace System and to 

prevent accidents and incidents. Although the complainant submitted his concerns 

to FAA in the form of a safety recommendation, the information mirrored the 

allegations sent to Senator Dayton. Specifically, that: 

• Northwest’s replacement mechanics were inadequately trained, 

• Northwest’s parts receiving processes were improperly conducted, and 

• FAA’s CMO management was not responsive to inspector concerns about 

Northwest. 

The Office of Accident Investigation forwarded the complainant’s allegations and 

safety recommendations to FAA’s Director of Flight Standards Service for action, 

in accordance with FAA Order 8020.11B, Aircraft Accident and Incident 

Notification, Investigation, and Reporting. 

On January 19, 2006, the Director issued a response to the Office of Accident 

Investigation summarizing the Agency’s conclusion on the complainant’s safety 

recommendations. Despite the fact that its two review teams confirmed that some 

of the complainant’s concerns were valid (e.g., the concern about training for 

replacement mechanics), FAA essentially concluded that all his safety 

recommendations lacked merit. This determination appeared to focus on the fact 

that, in FAA’s view, the recommendations were not consistent with FAA 

procedures for submitting safety recommendations. After reviewing the Director’s 

response, the Office of Accident Investigation issued a letter to the complainant on 

February 21, 2006, stating that the recommendations were closed and not adopted. 

We agree that some of the complainant’s recommendations focused more on 

concerns with operations in the CMO rather than direct safety issues at Northwest; 

however, many of the concerns about Northwest and the CMO’s oversight were 

valid. For example, FAA’s first review team acknowledged in its November 2005 

report that Northwest’s initial replacement training program was not effective. 

Yet, in response to the complainant’s recommendation that Northwest revise its 

aircraft mechanic and inspector training programs to ensure that mechanics and 

inspectors are competent to perform maintenance tasks, FAA officials advised the 

complainant in February 2006 that this recommendation was a subjective, 

unsupported opinion. 
 7

In this case, it appears that FAA’s review teams were not able to address the 

complaints in an objective way. FAA’s handling of the complainant’s safety 

concerns appeared to focus on discounting the validity of the complaints rather 

than determining whether there were conditions at Northwest and the Northwest 

CMO that needed correction. A potential negative consequence of FAA’s 

handling of this safety recommendation is that other inspectors may be 

discouraged from bringing safety issues to FAA’s attention. 

FAA needs to clarify its policy for reviewing inspector safety recommendations 

and ensure that the response to such recommendations remains focused on the 

substance of safety concerns, not the format in which they are submitted or the 

personal issues with the inspector who submits them. FAA might have 

accomplished that in this situation had it assigned an impartial review team. 

FAA Needs To Hold the Northwest CMO Accountable for Correcting 

Identified Safety Deficiencies 

FAA has not taken sufficient action to verify that the CMO has corrected 

deficiencies identified by its two review teams. FAA’s second review team 

conducted on-site testing at Northwest in November and December of 2005 and—

unlike the first review team—determined that at least 14 of the concerns expressed 

by inspectors and managers had merit. For example, the second review team 

determined that: 

• The CMO had not acted on the individual events that were listed in the 

complainant’s allegation and identified by other CMO inspectors in the weeks 

following the strike. 

• The CMO could have been more aggressive in pursuing enforcement actions 

against Northwest where warranted. The review team determined that the 

CMO had not issued any civil penalties against Northwest in fiscal years 2004, 

2005, and 2006. 

The second review team also identified a problem with how the CMO resolved 

safety allegations. The CMO investigated an allegation that a Northwest manager 

had signed off on a test that was not actually completed to expedite getting an 

aircraft back into service. The CMO concluded that there had been no regulatory 

violation, even though it confirmed that the manager did not complete the test and 

was not qualified to sign off on it. The second review team recommended that the 

CMO re-open the complaint. 

FAA finalized the report on its second review in June 2006. However, we found 

no evidence indicating that the report was issued to the CMO or that FAA’s Office 

of Flight Standards Service planned to verify that the findings and other inspector 
 8

concerns would be addressed. In fact, even though one of the findings in the 

second team’s report was that the CMO had not acted on issues identified early in 

the strike, the team left it to the CMO to further investigate and resolve the 14 

concerns expressed by inspectors and managers. 

The review team and the Office of Flight Standards Service also left it to the CMO 

to ensure that issues identified in more than 800 FAA inspection reports on 

Northwest’s operations would be addressed and resolved. The CMO should be 

required to report to the Director of Flight Standards Service on actions taken by 

the CMO and Northwest to resolve deficiencies identified by inspectors and FAA 

review teams. 

RECOMMENDATIONS 

We recommend that the Acting Federal Aviation Administrator: 

1. Require the Flight Standards Service to establish better internal review 

procedures to ensure that comprehensive, independent investigations of safety 

allegations and recommendations are consistently performed. 

2. Require the CMO in Bloomington, Minnesota, to report to the Director of 

Flight Standards Service on actions taken by the CMO and Northwest to 

resolve deficiencies identified by inspectors and FAA review teams. 

AGENCY COMMENTS AND OIG RESPONSE 

On September 25, 2007, FAA provided comments to our July 26, 2007, draft 

report. FAA’s full response is included in the appendix to this report. FAA 

concurred with both of our recommendations. FAA agreed to establish a new 

internal review capability that would allow it to perform independent assessments 

of safety allegations. FAA plans to implement this capability by 

September 30, 2008. In addition, FAA agreed to require the CMO in 

Bloomington, Minnesota, to report by November 2007 on actions taken by the 

CMO and Northwest to resolve deficiencies identified by inspectors and FAA 

review teams. FAA stated that the report would first be issued to the Division 

Manager in the Great Lakes region and then forwarded to the Director of Flight 

Standards Service. When properly implemented, these actions will satisfy our 

recommendations. Therefore, we consider the recommendations resolved. 

Although FAA concurred with both recommendations, the Agency identified three 

areas in our report in which it respectfully disagreed with our conclusions: 
 9

Safety Recommendations: FAA disagreed with our conclusion that it did not want 

to document the fact that some of the complainant’s concerns were valid. FAA 

stated that Flight Standards Service policy staff reviewed the complainant’s safety 

recommendations independently from the two FAA review teams and concluded 

that the recommendations did not contain the necessary, substantiating 

information. 

Our conclusion that FAA’s response to the complainant gave the appearance that 

FAA did not want to acknowledge the validity of the complainant’s concerns is 

based on FAA’s conflicting statements about the same issue. As stated in the 

report, FAA’s review team reported that Northwest’s initial mechanic training 

program was not effective; yet, it advised the complainant that his assertion related 

to inadequate mechanic training was an unsupported, subjective opinion. 

Also, the personnel conducting the reviews and those reviewing the complainant’s 

safety recommendations all reported their findings to the Director of Flight 

Standards Service. Therefore, results and data disclosed as part of the two FAA 

reviews were readily available to the Director and, in our view, should have been 

considered when reviewing and responding to the safety recommendations. 

Training: FAA also suggested that it did not adopt the complainant’s 

recommendation to improve mechanic training because the CMO was already 

addressing the problem. FAA stated that the CMO documented 16 meetings with 

Northwest management from April 2005 to August 2005, in which they discussed 

mechanic training. However, FAA did not provide information to verify that 

CMO staff actually discussed training concerns during these meetings. In 

addition, these 16 meetings all occurred before the strike. During FAA’s first 

review of the allegations, the CMO manager advised us that the CMO was 

comfortable with the mechanic training in place before the strike. The CMO 

manager did not become concerned about mechanic training until after the strike 

began, and after the complainant submitted his safety recommendations. 

Accordingly, we concluded that FAA’s assertion is not supported by the facts. 

Composition of First Review Team: FAA disagreed that the Director of Flight 

Standards Service declined our recommendation to change the composition of the 

first review team. FAA stated that the team leader was an experienced office 

manager from the Eastern Region who was selected for the review team by the 

Director of Flight Standards Service. Also, FAA stated that while the other two 

team members were staffers who reported to the same regional division manager 

as the CMO manager, they were not in line of authority for operations between the 

CMO manager and the regional division manager. 

We acknowledged in our report that the first review team included a manager from 

another region. However, the complainant had already expressed concerns that 
 10

staff from the Great Lakes Region would not be objective in assessing his 

recommendations. We advised the Director of Flight Standards Service of this 

concern prior to the start of the review, but he chose to dismiss our concerns and 

those of the complainant. We continue to believe that FAA’s first review team 

lacked the appearance of objectivity. 

ACTION REQUIRED 

FAA’s planned actions satisfy the intent of our recommendations. Since FAA’s 

response indicated that it disagreed with our core findings and conclusions, we 

will follow up, according to the provisions of DOT Order 8000.1C, to ensure that 

the Agency’s corrective actions are consistent with our recommendations until the 

final actions are completed. 

We appreciate the cooperation of FAA representatives during this audit. If you 

have any questions concerning this report, please contact me at (202) 366-1427 or 

Lou Dixon, Program Director, at (202) 366-0500. 

# 

cc: FAA Associate Administrator for Safety 

 FAA Chief of Staff 

 Anthony Williams, ABU-100 
11

EXHIBIT A. SCOPE AND METHODOLOGY 

This performance audit was conducted in accordance with generally accepted 

Government Auditing Standards prescribed by the Comptroller General of the 

United States and included such tests as necessary to provide reasonable assurance 

of detecting abuse or illegal acts. We conducted this review between September 

2005 and July 2007. 

An FAA inspector in the FAA CMO for Northwest made allegations of unsafe 

maintenance practices at Northwest and inadequate oversight by the CMO. The 

complainant reported these concerns to then Minnesota Senator Mark Dayton, 

who asked FAA and the Office of Inspector General to evaluate the allegations. 

To obtain details about the allegation, members of the Office of Inspector General 

audit and investigative staff interviewed the complainant at Senator Dayton’s 

office in Fort Snelling, Minnesota, on September 2, 2005. We also analyzed 

inspection data contained in FAA’s Safety Performance Analysis System and the 

Air Transportation Oversight System 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 Northwest as they related to 

the complainant’s concerns. 

To determine the effectiveness of FAA’s actions taken in response to the 

allegations, we accompanied FAA review team members as observers during their 

review conducted from September 7 to 15, 2005, in Bloomington, Minnesota. In 

addition, to determine if other inspectors in the CMO shared the same concerns as 

the complainant and to obtain additional information on safety concerns, the OIG 

investigative staff conducted separate interviews of 24 individuals: 12 current 

FAA inspectors, 4 current FAA managers, 7 Northwest mechanics on strike, and 

1 retired Northwest mechanic. 

We closely monitored FAA’s review and met extensively with FAA Headquarters 

officials to ensure that FAA’s report accurately reflected the results of its review. 

FAA provided us with the results of its first review in a report dated 

November 10, 2005. Because of continuing concerns that we had with the 

comprehensiveness of the review and the quality of the report, FAA conducted a 

second review during November and December of 2005. To determine whether 

FAA adequately addressed our concerns, we reviewed FAA’s January 19, 2006, 

memorandum on Flight Standards Service’s evaluation of the complainant’s safety 

recommendations and the June 2006 report on the results of the second team’s 

review. 

 

Exhibit A. Scope and Methodology 
 12

EXHIBIT B. OIG INVESTIGATIVE RESULTS 

In addition to the work we performed to monitor FAA’s reviews, OIG 

investigative staff conducted interviews with 24 individuals, including 12 current 

FAA inspectors, 4 current FAA managers, 7 Northwest mechanics on strike, and 

1 retired Northwest mechanic. These interviews revealed that other inspectors in 

the CMO shared several of the same concerns as the complainant. The following 

is a brief synopsis of the safety-related allegations concerning Northwest and the 

alleged lack of proper oversight of Northwest by FAA—specifically, the 

Certificate Management Office. 

• Northwest replacement workers did not receive proper training or enough onthe-job training. 

• Replacement workers did not properly complete maintenance paperwork or 

properly address technical problems as they arose. 

• Northwest made an unauthorized change in its procedures for processing 

repaired parts. 

• An alleged improper relationship existed between Northwest and FAA 

management that resulted in FAA discouraging the use of civil penalties, thus 

leading to ineffective oversight of the carrier. 

We provided a more detailed summary of our investigative interviews to FAA 

Headquarters in October 2005. FAA’s second review team evaluated these 

allegations and reported problems in each of the above areas. However, FAA did 

not release a report of its findings to show how it resolved the complainant’s 

concerns. Also, FAA did not develop a follow-up process to ensure that the 

Northwest CMO resolved all the concerns that were identified. 

 

Exhibit B. OIG Investigative Results 
13

Appendix. Management Comments 

APPENDIX. MANAGEMENT COMMENTS 

Federal Aviation 

Administration 

Memorandum 

Date: September 25, 2007 

To: Robert E. Martin, 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: Actions Taken To Address Allegations of Unsafe Maintenance 

Practices at Northwest Airlines

Thank you for providing us with the draft report of your audit of “Actions Taken to Address Allegations 

of Unsafe Maintenance Practices at Northwest Airlines, Project No. 07A3002A00.” We appreciate your 

acknowledgement of FAA’s increased oversight of Northwest operations when the mechanics strike 

began (August 2005), especially FAA’s effort in requiring Northwest to enhance its training program 

for replacement mechanics to ensure that Northwest continued to operate safely. 

We agree with the two OIG recommendations, as follows: 

OIG Recommendation 1: Require the Flight Standards Service to establish better internal review 

procedures to ensure that comprehensive, independent investigations of safety allegations and 

recommendations are consistently performed. 

FAA Response: Concur. Flight Standards Service has prepared a draft document to establish an internal 

review capability separate and distinct from existing Flight Standards Service oversight capabilities. 

This capability, based on a recommendation from the Flight Standards regional division managers, will 

be directly under the purview of the Director, Flight Standards Service. The draft is currently being 

reviewed by the Flight Standards regional managers and Flight Standards Service plans to implement 

this new internal review process by September 30, 2008. 

Recommendation 2: Require the CMO in Bloomington, Minnesota, to provide a report to the Director, 

Flight Standards Service on actions taken by the CMO and Northwest to resolve deficiencies identified 

by inspectors and FAA review teams. 

FAA Response: Concur. We recommend the CMO first provide the report to the Flight Standards 

Service regional division manager in Great Lakes region, who is responsible for and oversees the CMO, 
Appendix. Management Comments 

14

and that regional division manager will forward the report to the Director, Flight Standards Service, 

certifying completion of actions taken by the CMO and Northwest. Action to be completed by 

November 2007. 

However, there are three items of the draft report we respectfully disagree with, as follows: 

1. Safety Recommendations – The OIG draft report states FAA, despite finding the complainant 

had valid concerns, issued a letter to the complainant advising the two safety recommendations 

were subjective, unsupported opinion as FAA did not want to document the complainant's 

concerns were valid. In this regard, those safety recommendations were reviewed by Flight 

Standards Service Headquarters policy staff, independently from the two FAA review teams, 

who determined the safety recommendations did not contain the necessary, substantiating 

information per FAA Order 8020.11B, Aircraft Accident and Incident Notification, 

Investigation, and Reporting (dated 08/16/00, as amended). When the FAA Office of Accident 

Investigation convened a Safety Recommendation Board to review the two safety 

recommendations, they provided another separate and independent review of the two safety 

recommendations. 

2. Training Provided By Northwest – The OIG draft report states FAA informed the complainant 

the two safety recommendations were “Closed; Not Adopted” even though FAA determined 

some of the issues, such as problems with replacement mechanic training, were valid. In this 

regard, the CMO expressed concern to Northwest representatives about replacement mechanic 

training and proper documentation of maintenance activities prior to the date of the complaint’s 

two safety recommendations. The CMO documented 16 meetings with Northwest management 

during the period of April-August 2005 when they discussed training of mechanics. Prior to the 

strike, the CMO provided training to aviation safety inspectors (who provided strike 

surveillance at 29 targeted maintenance stations) with an emphasis on mechanic training. 

3. Composition of First Review Team – The OIG draft report states the Director, Flight Standards 

Service, declined the OIG staff recommendation to change the make-up of the first review team 

(to assure impartiality) as the review was a regional responsibility and one of the three team 

members was from another region. In this regard, the team leader is an experienced office 

manager from the Eastern region who was selected for the review team by the Director, Flight 

Standards Service. While the other two team members were staffers who reported to the same 

regional division manager as the CMO manager, they were not in line of authority for 

operations between the CMO manager and the regional division manager.