Licensing and the Labour Process in Australian Aircraft Maintenance:
Deskilling by Stealth?
Ian Hampsoni and Sarah Gregson
School of Management, Australian School of Business, UNSW
and
Industrial Relations Research Centre, UNSW
Prepared for the International Labour Process Conference,
18-20 March 2013
Rutgers University, New York
Abstract
Licensing protects ‘society’ (Polanyi, 1944) from the consequences of
improperly trained and incompetent practitioners’ work. It is a key
component mechanism to preserve job territory and to ‘socially
construct’ skill (Attewell, 1991). Becoming a licensed aircraft
maintenance engineer (or LAME, pronounced ‘lay-mee’), therefore, has
historically meant that the holder has undertaken sufficient theoretical
and practical training to be entrusted with the completion of skilled
tasks for which they have been duly certified competent by senior peers
and by the state (Fry, 1980; ICAO 2011). This gives them state sanction
not only to perform work, to supervise the work of others, but also to
certify that all work has been completed to an acceptable safety
standard. In this paper, however, we discuss ways in which licensing can
actually drive deskilling and reduce social protection, highlighting
‘reforms’ to aircraft maintenance licensing in Australia that, we posit,
may be creating a multi-faceted move away from safe maintenance
systems.
Acknowledgement
The research underpinning this paper was funded by an Australian
Research Council Linkage Grant (LP110100335) ‘The Future of Aircraft
Maintenance in Australia: Workforce Capability, Aviation Safety and
Industry Development’.
We thank the ARC, and our Partner
Organisations who have been generous with their time and support for
this project.
1
Licensing and the Labour Process in Australian Aircraft Maintenance:
Deskilling by Stealth?
Introduction
Deskilling is a central concept in labour process theory and a central reference point
in discussions about workplace change. We interpret the concept of ‘deskilling’ to be
multifaceted – as an employer strategy to control workers, as well as diminishing the
skill content of work. Deskilling applies to individual workers, to a workforce in
general, as well as to a labour process. ‘Babbagisation’ is a variant on ‘deskilling’ – the
concept registers processes through which management seeks to fragment complex
labour processes so that less skilled workers on lower wages can be hired to perform
particular defined tasks or sets of tasks, obviating employer need to ‘waste’ money
through paying more highly qualified tradespeople to perform tasks that are, in terms
of skill, ‘beneath’ them (Braverman, 1974; Thompson, 1989). As an instrument of
trade skill dilution, competence-based training has been criticised (or praised,
depending on your point of view) for its tendency to fragment work processes and
their underlying skills, and to reduce underpinning theoretical knowledge in the
pursuit of training that is immediately ‘useful’ in the workplace (e.g. Ashworth and
Saxton, 1990; McKay, 2004). In the case of aircraft maintenance, important
conceptual knowledge is being lost due to babbagisation of the labour process.
Licensing is a component of the ‘social construction of skill’ which contributes
to the preservation of ‘job territory’, as well as protecting society from ‘twin evils’ –
the consequences of work performed by improperly trained or incompetent
practitioners and the destructive effects of market forces on work quality (Polanyi,
1944; Attewell, 1991). Achieving a license has, therefore, usually been linked with an
assumption that the holder has undertaken sufficient theoretical and practical
training to be entrusted with the completion of skilled tasks for which they have been
duly certified competent by their more senior peers and by the state. A key
Australian policy document, for example, defines an occupational license as:
… any form of regulation that restricts entry to an occupation or a profession
to those who meet competency-related requirements stipulated by a
regulatory authority (ANTA, 2002:33)
To meet the standards of national authority, aircraft maintenance training has
comprised acquiring technical knowledge to a uniform standard, accruing time on the
job applying that knowledge to the performance of a broad range of technical tasks
and attaining sufficient knowledge of the legislative environment surrounding aircraft
maintenance and airworthiness (Fry, 1980:9).
Although seen predominantly as ‘technicians’ operating between aviation
design engineers and unlicensed maintenance workers, the history of LAME industrial
organisation suggests a widespread shared sense of independence, ‘professionalism’
and high ethical standards that underpin a sense of duty to protect the public from
the consequences of inexperienced, negligent or malevolent work practices.
2
Members of the Australian Licensed Aircraft Engineers Association (ALAEA), for
example, see themselves, as described in the organisation’s motto, ‘guardians of air
safety’. The Association’s executive members continually lobby to improve the
political, industrial and legislative environment in which LAMEs can ‘perform,
supervise and certify’ high quality maintenance work ‘for the safety of all who fly’
(ALAEA website, accessed 2013). For them, the license is an important marker of the
knowledge, skill and commitment to safety their members’ share, and the
Association has, on numerous occasions, mounted political and industrial challenges
to any threats to the prestige and substance of the maintenance license their
members hold.
In order to respond to a widely predicted (eg ICAO 2011b) impending global
(if not necessarily national) shortfall of licensed aircraft maintenance engineers,
proposals to change the licensing system have been put forward by the International
Air Transport Association (IATA) – the global peak employer body for airline
operators. Its Training and Qualification Initiative (or ITQI) proposes to reduce
maintenance worker training times and to introduce competence-based training
(IATA 2009) – in other words, to deskill the workforce. Seemingly in response, the
reform program of Australia’s Civil Aviation Safety Authority (CASA) bears an
uncanny resemblance to agendas pursued historically by employers in several
contests over the role of LAMEs in crucial decisions about when an aircraft is ‘safe’ to
return to the skies. Where once LAMEs had strong regulatory backing from the State
to make this decision independently and against organisational pressure, employers
have lobbied for years that the operators know best when this important stage
should take place – in other words, they prefer a ‘company approval’ system and
prosecute the familiar argument that self-regulation is entirely appropriate as
operator risk aversion is sufficient to prevent safety infractions. Therefore, the IATA
proposals articulate what the major airline lobbyists have always coveted, and while
there are dark rumblings about airline influence on the reform process, our research
so far does not allow us to make such claims with certainty. We note however that
two recent chairs of the IATA were two CEOs, one former and one current, of
Qantas, Australia’s national airline, which is at the forefront of militancy in airline
industrial relations. In addition, recent changes to the regulatory regime, we can
more confidently say, have a great many benefits for the operators while limiting the
role of skilled LAME decision-making but at the price of reducing the ‘socially
protective’ role occupational licensing of AMEs was designed to play.
This paper reports some outcomes from an Australian Research Councilfunded research project called The Future of Aircraft Maintenance in Australia. It is
based on over 50 hours of interviews and briefings with a range of industry
participants, as well as desk research into the changing suite of regulations issued by
CASA. First we briefly describe the labour process of AMEs and licensed AMEs,
locating its importance in the wider safety literature. Second, we describe the
reforms to the labour process proposed by CASA that have undermined the
industrial strength of aircraft maintenance unions, and the role of a license in the
decision to return an aircraft to service after maintenance. The third section of our
paper shows how this contest over the role of the licensed AME is far from new – in
fact, using members’ licenses as a speaking platform, the ALAEA has campaigned
3
vociferously over many years against the dominance of managerialist agendas in the
aviation industry that may overlook safety hazards in the quest for profit
maximisation.
1. The Labour Process of Licensed Aircraft Maintenance Engineers and its Socially
Protective Role
In earlier work (Hampson, Junor and Gregson, 2010; 2011) we have described the
labour process of L/AMEs, and we propose only to provide a sketch here. As their
motto suggests, licensed AMEs perform aircraft maintenance, supervise the work of
unlicensed maintenance workers and are authorised by the state to certify that a
‘release to service’ of an aircraft is appropriate. However, their work involves a
fascinating dichotomy – on the one hand, LAMEs’ skill, knowledge and experience
are vital factors in ensuring that non-routine matters that commonly arise in aviation
maintenance are handled appropriately through significant autonomous judgement.
In addition, as we have noted elsewhere, this work involves significant relational
skills – directing work, knowing which workers can be trusted to work independently
and those who cannot, negotiating with supervisors about the relative seriousness of
particular problems etc. On the other hand, it would be difficult to find workers
more heavily circumscribed by regulatory and manufacturer mandates that carry
heavy penalties for procedural violations. Notwithstanding potentially punitive
regulatory and management systems against rule-breaking, we know that a variety
of factors – unclear manuals, not having the correct tools, management pressure to
get the plane back into service, simply knowing a better way or making an
inadvertent mistake – mean that divergences from recommended procedures, both
erroneous and deliberate, are relatively common (Hobbs, 2004:4; 2008:12-25,
passim; Reason, 1997:49-54). The main point relevant here is that the skill, training,
analytical powers and professionalism of the LAME become crucial in determining
whether departures from procedure – whether accidental or intended – are
innocuous, innovative or disastrous (Hampson, Junor and Gregson, 2010).
It is here that babbagisation of the LAME labour process supported by the
new licensing system we discuss below might be most damaging. A worker licensed
to perform only a narrow range of tasks may not see a glaring fault in a nearby
component because it is outside their training and experience. ‘Knowing something
about everything’ so that a worker at least knows when to consult those with more
expertise is far preferable to maintenance workers who ‘know something about very
little’ and who may miss significant problems through lack of knowledge. Broader
training also provides constant reminders to apprentices of the importance of each
maintenance component for overall flight safety, whereas babbagisation risks
separation of the conception from the execution of the task and might
inappropriately downplay its importance in the total labour process and safety
management system. The aviation maintenance industry in Australia has also been
characterised by a high degree of personnel mobility, both internationally and
between the Regular Public Transport (RPT) and General Aviation (GA) sectors, and
this has been important for the incubation and transmission of expertise and skill.
4
However, in Australia, that mobility has been limited by two main factors.
More generally, motivation to enter the industry and to upskill within it is limited by
low levels of state and management sponsorship of training. Introductory training
and type training modules are expensive and workers may find it difficult to get
sufficient hours of experience to qualify as skilled. As Fry (1980:10) noted decades
ago, new aircraft models and greater technological sophistication may create an
‘infinite variety of specialist functions’ for which specific type training is something of
a quick fix. For him, broader, principles-based early apprenticeship training has, and
still has, we would argue, far greater potential to equip maintenance workers to
adapt quickly to new technologies as they appear.
Nor does the industrial relations environment provide a propitious
environment for LAMEs, in terms of working conditions, job opportunities and
related skill development. Qantas CEO, Alan Joyce, makes constant references to the
need for maintenance job cuts and wage restraint if the company is to be profitable
and internationally competitive. In July, 2011, he pointed to the airline's
maintenance and repair costs as ‘among the least efficient and most expensive in the
world’ because unions were getting in the way of his plans to rejuvenate operations.
Mr Joyce said that unions were stuck in the past, trying to retain outdated work
practices. A new ‘maintenance-on-demand’ system would mean fewer licensed
engineers working at airports, because aircraft would no longer undergo a routine
inspection before their next take-off. Only those planes where pilots notice and
report defects will be examined (Ooi, The Australian 21 July 2011:2). There was no
need, Joyce said, for licensed engineers to do transit checks on modern aircraft, for
example, when pilots could do this work. CASA agreed, ruling that pre-flight safety
inspections could be done by the pilot, a decision that ALAEA federal Secretary,
David Kemp, derisively characterised as ‘the same as asking a bus driver to do the
work of a mechanic’ (Benns, 2011:163). In addition, Qantas has recently done a $2
billion deal with GE Aviation for A320 engines that reduce fuel burn and so extend
the intervals between services. According to the company’s managing director, 'the
cheapest [maintenance] shop is the one you don't have'; he envisaged that a 20-year
old aircraft might have had only ‘one or two shop visits in its life’ (Heasley, SMH, 21
April 2012:5). This is, of course, music to the ears of cost-conscious operators but
betrays technologically optimistic assumptions that it is possible to design, build and
operate aircraft that will never have problems.
2. The Reforms to the License Structure, Training and Qualifications
The licensing of aircraft maintenance workers began in the aftermath of World War
One and, since then, engineer industrial organisations have fought an ongoing battle
to increase the status of the license and associated remuneration. The current
reform program can thus be viewed as the latest chapter in an ongoing struggle.
Maintenance work is heavily regulated from the international sphere.
Developed countries are signatories to the International Convention on Civil Aviation
(the ‘Chicago Convention’) which in 1944 formed the International Civil Aviation
5
Organisation (ICAO) (Yadav, 2010). Part of the ICAO’s role is to develop and support a
range of technical standards for international civil aviation – the so-called Standards
and Recommended Procedures (SARPS). Among these, the Convention’s Chapter 4
(4.2.2.1) of Annex 1, on personnel licensing, tells us that:
the privileges of the holder of an aircraft maintenance licence shall be to
certify the aircraft or parts of the aircraft as airworthy after an authorized
repair, modification or installation of an engine, accessory, instrument,
and/or item of equipment, and to sign a maintenance release following
inspection, maintenance operations and/or routine servicing (ICAO, 2011a,
Ch 4, , also see ICAO 2003:vii)
These standards are applied by national regulatory bodies, like Australia’s CASA and
the American FAA.ii They do not fully determine standards and systems at the
national level however, and their application and interpretation in particular national
spheres have increasingly diverged – in particular between European and American
‘models’. Cross-jurisdictional collaboration took place between the European Civil
Aviation Conference (ECAC) and the Federal Aviation Authority (FAA) – together
constituting the JAA (Joint Aviation Authorities), until the formation of the European
Aviation Safety Authority (EASA) in 2003. EASA branched out on its own, developing
a system of regulation which caught the eye of Australian reformers. They sought to
reshape the existing licensing requirements towards the EASA standard, in particular
because the new system was being widely adopted throughout Asia (CASA, 2010a).
There had been indecision over whether Australia would follow the US or Europe
and, after going some way with the US system, CASA abruptly switched course
towards the European system in the early to mid-2000s. Transition to the new
licensing system began in 2007, with Civil Aviation Order 100.66, reforming the ‘old’
Civil Aviation Regulations (CAR31), and ushering in new Civil Aviation Safety
Regulations (CASR part 66), which laid out the structure of the new system (CASA
2010b;c). New licenses were issued to LAMEs on 27 June 2011, with a ‘transition
period’ extending until 2015.
The changes were justified on the following bases: to allow increased
international labour transfer through mutual recognition of skills, qualifications and
licenses between Australia and the various national aviation authority (NAA)
‘jurisdictions’ of Europe, as well as other international EASA-approved MROs
(maintenance repair and overhaul organisations). ‘Harmonisation’, it was claimed,
would also produce an efficiency dividend, by overcoming work demarcations
between holders of licenses in the five former license categories – Airframes,
Engines, Electrical, Instrument and Radio – and thereby improve the labour
‘flexibility’ allegedly required to meet the highly technical demands of modern
aviation systems. As well as providing globally recognised licenses and qualifications
for employees, it was argued that these reforms would allow Australian MROs to
attract more maintenance work from overseas operators who used the EASA system
(CASA, 2010c). However, as it turned out, the reformed licenses and their
underpinning qualifications were not recognised by EASA itself, nor in some other
EASA-approved MROs, indicating a serious failure of the reform process – we will
return to this point.
6
The ‘old’ CAR 31 License system
The structure of licenses known as the CAR31 system (Civil Aviation Regulation 31)
that had developed in Australia, was fundamentally different to the new EASA
system because it enabled LAMEs to certify for completion of a stage of
maintenance or to supervise and coordinate maintenance on either a specific type of
aircraft, like the Boeing 747 or types of components (eg engines), more commonly
found in large aircraft in the RPT sector as well as on a broad category of aircraft, like
single piston engine aircraft (such as might be found in general aviation (GA) (CASA,
2007: 11; CASA 2002: 16-18). LAMEs were also responsible for signing the ‘release to
service’ – certifying that the plane was airworthy. The strength of the CAR31 system
was its ability to encompass both RPT and GA within a single licensing system based
on adoption of ICAO Annex 1 AME privileges (ICAO, 2011a (4.2.2.1), also see ICAO
2003:vii). Arguably, the greater deployment of small planes making up GA in
Australia (with a population of 22 million people in a land mass the size of Europe)
made its aviation requirements fundamentally different to Europe where it was
economically viable to use larger planes.
The building blocks of the old system were categories within which LAMEs
would hold group ratings. There were five categories: Airframes, Engines,
Instrument, Electrical and Radio. ‘Groups’ defined license privileges within and
across each category. This can be illustrated more easily with the aid of a table (see
Table One). In addition, license privileges could be held on ‘types’ of aircraft. For
example, a person might be trained, qualified and licensed in group one engines
(allowing them to work on, and certify maintenance for, engines in light planes).
The same person might then seek to move into, say, group 21 engines – such as
might be found on a large passenger jet. This would require specific knowledge
about each particular large complex engine – these were seen as sufficiently
different to each other to warrant a separate ‘type’ license. A person could start on
broad categories in GA then move into larger more complex types in the RPT sector
– this work is generally better paid, and with pay increments linked to license types
(a complex industrial relations issue we lack space to explore here). Importantly for
our purposes here, however, a career path existed from GA to RPT.
7
Table One
GROUPS
AIRFRAMES
ENGINE
ELECTRICAL
INSTRUMENT
RADIO
1
Aeroplanes not
covered in Groups
2-20
Piston engines in
aeroplanes and
airships
Single
generator
power
systems
All general
instruments
not in gps 3
or 20
VHF and
HR other
than group
20
2
Helicopters not
with hydraulic flight
control
Piston engines in
Helicopters
Multi
generator
systems
except gp 20
Auto pilots
(except gp
20)
Audio and
cockpit
recorders
3
Wooden Airframe
Supercharging and
turbocharging
systems
20
Aeroplanes, with
(jets) and heavier
than 8,000kg as
specified by CASA
(after 2011 reforms
now 5,700kgs)
Auto pilots
(except gp
20)
Electrical
systems in
aeroplanes
above 8000kg
21
Piston and gas
turbine engines in
aeroplanes and
airships
22
Piston and gas
turbine engines in
Helicopters
Radios in
RPT sector
Adapted from Civil Aviation Safety Authority (CASA) (2007:19-20) also see CASA (2002:16-18)
Becoming a LAME
To become a LAME under the old system, a person was required to gain a basic
Aircraft Maintenance Engineer’s certificate. This meant doing a four-year
(Certificate IV) apprenticeship, combining classroom training at a recognised
provider (TAFE) with work experience under the guidance of qualified personnel.
Governments typically allowed for around 1,280 funded classroom training hours
that took place alongside practical workplace experience. Since the training reforms
of the mid 1990s (a useful time point to begin our exposition) a typical career path
would see an AME complete a four-year apprenticeship in one or two of the broad
streams – structures and engines (to become a ‘framie’, or ‘blackhander’) or
electrical, instrument and radio (to become a ‘sparkie’). In practice, however, many
‘framie’ AMEs working in GA would be called upon to do electrical work due to the
fact that most Air Operator Certificate (AOC) holders utilising small planes were also
small employers, without the capacity to employ large numbers of maintenance
workers. In these situations, AMEs would often be required to work across the
category boundaries and, indeed, many LAMEs eventually gained licenses across
8
numerous categories. This is an important strand to our deskilling argument – prior
to the EASA/CASR part 66 reforms, there existed many multiskilled AMEs and LAMEs
with licenses spanning multiple categories and crossing the framie/sparkie divide.
The new system will not allow for this ‘flexibility’ to slowly acquire license privileges
in ‘chunks’.
At this point, it is important to distinguish between AME qualifications, and
licenses. Recall qualified (and/or ‘approved’) people do aircraft maintenance, but
only licensed people can return a plane to service. Under the CAR31 system, to gain
a license, a person first needed to be trained towards an AME qualification (entailing
a mix of classroom and on job training), then gain experience in the type of
maintenance for which s/he seeks to exercise license privileges (with records kept in
a Schedule of Experience – or SOE). The license was issued by the Civil Aviation
Safety Authority (CASA), after the applicant passed a set of relevant theoretical
examinations and had their SOE accepted. People seeking licenses could ‘self study’
certain theoretical modules and then sit the examination (see CASA 2002; 2007).
The examination provided proof that a person had the necessary theoretical
underpinning knowledge for a license. The recent changes, however, downgrade the
importance of this knowledge. Our interviewees have recounted how the
examination process used to be predominantly essay-based assessment that
required the examinee to explain concepts and even to draw certain aircraft systems
from memory to demonstrate a depth of understanding. In the 1980s, however, this
form of assessment was abruptly replaced with multiple-choice tests. Also, formerly,
granting the license was also a ‘ritual’ of enculturation, signifying membership of an
important community, with a crucial socially protective role. Interviewees have
recounted how, to inculcate a professional ethic, it was common practice for the
CASA representative to personally deliver the license and give the recipient a
motivational talk about how the LAME was in the front line of passenger safety and
bore a weighty responsibility in the event of an aircraft crash attributed to faulty
maintenance – and would therefore enjoy the support of the regulator to that end if
a conflict with management arose. Eroding the role of the examination and the
issuance of a license has been a central aspect of deskilling (as employer strategy to
control labour), which we will examine further below in the context of a description
of the licensing reforms.
The EASA/CASR part 66 reforms and their Interaction with the training system
As mentioned, CASA began the training and licensing reform process in 2007, with
the issue of Civil Aviation Order 100.66. These ushered in CASR (1998) parts 42, 66,
145 and 147. Not all of these are germane to our argument about deskilling. For our
purposes, the key points are the part 66 licensing system, and the training and
assessment done under part 147 (and, to a lesser extent, part 145). Part 145
governed the activities of Maintenance Organisations. Part 147 laid out the
requirements for CASA to approve training organisations to deliver and assess
competence as a prelude to the issue of a license. After the transition period, CASA
would still issue the license, but only on the recommendation of an approved part
9
147 organisation. CASA would no longer administer the examinations and, crucially,
would not set the central bank of questions. In the eyes of some critics, this
removed one important guarantee of safety – that the examination would really test
whether an applicant for a license actually possessed sufficient and reasonably
uniform underpinning theoretical knowledge.
To fully appreciate this, it is important to be aware of the broader context of
training reform in Australia. As argued elsewhere, in recent decades, Australia’s
training reforms have been problematic, in part due to excessive reliance on ‘market
design’ principles (Hampson and Junor, 2010). Australia is a Federation, in which the
Constitution assigns powers over training to the States, each with its own training
authority. Australia’s training institutions are undoubtedly prone to poor assessment
practices (see SEWRSBERC, 2000; Hampson, 2004) and difficulties assessing
recognition of qualifications.iii Similarly, because Registered Training Organisations
(RTOs) are profit-making organisations and have to compete for students, there is a
tendency to lower standards through a competitive ‘race to the bottom’ where
‘lowest required class hours’ and ‘cheapest price per module’ are the key
determinants for attracting high student numbers. Some interviewees complain that
standards in competing RTOs are too low, but under the system of ‘mutual
recognition’ they have little option but to accept students they think may have
substandard training when granting prior standing to students seeking or RPL
towards further training. The competitive profit-driven environment similarly puts
pressure on the content of theoretical exams. Under the ‘old’ system, the content
was standardised, but under the new system, RTOs have to develop or purchase
their own examinations with concomitant risks to standardisation and potentially
quality.
We now turn to the changes made to the Australian license structure to
highlight some of the ways in which they promote deskilling. The EASA part 66
system sought to incorporate the former CAR 31 system of five categories of license
(Airframe, Engine, Electrical, Instrument and Radio) and numerous Group and Type
ratings, into the EASA system of B 1 (Airframe, Engine, Electrical) and B 2 (Electrical,
Instrument and Radio – Avionics) (See figure 1). The ‘C’ category engineer does not
do any direct maintenance in this framework – s/he is conceptualised as an
academically trained (bachelors) engineer, who handles the paperwork and does the
final ‘release to service’ of the whole plane – but only after ‘base’ maintenance (see
below), based on the paperwork that the B level ‘support staff’ engineers provide.
CASA oversaw the (re) distribution of privileges through ‘exclusions’ which
meant that a person might be granted a B1 license that covered the old categories
but contained some limitations (see CASA 2011). The system created a situation
where license holders who had worked across multiple categories were crammed
uneasily into one of two broad categories through ‘exclusions’ and, in this way, the
new framework actually works against the rationale of flexibility that justified the
changes. A ‘full B1’ license holder is permitted to sign for Airframe, Engine and
Electrical work. However, the distribution of electrical privileges was not
straightforward. As our interviewees report, some LAMEs were left unsure about
the extent of their privileges and some even claimed to have lost privileges in the
10
There are different methods for obtaining an initial licence in one of the five base licence
categories. The most common method, at approximately 80%, is for individuals to submit a
schedule of experience and to sit CASA exams to demonstrate theoretical knowledge. There is no
accredited course for individuals to undertake to prepare for the exams and individuals must
develop their own preparation methods. The other methods of obtaining a licence are recognition of
defence force qualifications or recognition of international qualifications. To obtain an aircraft type
transfer
– ergo
deskilling
by legislative
decree
in that
they were
allowed
to
rating
requires
the engineer
to complete
a course
provided
by anot
training
organisation
authorised by
exercise
license privileges they possessed by virtue of changes to the regulations.
CASA.
Perhaps
more
alarmingly,
LAMEs of
claimed
to have
issued with
with competency based
The even
CASA
licensing
exams some
and schedule
experience
willbeen
be replaced
privileges
they
did
not
formerly
have!
Although
in
some
cases
this
may
have
been of a diploma at an
training administered by CASA approved training organisations. The completion
approved
training organisation
will documentation
demonstrate competency
to licenses
enable the
individual to be issued
due to
misunderstanding
the complex
– the new
sometimes
with
a
licence.
came with 30 pages of text, replacing one or two pages that clearly described their
The other
methods
for obtaining
licence
based on recognising
defence
orItinternational
privileges
– what
they could
do, witha long
statements
of what they
could force
not to.
qualifications
will
remain
largely
unchanged.
The
licensing
for
specific
aircraft
types will also
left many utterly confused about what exactly their hard won licenses entitled them
remain largely unchanged. The number of base licence categories will be reduced from five to two;
to do – and anxious, lest they unwittingly exceeded their license privileges and failed
and two ‘release to service’ engineer categories will be introduced which will align Australia’s
to adhere
tocategories
the regulations.
licence
with those operating in Europe (Figure 1).
Figure 1:
Current Licence Categories
Proposed Licence Categories
Airframe
Engine
B1
Electrical
Instrument
B2
Radio
Release to service engineers
A
C
5
Source: Modified from CASA 2010c: 5
A more serious instance of the deskilling of the LAME labour process takes
place with the possibilities presented by the A Category license. The Cat A license
can be awarded after achieving Certificate 2 level training (680-800 hours) and two
years’ work experience. Such a person would be qualified to perform, and licensed
to certify for, certain limited line maintenance tasks including ‘simple defect
rectification’.iv The list of tasks includes the replacement of wheel assemblies, brake
units, emergency equipment, ovens, boilers, beverage makers, lights, seats,
harnesses, aircraft batteries, and ‘replacement of any other component for an
aircraft type if the task is one that CASA approves as a simple task’ (emphasis
added). We argue that there is the possibility for the scope of work performed and
11
certified by Cat A license holders to expand under this latter provision. To
appreciate this point once again requires understanding two basic aircraft
maintenance concepts – line and base (or heavy) maintenance. Line maintenance is
simple, ‘turnaround’, ‘hangar’ or ‘overnight’ maintenance – checking that equipment
works, topping up the oil and hydraulic fluid etc. Base (or heavy) maintenance takes
place off-line when the aircraft is not in service. At the extreme, ‘D’ checks involve,
inter alia, stripping the interior out of the aircraft and checking the frame for cracks
and corrosion, and perhaps engaging in considerable rectification work on major
components, such as wheel assemblies. These checks can involve 75,000 person
hours on a large plane, and, being labour intensive, they are prime targets for
outsourcing and offshoring (a topic beyond our reach here – but see Quinlan,
Hampson and Gregson, 2013 forthcoming). They are also targets for babbagisation.
‘Phased maintenance’ is a process in which some of the ‘intermediate’ content of
‘base’ maintenance (‘B’, ‘C’ checks) is brought within the purview of line
maintenance. That is, some maintenance operations are packaged up in such a way
that they can be performed alongside or at the same time as line maintenance.
It is now possible that many maintenance operations will eventually come
under the purview of a Cat A license holder, who will have considerably less training
and experience than a B level license holder. Under the system proposed above,
there is a distinct possibility that there will be an expansion of the scope of Cat A
work with regulatory approval and, in particular, there exists the possibility that B
and C check work will leak to a Cat A licensed person doing line maintenance. Strong
financial incentives exist in the form of leasing costs to use the time an aircraft is
undergoing line maintenance overnight (Sydney airport has a curfew where planes
cannot land or depart between 11pm and 6am) to perform maintenance that would
otherwise take the aircraft out of service. Therefore, as a direct consequence of the
part 66 reforms, the possibility exists for the transfer of much work currently done
by experienced licensed engineers to a category of lower skilled license holder in a
process clearly recognisable as the ‘babbagisation’ of aviation maintenance work.
The shift towards Cat A licenses is also industrially contentious, due to the
coverage questions it raises between the main aviation unions. The ALAEA covers
licensed aircraft maintenance engineers, but the work identified above in the CASA
part 145 MOS Appendix as destined for Cat A license holders is work already, for the
most part, covered by another union, the Australian Manufacturing Workers Union
(AMWU), whose rules cover AMEs currently doing much of the above work. The
introduction of the Cat A license has certainly sparked industrial tensions – indeed,
several of our interviewees were suspicious that this was part of its intent. The
ALAEA claims that its rules give it coverage of license holders – ie Cat A license
holders should be able to be recruited to the ALAEA. The AMWU claims that the
potential holders of a Cat A license are workers they already potentially or actually
cover and they are unlikely to give up coverage to the ALAEA easily. A member
poaching war between the two unions has already broken out but, at the time of
writing, there are signs that the two unions may join forces against certain negative
aspects of the Cat A.
12
Both these unions have a common interest in the construction of an orderly
career path through the Cert II / Cat A license to Cert IV and to the Diploma which is
now, following the part 66 reforms, the underpinning qualification for B level
licenses. A similar career path exists in Germany, although our research has found
that the implementation and use of the Cat A license in Europe varies considerably,
with some countries using them extensively, while other countries, notably Sweden,
have so far successfully resisted them, in part because of the industrial relations
problems they engender. The development of a coherent training and career
pathway would entail some major changes to the qualifications and license
structure, with some careful thought given to the industrial relations issues.
Currently, some of the competencies written for the Cert II qualification are not
written in such a way that they can provide advanced standing for the Cert IV (or
even Cert III). Another problem arises when AMEs with a Cert IV qualification are
considered. If they are to gain the Cat A license, they will be required to undertake
‘gap training’ to fill certain gaps that currently exist between a Cert IV AME
qualification and the Cert II in Line Maintenance (concentrated as it is on certain very
specific tasks). Clearly, many Cert IV holders will not be happy to learn they will
require extra training to get a Cert II qualification, especially if they have to pay for it.
We now turn to the issue of safety. Examination of the new system makes it
difficult not to conclude that Cert II qualified people may lack the underpinning
knowledge, experience and ‘workplace maturity’ to make safe calls on certain
aircraft maintenance procedures. Firstly, it is foreseeable that inexperienced Cat A
license holders might perform their allotted task adequately, but lack sufficient
diagnostic skills, underpinning theoretical knowledge and situational awareness to
recognise safety-critical problems in their area. For example, it is easily conceivable
that a Cat A license holder might change a wheel in a wheel bay and not notice that
there is a crack in the spur above their line of sight or they may not notice or
appreciate the significance of a hydraulic leak, whereas an experienced LAME would
take into account the whole wheel bay area when performing the same task.
‘Workplace maturity’ refers to the capacity of a young person with Cert II training
and a Cat A license to operate independently of organisational pressure, with flight
safety as the highest priority. We recognise that it would be difficult for that person
to resist pressure applied by an aggressive manager who is perhaps motivated more
by a performance bonus for on-time departures. Increasingly, such managers do not
have technical qualifications, and their pressure on staff to ‘sign off’ that certain
procedures have been completed may well be motivated by organisational, rather
than safety, considerations. In the same vein, the Cat C license holder may sign off
that the aircraft is safe to fly without ever coming near the aircraft itself. Similarly, if
the difficult conversations LAMEs must sometimes have with more senior airline
officials where they insist a plane is not safe to return to service are marginalised by
the regulatory process, this may have catastrophic consequences. These
conversations are only possible if the license holder is mature enough to resist
potential bullying, backed by a strong union and supported by an appropriately
interventionist regulator – the new reforms make some of these important supports
problematic.
13
EASA-fication of Australian aircraft maintenance?
Another fundamental development limiting Australian aviation workers’ capacity to
resist deskilling is the emphasis on ‘company approval’ in the EASA system. CASA
has uncritically emulated this feature, arguably even taking it further, by requiring
employers to ‘approve’ aircraft maintenance engineers (licensed and unlicensed) to
perform specific roles and tasks – as well as potentially allowing an expansion in the
scope of Cat A licensed tasks (with the consent of the regulator). Our partner
organisations and researchers have identified subtle changes in the language of
regulation that indicate that the role of the license is being downgraded, and that
the power to release an aircraft to service is being diffused from licensed and
potentially unionised workers to other parts of ‘the organisation’. As we will see in
the following section, this is far from unprecedented historically reflects longstanding employer intentions.
Early in our research we found there were fundamental misunderstandings
about the EASA system within Australia – as well as within Europe itself!
Commentators on the development of the ‘EASA’ system (eg Haas, 2009; 2010)
describe a political contest over how best to assure the ‘high skills’ necessary for
‘high reliability’ functions (like airline maintenance). For him, this was a choice
between a system based on ‘company approvals’ of training and qualifications, and a
system based on occupational licensing via national aviation authorities’ and
national qualification authorities’ systems ‘harmonised’ at the European level.
According to Haas (2010:597), in the case of aircraft maintenance and contrasting
with other occupations, the European states have “achieved the impossible … in
completely harmonizing qualifications … and having them automatically recognised
across Europe”. Based on our preliminary interviews with European contributors to
the project, we reject these claims – our interviewees report a large variation in
training standards and in the organisation of aircraft maintenance work across
Europe (which subsequent research will track with more precision). The variation
reflects in part the EASA system’s emphasis precisely on company approvals, and the
right of employers to define the terms of the exercise of license privileges. For
example, a licensed engineer may hold the EASA Cat B1 license but be ‘approved’ (at
the time of employment) to do only Cat A work and, of course, paid only according
to work performed.
In Britain, the implementation of the EASA system, with its high training
hours requirements (2,400 hours to B level) was deemed “not sustainable within the
framework of existing training institutions” (Watson, 2006:322). Something similar
may be the case in Australia. Part of our research has attempted to compare the
hours required by the EASA syllabus with the training hours currently funded in
Australia, which stands at around 1,280 hours for classroom training, which looks
unfavourable. On the other hand, it is not really an apples-with-apples comparison,
since much of the European EASA training towards the B license takes place in offthe-job simulated environments, while much of this training in Australia takes place
on the job. At time of writing we are unsure how to do a valid comparison – we do
note, however, that the capacity of airlines (and small air operator certificate
holders) to provide on-the-job training in aircraft maintenance is probably in decline,
14
due to competitive pressures and the need to eliminate ‘idle time’ at the workplace.
We do expect, however, that the comparison will be unfavourable to Australia –
such is the view of many potential overseas employers of Australian maintenance
labour, who have refused to recognise the new licenses and qualifications.
Sections of the aviation industry are scathing about the workplace effects of
these reforms, although their feedback does not present an entirely consistent
picture. Competence-based training has been blamed for stripping conceptual
knowledge from training while, at the same time, the training is portrayed by some
as requiring increasing academic content at the expense of practical competence.
Training organisations are bound by their profit orientation to offer content within
government-funded training hours, potentially reducing the possibilities for trainees
to develop ‘hand skills’ through supervised practice. Employer interviewees thus
complain that new graduates lack hand skills – while training organisations and
employers disagree over the proper place for these skills to be developed – and, of
course, over who is to make the necessary resources available.
One fundamental difference between the CAR 31 license system and the new
part 66 framework is that the old system allowed a license capacity to be acquired in
‘chunks’, as explained above, and allowing learned theory to be reinforced by on job
practice. The new system requires an extended period of ‘front end’ training, with a
greater emphasis on academic learning. Making the two compatible is difficult. As
mentioned above, many of the ‘Aus-EASA’ licensed people cannot gain employment
overseas, as the outputs of Australia’s ‘EASA Lite’ training and licensing system are
not recognised uniformly outside the country. In the cruellest of ironies, airlines are
now importing overseas trained and EASA-qualified LAMEs on temporary
employment visas (457s) – which are operational as long as the employment
relationship is maintained. These workers can, however, be deported almost
immediately if they are dismissed, a situation which directly undermines the
workplace environment necessary for workers to feel free to speak up about safety
issues.
3. The History …
LAMEs first began to organise into a separate union from the late 1950s on the basis
that their licenses created unique industrial issues for members that were not well
served in larger, more diverse unions. Although the newly organising Australian
Licensed Aircraft Engineers Association’s arbitral registration was hotly disputed by
other unions and took five years to achieve, officials argued that licensed engineers’
interests required special representation and expertise beyond common union
issues. Officials needed to understand the complicated position of licensed workers
who were both agents of the state and operator employees. They also argued that
their new Association was uniquely equipped with specialist expertise to represent
members in the event of an aviation incident or accident where there might be a risk
of prosecution.
15
The expertise, responsibilities, powers and remuneration pertaining to a
license holder have been contested for many years. Although the license could put
LAMEs in an invidious position, it also allowed them to operate at the apex of a
complex labour process whereby the requirement to get their signature on a
maintenance release form gave them enormous workplace and industrial power. For
that reason, operators, and particularly QANTAS, have consistently lobbied
politicians and the regulator for lower levels of regulatory oversight, including
downgrading of LAME powers, citing ‘red tape’ as an unwarranted business
constraint.
In 1971, in particular, this issue came to a head in what John Aldiss, former
ALAEA president, described as the ‘most concerted effort’ by the regulator to
respond to operator calls for more control over licensing (Aldiss, 2013). There are
many similarities with today’s landscape. From the late 1960s, the Department of
Civil Aviation’s (DCA, a forerunner to CASA) had been making noises about changing
the regulations to increase ‘flexibility’ for operators. Two formal proposals (the
second to allegedly answer the confusion engendered by the first) were issued in
1969, containing recommendations that would undermine the LAMEs role in
certifying aircraft maintenance work as safe.v At the heart of the issue was the
Department’s view that it should regulate the airlines and the airlines should control
the LAMEs, ensuring there was no conflict of interest between employer and
employee that it claimed might constitute a violation of common law. In its view:
It is not possible for LAMEs to be responsible to both operator and the
Department. If they act contrary to the directions of the operator in the belief
that they act in the interests of their responsibility to the Department, the
operator would then be held responsible in an area over which he has no
control. An employee should be responsible only to his employer who is
responsible for the actions of his employee. (DCA 1971)
In the DCA’s view, the operators needed more flexibility to control what
maintenance engineers did and what training they received. The breadth and depth
of knowledge acquired by LAMEs through careful training and long experience was
wasted if LAMEs’ current positions did not utilise what they knew. On the other
hand, the regulator asserted that it was now outside the capabilities of generalist
licensed engineers to have sufficient expertise regarding all the highly specialised
tasks required on every complex aircraft type they might be expected to service.
Damned both ways in the DCA’s formulation, LAMEs knew both too much and too
little.
The changes the DCA suggested to rectify these ‘problems’ were significant
but, at the time, the ALAEA complained that the Department was failing to consult
sufficiently beyond the large operators. In a letter seeking legal advice on the
changes, the ALAEA federal secretary pointed out that the regulatory backing LAMEs
received from the Department was under threat. Until that time, he argued, LAME
licenses stipulated that holders were responsible to the Director-General for Civil
Aviation for the quality of their work. Under the proposed amendments, however,
Regulation 39 (1) was to make reference to work performed while “acting in the
16
course of [their] employment”, making LAMEs responsible only to their employer ‘in
respect of all matters pertaining to air safety’. In addition, the amendments allowed
the Director-General to authorise ‘appropriate persons’ to perform certification
duties, but did not define the qualifications and experience required of persons so
authorised to certify work as safe.vi
The DCA maintained that the airline operators should be permitted ‘a degree
of latitude’ about assessing who was sufficiently skilled to certify specialist work, its
proposal suggesting that complex aircraft type ratings could be replaced by an
employer-certified ‘maintenance authorisation’ for particular work (DCA, 1969:27).
This was not an attempt to relax standards, the DCA assured the industry and other
interested parties – in fact, the Department argued, it had always supported policies
that would ‘delegate as much authority as possible to the airlines’ and, to this end,
the new arrangements were designed so that ‘[t]he training of each LAME could be
directed specifically towards those duties and responsibilities which he is required to
accept within the organisation.’ (DCA, 1969:29). The certification would provide no
authority to perform similar work outside the issuing organisation, the DCA pointed
out, although it might influence subsequent employers and the ‘regulator’ to issue
later authorisations. Relieved of the burden of expectation that engineers would
know all there was to know about every aircraft, the DCA argued that LAMEs would
have more time to devote to accruing expertise on the aircraft models and specific
tasks for which they were actually employed. Department officials appeared
confident that employers could be entrusted to provide ‘detailed directed formal
training and formal authorisation’ without compromising safety. Although, unlike
today, it did maintain that all training programmes would be subject to Department
approval, its insistence on training that covered ‘only those aspects appropriate to
the duties’ suggests it wanted to maintain oversight to ensure that the training
offered did not become too broad and therefore irrelevant (ibid). According to the
DCA, ‘if an operator is considered capable of maintaining an aircraft of the size of a
DC9 he [sic] must also be considered capable of maintaining it in accordance with
the system which does not require such endorsements’ DCA, 1969:28). Although the
DCA expressed ‘hope’ that its recommendations would not reduce LAME
remuneration or inspire industrial disputation, obviating the need to remunerate
highly skilled LAMEs for each qualification they gained outside employer
requirements was a key factor driving operator pressure for this change. (DCA,
1969:29). The proposal was summarised with the following rationale: ‘...the
flexibility of the proposed licensing arrangements will permit more autonomy for the
operator and will achieve greater economy in training than is possible under the
current system’ (Ibid, :30). That the regulator proposals were an attempt to meet
operator wishes is further supported by a Qantas document, prepared at the same
time as the DCA proposals were emerging and forwarded to the ALAEA by Senator
Cotton, the then Minister for Civil Aviation. The ‘key tasks’ for Qantas outlined in the
document were to ‘reduce DCA activity to surveillance only in all aspects’, ‘secure
full delegation for basic training’ and ‘eliminate DCA mechanic licence’. Dates were
set for the achievement of a ‘company approved person’ system that would ‘give
greater flexibility and control to Company’.vii
17
These were not changes that the ALAEA could accept. Firstly, Association
officials resented the inference in the DCA’s position that maintenance work
comprised merely a ‘series of allotted tasks’ that, if too complex, would be
beyond the capabilities of a LAME. Secondly, it disputed the possibility that, under
the new regulations, operators could appoint ‘authorised’ or ‘specified’ persons
to perform release functions who would not necessarily be licensed aircraft
engineers and could, in fact, be simply company supervisory staff. Thirdly,
although the Association thought the level of training at Qantas was
‘exceptionally high’ it warned of the dangers in making the employer the final
arbiter of employee competence and qualification level (ALAEA, 1971:5). Fourthly,
it opposed the bifurcation of training modules according to employer need,
stating that broad training across all categories, even where employees were not
rated, was a vital component of inter-LAME cooperation and, therefore, safety
(ibid: 22). Most of all, it disputed the Department’s claim that LAMEs’ delegated
powers and responsibilities made operators responsible for actions not under
their authority. The ALAEA position was that the license simply made each LAME
responsible for their own actions to the Department and, more importantly, their
delegated authority enabled the LAME to resist organisational pressures that
even the Department acknowledged existed to release aircraft they were not
satisfied were safe. As the ALAEA report asserted, ‘No LAME could reasonably be
expected to resist ‘pressure’ if an operator (with all of an employer’s sanction) is
to be the final arbiter as to the release of an aircraft’ (ibid:4).
This dispute is like a familiar song on the aviation ‘hit parade’, where so many
of the aspects of the dispute – the conceptualisation of LAME work, each LAME’s
authority to issue maintenance releases, the nature of LAME training – were, and
still are, disputed refrains. The main difference between this dispute and today’s
situation, however, is the industrial context in which the two disputes are taking
place. Although LAMEs are greater in number now than they were in the 1970s,
union density is much lower, while still impressive in the larger airlines. Higher
membership density meant that, in 1971, the regulator’s recommendations were
beaten back by the ALAEA’s strategy of political lobbying, legal action and the mere
threat of national industrial action. Today, the operators wield outsourcing as a
significant industrial weapon and it has a significant disciplining effect on labour
organisations in the aviation sector. In addition, the divide and rule strategies
exploited by the operators during enterprise bargaining periods cuts against, but
does not ever rule out, the possibilities of united action against employer incursions
into working conditions and aircraft safety.
Conclusion
The outcomes of this deskilling and ‘babbagisation’ of the L/AME labour process are
at the time of writing uncertain – particularly as the terms of the debates over the
safety of aviation maintenance could be transformed in an instant in the event of a
major disaster that was traceable to a maintenance problem. The crucial factor
mitigating against this strategy is the limit imposed by the safe functioning of
18
aircraft. That said, safety is a socially constructed and contested concept, existing in
a vortex between the twin pressures of production and protection (Reason, 1997).
At the workplace, where one side of the employment relationship defends the
importance of safe operating procedures, the other sees ‘rolled gold’ maintenance
and union featherbedding that is ripe for ‘lean’ work reorganisation. In Australia, the
main employer has offshored significant amounts of maintenance to escape union
influence, while ‘harmonisation’ of Australian licensing and qualifications with
European systems has allowed the importation of EASA licensed engineers.
Meanwhile, ironically, Australian licenses and qualifications have encountered
problems with recognition in key European and other MRO providers. This weakens
Australian aviation workers’ ability to resist, as their employment opportunities are
limited to Australia, while EASA-licensed workers are welcomed by employers under
the ‘skilled immigration’ program.
The intersections and interactions between regulations, licenses,
qualifications, skills, work organisation and industrial relations, in the realm of
aircraft maintenance, are complex. Labour process theory provides a fruitful, if
broad brush, explanatory framework through its concepts of deskilling,
‘babbagisation’, resistance, and its critique of technological determinism. The
reforms to the Australian licensing and training systems have set the scene for
labour cheapening and the degradation of work – and potential increased risk to the
safety of the flying public. Individual workers, hemmed in by restrictive and
expensive licenses, may not be sufficiently supported by government or employers
to learn and develop expertise. In addition, entire sections of the maintenance
workforce might not be given the opportunity to expand their skills because the
work available in the industry does not offer sufficiently complex scenarios on which
they can build experience and knowledge (for example, where heavy maintenance
facilities are closed as a cost-cutting measure, thereby diminishing the extent of onthe-job training opportunities). Amid the increasingly tired political rhetoric about
Australia as the ‘clever country’, we note that the deskilling agenda within aircraft
maintenance has been ratified by, and even implemented by, the very licensing
regime charged with monitoring and regulating safe standards of work in the
industry. While we acknowledge that air travel is still comparatively safe, it is
foreseeable that these changes signify a dilution of training and maintenance
standards and contain concomitant risks to the safety of aircraft released to service
after maintenance.
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i
Corresponding Author: I.Hampson@unsw.edu.au
The institutions of international airline regulation are discussed in Belobaba et al, 2009, ch. 2,
although the regulation of aircraft maintenance and its implications are not.
iii
Indeed, as we write, the training system awaits the announcement of yet another ‘new’ set of
standards for the conduct of training and assessment in RTOs. Similar exercises take place
periodically in the Australian training sector, with each of the new ‘systems’ since 2000 coming with a
fresh set of standards that ultimately fail to ensure quality of training and assessment (see Hampson
and Junor, 2010).
iv
The tasks are listed in an appendix to the CASR Part 145 Manual of Standards. See
http://www.comlaw.gov.au/Details/F2011C00688, Appendix II
v
It should be noted that the second proposal was issued only after meetings with airlines that had
raised concerns, see DCA (1971). Department of Civil Aviation, Proposals for changes in aircraft
maintenance engineer licensing with respect to major regular public transport operators, Issue 2,
November 1969, copy contained in ALAEA, A report on proposals to alter the system of licensing
aircraft maintenance engineers and the system of maintenance and certification authority in the
Australian aircraft industry, Sydney, June 1971, p. 31.
vi
Letter, D.G. Coleman, Federal Secretary, ALAEA to W.C. Taylor and Scott, Solicitors, 19 th March
1971, ALAEA archive. Bexley.
vii
Copied document, Box labelled ‘Licensing Committee’, ALAEA archives, Bexley.
ii
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