Going LOTO for Safety

Published in Midwest Flyer – June/July 2018 issue

Wherever you go, when you meet people who are pilots or aircraft technicians, their passion for many things, if not all things aviation, is readily evident. It is what most often makes aviation feel like an extended family. But another interesting facet of those in aviation is their passionate concern for safety and following proper safety procedures.

One safety procedure people in aviation will hear more about in the very near future is referred to as LOTO, which stands for Lock-Out/Tag-Out. It was developed by the Federal Aviation Administration’s (FAA) General Aviation Joint Steering Committee (GAJSC) which has identified a number of fatal general aviation accidents caused by flying in an aircraft that was undergoing maintenance and had not yet returned to service.

The federal Lock-Out/Tag-Out standard, 29 CFR 1910.147, developed by the Occupational Safety & Health Administration (OSHA), went into effect in 1989. Its purpose was to prevent injuries and deaths caused by inadvertent start-up of equipment during maintenance or servicing. The FAA has its own Occupational Safety and Health Program: 3900.19B. The GAJSC’s procedures are of course aviation specific.

Pilots trust their mechanics to help keep them flying by performing exacting maintenance on their aircraft. But before flying an aircraft that has just come out of maintenance, pilots need to ask the question, “How do I know the aircraft is safe to fly?”

In a recent article published by the FAA, they “…suggest you consider adopting an informal lockout/tagout procedure to ensure that you, and other pilots, are aware that the aircraft you’re about to fly may not have been returned to service.”

In fact, Title 14 of the Code of Federal Aviation Regulations (14 CFR), Section 91.9 (a) says, in part, that no person may operate a civil aircraft without complying with the operation limitations specified in “the approved Airplane or Rotorcraft Flight Manual, markings, and placards.” It goes on to say, “Placards also alert us to non-working equipment or instruments. You may operate most types of light aircraft with inoperative instruments, as long as they are not part of the VFR day type certification. In addition, the aircraft must have a placard that says ‘inoperative.’ If the instrument is removed from the aircraft, a placard must provide the status. In all cases, the pilot or mechanic must determine that the inoperative instrument does not pose a hazard to flight safety.”

In addition, the FAA article states, “Pilots and mechanics share a responsibility to indicate properly inoperative instruments or equipment. Look at 14 CFR, Section 91.405. It requires owners or operators to have inoperative instruments or equipment repaired, replaced, removed, or inspected at the next required inspection with placards installed, as required. In 14 CFR section 43.11, it says the person performing required maintenance must have a placard placed on the items permitted to have deferred maintenance.”

While most aircraft owners maintain a good awareness of the mechanical status of their aircraft, clearly some have missed that point and have flown or attempted to fly a plane that was in fact, not airworthy. The resultant accidents have been serious enough for the GAJSC to begin an active outreach to pilots and maintainers. The FAA article reminds pilots to “…make it a point to coordinate with your mechanic before, during, and after maintenance procedures. Ask questions about any procedures you may not be familiar with so that you will have the full scope of the type of work that was performed.”

Remember, you as the pilot-in-command are responsible for your aircraft, your safety, and the safety of your passengers and innocent people along your flight path.

So, plan for and take the time to check with your mechanic before you fly. Include time to do a runup before planning your next flight. Taxi back and shut down. Now take a look at everything one more time. Check to be assured that everything is tight and proper for flight conditions. If something isn’t properly secured, for instance, it almost goes without saying that both you and your mechanic will be much happier having made that discovery on the ground. Trust, but verify.

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