Thirty Years of Outsourcing Safety
So stated a press release that Colgan Airlines released on the first day of the NTSB hearings into Colgan 3407. In an effort to limit the damage to their reputation, Colgan was quite willing to throw their deceased crewmembers under the bus. In the hearings, Colgan management was evasive and defensive, attempting to ward off every suggestion that culpability for this accident might not begin and end with the two individuals not there to defend themselves. In doing so, Colgan management came off looking like rank amateurs.
Nobody can deny the kernel of truth within Colgan's statement. This crew did undoubtedly make a number of serious mistakes, some commonplace and others nearly inexplicable, which compounded on each other and resulted in tragedy. Yet these mistakes did not take place in a vacuum; there were a number of circumstances that may have contributed. In my previous posts I have explored how latent training errors and self-induced distraction may have been factors. Any serious look at this accident must also examine the regional airline industry itself for widespread patterns and trends that helped create the right environment for an accident like this.
At the time of the accident, the Captain had approximately 3300 hours of flight time and the FO had 2300 hours. By most airlines' standards this was an inexperienced crew, but they actually weren't horribly inexperienced compared to some of the crewmembers at the regional airlines. At airlines like Colgan, Pinnacle, and Mesa, in the not-so-distant past one could find 2000-2500 hour new Captains paired with 250 hour newhire First Officers. Worse yet, the Captain might be new to not only the left seat, but the airline and their routes as well; all three of the above companies hired direct-entry Captains. This was because they did not have enough First Officers qualified to upgrade due to a combination of growth, attrition, and their newhires' low flight time. Captain Renslow had 625 hours total time when he was hired at Colgan. First Officer Shaw, with sixteen hundred hours of fair weather flying in mostly single-engine piston aircraft, was actually a "high-timer" for the period in which she was hired.
Colgan testified at the NTSB hearing that a particularly favorite source of pilots is an institution known as Gulfstream Academy; they hired Captain Renslow from there. This "academy" is actually a functioning Part 121 airline in Florida that flies as Continental Connection. Brand-new commercial pilots pay $30,000 to buy a "job" as a First Officer on a Beech 1900 turboprop. Few of Gulfstream's paying passengers have any idea of their crew's extreme inexperience. After 250 hours on the line, these pilots are hired via bridge programs at airlines like Pinnacle and Colgan. They are a management dream: too inexperienced to be hired anywhere else, possessing some airline time to make training go smoother, and willing to work for any wage that's an improvement on paying bucketloads of money for their job.
What these pilots do not have is the experience of taking over the controls from a student who has put the airplane in danger, or having scared themselves straight on a low approach in a decrepit old freighter - or for that matter, having practiced hundreds of successful stall recoveries. Gulfstream portrays this as boring, useless timebuilding to potential enrollees looking for a shortcut, and a certain class of airline management enthusiastically agrees. After all, the modern regional airliner is relatively idiot-proof. If management could hire monkeys to fly them, they would - provided the price of bananas did not go too high.
The noteworthy thing here is that not all airlines stooped to hiring low-time pilots from the likes of Gulfstream. There were plenty of experienced pilots to be had but for a modest price. Despite paycuts and gutted contracts and seniority list stagnation, the major airlines were flooded with resumes from supremely qualified candidates when they began hiring again. It was the regional airlines, with their inferior pay, benefits, schedules, and work rules, who had to settle for pilots with little aviation experience, and a particular class of regional that struggled to fill their classes despite no hiring standards at all.
Here's a real-life example of how Colgan's low pay deprives them of experienced pilots. In the summer of 2007, I briefly considered applying to Colgan. With 4500 total hours and 2200 hours in the Q400, I would have been much more qualified than the average newhire. I chose not to apply because of Colgan's insultingly low pay rates and lack of work rules or union protection, and because the airline's cheapness in compensation bespoke a cheapness in other areas to me.
Training is a perfect example. Like many regional airlines, Colgan has sought to decrease training costs through outsourcing (to FlightSafety), shrinking their training footprint, and allotting a minimum number of hours for Initial Operating Experience (IOE). Colgan's pilots, and those of many regional airlines, are taught by sim instructors who often have never touched the actual airplane, and usually teach for several airlines with differing procedures. Ground instructors may have never flown any airliners! Is it any surprise that Coglan pilots were a little hazy on the significance and proper usage of the Ref Speeds switch? After sim training, Colgan pilots were given 30 hours to complete IOE; any more required approval and invited unwanted scrutiny. That's not very much for inexperienced pilots learning a rather quirky airplane. At Horizon you could go to 50 hours without them batting an eye, and ANA actually requires 70+ hours for their pilots. Sure, you can hammer out the basics in 30 hours, but that doesn't leave much time for a check airman to impart the nuances of the airplane - like, for example, "Be particularly mindful of your airspeed when you put the gear down and the props to 1020, there's a ton of drag and you can get too slow very quickly if you don't pay attention."
Hiring woefully inexperienced pilots and rushing them through training is bad enough; subsequently operating under policies that encourage them to fly sick and/or tired is simply asking for trouble. Unfortunately, many regional airlines including Colgan do just that. It's another side effect of a mentality that stresses cost savings above all else and pretends there are no negative consequences for safety in doing so.
Most regional airlines operate with fewer pilots per airplane than the majors. This is partially a result of differing stage lengths, regulations, and contract work rules, but many regional airlines also intentionally short-staff themselves as far as they can and still maintain schedule integrity. Low-paid regional pilots who are trying to build hours can generally be depended upon to pick up plenty of overtime, after all. The problem is that running so close to the edge means that a few months of high attrition or recruiting difficulties can make the airline severely short-staffed in perpetuity. Pilots suffer the most under these conditions: their schedules get built to the maximum limit, they have fewer days off to recuperate between trips, and even those days are subject to "junior-manning" as desperate crew schedulers force pilots to work on their days off. A few bad months can leave one feeling chronically fatigued. A long or difficult commute only makes things worse.
Many people have correctly noted that it is a pilot's own choice to commute. This is a decision most pilots will make a few times throughout their career, and it's never easy. I chose to leave a city and area I love dearly in order to avoid a notoriously bad commute, but my choice may have been different if Dawn and I had family in Portland, or had kids in school, or if the cost of living in my base was higher. The Seattle-Newark commute has to be one of the worst out there; the FedEx Captain who gave FO Shaw her last ride to work told her as much. Her choice to move to Seattle was apparently sparked as much by financial considerations as personal ones. Ms. Shaw was barely able to make ends meet in Norfolk by holding down a second job as a barista, so New York was clearly out of the question. She and her husband had moved to Seattle to live with her parents, at least initially.
From the multiple yawns noted on the CVR transcripts, it's likely the crew of 3407 was tired. One can understand why: it was after 10pm, they'd both been up very early, and the FO likely had very little quality sleep the night before. Moreover, they'd spent the entire day in the crew room due to a cancelled roundtrip. In my own experience, this is more tiring than actually flying, especially if there's no dark and quiet place to sleep. Most airlines provide such a place near their crewrooms, but not Colgan: they actually left the lights on full-time to discourage pilots from sleeping!
The FAA is quite clear that crewmembers must be fit to fly, and must remove themselves from duty if any condition, including fatigue, would impact their performance. Virtually every airline has a fatigue policy in their contract or FOM. How they actually administer that policy, however, varies widely by airline. At most majors, calling in fatigued is a non-jeopardy event; some even let you use your sick time. At Colgan and many regionals, calling in fatigued results in loss of pay and potential disciplinary action. Fatigue calls are usually tracked and monitored for any "patterns" of fatigue, which is left up to management's discretion and may be a mere two events. Besides the threat of discipline including termination, unscrupulous managers have been known to force fatigued pilots to undergo sleep studies during unpaid time off, or even report them as chronically fatigued to the FAA's aeromedical division. Such scare tactics are meant to cut down on "absenteeism" which threatens schedule integrity at chronically understaffed airlines. The practical effect is that pilots will often just fly tired in all but the worst cases. Most of the time they make it to their destination without incident and the airline can justify their policies as being "safe."
A similar story plays out in the realm of sick call policy. Again, the airlines' policies, ostensibly in place to prevent schedule disruption due to sick time abuse, having a chilling effect on the proper use of sick time as well. To begin with, sick time accrual at many regionals is agonizingly slow. In Colgan's case, it takes a newhire nine months to accrue enough sick time to cover a four-day trip. A newhire already at poverty-level wages can ill afford an unpaid week. Secondly, sick calls are often handled in the same paranoid manner as fatigue calls. Calling in sick at many regionals prompts personal questions from crew schedulers and follow-up calls from chief pilots. If you're unfortunate enough to fall ill on a holiday, around your vacation, or even on a weekend, they'll often demand a doctor's note - procured at your own expense under often-inferior health plans. Mind you, there are many things that a pilot should call in sick for that don't require a visit to the doctor and can usually be handled with rest and OTC medications; FO Shaw's head cold comes to mind. If their policies result in such a marginal pilot deciding to fly, management doesn't seem to mind. At least the schedule gets covered, and it's pretty rare that a sick FO fails to notice her Captain doing something disastrously boneheaded.
It's easy to vilify regional airline management for this behavior, but the reality is that it is generally borne of financial necessity rather than a perverse hatred of pilots or the pursuit of personal enrichment. Regional airlines live and die by their cost structures because the major airlines they contract with have made it this way. Virtually all regional airline management is cheap; the main difference between them is the degree of their aggressiveness in cutting costs and how vile they're willing to be to their employees. The most foul - i.e., the most cheap - have reaped the most growth in recent years as they lap up contracts with major airlines. In the case of Colgan, this came in the form of 15 Q400's to be flown as Continental Connection.
Now, the major airlines do have certain performance metrics that must be met along with the baseline requirement of low cost - witness Mesa's fall from grace - but otherwise the majors generally leave their regional airline partners to their own devices. They don't concern themselves with hiring practices or minimum experience levels, training programs, or sick and fatigue call policy. They generally are not involved in whatever safety programs the regional airline participates in. In short, by their silence they endorse regional managements' view that penny-pinching in every aspect of the operation doesn't impact safety so long as everything is legal. Of course, when a regional partner suffers a crash, the majors are very quick to point out the actual identity of the carrier involved. It's a convenient about-face after selling the victims a ticket with their name on it and festooning the outsourced airplane with their livery. Those passengers likely expected a mainline standard of safety, but only after an accident does mainline fall all over themselves to explain just how little they had to do with the operation of that flight.
The circle of blame for this unholy situation only expands outward from there. You can include the Congress of 1978 for deregulation, subsequent Congresses for lack of oversight, the FAA for turning a blind eye to the regionals' most abusive practices, pilots for being willing to take such low-paying jobs in hopes of an eventual payoff, and so on. Ultimately, though, what we're seeing is the free market at work. The situation exists because it benefits all of us as a collective group of consumers. Passengers are paying less, in real dollars, than they've ever paid to fly, and they still think they're getting stiffed. Improving safety would require increasing fares, and passengers are utterly unwilling to pay more (if you doubt me, read some of the comments here). While the flying public always make concerned noises about aviation safety, most people know enough basic math to reason that even if the regionals are more dangerous than the majors, the accident rate is still so low that there's a miniscule chance of ever being personally affected. Why spend more money for something that won't affect you? The logic isn't flawed, but it does need to be followed to its ultimate conclusion for real moral clarity on the situation: I am willing to let others die so I can save a few bucks.
As collaborators get the innermost circle of hell to themselves, I've waited to the end of this post to write about one particular group's culpability in creating the environment that fostered this accident: our very own Air Line Pilot's Association. This may come as a surprise to some of you, as I've defended airline unions on this blog before and have noted that I am active within the union. I still maintain that unions are necessary in this industry to guard against management's worst tendancies, but I fully recognize that ALPA has been utterly clueless on the matter of outsourcing and in fact fully cooperated with management in creating the two-tier system we see today when it benefitted them. Having bought into management's stance that regional jet feed was necessary for mainline growth but could not be operated cost-effectively with the payrates that mainline pilots expected, ALPA's mainline MECs declined to fly the first wave of RJs but gladly shared in the revenue they produced. They didn't concern themselves with the question of who would fly those RJs or under what conditions. When regional pilots unionized - often under ALPA - and attempted to better their lot, they got little help from their mainline counterparts. ALPA granted management scope relief after scope relief, but there was never any insistance on requiring that ALPA pilots fly the RJs, or setting a minimum standard contract, or at least insisting on some oversight of the outsourced operation's safety programs. All these things were determined to be the regional pilots' problems, despite the fact that any attempt to solve them, like the Comair strike in 2001, only made mainline shift flying to other, cheaper carriers.
Even after everything that's happened since then, this mindset is still quite prevalent at ALPA. A few months ago I was involved with a group of WidgetCo pilots in a grassroots effort to force their union to at least study the feasability of recapturing 76-seat flying. Just before a meeting of the union's Atlanta council, we were called into a meeting with the MEC chairman. He rejected the idea of recapturing outsourced flying outright, saying it would be too expensive and there would be no benefit for the majority of the membership. He said not to worry about scope, that ALPA was done giving up scope (this was a few days after he had granted scope relief to increase the allowed number of 76 seat airframes!); he then stated that outsourced flying was good for mainline pilots because the low cost flying brought in revenue they shared in. This is coming from the popular union head of the world's largest airline, and a likely future candidate for ALPA's presidency. I left that meeting utterly shaken that ALPA would or could be part of the solution to the mess we're in, at least in its current form.
If anything is going to change, it will likely come through the legislative response that has already begun in response to the Colgan hearings. Randy Babbitt, the FAA's new administrator, is much more favorable to changing duty and rest regulations than previous administrators have been; meanwhile the Senate's Aviation Subcommittee is going to be holding hearings into working conditions and safety at the regional airlines in early June. It'll be interesting to see whether any substantial legislation actually emerges from the process. In the meantime, those of us at the regionals can do our own little bit to keep our airlines safe, whether that means enforcing cockpit discipline, making an active effort to refresh our knowledge of systems and procedures, or standing up to management intimidation when we shouldn't be flying.