Narrative:

I was approached feb/tue/05 by the maintenance control quality assurance representative as to a deferred maintenance item and procedure that occurred jan/thu/05 for aircraft X. This query was in response to a letter of investigation received from the local FAA primary maintenance officer. Although I'm not privy to the details of the letter of investigation; my understanding is the FAA is questioning the validity of the procedure conducted versus the use of MEL 2522C (seat(south) inoperative) as proper in this incident. The facts are as follows: aircraft Y (DF781) jan/thu/05. The seat assembly at row 5ABC was reported loose in the seat floor track. The local ZZZ contract mechanic was contacted. It was determined that the forward inboard seat leg was internally stripped preventing the seat assembly from being properly secured to the floor track. The lack of parts and mechanic skills prevented a timely fix in ZZZ. It was recently communicated to maintenance control that merely restricting the seats from use by the application of MEL 2522C was no longer a valid relief in sits where seat assemblies would not secure to the floor tracks. I directed the contract mechanic to remove the seat assembly from the passenger cabin and stow it in the aft cargo pit. I had the mechanic placard the seat assembly 'do not remove.' I further instructed the mechanic to make a placard of such a size as to be obvious to ramp service and to affix said placard in such a way that it would not easily fall off. The life vests from the seat assembly were stowed in the spare life vest pouch. All electrical connectors were capped and stowed. Sometime in 2004; concerns were raised by the FAA regarding the weight and balance when removing seat assemblies from the passenger cabin. Procedures were established by the company to have the weight and balance computations altered by operations engineering reflecting the removal of seat assemblies. Further; subsequent concerns were raised in regards to the life vests installed underneath the seats as being hazmat when placed in the cargo compartment. DF781 documents the specifics that I took for the removal and stowage of the seat assembly as well as the compliance of the weight and balance and life vest issues. Specific directions were provided that the seat assembly was 'not to be removed' from the aircraft and its presence was to be checked at each station along with informing the station load planner of the 115 pound seat assembly in the aft pit. This direction was reinforced by the inclusion of an automatic-generating log write-up at each station requiring a signoff. Finally; specific direction was given to contact operations engineering (accompanied by the phone number) of maintenance control (if the repair was accomplished on a wkend) when the seat assembly was reinstalled so that the weight and balance computations could be returned to its original confign. The above procedure is not exclusive to myself nor maintenance control but has been a longstanding and common; albeit evolving; application of the MEL in similar sits; across all fleet types. This procedure pre-dates my employment (aug/85). My actions do not reflect willful disregard or negligence as I was unaware of any changes to this longstanding practice. Due diligence was demonstrated to the safety of the passenger and airworthiness of the aircraft as documented in DF781. E-mail issued feb/wed/05 by the local quality assurance representative prohibits the removal of the seat row assembly from the passenger cabin making the current policy clear and unquestionable.

Related reports:

Google
 

Original NASA ASRS Text

Title: AN A320 PAX SEAT COLD NOT BE SECURED IN THE SEAT TRACKS. SEAT REMOVED AND STOWED IN AFT CARGO PIT. FAA INVESTIGATION RESULTED ON DETAILS OF DEFERRAL.

Narrative: I WAS APCHED FEB/TUE/05 BY THE MAINT CTL QUALITY ASSURANCE REPRESENTATIVE AS TO A DEFERRED MAINT ITEM AND PROC THAT OCCURRED JAN/THU/05 FOR ACFT X. THIS QUERY WAS IN RESPONSE TO A LETTER OF INVESTIGATION RECEIVED FROM THE LCL FAA PRIMARY MAINT OFFICER. ALTHOUGH I'M NOT PRIVY TO THE DETAILS OF THE LETTER OF INVESTIGATION; MY UNDERSTANDING IS THE FAA IS QUESTIONING THE VALIDITY OF THE PROC CONDUCTED VERSUS THE USE OF MEL 2522C (SEAT(S) INOP) AS PROPER IN THIS INCIDENT. THE FACTS ARE AS FOLLOWS: ACFT Y (DF781) JAN/THU/05. THE SEAT ASSEMBLY AT ROW 5ABC WAS RPTED LOOSE IN THE SEAT FLOOR TRACK. THE LCL ZZZ CONTRACT MECH WAS CONTACTED. IT WAS DETERMINED THAT THE FORWARD INBOARD SEAT LEG WAS INTERNALLY STRIPPED PREVENTING THE SEAT ASSEMBLY FROM BEING PROPERLY SECURED TO THE FLOOR TRACK. THE LACK OF PARTS AND MECH SKILLS PREVENTED A TIMELY FIX IN ZZZ. IT WAS RECENTLY COMMUNICATED TO MAINT CTL THAT MERELY RESTRICTING THE SEATS FROM USE BY THE APPLICATION OF MEL 2522C WAS NO LONGER A VALID RELIEF IN SITS WHERE SEAT ASSEMBLIES WOULD NOT SECURE TO THE FLOOR TRACKS. I DIRECTED THE CONTRACT MECH TO REMOVE THE SEAT ASSEMBLY FROM THE PAX CABIN AND STOW IT IN THE AFT CARGO PIT. I HAD THE MECH PLACARD THE SEAT ASSEMBLY 'DO NOT REMOVE.' I FURTHER INSTRUCTED THE MECH TO MAKE A PLACARD OF SUCH A SIZE AS TO BE OBVIOUS TO RAMP SVC AND TO AFFIX SAID PLACARD IN SUCH A WAY THAT IT WOULD NOT EASILY FALL OFF. THE LIFE VESTS FROM THE SEAT ASSEMBLY WERE STOWED IN THE SPARE LIFE VEST POUCH. ALL ELECTRICAL CONNECTORS WERE CAPPED AND STOWED. SOMETIME IN 2004; CONCERNS WERE RAISED BY THE FAA REGARDING THE WT AND BAL WHEN REMOVING SEAT ASSEMBLIES FROM THE PAX CABIN. PROCS WERE ESTABLISHED BY THE COMPANY TO HAVE THE WT AND BAL COMPUTATIONS ALTERED BY OPS ENGINEERING REFLECTING THE REMOVAL OF SEAT ASSEMBLIES. FURTHER; SUBSEQUENT CONCERNS WERE RAISED IN REGARDS TO THE LIFE VESTS INSTALLED UNDERNEATH THE SEATS AS BEING HAZMAT WHEN PLACED IN THE CARGO COMPARTMENT. DF781 DOCUMENTS THE SPECIFICS THAT I TOOK FOR THE REMOVAL AND STOWAGE OF THE SEAT ASSEMBLY AS WELL AS THE COMPLIANCE OF THE WT AND BAL AND LIFE VEST ISSUES. SPECIFIC DIRECTIONS WERE PROVIDED THAT THE SEAT ASSEMBLY WAS 'NOT TO BE REMOVED' FROM THE ACFT AND ITS PRESENCE WAS TO BE CHKED AT EACH STATION ALONG WITH INFORMING THE STATION LOAD PLANNER OF THE 115 LB SEAT ASSEMBLY IN THE AFT PIT. THIS DIRECTION WAS REINFORCED BY THE INCLUSION OF AN AUTO-GENERATING LOG WRITE-UP AT EACH STATION REQUIRING A SIGNOFF. FINALLY; SPECIFIC DIRECTION WAS GIVEN TO CONTACT OPS ENGINEERING (ACCOMPANIED BY THE PHONE NUMBER) OF MAINT CTL (IF THE REPAIR WAS ACCOMPLISHED ON A WKEND) WHEN THE SEAT ASSEMBLY WAS REINSTALLED SO THAT THE WT AND BAL COMPUTATIONS COULD BE RETURNED TO ITS ORIGINAL CONFIGN. THE ABOVE PROC IS NOT EXCLUSIVE TO MYSELF NOR MAINT CTL BUT HAS BEEN A LONGSTANDING AND COMMON; ALBEIT EVOLVING; APPLICATION OF THE MEL IN SIMILAR SITS; ACROSS ALL FLEET TYPES. THIS PROC PRE-DATES MY EMPLOYMENT (AUG/85). MY ACTIONS DO NOT REFLECT WILLFUL DISREGARD OR NEGLIGENCE AS I WAS UNAWARE OF ANY CHANGES TO THIS LONGSTANDING PRACTICE. DUE DILIGENCE WAS DEMONSTRATED TO THE SAFETY OF THE PAX AND AIRWORTHINESS OF THE ACFT AS DOCUMENTED IN DF781. E-MAIL ISSUED FEB/WED/05 BY THE LCL QUALITY ASSURANCE REPRESENTATIVE PROHIBITS THE REMOVAL OF THE SEAT ROW ASSEMBLY FROM THE PAX CABIN MAKING THE CURRENT POLICY CLR AND UNQUESTIONABLE.

Data retrieved from NASA's ASRS site as of January 2009 and automatically converted to unabbreviated mixed upper/lowercase text. This report is for informational purposes with no guarantee of accuracy. See NASA's ASRS site for official report.