Aircraft Maintenance in Australia: Issues and Prospects

Ian Hampson1, Doug Fraser, Anne Junor, Michael Quinlan, and Sarah Gregson

Industrial Relations Research Centre, andAustralian School of Business,

University of New South Wales,

International Labour Process Conference, London, 7-9 April, 2014.

ABSTRACT

This paper reports some preliminary results of an Australian Research Council funded Linkage project into the Future of Aircraft Maintenance in Australia. Offshoring by the main carrier, Qantas, from 2006, raised questions about safety and the future of the industry, a future which will be shaped by political, industrial and ideological struggles, and to which the development of workforce capability and the organisation of the labour process is central. There are two sets of concerns our research has highlighted that we will discuss here.

First, in a Senate inquiry in 2007, the Australian Licensed Aircraft Maintenance Engineers Association (ALAEA) argued that offshoring raises concerns about the safety of maintenance performed in overseas Maintenance and Repair Organisations (MROs). Australian airlines have been slow by international standards to go down the offshoring route. The US is a good comparator, because of the availability of information and because there has been a robust debate about offshoring – in contrast to Australia. Also in the US the regulator (FAA) is exposed to much greater scrutiny by other public agencies than is CASA in Australia. In the US, until 2012, the regulator was effectively able to ‘wash its hands’ of accountability for the quality of maintenance in ‘uncertificated’ (that is, unapproved and obviously uninspected) shops. Recent regulatory changes have closed off this loophole, and offshored shops will be required to be certificated, and inspected annually. As well as improving safety and compliance, this measure could potentially remove some of the cost advantages that offshoring enjoys – particularly if, as proposed by some activists, the costs of inspection are forced on the airlines, rather than externalized to the taxpayer. We explore the question of whether there is scope in Australia for learning from the US experience, and whether tightening regulatory oversight of offshore MROs, and sheeting the cost to the airlines, may be part of the solution to bringing some maintenance back to the country. That is, regulatory insistence on ‘safety’ can be a kind of industry policy – and one that sidesteps the usual ideological constraints on the latter.

Second, industry policy and the development of workforce capability are linked. In both spheres, the trend has been towards more market-based policies. We document the collapse in the training of L/AMEs. This is serious because of a looming global shortfall of licensed personnel and skills, which is projected by the International Air Transport Association (IATA), and the International Civil Aviation Organisation (ICAO). How national training systems meet this shortfall will be a major determinant of

1 Corresponding author – I.Hampson@unsw.edu.au

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the future of the industry. We touch on the debate over industry policy, where although there is a strong ideological preference for market-based ‘solutions’, there are exceptions made for certain industries, and certain State governments have endeavoured to support the MRO industry. Federal government leadership could help preserve and develop the industry.

This paper is a sequel to one delivered by Sarah Gregson to last year’s ILPC on our current research project on the labour market for aircraft maintenance engineers (AMEs) in Australia. While it still has the status of preliminary results, it presents an update on the findings that are emerging as we approach our final reporting date in July.

The earlier paper centred on the important but technical issues that came out of reforms to the licensing system for aircraft maintenance. This one covers the broader set of issues created by the offshoring of a growing part of this work, and in particular the looming global shortage of skilled personnel which threatens not only the offshoring model, but the safety of air travel throughout the world for the next 20 years. We also look at the way these issues – always inherently political – have become intensely politicised, even incendiary, in the period since last year's change of national government, and how that has affected our research task.

1. Background and history

There are two key players in this drama: Qantas, the "national" airline, and the Australian Licensed Aircraft Engineers Association or ALAEA, the union which represents licensed aircraft maintenance engineers (hereafter referred to as LAMEs). It should be noted that these two do not account for the full story by themselves: Qantas now has one securely established competitor in the domestic market, Virgin Australia, which is majority-owned by Etihad, Singapore Airlines and Air New Zealand with only a residual holding from the Virgin group, and runs a horizontally integrated operation of roughly equal proportions, with each major airline owning a full-service, a budget and a regional brand, while Qantas has at least half a dozen other unions, of which three are also our partners in this project. However, these two organisations have emerged as the clear protagonists in the public debate over the last two years on the future of the Australian industry.

Qantas is the last survivor of the three airlines which effectively monopolised Australian aviation from the immediate post-World War 2 period through to the 1990s. From around 1950 onwards, passenger services on the main air routes between Australian capitals were run as a regulated duopoly involving a government-owned airline (TAA, later Australian Airlines) and a private one, Ansett. This was essentially a politically convenient compromise, rather than the result of any objective analysis of the most appropriate industry structure to serve the market as it then was. In hindsight, it is perfectly clear that the size of the market in that period could never have supported more than two competitors; in many nations with much larger populations, the sector remained a monopoly until well into the 60s. Even the survival of two competitors was precarious, so the duopoly needed to be heavily regulated to ensure that neither player competed sufficiently hard to pose a serious threat to the other.

At the same time, a single airline, the original Qantas, which had started out in private ownership before the war but was now government-owned, held a monopoly of flights in and out of Australia, originally in close cooperation with BOAC (later British Airways) with whom it had shared the Imperial air service to London since the days of the Empire flying boats in the 1930s. This too was rational in the economic circumstances of the time, since the 50s were a period when virtually every country felt the need for its own flag-carrier airline as the only reliable means of ensuring that it got

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the level of international services it required, and the size of the world market at the time meant that only the biggest and richest nations could hope to survive in that market with more than a single national airline.

While far from efficient by today's standards, and arguably not even the most efficient arrangement that could have been followed at the time, this framework provided the important advantage of stability and long planning horizons. This made it possible for the three major airlines to build up state-of-the-art fleets and a structure of maintenance shops at or close to best world standards. Being at ‘the end of the line’ geographically meant that Qantas engineering ‘had to fix things itself’, and developed a very high level of technical excellence, evident for example when industry leaders like Rolls-Royce drew on innovations generated on the engine repair line in Sydney (eventually closed down in 2006). In the process they became major contributors to the development of apprenticeship in aircraft engineering, especially once the occupation had emerged as an independent trade towards the end of the 1950s. Increasingly as time went on, this meant that most people who worked as maintenance engineers in Australia had done their training either in the defence services or in the shops of one of the three major airlines.

As might be expected, the regulated system on both the domestic and international fronts came under growing pressure as air travel drew closer to becoming a mass-market commodity. The international segment was progressively opened up to foreign competition from the 60s onwards, though still under legislation which strictly controlled access, and which remains in force today much as it was then. The domestic duopoly, though coming under increasing criticism (especially over the practice of both airlines running their services between each destination pair at exactly the same time), generally continued to provide a level of service that satisfied the needs of the travelling public. It was only towards the end of the 80s that the regulation which supported it began to be broken up, and only in the mid-90s that it finally became effectively possible for new entrants to come into the market on the major intercapital routes. Meanwhile Qantas and TAA were amalgamated in the late 80s, and the combined entity was privatised in stages from 1992 onwards.

Despite this nominal freeing-up, the market appeared to preserve the characteristics of a natural duopoly, with the result that it became next to impossible for a third player to establish itself for longer than a couple of years at a time in the face of predatory behaviour, and ultimately takeover, by one or another of the two incumbents. This was effectively the situation up to the start of this century, when the industry moved abruptly into a new phase.

At the end of 2001, Ansett went out of business. This development was unexpected and came at the end of a succession of unwise commercial decisions coinciding with the collapse in demand for air travel that followed the 9/11 disaster. One of the immediate casualties was its apprentice program, leaving Qantas as virtually the only large civilian training provider. The other was Ansett's maintenance workshops. Some of these facilities were taken up by Qantas, but the demand was never fully restored, since the new competitors who came into the market over the next few years to fill the gap (including one created by Qantas outside its articles of association) were built on the budget or low-cost carrier (LCC) model, which normally does not involve the carrier owning its own workshops.

The outcome was that Qantas, or at least that part of it which continued to trade under its original business identity, became for some years both the only customer and the only provider in key areas of Australian MRO. To a large extent this remains the situation today, leaving Australia highly dependent on Qantas both for its high-end civilian MRO infrastructure, and for its supply of AMEs with the skills required to service current-generation large passenger aircraft. This largely explains

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why its activities in this field are considered a matter of public concern rather than a purely internal affair of the company.

It will be apparent to anyone with even a slight knowledge of economics that it is undesirable for an entire industry segment to depend to this extent on the strategies and success of a single company, since even a business strategy which effectively maximises the utility of the dominant company does not necessarily work to the benefit of the industry as a whole. If this is true even when that strategy is effective, it is all the more so when the dominant company fails to maximise its own utility.

Qantas’s poor commercial performance over the last 2-3 years is a matter of considerable public controversy, which it is beyond the scope of this paper to cover in any detail. Regardless of the reasons, Qantas has gone in the space of a couple of years from reporting strong growth in a domestic market that ensured a high measure of de-facto protection from its natural duopoly characteristics, to a pre-tax loss of over $300 million for the first half of 2013-14, accompanied by the loss of its investment-grade credit rating at the start of this year. It responded with an immediate plan for $2 billion worth of cost reductions, including a reduction in employment of 5000 jobs, equivalent to about 15% of its workforce. While represented in public as an unexpected crisis, this cost reduction strategy is partly a continuation of a process which has been in progress, albeit on a lesser scale, since at least as far back as 2005.

Since its privatisation (and possibly for some time before), Qantas has followed the lead of other corporations in the 90s by running through the managerial fashions of the period, including the mantra of ‘shareholder value’ and the McKinsey model which involved restructuring large integrated enterprises for accountability purposes into quasi-independent profit (or cost) centres. This model provided the rationale for successive waves of outsourcing. In the case of aircraft maintenance, this meant moving an ever larger proportion of the work offshore.

All this happened against the background of a growing global industry of third-party MRO. This originated soon after airline deregulation in the US in the 90s, but has expanded spectacularly in this century with the worldwide success of the budget carrier model (Tang and Elias, 2012). The current value of this industry was estimated in 2013 at $US65 billion a year (ARSA, 2013:3). A significant part is located in low-wage countries, relying primarily on low prices to draw in the price-driven segment of the international market (though there has been a tendency in the last few years for the industry to become a lot more differentiated, with an increasing number of plants in the old industrialised countries taking in specialised work from Third World airlines). According to a survey undertaken at the start of 2013 by an American consultancy, only 16% of airlines in a global sample (22% of North American airlines) reported offshoring their maintenance for reasons other than cost (Spafford and Rose, 2013:9).

The mainstay of this industry up to now has been heavy airframe maintenance – major periodic checks and overhauls which at their most ambitious (the D checks) amount practically to a rebuild, as the aircraft is stripped back to the bare metal looking for cracks and corrosion. This process is very labour-intensive - labour makes up an estimated 70% of total costs across the whole segment (ARSA, 2013:7), making it easy for a competitor in a low-wage country to undercut Australian prices substantially, especially as some of the operations in the major checks (e.g. stripping out seats and interior fittings, washing parts, removing paint and sealant) do not require especially skilled labour. As maintenance is a part of the service package which is invisible to the traveller unless seriously neglected, this has been an obvious first-line option for airlines facing pressure to reduce their cost base ever since the 1990s.

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In the last two years, Qantas has accelerated its maintenance offshoring program, with the closure of several facilities and the loss of over 1000 jobs. Of the 5,000 jobs to be cut in response to its latest trading result, it is generally believed that about 1500 will come from maintenance, but at the time of writing Qantas has yet to disclose the exact number – not even to the unions with whom it is obliged by its industrial agreement to negotiate such staff reductions.

Returning to the ALAEA, the union has traditionally had a particular strategic importance to Qantas because of the prominent role its members play in ensuring aircraft safety. LAMEs differ from other maintenance engineers in that their licence entitles them to sign off on the satisfactory completion of maintenance, and perhaps more importantly to release the aircraft back into service once maintenance has been done. In a different kind of quality assurance scheme, this role might belong either to a government-appointed inspector, or to a quality controller employed by and accountable to the enterprise concerned. In the case of aircraft maintenance, the LAME, while employed by the airline or maintenance provider, effectively exercises a devolved role of inspector on behalf of the state. This has been the accepted way of assuring the safety of aircraft maintenance ever since the Chicago convention was signed in 1946 – in other words, the arrangement is grounded in international law, enforced by each state through what is in effect delegated legislation.

Thus LAMEs, besides exercising one of the highest levels of specialist skill in the blue-collar workforce, enjoy additional delegated state authority which in the letter of the law at least, can override the authority of their employer in the event of conflict. In both senses, they represent the kind of "labour aristocracy" described by Lazonick and O'Sullivan (1994:16), in effect exercising a kind of managerial prerogative which management is unable, or in this case legally unqualified, to exercise in its own right. The ALAEA thus represents a classic craft union (Haas, 2008: 605), and at times in the past has been resented by the other unions for its perceived closeness to management.

In practice, this delegated authority structure, and the kind of partnership which it more or less enforced, was generally accepted by the employer and worked to the benefit of both parties so long as airlines were owned and managed predominantly by people with some kind of a background in active flying, and so long as passenger flights still crashed often enough for safety to be an important consideration for customers choosing which airline to fly with. Qantas did well out of its reputation as “the only airline that’s never had a crash” through the postwar decades, and continued for some time afterwards to cite its safety record as a corporate asset (though by the time of that line from Rain Man, which Australians still love to quote 25 years on, this was clearly meant to be viewed as the concern of an obsessive personality rather than of a representative passenger). As air travel in general went through a major improvement in safety, this record became less valuable as a competitive strength, leaving the way open for a later generation of generalist managers to view the union’s standing in terms of featherbedding and an undesirable loss of control.

2. Research in a politicised environment

The three processes – changing management attitudes to the safety assurance protocols, the growing availability of low-priced offshore MRO, and the souring of relations with the ALAEA – came to a head in October 2011. Management grounded the entire airline for two days without notice in an attempt to force resolution of an enterprise bargaining process (the one context in which a circumscribed right to strike still exists under Australian industrial law) which had stalled over management’s refusal to accept limits on maintenance offshoring.

The consequences of this lockout were ambivalent for Qantas. On the one hand, the dispute was resolved substantially in management's favour by Australia's somewhat toothless industrial arbitrator, and the decision was subsequently taken by Qantas management as a signal that it could continue to offshore its maintenance without encountering any serious obstacles even under a Labor

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government. On the other, the sudden cessation of flights at least temporarily alienated much of Qantas's loyal customer base – a perilous gamble to take at a time when little else beyond Australian customer loyalty differentiated Qantas International from its growing number of competitors, and when Virgin Australia had embarked on its process of transformation into a full-service airline competing with Qantas on its most protected home territory. Rightly or wrongly, the collapse of Qantas's trading performance is widely seen to have originated at this point. Above all, though, it meant that the dispute between Qantas and the ALAEA, previously of interest only to industry insiders, suddenly became a highly public issue, and in consequence, intensely politicised.

The politics became more intense after the change of government in September 2013. In preparation for the release of its trading figures in February, Qantas went to the new Government seeking assistance on the grounds that it was not playing on a level playing field with the foreign-owned Virgin. Since the incoming Government from the start had been openly contemptuous of direct assistance to manufacturing (to the extent that Australia's two remaining car manufacturers announced their intention to close their plants before any actual change in assistance policy had occurred), Qantas needed to seek other means or at least a different rationale. The Labor government which oversaw its initial privatisation in 1992 had imposed a number of largely cosmetic restraints, enshrined in the articles of association of the privatised company, to safeguard its "national" status. These involved restrictions on its foreign ownership, and particularly its ownership by foreign airlines, together with a provision (dubiously enforceable owing to the lack of clarity in its drafting) to retain its headquarters and an unspecified proportion of its operations in Australia. While in practice Qantas had been blithely circumventing these obligations for a decade through the medium of its Jetstar subsidiaries (which are exempted from the requirements because they were incorporated under different articles of association), it chose to present a case that these restrictions were impeding its competitiveness, and sought repeal of the relevant part of the Act.

Leaving aside the merits of these claims, they went directly to several of the main causes of public controversy, and drew opposition from the upper house of Parliament which the Government still does not control. The result of the impasse was two sets of Senate committee hearings which brought into the public domain a certain amount of material previously circulated only within the industry, because evidence presented to the committees was protected under parliamentary privilege. Members of our team made a submission in a private capacity to one of these hearings (Fraser et al, 2014) which was quoted at length and verbatim in the committee's final report (SCRAAT, 2014), bringing our research to a much broader audience than it had previously enjoyed. Around the same time, the Government announced its own inquiry into the regulation of aviation safety (one of a clutch of public inquiries which appear to have been designed primarily to embarrass the previous government), to which our project made an official submission (Hampson et al, 2014) which has also received widespread publicity, some of it from the mainstream media.

Consequently we find, whether or not we wanted it, that our research has become part of an active and heated political process. We fully expected this to happen once our report was presented, but events have run ahead of us, and we now find ourselves faced with the need to complete the final phase of our research in this environment of partisanship and inflamed feelings. This has added to a number of challenges that already make it difficult to research the industry in this country.

To begin with, research in this field in Australia faces practical difficulties. Aviation is a relatively new field of academic research in this country, and very little scholarly writing exists on the history of our industry. As we argued at the beginning of our project (Hampson et al 2010) the academic study of aircraft maintenance is fragmented into academic specialisms that, by and large, do not talk to each other. On top of this, the whole environment is evolving so rapidly that the process of academic publication is left well behind, leaving us to rely for much of our information on blogs, trade

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publications and other grey literature, plus occasional background articles in mainstream media which vary widely in quality. While much of this literature seems to us very reliable and well informed, it undoubtedly lacks the standing that academic research enjoys, and consequently is open to challenge – informed or otherwise – without the safeguard of peer review.

Statistically, we find ourselves in an even harder position. The labour market data in particular leave many gaps, mainly because the occupation of AME is a very small one, located at or beyond the 4-digit level in our occupational and industry classifications; very few of the national statistical series of real interest (critically including the National Accounts) are available at this level of disaggregation, while some which do offer this level of specificity (notably the Labour Force survey) are unreliable because of the very small sample sizes. One important consequence is that the last accurate figure we have for the number of people employed as aircraft engineers dates from the last Census at the end of July 2011, and consequently takes no account of the substantial number of jobs (close to 10% of the civilian total identifiable from Census records) which have been shed since then.

Other statistical information of central importance to the study is simply not available. Perhaps most importantly, we have no fully reliable information on how many Australian planes are serviced overseas, what maintenance is involved, or where it is done. In contrast with the situation in the US, where airlines are forced to report this information to the regulator, neither the safety authority nor the national transport research bureau collects these data, and they are generally not included in airlines’ publicly available corporate reports.

In normal circumstances we might expect to fill many of these information gaps by interviewing a range of informants across different segments and interest groups. Unfortunately this has proved far easier with some interest groups than with others. In and ideal world we would have had Qantas as an active partner, but in the event it was not possible to arrange this. Even tightly circumscribed access to their internal data and the occasional backgrounder on their decision-making processes would have left us in a much better position to assess the objective factors that drove the twists and turns of their strategic decision making. But the adversarial nature of the current discussion makes this even more unlikely now than it was to begin with. In practice, the absence of involvement from their side has had the perverse effect of encouraging everyone – not just us – to see the underlying issues a little too exclusively in terms of Qantas and its management, in the process overlooking other segments of the industry which are equally in trouble and which also make a strong contribution to the economy and to the country’s skills base.

On the other hand, our partners from the union side have been commendably forthcoming, but their evidence faces a growing legitimation problem as the debate gets more polarised. The information they can provide is essential to our understanding of the industry – after all, if you want to know what is happening on the shop floor, the best people to tell you are those who are working there – and their technical knowledge even more so, since we came to the project without relevant in-depth engineering knowledge, and much of the matter of interest is practical rather than theoretical, meaning that a technician can often speak more authoritatively than the academic aeronautical engineers we have at our disposal within the University. But as all industrial relations researchers understand, the evidence of workers and their unions almost invariably carries less credibility in the Anglophone public mind than that of other interested groups - even though such other groups are every bit as susceptible to biases of collective self-interest - and this loss of legitimacy is exacerbated when the situation is one of open conflict.

This problem has come increasingly to light as the Senate committee hearings proceeded, with union sources bringing forth not only detailed accounts but documentary evidence of serious problems encountered with offshore maintenance, but senior managers dismissing these accounts as

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“scaremongering” and “dogwhistle politics” and in some cases even attributing them to racism. In such an environment technical expertise is far too easily outweighed by partisanship, and this failure of trust can be expected to flow through into the reception of our findings.

The growing nastiness of the debate has posed further ethical problems by increasing the difficulty of finding informants who are prepared to have their input attributed, or even de-identified and placed in our database of transcripts. Interviewees or potential interviewees admit to being scared of retribution, and in many cases are bound by confidentiality clauses in their work contracts that create their own ethical dilemmas for them too when they witness – or are ordered to participate in – unsafe practices. It is characteristic of the LAME’s labour process that the person has to certify that maintenance processes are safe by signing maintenance records and certificates of release to service, which are stored for many years in case they are needed for an accident or incident investigation and it is necessary to identify who was involved in a maintenance procedure and what they did. This allows information sources to be traced, exacerbating this desire for deniability. Conversely, they are also often keen to speak off the record to a researcher, but that creates its own ethical issues, since University Ethics protocols prevent the use of material which has been told to a researcher in the expectation that the informant’s identity will not be revealed. Such unattributable backgrounders, particularly when they refer to general practices or conditions rather than specific incidents for which no other evidence exists, can greatly assist the researcher to understand how the pieces fit together, but that understanding can be difficult to work into a rigorous scholarly argument.

3. How safe is offshore maintenance?

As noted above, the fact that so much of the controversial maintenance occurs in neighbouring Asian countries has provided some participants in the debate with an excuse to rationalise any objections as being motivated by racism. So the first thing to be clarified is that this is not an issue about Asia, and certainly not one about Asian workers, their capabilities or their attitudes.

For one thing, the world MRO industry is getting more diverse and more geographically dispersed all the time, so the nearby Asian countries are no longer the obvious first choice for outsourcing that they were even a couple of years ago. In recent weeks Virgin has revealed that it flies its little Embraer 190 regional jets all the way to Portugal for major heavy maintenance (Sydney Morning Herald, 28/3/14). Secondly, it is well accepted today that factories in countries like India, China and Thailand are capable of turning out a product that fully meets the standards of respected first-world manufacturers like BMW, Honda, Triumph and Piaggio, just so long as the quality specifications are written into the contract and the production process is adequately monitored. Thirdly, one of the really worrying things about the anecdotes we have heard is that some of the worst reported cases of shoddy maintenance have come from plants in countries like Singapore and Hong Kong which enjoy a good reputation for their commitment to high quality and a level of workforce supervision at least comparable to any found in Australia. Nor should we forget that there have been incidents which could be traced back to sloppy maintenance even in first-world countries – for example, a British A319 which lost parts of its engine cowls just after takeoff last year (Guardian, 31/5/13). If there is a problem, it is clearly one that respects no national boundaries.

The concerns we have encountered are more to do with the lack of control exercised by Australian safety authorities over work done in other countries. The Australian Civil Aviation Safety Authority (CASA) used to inspect offshore plants that took Australian work before certifying them, and inspect them with more rigour than it currently does. Many informant have expressed concerns about the quality of the inspections which CASA still makes, and allegations that they involve desk audits of documented procedures rather than actual inspections of what happens on the shop floor. Qantas

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also makes its own inspections of offshore plants to which it outsourced, sending inspectors with the planes that went there for work; on one account these inspections were more rigorous than CASA’s. Now, the numbers of inspectors and certainly the LAMEs sent overseas with Qantas planes are fewer. Increasingly the experience appears to be that the regulator is offshoring the supervisory responsibility along with the maintenance, as there is increasing use of mechanisms that allow a National Aviation Authority (NAA) like CASA to enter into Bilateral Aviation Safety Agreements (BASAs) with other countries NAAs which involve accepting their approvals and obviating the formal need for inspection (Hampson et al 2014). In this regard Australia contrasts strongly with the US, where the GAO and the Federal Aviation Administration (FAA) have become increasingly stringent in their approach towards foreign maintenance shops over the last decade. In the initial phase of unrestrained outsourcing and offshoring that followed airline deregulation in the 1990s, much of this work went to newly minted establishments in places like El Salvador that had no tradition of precision engineering, and no proper training structure to support the necessary skills. This put logistical strains on the FAA’s ability to certify and inspect outsourced and offshored maintenance, and many airlines were sending maintenance to shops that were not inspected thoroughly, or not inspected at all. The latter, known as ‘uncertificated’ shops, lacked any kind of NAA approval. A number of messy, spectacular crashes resulted (Tang and Elias, 2012).

In two articles from our project, Quinlan et al have reviewed the US policy literature on offshoring and outsourcing. They found that regulatory failure and supply chain disarticulation had been associated with several incidents and indeed fatal accidents (Quinlan, Hampson and Gregson, 2013). In their second article (Quinlan, Hampson and Gregson, forthcoming), they examined the US regulatory response. In general, there has been a crackdown on offshoring, driven by Congressional legislation. The FAA Modernisation and Reform Act 2012 required the FAA, inter alia, to regulate that all ‘covered’ maintenance work be performed by certificated repair stations by 2015. FAA thus announced in 2012 new rules requiring airlines to develop acceptable policies for contract maintenance, including notifying them of all persons contracted to provide maintenance, and making sure they are appropriately trained, licensed and certificated.

Three things make the Australian situation different. First, Australia was slower to start offshoring, and so has an opportunity to observe the US experience through its successive phases and need not go through the same protracted and sometimes fatal learning process. Second, the US has seen a robust debate about the safety of offshored maintenance, based on some sensationalist media documentaries, as well as the kind of hard information which, as mentioned above, is not available in Australia to researchers, much less the public. Third, the FAA is itself subject to political scrutiny and indeed direction by other US government agencies, in a way that CASA is not. Apart from the occasional Senate inquiry, CASA does not have to manage constant political oversight, intervention and direction, though this situation may be changing in the light of current inquiries.

While the lack of CASA oversight does not automatically guarantee that offshored work will be done badly – after all, airlines themselves have an interest in protecting themselves from serious embarrassment – it certainly works to the advantage of those businesses which are prepared to relax their standards for the sake of offering a more competitive price. And from the perspective of the Australian travelling public, it leaves the way open for suspicions that offshore maintenance shops can undercut the price of domestic maintenance primarily because they are a little too prepared to be relaxed about safety.

We have to recognise that safety science is less precise and less rigorous in the case of aviation than in other areas because airline safety offers very little basis for statistical inference. Really serious

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accidents involving passenger flights happen very rarely, especially when set against the millions of passenger-kilometres flown every month, in all parts of the world, in all weathers. This extremely low incidence makes it difficult or impossible to predict such accidents through the normal statistical methods used in safety science, because the number of cases you have to work with is too small when set against the "population" for standard inferential analyses to work. It also means that that airlines which devote resources to tightening up their safety procedures generally cannot expect to see a measurable short-term gain in safety performance to justify the expenditure, and vice-versa when money is saved in this area.

Yet experience shows that accidents still do happen. And with each one that happens, we learn a little more about the sorts of thing that can help to cause them – even if in the vast majority of cases they are not enough by themselves to bring down a plane. Our argument is that if these contributory factors are known, and if there is a known way to address them, then the industry has the responsibility to manage its risk by addressing them, even in the absence of a measurable safety payoff.

An extreme but often quoted incident that illustrates this point. A Boeing 747 running China Airlines flight 449 fell apart in mid-air in 2002. The post-crash investigation traced the problem all the way back to 1980 when as a new plane, it suffered a tailstrike which caused cracks and scratches in the fuselage. These were never properly fixed, and never picked up by inspections, though it might have been expected that they would be if the inspections had been done by the book. In the event, the plane kept flying for over 20 years before the crack suddenly grew into a split big enough to cause the whole tail section to come off. This tendency for a small scratch or ‘knick’ to develop, through repeated pressurisation and depressurisation into a major tear (known colloquially as ‘unzipping’) is a serious problem in aircraft skins, and Boeing (since the Aloha incident) has recommended regular inspections to catch and repair the scratches – some of which are found in aircraft skins following paint and sealant removal with unapproved tools like pocket knives, screwdrivers and even angle grinders in poorly supervised MROs.

The China Airlines 449 was admittedly a one-off (as indeed are most major airline disasters), and will probably remain so. But the case illustrates how it only takes a very small maintenance failure to lead ultimately to disastrous results, and it can be very difficult to predict which of these apparently trivial mistakes will be the one that leads to disaster, especially since such a long time can elapse between the error and the consequences. You might compare this to the Challenger disaster, where the whole shuttle along with its crew was destroyed by one little O-ring made out of the wrong kind of rubber, which had performed faultlessly in every previous launch.

The lesson is that while many offshore workshops undoubtedly provide a high level of service and will never knowingly compromise safety, the knowledge that there are some which work to more relaxed standards, and the lack of certainty as to which they are, justifies a high level of supervision and monitoring precisely because they are located outside the immediate ambit of domestic safety supervision. In the US, an unlikely political coalition of business travellers and the Teamsters’ Union called CLAMOR (Coalition to Legislate Aircraft Maintenance Outsourcing Reform) has argued that making offshored and outsourced shops subject to the same standards of safety regulation as in-house maintenance – or even domestically outsourced maintenance – would help level the playing field. That effect would undoubtedly be greater if the airlines themselves, rather than the taxpayer, were required by law to cover the full costs of enhanced inspection.

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4. A Crisis in Labour Supply?

The lack of certainty about the real extent of the risks means that we will probably see a continuation for some time of fruitless debate about the riskiness of sending maintenance offshore in today's situation. But as time goes on, that possibly inconclusive discussion is becoming increasingly overshadowed by a far greater threat to aviation safety whose certainty has been endorsed by the highest-level institutions in the world aviation – the ICAO and the International Air Transport Association (IATA). This is the looming prospect that the whole world will find itself short of trained personnel to keep up current standards of maintenance on its fleet.

The two organisations (ICAO and IATA) undertook detailed projections around 2009-10 with a view to forecasting the future world demand for skilled aircraft maintenance personnel. The ICAO forecasts used a benchmark ratio of 20 skilled workers per passenger or cargo jet and three for each aircraft in the "other" category – mainly twin-engined turboprops in commercial or charter service. (Neither these nor any other of the publicly available detailed forecasts make allowance for general aviation or helicopters.) These ratios were reportedly derived empirically from representative (as opposed to best) current practice by industry experts in each member nation. They can safely be presumed to make allowance for a gradual reduction of maintenance needs relative to fleet size as more new-generation aircraft of less maintenance-intensive designs, e.g. the Boeing 787, come into service, since they were expected to hold good as averages through to 2030. Using these benchmarks, the world demand for qualified AME labour is expected to reach almost 850,000 by 2030, all of whom will need to be trained from scratch within the intervening period, as the projections assume an annual attrition rate of 5% of the current workforce.

Both the ICAO and the IATA projections were made with declared intent of assessing the adequacy of the current training infrastructure to meet future demand. Both suggest the need for major upgrades of capacity in most parts of the world. Table 1 below contains specific estimates of the average requirement for newly trained personnel over the next twenty years and the likely shortfall in each year, assuming the potential output of each national training system remains at its estimated 2010 level.

Region Annual training need

Annual surplus/ shortfall

Shortfall (surplus) as % of training need

Africa 3769 -3169 84.1

Asia-Pacific 19010 -14745 77.6

Europe 22977 -8352 36.3

Latin America

6881 -5566 80.9

Middle East 4107 -2062 50.2

North America

13586 15824 (116.5)

World 70331 -18071 25.7

Table 1

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Estimated average annual training requirement and shortfall by region, 2011-2030(Source: ICAO, 2009)

It will be noted that the biggest shortfalls are expected to arise in precisely those parts of the world to which Australian carriers are increasingly turning to meet their maintenance requirements. The Asia-Pacific region as a whole is projected to train less than a quarter of the number of new aircraft mechanics it will need to accommodate the requirements of its own national fleets over each of the twenty years to 2030. While serious attempts are being made to build the capacity in some Asian countries, notably Malaysia and China, it seems hard to believe that even a massive investment will make it possible to train up the numbers required within the next decade at least.

IATA’s research adds a further dimension to this information by attempting to map the pattern of growth. Its consultations with member airlines indicated that the strongest net growth in demand was expected to occur within the 4-year period from 2009, and remain strong over the full present decade, tapering off after that point. Even making allowances for a pause in growth likely to have resulted from the 2008 world recession, this would indicate that the pinch is likely to be felt most strongly somewhere around 2020 or in the years immediately following. By coincidence, that is just the time at which a high proportion of the current Australian AME workforce could be expected to retire, always assuming they still have jobs by then.

The first impact of this emerging shortage will be on the viability of the outsourcing model. As the low-wage source countries find themselves with fewer and fewer qualified workers to meet their own needs, wages will eventually go up in response, and the wage cost differentials between emerging and industrialised economies will compress accordingly. If wages do not keep pace with demand, the best workers in those countries will find more incentive to migrate to industrialised countries whose own emerging shortages will encourage them to offer favourable migration programs, leaving the low-wage countries with a growing perceived problem of less capable workforces. Just as importantly, skill shortages will mean that such countries no longer have unlimited potential to accommodate new business from wealthy parts of the world, and their MROs will have an incentive to charge premiums over what they charge their local customers. Ultimately, the inability to recruit skilled labour will put a brake on the expansion capacity of such providers, particularly those which have competed most strongly on the basis of their labour cost advantage.

Already this development is showing up as something more than speculation. According to the AviationPros newsletter, an offshoot of the respected Aviation News, the major Hong Kong MRO HAECO (which recently took over maintenance on Qantas's remaining 747s) has acquired one of the biggest US MROs with a view to accommodating some of its demand within the continental USA, after experiencing a 21% drop in profits in the first half of 2013 due to problems in recruiting enough skilled labour. It is reportedly seeking government assistance to bring in more qualified personnel from overseas. According to industry expert Chris Spafford, China in particular is expecting a major curtailment of its ability to service foreign widebodies because the growth of its own fleet has completely outstripped the growth of its workforce (AviationPros.com, 3/2/14). Even the Gulf states, which only a few years ago were expected to have no problems recruiting maintenance labour because of the huge pool of trained labour available close to hand in the Indian subcontinent, are now expecting to undertake significant recruitment within the next five years, with none of the local training providers confident of being able to meet the full demand. In the words of a Lithuanian training provider, "… the deficiency of skilled professionals will definitely take its toll, as this is a global problem that cannot be solved by merely hiring people from other regions" (AviationPros.com, 5/2/14).

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More remarkably, even in North America – the one region expected by the ICAO in 2009 to be training well in excess of its needs for skilled labour – Spafford estimates that recruitment in the US is falling 15 to 17% below the rate of natural attrition (AviationPros.com, 3/2/14). In a survey conducted by Spafford and Rose a year earlier for the Oliver Wyman consultancy, American operators cited lack of skilled labour as the main factor that prevented them from repatriating more of the maintenance currently done offshore (Spafford and Rose, 2013).

Nature abhors a vacuum, and markets eventually sort things out, one way or another. We can confidently expect that even if no conscious strategy is adopted to fill the gap in training, the market will adjust somehow; the problem is how it will adjust. The best analogy might be squeezing a tube of toothpaste with the cap screwed firmly down: if you squeeze hard enough for long enough, eventually the toothpaste will come out somewhere - it just might not come out anywhere it will do much good. So in the absence of purposive and effective action, it is possible to foresee a fairly frightening scenario developing even within the current decade.

That scenario begins with a steep rise in prices for MRO services across both developed and low-wage countries, probably eclipsing most or all of the savings made by industrialised countries over the last decade in running down their own maintenance facilities. The most reputable offshore providers are likely to find growing queues for their services, and as the market tightens, it is only to be expected that the biggest international carriers will muster their market power to ensure that less wealthy airlines are relegated to the back of the queue. The less scrupulous providers, as already noted, will see their best workers leaving in droves to walk into the welcoming arms of more generous employers in the developed world, leading to further deterioration not only in their own reputation, but in the reputation of other providers in the same countries. Even that will probably do little to remedy the shortfall of capacity. We can expect to see an increasing number of aircraft left idle because necessary checks etc. cannot be done on schedule, with corners increasingly being cut and quality skimped to keep up with the necessary checks on the remainder. The consequences are likely to be seen first in older planes which need a higher level of maintenance, and in lower-value ones where the cost of keeping up the obligatory level of maintenance is likely to loom large in comparison with the resale value of the aircraft – something which in Australia at least, can be expected to have greatest impact on the smaller regional airlines which make up the surviving competitive fringe of the industry. Quality assurance will probably be the first casualty, not simply because of time pressures, but because it will be a slower business training up a sufficient number of LAMEs to keep pace with the growth in AMEs with basic trade qualifications.

The skilled workforce which is available is likely to be subjected to work intensification, longer and more frequent shifts and more repressive management practices in an effort to squeeze the maximum available productivity out of the people to hand. That in turn can be expected to increase fatigue, safety violations and the incentive for experienced workers to exit the industry. In the meantime, the temptation will grow to fill the gap with inadequately skilled labour.

Of course the market will eventually step in somehow to make good the skills shortfall. But it is hard to believe that corners will not be cut, standards lowered and essential content overlooked in the rush. Even the official IATA-sponsored ITQI program (IATA, 2009) is suspected by many of streamlining the training process to an extent that will make it impossible for most trainees to develop the full range of skills and experience currently expected of a newly qualified AME. Our own projections have suggested that to stand any chance of filling the gap even within Australia, it would be necessary to reduce the duration of training to two years, roughly half of what it currently takes to complete an apprenticeship. And this is not even taking into account what may happen when the

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unregulated private training industry makes its move, especially in developing countries which have limited control over their training system. Despite this, it can be expected that the first movers will gain global market advantage (regardless of quality), and that those countries that have badly degraded their workforce development capability will miss out on their opportunity to become competitive in the world training market.

This is admittedly something of a worst-case scenario, and may not come to fruition in all its depressing detail. But the fact remains that nations which want to escape the worst of the pain have little option but to return as soon as possible to a greater measure of self-reliance, repatriate a proportion of their outsourced maintenance, and give serious attention to their level of training activity.

Where does Australia stand in the face of this challenge? The picture at the moment is not good. Our own calculations, about which we admittedly cannot be wholly confident because of the lack of available data, suggest that Australia is currently at around 70% of the number of qualified AMEs that would be needed to meet the ICAO benchmarks for its fleet. On our best estimate, the current employed population of civilian AMEs by the second half of this year will be about 1000 lower than on census date in 2011, even assuming attrition at the standard ICAO assumed rate of 5%; in fact, the last available estimates from Employment Department sources (joboutlook.gov.au, December 2012) suggested that it could have been running at anything up to three times that rate. The main message in this is that recruitment to the training system is below the level required to keep the size of the workforce constant. Most importantly, civilian apprenticeship commencements have declined almost exactly in line with the reduction in Qantas's training activity, while wastage has grown steadily (probably a reflection of the occupation attracting less capable recruits) to the point where the net recruitment (commencements less wastage) in the first quarter of last year was the lowest since records have been kept. In recent years Australia has been dependent on Defence establishments for something like 75% of its apprenticeship completions, but this contribution reflects a single large spike of commencements in 2008, and we expect it to have ceased to have any significant effect on completions by the end of 2013.

It must be kept in mind that a large proportion of Australia's maintenance requirement will continue to have to be met within Australia for the foreseeable future because it cannot feasibly be sent offshore – either because the nature of maintenance (e.g. overnight and weekly line maintenance on domestic flights) means that it has to be done on the spot, or because it is either impracticable or not cost-effective to fly the aircraft overseas for service. In a submission to a Senate committee in 2011, the ALAEA estimated that even if all the heavy maintenance were sent offshore that it was possible to send offshore, around half its existing members in Qantas would still need to remain employed in Australia. To this must be added the burden of maintenance on aircraft used in regional airlines and general aviation, where it is arguably even more critical that the effort be kept up because of the considerably greater average age of this proportion of the fleet. On current indications the training system will not provide enough qualified workers to meet even this requirement by the end the present decade.

In short, the Australian industry appears to be dominated by a false complacency where skills supply is concerned, with Qantas working on the assumption that there will always be capacity in low-wage countries to take on the maintenance load which it is no longer prepared to carry in Australian shops, and the rest of the industry working in the expectation that it will be able to meet its ongoing skill needs either from displaced or disaffected Qantas workers or from skilled defence personnel moving into civilian work. Thanks to a glut of laid-off Qantas workers seeking new opportunities in the AME labour market, the number of unfilled vacancies fell in the last two years to the point where

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the occupation was taken off the Skilled Occupations List in August last year, removing its eligibility for special Commonwealth support and consequently exacerbating the decline in recruitment.

A different way of describing the problem would be that Qantas seems to have become stuck in a mindset which the rest of the world is rapidly recognising as superseded and inappropriate. While it seeks constantly to find new areas of maintenance work that can be offshored, airlines in other parts of the world are starting to see the case for bringing more of their maintenance back on shore. In the 2013 survey already mentioned, more than 25% of operators in the global sample and 30% of those in North America were willing to return heavy maintenance to domestic providers provided the cost differential was less than 15% (Spafford and Rose, 2013:9). Admittedly this is due in part to a severe compression of wages in the US in the wake of the recession, especially in the more depressed states like Louisiana where it is estimated that American wages have fallen below the average for the Asia-Pacific region as a whole. Even there, however, it is expected that wages will need to go up significantly to attract sufficient skilled labour (AviationPros.com, 3/2/14).

The underlying message is that while Qantas continues to run down its MRO capacity, competitors in other countries are steadily moving towards an investment mindset in expectation of the global skills shortage. One disadvantage of the intensely adversarial and politicised nature of the current debate in Australia is that Qantas is likely to lock itself into its current downsizing strategy long enough to meet the crisis completely unprepared – a disadvantage which it threatens to transfer to the rest of the Australian aviation industry.

4. Is there a way out?

One thing which is painfully clear is that we cannot realistically expect the market to provide any resolution of the current problem in Australia. The problem lies not just with the attitudes and strategies of Qantas, but with the structure of MRO in Australia, which has failed to keep pace with a world where MRO has found its feet as an independent business, either separated completely from the business of carriage, or in the case of the more entrepreneurial carriers, run as an arm’s-length subsidiary. While there are a number of independent MROs in Australia, none of them has the scale required to take over the volume of work previously carried by Qantas alone, and the biggest of the civilian providers now appears to be in trouble because of disappearing demand, in part due to its own failure to offer an adequate service. This is a situation which is unlikely to see a quick spontaneous shakeout and restructuring, let alone one that leaves Australia in an advantageous position in an increasingly global market.

In this context it becomes painfully clear how those countries which pose the biggest commercial threat to legacy national airlines like Qantas have been spared the stylised public set-piece battle between laissez-faire and intervention which has crippled policy development in Australia for the last quarter of a century. Countries like China, Singapore and the Gulf states are and always have been serenely pragmatic in their attitude to industry development, following approaches which work well for them and the businesses they support, but which have been treated as off limits on ideological grounds by both the major parties in Australia. While it would be unwise to expect the same approaches to work with Australia's very different institutions, business settings and relatively small market power, the need for purposive industry policy becomes more apparent all the time, just at a point where the capability to develop effective industry policies has been rigorously purged from the Australian policy community for almost two decades.

In the present political circumstances, to speculate on the political feasibility of a considered and targeted industry strategy would probably be inviting disappointment. Nevertheless, it is useful to

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consider just what a strategy aimed at the restoration of a globally competitive MRO sector in Australia would have to achieve.

The key objective would have to be establishing Australian MRO as an independent sector quarantined from whims of internal airline politics. The essential first step in this process would involve forcing or persuading Qantas to divest its workshops before it runs them down any further. This would be a matter of some urgency, since Qantas has already abandoned this segment of MRO where Australia suffers least comparative disadvantage from its labour costs, namely engine overhaul where these costs represent only around 22% of the total (ARSA, 2013) and much of the existing capacity is focused on current-generation designs, with the more advanced types like the Airbus A380 and the Boeing 787 already consigned overseas except for line maintenance.

Once the Qantas workshops were divested, it would be necessary to provide them with a guaranteed baseload demand for a period of several years while they consolidated, restructured and sought out new business. This would probably need to be done by some kind of statutory minimum requirement on Australian operators to use Australian-based maintenance services, possibly enforced as a term of their operating licence.

As part of this adjustment process they would need to be facilitated to join forces with other existing MROs, Defence facilities and contractors, and possibly some areas of advanced manufacturing. Although Australia's aircraft manufacturing sector is pitifully small, there are islands of very high competence spread across all these areas, especially defence contracting where offsets for defence purchases have provided the main opportunity for expansion. To quote just one example, Australia now handles more outsourced manufacturing work for Boeing than any other country outside the US. Bringing together these capabilities and exploiting the possible synergies would set a path for an Australian industry to develop unique capabilities serving global niche markets in new areas of high-value business, of which the two most likely candidates that suggest themselves are engine replacement (retrofitting existing airframes which are still at a fairly early stage in their service life with new-generation fuel-efficient engines as an alternative to buying new aircraft) and ETOPS maintenance (a special category of authorisation for twin-engine planes which permits them to fly courses that take them several hours away from the nearest emergency airport).

Above all the new industry would need to be consolidated sufficiently to develop the critical mass which would give it resilience in an unpredictable world market and the capacity to “carry” necessary but less profitable functions, notably GA, which are unlikely ever to achieve secure viability in the hands of stand-alone enterprises. It would also need to develop the capability in its plants and its people to handle the most advanced types (Boeing 787, 777X, Airbus A380, A350) as they come into service, since this is the work likely to bring in the highest returns. Part of this task would be to exploit existing relationships with suppliers like Boeing and Rolls-Royce with a view to taking on outsourced OEM work, which is rapidly emerging as the new area of strength in MRO.

Over and above its trading activity, the priority for the restructured industry would be to launch a major investment in rebuilding the skilled workforce before 2020. This would mean retaining as many as possible of the existing experienced workers to ensure that their knowledge was passed on to the next generation – another argument for commencing the transformation as soon as possible before it is too late. Part of the rebuilding process would involve liaison with the training sector to achieve a significant streamlining of the current apprenticeship, but without degrading its quality.Even so, it seems unlikely that Australia will be able to achieve any worthwhile degree of self-sufficiency without relying to some extent on skilled immigration, and one argument for keeping wages high would be to attract the best available workers from other parts of the world before the market for their labour became too competitive.

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This is a challenging enough set of objectives even to list on the fly, without going into any detail of the means by which they might be achieved. The question of its political feasibility in the current environment is, as already noted, a source of despair in its own right, even before we move on to the policy tools by which it might be achieved. However, it should be noted that aviation industry development initiatives have got off the ground in at least four of the States over recent years, though the NSW program which seemed the most technologically ambitious barely survived the last change of government, and the commercially ambitious Victorian scheme appears to have come somewhat to grief because of what turned out to be a mistaken choice of key industry partner. Even supposing these strategies can be revived, though, it is hard to see them achieving much without coordination, enthusiasm and above all funding at the Commonwealth level.

It is not the kind of prospect about which one can easily feel optimistic in Australia today. As our much loved, much hated and in the view of many, best ever past Prime Minister, Gough Whitlam, said forty years ago in a different context: what we need, Comrades, is a bloody miracle. But the emerging global MRO market will be big enough to provide business for every country with the wit and the organising capability to gear up for a place in it, and it would be a shame if Australia were to miss the opportunity through political sclerosis. And besides, the alternative is even more distressing to contemplate, not just from the point of view of the Australian economy, but in terms of the safety of the travelling public.

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.

References

Aeronautical Repair Stations Association (ARSA) (2013) Global MRO Market AssessmentFraser, D., Hampson, I., A. Junor and M. Quinlan (2014) Submission to Senate Reference Committee on Rural and Regional Affairs and Transport inquiry “Qantas' future as a strong national carrier supporting jobs in Australia”Hampson, I., D. Fraser, A. Junor, M. Quinlan and S. Gregson (2014) Submission to the Commonwealth Air Safety Regulation ReviewHampson, I., A. Junor and S. Gregson (2011) Missing in action: Aircraft maintenance and the recent ‘HRM in the airlines’ literature, International Journal of Human Resource Management, December, pp. 1-15Hampson, I. and S. Gregson (2013) Licensing and the Labour Process in Australian Aircraft Maintenance: Deskilling by Stealth? Paper presented to the International Labour Process Conference, 18-20 March, Rutgers University, New YorkIATA (2009) International Air Transport Association, IATA Training and Qualification Initiative (ITQI) Report 2009, http://www.iata.org/NR/rdonlyres/6CBC71E3-2287-40AC-A3C7 D712247A2C7/0/ITQIReport_Spring09_v12_20090423.pdf, accessed 21/9/09ICAO (2009) ICAO Global Forecasts 2010-2030ICAO (2011b) News Release, ICAO Study Reveals Strong Demand for Qualified Aviation Personnel up to 2030, http://www.icao.int/Newsroom/News%20Doc/PIO.03.11.EN.pdf, Accessed 080313

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Lazonick, W. and O’Sullivan, M. (1994) Skill formation in wealthy nations: Organizational evolution and economic consequences. Oslo, STEPQuinlan, M., I. Hampson and S. Gregson (2013) Outsourcing and offshoring aircraft maintenance in the US: Implications for safety, Safety Science, 57 283-292Quinlan, M., I. Hampson and S. Gregson (2013, forthcoming) Slow to Learn: Regulatory oversight of the safety of outsourced aircraft maintenance in the USA, Policy and Practice in Health and Safety, SCRAAT (Australia, Senate, Rural and Regional Affairs and Transport References Committee) (2014) Qantas' future as a strong national carrier supporting jobs in Australia, Canberra, Parliament of AustraliaSpafford, C. and Rose, D. (2013) Thrive Rather Than Survive: It’s Time for MROs to Act. MRO Survey 2013, Oliver WymanTang R. and Elias B. (2012) Offshoring of Airline Maintenance: Implications for Domestic Jobs and Aviation Safety, Congressional Research Services Report to Congress,7-5700 R42876, Washington DC, 2012

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