Careful analysis of potential hazards can assist in the mitigation.docx

Careful analysis of potential hazards can assist in the mitigation
of future accidents. Two approaches to hazard analysis include
the preliminary hazard analysis and the detailed hazard analysis.
Both methods are used to help identify and prioritize the
potential hazards at a job site that can end in the possibility of a
severe accident. A preliminary hazard analysis is conducted to
identify potential hazards and prioritize them according to (1)
the likelihood of an accident or injury from a hazard and (2) the
severity of an injury, illness or property damage that may result
if the hazard had caused the accident (Goetsch, 2010). In
contrast, a detailed hazard analysis involves the application of
analytical, inductive, and deductive methods (Goetsch, 2010).
Expertise and reasoning can be two useful applications when
performing a hazard analysis. Typically a preliminary hazard
analysis along with previous expertise would be sufficient in
determining possible job site hazards and developing methods to
avoid them. If needed, more detailed methods can be used for
conducting detailed analysis. They are:
fault tree analysis (FTA).
Failure mode and effects analysis is a formal step-by-step
analytical method used to analyze complex engineering systems.
The hazard and operability review is an analysis method that
allows problems to be identified even before a body of
experience has been developed for a given process or system
(Goetsch, 2010). The technique of operations review is a
method that allows supervisors and employees to work together
to analyze workplace accidents and incidents. The human error
analysis basically predicts that accidents are caused by human
errors while the fault tree analysis visually displays the hazard

analysis in detail.
Hazard analysis is extremely important in the construction
industry. It is very important to analyze the probability of any
types of accidents on-site and also to
Reading Assignment
Chapter 8:
Job Safety and Hazard Analysis
Chapter 9:
Accident Investigation, Record Keeping, and Reporting
Learning Activities (Non-Graded)
See information below
Key Terms
1. Accident investigation
2. Accident report
3. Emergency procedures
4. Faultfinding
5. Frequency
6. Hazard analysis
7. Hazard and operability review
8. Human error analysis
9. Immediacy
10. Principal’s office syndrome
11. Probability
12. Risk analysis
13. Technic of operations review
14. Witnesses
Coordinate medical response in the event of an accident. In the
case of an accident, the first thing management and supervisors
need to do is implement their emergency plan. Each accident
should be treated as if it were a larger accident. The main points
to ultimately cover in an accident investigation are: who, what,
when, where, why, and how. In coordinating the accident
investigation, you should consider the following:

accident, and
necessary.
Thorough accident investigation is just as important as
performing a careful hazard analysis. Accidents are investigated
for the purpose of identifying causal factors that have the
possibility to lead to other accidents. Facts need to be
uncovered, recorded, and reviewed in order to assist in the
future mitigation of potential hazards involving the same
situations.
Reference
Goetsch, D. L. (2010). Construction safety and the OSHA
standards. Upper Saddle River, NJ: Prentice Hall.
The Federal Aviation Administration (FAA) published a Draft
Policy Statement on the Occupational Safety and Health
Standards for Aircraft Cabin Crewmembers on December 7,
2012. The purpose of this policy is to “enhance occupational
safety and health in the aircraft cabin by establishing the extent
to which Occupational Safety and Health Administration
(OSHA) requirements may apply to the working conditions of
aircraft cabin crew while they are onboard aircraft in operation”
(DOT/FAA, 2012).
This policy statement was designed to address the problem that
FAA’s “regulations do not completely encompass the safety and
health aspects of the work environments of aircraft
crewmembers while the aircraft is in operation, and that there
are working conditions for which it has not promulgated
occupational safety or health standards. . . . In particular, FAA
has not promulgated standards related to the working conditions
addressed by OSHA’s hazard communications and blood borne
pathogens standards” (DOT/FAA, 2012).

However, the FAA has issued numerous regulations directly
affecting the workplace of pilots, flight engineers, cabin
attendants, and other persons whose workplace is on aircraft in
operation. These regulations cover: aircraft performance and
structural integrity; safety equipment for emergency ditching
and evacuation; fire protection; protective breathing rescue
aids; emergency exits used by crewmembers; cockpit lighting;
crewmember seat belts; toxicity; noise reduction; smoke
evacuation; ventilation; heating and pressurization; maximum
hours of duty and duty aloft; and radioactive and other
hazardous materials (DOT/FAA, 1975).
Currently, “the FAA exercises statutory authority pursuant to 49
USC section 44701 et seq., governing aviation safety and may
issue regulations that are related to flight safety. . . The OSHA
exercises statutory authority pursuant to 29 USC section 651 et
seq., governing the occupational safety and health of
employees” (MOU between FAA and OSHA, 2000).
HISTORY
1975 Federal Register Notice – Occupational Safety or Health
Standards for Aircraft Crewmembers:
Title VI of the Federal Aviation Act of 1958 “contains the
principal substantive provisions that authorize and require the
FAA to promote the safety of civil aircraft operations by
prescribing and revising standards, and regulations governing,
in the interest of safety, the design and materials, workmanship,
construction, and performance of aircraft, maximum hours of
periods of service of airmen and other employees of air carriers,
and the transportation of dangerous articles. With respect to
civil aircraft in operation, the above mentioned safety
regulatory responsibilities directly and completely encompass
the safety and health aspects of the work
Page 1 of 10
MGMT 425 Group Project: Case Study – FAA Draft Policy
Aircraft Cabin Crew Safety and Health
environment of aircraft crewmembers. Aircraft design and
operational factor are indivisible from occupational safety or

health factors insofar as they affect the workplace of those
crewmembers. Aircraft design and operational problems
affecting the flight safety of crewmembers necessarily affect
their occupational safety or health. Regulatory solutions to
these problems necessarily involve practices, means, methods,
operations, or processes needed to control the workplace
environment of aircraft crewmembers.”
August 7, 2000 – Federal Aviation Administration/Occupational
Safety and Health Administration Memorandum of
Understanding (MOU):
The MOU directed that a FAA/OSHA team determine whether
certain OSHA requirements could be applied to the working
conditions of employees on aircraft in operation (other than
flight deck crew) without compromising aviation safety. The
MOU also called for a report regarding whether and to what
extent OSHA’s existing standards and regulations on
recordkeeping, blood borne pathogens, noise, sanitation, hazard
communication, anti- discrimination, and access to employee
exposure/medical records may be applied to employees on
aircraft in operation (other than flight deck crew) without
compromising aviation safety.
December 2000 – FAA/OSHA Aviation Safety and Health Team
First Report:
This report identified several legal, enforcement, compliance,
and safety issues that made it inadvisable to recommend that
jurisdiction over the working environment (aircraft cabins) of
employees on aircraft in operation are granted or ceded to
OSHA. The Team recognizes that there is a lack of reliable
empirical data concerning the occupational safety and health
issues associated with employees on aircraft in operation.
This report also identified matters for further consideration:
· Need to determine the degree to which OSHA Act’s
territorial limitation to employment performed within the
boundaries of the United States would affect OSHA’s ability to
provide effective protection for a significant percentage of
crewmembers who work on flights that operate in part beyond

the territorial boundaries of the United States.
· Need to determine whether it would be necessary for the
respective agencies to engage in notice and comment
rulemaking prior to applying the enumerated OSAH standards or
regulations to employees on aircraft in operation, and, if so, the
manner in which to most expeditiously promulgate standards
that are applicable to aircraft in operation.
· Need to determine the manner in which OSHA and FAA
would cooperate to assure that standards applicable to
employees on aircraft in operation (other than flight deck crew),
which may be promulgated at a future date, would not be
written or enforced in a manner that could compromise the safe
operation of an aircraft.
· Need to determine the effect that state jurisdiction and state
plans would have on FAA’s ability to assure aviation safety.
· Need to determine the effect that state jurisdiction and state
plans would have on OSHA’s ability to enforce standards
applicable on aircraft that operate in, and over, a number of
States.
Page 2 of 10
· Need to determine and address the potential preemptive
effect that FAA regulations and other federal agency regulations
and standards may have on OSHA’s authority to apply
particular OSHA standards or regulations to an aircraft in
operation.
· Need to determine whether it would be necessary to conduct
OSHA inspections on an aircraft in operation in order to
effectively enforce any applicable OSHA standards or
regulations, and, if necessary, whether the process of
conducting such OSHA inspections would affect aviation safety.
· Need to determine the manner in which OSHA would conduct
its inspections on an aircraft in operation in order that such
inspections would be conducted in accordance with the
delegation authority to the Secretary of Labor under the OSH

Act and in order that such inspections to be consistent with the
procedures developed in OSJA’s Field Reference Inspection
Manual.
· Need to determine the method and manner for obtaining FAA
approval of any OSHA abatement requirements that potentially
affect aircraft safety prior to any abatement action by an
employer/airline.
· Need to determine the method and manner in which OSHA
inspectors would be trained concerning the application of
relevant standards on aircraft in operation and the manner in
which inspections would be conducted on aircraft in operation.
· Need to determine the manner and method for conducting
outreach programs to airline employers and employees
regarding the nature and scope of the OSH Act and any OSHA
standards and regulations that may be applicable to aircraft in
operation.
June 18, 2002 - FAA/OSHA Aviation Safety and Health Team
Action Plan:
“Under the Team’s recommended plan, air carriers would
voluntarily enter into an aviation safety and health partnership
program (ASHP) with the FAA. This voluntary aviation safety
and health program would specify the kinds of occupational
safety and health protections air carriers would provide,
establish a steering group consisting of members from the FAA,
air carriers, and employee unions, and contain evaluation
criteria to assert program effectiveness. OSHA would provide
technical assistance and program evaluations, as resources
allow.
Voluntary occupational safety and health partnership programs
have been successfully implemented by OSHA in various
industries where OSHA possesses jurisdiction over the working
conditions. Under this voluntary partnership program between
air carriers and the FAA over the working conditions of flight
attendants on aircraft in operation, FAA retains its complete and
exclusive jurisdiction over aviation safety while increasing its
role in the safety and health of crewmembers on aircraft in

operation (other than flight deck crew). The voluntary
partnership program should provide enhanced flight attendant
safety and health protections more quickly that if either or both
agencies were to engage in rule-making. The program would
also preserve the FAA’s preeminent authority over aviation
safety issues by reserving to the FAA complete and exclusive
responsibility for determining whether proposed abatements of
safety and health hazards would compromise or negatively
affect aviation safety.
OSHA’s role in the program will be advisory only. OSHA will
provide technical guidance, to the extent resources allow, to the
FAA, particularly concerning compliance and evaluation of the
Page 3 of 10
program. OSHA will assist the FAA in developing general
guidelines as to how to apply the elements of certain OSHA
requirements. OSHA will provide protocols to the FAA that will
set out the basic elements and criteria of the standards or
regulations. Since OSHA does not have jurisdiction over the
workplace involved, these protocols suggested by OSHA will be
subject to the FAA’s approval.”
March 24, 2010 – AFA-CW reports passing of FAA
Reauthorization Bill with provisions for flight attendants:
“The Association of Flight Attendants-CWA (AFA-CWA)
reported on Tuesday that the US Senate has passed a version of
the US Federal Aviation Administration (FAA) Reauthorization
Bill, containing provisions for flight attendants.
The measures included in the bill that the AFA-CWA supports
feature: a follow-up on the results of the FAA flight attendant
fatigue study; OSHA workplace safety and health protections;
provisions for cabin air quality that would identify equipment
and technology available to detect and filter highly toxic
contaminants in the air supply; English language standards for
flight attendants; and a program called "Return to the Cabin"
that would allow flight attendants opportunities for

rehabilitation after testing positive for alcohol or drug abuse.
The AFA-CWA represents 50,000 flight attendants at 22
airlines.”
November 30, 2012 – Press Release – FAA Proposed Policy to
Improve Flight Attendant Workplace Safety:
“The US Department of Transportation’s Federal Aviation
Administration (FAA), working with the US Department of
Labor’s Occupational Safety and Health Administration
(OSHA), today proposed a new policy for addressing flight
attendant workplace safety. While the FAA’s aviation safety
regulations take precedence, the agency is proposing that OSHA
be able to enforce certain occupational safety and health
standards currently not covered by FAA oversight. “Safety is
our highest priority and that certainly extends to those who
work in the transportation industry,” said US Transportation
Secretary Ray LaHood. “Under this proposal, flight attendants
would, for the first time, be able to report workplace injury and
illness complaints to OSHA for response and investigation.”
This policy announced today with the FAA will not only
enhance the health and safety of flight attendants by connecting
them directly with OSAH, but will by extension improve the
flying experience of millions of airline passengers, said US
Secretary of Labor Hilda L. Solis. Flight attendant workplace
issues could include things such as exposure to noise and blood
borne pathogens and access to information on hazardous
chemicals. The FAA and OSHA will continue to work to
identify additional conditions where OSHA requirements could
apply. They will also develop procedures to ensure OSHA does
not apply any requirements that could affect aviation safety.
Flight attendants contribute to the safe operation of every flight
each day,” said Acting FAA Administrator, Michael Huerta.
“This proposed policy is an important step toward establishing
procedures for resolving attendant workplace health and safety
concerns.” “We look forward to working with the FAA and the
airlines to assure the protection of flight attendants,” Dr. David
Michaels, assistant secretary of labor for occupational safety

and health.”
December 3, 2012 – US flight attendant union touts OSHA
move to up aircraft cabin standards:
US-based flight attendant union The Association of Flight
Attendants-CWA said it has successfully achieved Occupational
Safety and Health protections for commercial aircraft, after
Page 4 of 10
tireless advocacy to improve safety and health standards in its
members' workplace.
AFA said it commends the Obama Administration, the Federal
Aviation Administration and the Occupational Safety Health
Administration for their collaborative approach to reach the
policy statement released last week that will correct a nearly
four-decade old exclusion of OSHA in the passenger cabin.
According to the union, in 1975, the US FAA claimed exclusive
jurisdiction over workplace safety and health for all
crewmembers, preventing OSHA, the agency that regulates the
safety and health of most U.S. workers, from protecting Flight
Attendants and other crewmembers while working on board
commercial airline flights.
AFA said it has pursued legal and regulatory solutions to extend
OSHA safety and health protections to workers in the airline
industry. Today's FAA policy announcement comes after AFA
aggressively advocated for Flight Attendant safety and health
protections to be included in the FAA reauthorization bill that
was signed by president Obama in February 2012.
Flight attendants currently have OSHA protections at work in
places other than where they spend the majority of their time --
the passenger cabin. The new policy statement extends many of
the OSHA protections already in place to the aircraft cabin, the
union said.
December 7, 2012 - Policy statement on Occupational Safety
and Health Standards for Aircraft Cabin Crewmembers (Docket
No.: FAA-2012-0953):

The Federal Aviation Administration (FAA) published a Draft
Policy Statement on the Occupational Safety and Health
Standards for Aircraft Cabin Crew members on December 7,
2012. The purpose of this policy is to “enhance occupational
safety and health in the aircraft cabin by establishing the extent
to which Occupational Safety and Health Administration
(OSHA) requirements may apply to the working conditions of
aircraft cabin crew while they are onboard aircraft in operation”
(DOT/FAA, 2012).
2012 – Association of Flight Attendants –CWL - FAA Proposed
Policy Statement to Bring OSHA to the Cabin
We made history. Four decades after OSHA was created and
safety and health protections were extended to the workplace of
most Americans, we have finally achieved OSHA protections
for Flight Attendants in the aircraft cabin.
The FAA released a policy statement that extends many of the
safety and health standards we already have in our workplaces
outside the aircraft cabin. This is an enormous achievement and
it would not have been possible without the persistent, tireless
work of our union.
You were a part of making this happen. For decades AFA has
pursued legal and regulatory solutions to extend OSHA safety
and health protections to workers in the airline industry. The
roadblocks have been enormous, but our union kept this as a
priority and through the leadership and dedicated work of our
Air Safety, Health and Security Department as well as the
grassroots organizing led by our Government Affairs
Department and thousands of your calls to Capitol Hill, we
succeeded in ensuring that OSHA standards in the cabin were
included as part of the FAA reauthorization bill. The bill
provided a path, but without our persistence and collaboration
with these agencies this policy statement may not have come to
fruition. It is our focused and expert work for Flight Attendants
that achieved this historical result today.
Page 5 of 10

"Flight attendants are our first responders in the sky, so
ensuring a safe workplace for them helps to keep air travel safer
for everyone," said Rep. Mazie Hirono (D-HI), a member of the
House Committee on Transportation and Infrastructure and U.S.
Senator-elect for Hawaii.
We must also recognize the Obama Administration for making
this possible. Obama appointees lifted roadblocks and
determined they could work together to address concerns related
to the unique conditions of our work space so that safety and
health standards could be applied to the cabin. The Obama
Administration supported the work between these agencies, as
noted in the FAA press release, with the incredibly supportive
statements from Department of Transportation Secretary Ray
LaHood and Department of Labor Secretary Hilda Solis.
Not all of our members may be aware of how long we have
fought to achieve this result. In 1975, the FAA claimed
exclusive jurisdiction over workplace safety and health for all
crewmembers, preventing the Occupational Safety and Health
Administration (OSHA) – the agency that regulates the safety
and health of most U.S. workers – from protecting Flight
Attendants and other crewmembers while working on-board
commercial airline flights.
We are meeting with your AFA local leaders to review what this
policy change will mean for us and when we can expect it to
take effect. We will keep AFA members closely advised on
implementation and what it means for our work place.
Thank you for all you do every day to keep our skies safe.
January 22, 2013 - Policy Statement on Occupational Safety and
Health Standards for Aircraft Cabin Crewmembers: Comments
of Airlines for America:
Airlines for America (“A4A”) submits these comments in
response to the request for comments that the Federal Aviation
Administration (“FAA”) has issued concerning its proposed
statement about occupational safety and health standards for
aircraft cabin crewmembers. The Draft Policy Statement solicits

public comments about the Occupational Safety and Health
Administration (OSHA) assuming responsibility for blood borne
pathogen, hazard communication and hearing conversation
regulatory programs affecting aircraft cabin crew while they are
onboard aircraft in operation. It further proposes that such
requirements not be incorporated into FAA’s regulatory
programs but rather proposes that jurisdiction to control and
regulate those health and safety programs be transferred to
OSHA.
We believe that an alternative approach be used because of
important unresolved outstanding issues concerning such an
assumption of regulatory authority. The joint FAA/OSHA
Aviation Safety and Health Team summarized those issues over
a decade ago when it concluded that it had “identified several
legal, enforcement, compliance, and aviation safety issues that
made it inadvisable to recommend that jurisdiction over the
working environment (aircraft cabins) of employees on aircraft
in operation be granted or ceded to OSHA. Nothing in the
record today suggests that this situation has changed. What has
changed, however, is the maturation and potency of voluntary
civil aviation safety programs, particularly the Safety
Management Systems (SMS). An SMS based approach is, under
the current circumstances, the best way to meet FAA and
OSHA’s commend able policy objectives.
The basic issue that the Draft Policy Statement raises thus is not
the importance of occupational health and safety to
crewmembers. That is clear and indisputable. Rather, the
question is what is the most efficacious means to achieve that
goal? We believe that a SMS- based approach is the optimal
response.
Page 6 of 10
January 28, 2013 – Carriers Object to FAA’s Plan for New
Flight Attendant Work Conditions:
Most U.S. airlines are opposing an FAA proposal to give the

Occupational Safety and Health Administration (OSHA) some
regulatory authority over in-cabin working conditions for flight
attendants. Instead, they are advocating a voluntary, data-based
program to address the concerns--citing civil aviation's existing
Safety Management System as a model--or calling on the FAA
to craft more occupational safety standards itself.
Trade group Airlines for America also is suggesting that the
OSHA Airline Ground Safety Alliance be expanded to include
flight attendant participation.
The FAA proposal, issued in the form of a draft policy
statement, would let some OSHA requirements apply to the
working conditions of flight attendants while they are on board
aircraft in operation. That came in response to the FAA
Modernization and Reform Act of 2012, which directed the FAA
to develop a policy statement on when OSHA requirements may
be applied to crewmembers while working in an aircraft.
Under the proposal, the FAA says OSHA rules would apply in
the cabin for areas in which the FAA has not crafted its own
occupational safety or health standards. Specifically, those
would be standards for blood-borne pathogens, hearing
conservation and hazard communication (under which the
identities and hazards of chemicals must be made available and
understandable to workers).
Additionally, the FAA and OSHA would work on a
memorandum of understanding to «establish procedures to
identify any additional working conditions where OSHA
requirements may apply.»
Responses to the proposal, which were due by Jan. 22, reveal
some of the concerns and fears that airlines have about OSHA
involvement, as well as how the unions supporting the change
believe it should be applied.
Airlines say they are worried about the complexity and burden
of having two agencies regulating safety in the same workplace,
as well as the potential OSHA inspection of aircraft, which
could interfere with operations. In its proposal, the FAA says
OSHA “anticipates that it will respond to and investigate

complaints or referrals without a need for any inspection of
aircraft in operation,” but it does not offer guarantees.
Airlines also are concerned that OSHA's involvement could
make the airlines subject to multiple, and perhaps conflicting,
state rules, because the OSHA Act encourages states to develop
and operate their own job safety and health programs, as 26 now
do. The Association of Flight Attendants-CWA (AFA) and the
Transportation Trades Department (TTD), which includes the
AFA among its 31 affiliated unions, also note that concern, but
say they are comfortable with the proposed policy's assurances
that OSHA will «initiate a process to ensure that airlines will
not be subject to multiple different sets of rules as they fly into
and out of different states.»
The unions, which have been fighting for OSHA involvement
for years or even decades, say there are good reasons to apply
the OSHA standards in the categories the FAA proposed.
The blood-borne pathogen and hazard communication
regulations will provide better equipment for hazard isolation,
cleanup, disposal and personal protection, the unions say, and
they
Page 7 of 10
anticipate regular noise exposure monitoring, audiometric
testing and hearing protection. TTD cites concerns about fuel
vapors and cleaning solution chemicals, and the International
Association of Machinists and Aerospace Workers (IAM)
believes attendants should be allowed to wear protective gloves
when collecting trash from passengers.
IAM seems to be pushing for the most expansive application of
OSHA regulations, suggesting they could be applied for issues
such as cabin air quality, lifting and moving of baggage, the
operation of aircraft doors and a long-running risk from the
“explosion” of inflight coffee makers and water heaters. The
FAA issued directives on the latter problem in 1993 and 1994,
but the IAM says the problem never disappeared and the FAA

issued a safety alert about exploding hot coffee filters a few
weeks ago.
February 4, 2013 – NBAA Cautions FAA On Expanding OSHA
Policy to Part 91, 135:
FAA's proposed policy to extend the applicability of certain
Occupational Safety and Health Administration (OSHA)
requirements to aircraft operators carrying cabin crewmembers
is raising concerns from business aviation advocates that it
could cause confusion and hamper business aircraft operations.
FAA released the proposed policy Dec. 7 at the direction of
Congress, saying it would establish a memorandum of
understanding with OSHA to identify the areas where OSHA
standards would apply.
The National Business Aviation Association says this could
cover OSHA standards for recordkeeping, blood-borne
pathogens, noise, sanitation, hazard communication, anti-
discrimination and medical records access for cabin
crewmembers.
But flight attendants are not required in either Part 91 or 135,
NBAA notes, saying, «Unfortunately, the FAA's proposed
policy raises a number of concerns related to the application of
occupational safety and health (OSH) standards to operations
not previously covered or even analyzed in the development of
those standards.»
The proposed policy specifies that it is applicable to Part 91,
135, 121 and 125, but does not outline how the OSHA
regulations would be applied to each of those segments.
“It appears that this proposed policy could apply a number of
OSHA requirements to these small- and medium-sized
businesses without determining the effect on these entities as
required by the regulatory Flexibility Act,” NBAA says. “We
believe [the proposed policy] could have a substantial impact on
our members.”
NBAA also questions how it would apply to various states that
have opted out of the OSHA standards in favor of their own.
Noting operations frequently cross states, the association says it

would be unreasonable to require training for every possibility.
“Until the FAA is able to identify a complete list of OSHA
standards that would apply and ensure that those standards have
considered the regulatory impacts on small businesses, it would
be inappropriate to apply this proposed policy to either
noncommercial or on-demand commercial operations,” NBAA
says.
The policy has also drawn objections from commercial carriers,
which say they should be able to use data-based voluntary
programs in place of some mandatory standards. Labor groups
have long been pushing for expansive coverage, to include areas
such as cabin air quality,
Page 8 of 10
lifting and moving baggage, and operation of aircraft doors to
the risk of dangers from cabin equipment.
February 27, 2013 - President of the Association of Professional
Flight Attendants (APFA) union, Laura Glading, letter of
support to the Honorable Rick Larsen, Ranking Member,
Subcommittee on Aviation Committee on Transportation and
Infrastructure:
Dear Representative Larsen:
Your comments in your opening statement at this morning’s
hearing regarding efforts to extend occupational safety and
health protections to flight attendants were greatly appreciated.
As you know, Flight Attendants have been working on this issue
for much too long, and we look forward to working with you on
this and other issues important to our profession in the future.
I also look forward to briefing you on the proposed merger of
American Airlines and US Airways at your convenience.
Again, on behalf of the over 16,000 Flight Attendants of
American Airlines thank you.”
CASE STUDY QUESTIONS
1. Identify and analyze the main issues of this case study. What
are the pros and cons of the FAA implementing this policy?

Reference supporting comments for the pros and cons you cite.
Comments are located on the Notice of Proposed Rulemaking
comment web page:
http://www.regulations.gov/#!docketBrowser;rpp=25;po=0;D=F
AA-2012-0953;dct=PS

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