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REPORT OF THE - Archives - Syracuse University

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hours per day, including time taken to train security personnel. The low level of training<br />

for Alert employees at both Heathrow and Frankfurt reflected these restrictions.<br />

The absence of management control and direction was apparent in the day-to-day<br />

working level of these Pan Am security operations. Experience and qualifications seemed<br />

to have had little to do with the hiring of at least some Alert Security personnel, Pan Am<br />

had no set procedure at either Frankfurt or Heathrow for distribution of FAA security<br />

bulletin information, such as that for the radio bomb, to these security workers.<br />

Given the circumstances then prevailing, it is not surprising that the FAA inspector who<br />

reviewed Pan Am's Frankfurt security operation in October 1988 could conclude that it<br />

had very substantial problems. It is astonishing, however, that Pan Am permitted those<br />

problems and others to continue at that level month upon month after the disaster.<br />

The problems repeatedly reflected in Pan Am's Frankfurt operations could be solved - as<br />

events would prove - with only a relatively brief but concentrated amount of management<br />

attention. It took just one week of that attention in September 1989, following a meeting<br />

between the Pan Am Chief Executive Officer and the Administrator of the FAA.<br />

The Federal Aviation Administration<br />

For years, FAA security personnel questioned Pan Am's commitment to implementation<br />

of the FAA extraordinary security procedures. As early as October 1986, the FAA had<br />

convened an unusual meeting of Pan Am's security management at FAA's regional<br />

headquarters in Brussels, to discuss Pan Am's implementation of the extraordinary<br />

security procedures the FAA had promulgated.<br />

FAA inspectors reported Pan Am's operations at Frankfurt and Heathrow were in<br />

compliance with FAA standards as late as October 1988. Yet the FAA proposed large<br />

fines for deficiencies found at those same airports as the result of its post-Flight 103<br />

inspection undertaken approximately 60 days after the October 1988 inspection. True, the<br />

investigation of Pan Am operations during December 1988 - January 1989, following<br />

Flight 103, presumably was more thorough than a "routine" FAA inspection. Obviously,<br />

however, the problems found during this investigation did not suddenly arise during the<br />

two months before Flight 103.<br />

The October 1988 security inspection of Pan Am at Frankfurt did find substantial<br />

problems. But, the FAA security system was not set up so that this sort of inspection<br />

report would ring an alarm, let alone lead to a quick, decisive regulatory response even<br />

for a carrier like Pan Am with a history of security problems. The report of the October<br />

Frankfurt inspection was not even finalized in FAA's Brussels headquarters until after<br />

December 21, 1988.<br />

It might be unrealistic to expect that FAA headquarters could or would react to each<br />

security flaw identified by any of its agents after a field inspection. Nor should it be<br />

necessary for senior FAA management to become involved before adequate security will<br />

be assured in the field. But the circumstances at Frankfurt in the fall of 1988 were<br />

anything but routine.<br />

Also troubling is the FAA's response to the problems of Pan Am at Frankfurt after Flight<br />

103 had exploded.<br />

Both the public and the regulatory spotlight were focused on just those types of security<br />

problems throughout early 1989. Congressional hearings were held. The Secretary of<br />

Transportation set up a task force expressly to look into the matter. The Commission<br />

would have expected the FAA to give top priority to security operations at the two

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