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Fuel Tank Safety. Mike Kaszycki, FAA Dave Gibbons, JAA. Fuel Tank Safety. Harmonization of Unsafe Condition Criteria Fuel Tank Safety Reviews Implementation of Unsafe Condition Criteria Continued Operational Safety/Maintenance Fuel Tank Inerting Summary.
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Fuel Tank Safety Mike Kaszycki, FAA Dave Gibbons, JAA
Fuel Tank Safety • Harmonization of Unsafe Condition Criteria • Fuel Tank Safety Reviews • Implementation of Unsafe Condition Criteria • Continued Operational Safety/Maintenance • Fuel Tank Inerting • Summary
Harmonization of Unsafe Condition Criteria • FAA and JAA fuel tank safety review requirements reference different regulations: • FAA: FAR 25.901 & 25.981(a) & (b), amendment 25-102 • JAA: JAR 25.1309 • FAA and JAA developed harmonized policy • Includes unsafe condition criteria for determining mandatory action from SFAR 88 & JAA fuel tank safety reviews. • JAA issued policy letter on February 3, 2003 • FAA issued policy memorandum on February 25, 2003 • Expectation is to have common solution set.
Unsafe Condition Criteria Four-Element Unsafe Condition Evaluation Criteria • Element 1. Single Failures – all tanks • Element 2. Combination of failures: a) Fuel tanks with low flammability exposure time: Known combinations of failures are considered an unsafe condition. b) Fuel tanks with high flammability exposure time: Non-compliant design features and associated maintenance actions identified by the system safety analysis will be used for establishing unsafe condition. • Element 3. Unacceptable service experience – all tanks • Element 4. Determination of the flammability exposure time of each fuel tank: • Heated CWT = High flammability exposure • Other tanks = Low flammability exposure
Fuel Tank Safety Reviews • FAA/JAA are participating in joint SFAR 88 reviews of several type certificate holders, together with certifying authorities: • Airbus (Toulouse) March 19 - 20 • Boeing (Seattle) April 22 - 25 • Embraer (Ft. Lauderdale, FL) April 29 – May 1 • Bombardier (Montreal) May 6 – 8 • Other TC holder reviews may only have the certifying authority participation, depending on the results of the above reviews(JAA will provided standardization of European NAA reviews).
Implementation of Unsafe Condition Criteria • OEM review identified harmonization issues with implementation of the unsafe condition criteria. • Authorities differed in interpretation of portions of the unsafe condition criteria. • We are committed to jointly resolving open issues from SFAR 88 review.
Continued Operational Safety/Maintenance • SFAR 88 requires identification of additional or enhanced maintenance and inspection procedures, in addition to possible design changes. • When SFAR 88 was issued, FAA believed the most practical method to incorporate necessary maintenance and inspection instructions would be by operating rules. • After rule was issued, several aviation authorities and industry groups indicated mandating by airworthiness directives would be preferred. • As part of the harmonization program, the FAA agreed that airworthiness directives would be used to mandate any maintenance and inspection procedures required to address unsafe conditions.
Continued Operational Safety/Maintenance • FAA will change the operating rules back to their pre-SFAR 88 wording. • FAR sections 91.410(b), 121.370(b), 125.248(b) and 129.32(b). • ADs will be issued to require maintenance actions necessary to address unsafe conditions. • Maintenance and inspection instructions not required to address unsafe conditions will be evaluated under existing standard maintenance review processes.(e.g., MRB) • If practical, ADs will use the December 6, 2004, compliance date to be harmonized with JAA policy letter. • Any change to this target date will be harmonized • Requirement deleted for U.S. operators to perform a design reviews for STC holders who did not complete SFAR 88 reviews.
Fuel Tank Inerting • Boeing applied to FAA for certification of Flammability Reduction System (FRS) for 737 and 747 airplane models. • FRS is based on using fuel tank inerting system to reduce center wing tank flammability • Boeing applied to JAA for 737 Next Generation models to formalize harmonization process. • FAA and JAA have developed harmonized certification requirements. • FAA 737 issue paper P-1 contains proposed FAA special conditions • JAA CRI PTC E-10 contains proposed JAA special conditions • Plan is to publish both FAA and JAA proposed special conditions for comment concurrently in June 2003 with 60 day comment period.
Fuel Tank Safety – Summary • Harmonization of implementation of the unsafe criteria continues to support common solution set. • Fuel tank safety reviews are taking place to support mandatory action decisions by June 2003. • FAA and JAA have harmonized certification requirements for fuel tank inerting.