Transcript Diapositive 1 - European Aviation Safety Agency

European Aviation Safety
Agency
Fuel Tank Safety Training
November 23, 2007
EASA presentation
FTS November 2007
European Aviation Safety Agency
Health warning
This presentation was given to set
the scene and launch discussions
It is presented un-modified to reflect
accurately the workshop.
This presentation must be read in
conjunction with the conclusions
slides.
FTS November 2007
European Aviation Safety Agency
Fuel Tank Safety - Training
09.30 – 10.00
Welcome and Registration
10.00 – 10.15
Opening of the seminar and welcoming speech
– Background
10.15 – 11.00
Legal status of decisions/ Summary of decision
Aircraft applicability /
Short term / final
training
11.00 - 12.30
NAA views / Manufacturers Views / AEA views
12.30 – 13.30
Lunch time
15.00 – 15.15
Conclusions: revision to EASA documents
15.15 – 16.00
Questions and answers
16.00
Closure
FTS November 2007
European Aviation Safety Agency
Fuel Tank Safety
Background
23rd of November 2007
FTS November 2007
European Aviation Safety Agency
EASA and fuel tank safety
 Ignition prevention
 Flammability reduction
 Instruction for continued
airworthiness
FTS November 2007
European Aviation Safety Agency
Ignition prevention (1/3)

TWA 800 accident (July 1996) prompted FAA to
launch a review of in-service record.

Another significant event had occurred in 1990
(PAL 737-400) and other events have occurred
since (THA 737-300 in 2001, cargo 727-200 in
2006).

FAA and JAA decided to launch design reviews to
identify any shortcomings in the transport
aircraft fleet.
FTS November 2007
European Aviation Safety Agency
Ignition prevention (2/3)
 JAA INT/POL/25/12 published in 2000 to
set the technical criteria, based upon
25.1309 (no single failure or combination
of failures not shown to be extremely
improbable).
 Corresponding requirement introduced in
CS 25 Amendment 1 at the end of 2005.
 FAA had previously released
corresponding SFAR 88 and FAR 25 Amdt
102.
FTS November 2007
European Aviation Safety Agency
Ignition prevention (3/3)
 Outcome of the design reviews showed



issues of various importance on nearly all
projects; ADs were issued.
No significant margin available when
establishing compliance with 25.1309.
“Flat” fault tree: design reviews typically
identified combination of 2 failures that could
cause fuel tank ignition; many failures are
dormant.
Very close from critical part concept.
FTS November 2007
European Aviation Safety Agency
Flammability reduction

Past certification and design reviews were
conducted assuming a flammable air/fuel vapor
mixture with the hullage space.

FAA sponsored a nitrogen system changing the
paradigm. Introduction of such system would
allow adding a further layer of protection.

FAA is promoting retrofit while EASA would be
happy to rely on forward fit (at least, for product
the agency is primary certificating authority).
FTS November 2007
European Aviation Safety Agency
Instructions for Continued
Airworthiness (ICA)
1.For ignition prevention related actions,
TC/STC Holders have published by 31-122005 (or beginning of 2006):
- all maintenance instructions, warnings and
procedures necessary to ensure the ongoing
integrity of the critical design feature of the
identified ALI’s and CDCCLs to be approved
before 31/12/2005. This should also include
enhanced fuel tank entry and exit procedures.
FTS November 2007
European Aviation Safety Agency
Instructions for Continued
Airworthiness (ICA)
2. For all other instructions for continued airworthiness,
e.g. the development of additional scheduled
maintenance tasks
- TC/STC Holders have developed those instructions by
31/12/2006 (some were delayed till beginning of
2007). To our knowledge all MRBR have been EASA
approved.
- In accordance with Part M.A.302, Operators will be
required to take into account the above into their
approved maintenance programmes within 12 months
of receipt of the updates.
FTS November 2007
European Aviation Safety Agency
Instructions for Continued
Airworthiness (ICA)
3.
Due to CDCCL’s being a new concept
EASA recommends that TC/STC Holders
consider assisting their operators by
providing guidance on the unique aspects
of their identified CDCCLs (and possibly
ALI’s) that would need including into
operator and maintenance organisation
training syllabi.
FTS November 2007
European Aviation Safety Agency
Instructions for Continued
Airworthiness (ICA)
-
- All TC (EU and non EU) have agreed to the
EASA time frames for ALI, CDCCL and MRBR
revision
All ALI and CDCCL have been published by
the manufacturers beginning of 2006. All ALI
and CDCCL for European products have been
mandated by EASA AD in 2006.
all ALI and CDCCL for non EU products are in
the phase of being mandated by EASA AD
(December 2007)
FTS November 2007
European Aviation Safety Agency
Instructions for Continued
Airworthiness (ICA)
Interesting difference between EASA and FAA:
EASA Part M.A.302 (12 months) and FAA needs
an Airworthiness Directive to mandate ALI and
CDCCL (for in service aircraft: FAA planning date
is 8 December 2008). So implementation on EU
side is more than 18 months ahead from FAA
Component Maintenance Manual will be FAA
approved (no deviations allowed unless approved
by FAA); EASA leaves CMM under control of TCHolder. Appropriate text is highlighted in the
CMM.
FTS November 2007
European Aviation Safety Agency
Fuel Tank Safety - Training
Publication of Decisions 2007/001/002 and 003:
2007-001: to add AMC to Part-M and training to
personnel of CAMO organisations,
2007-002: to add AMC to Part-145 and training of
personnel in AMO organisations,
2007-003: to add AMC to Part-66 and training to
personnel holding a 66 licence.
http://www.easa.europa.eu/home/rg_agency_desc_main.html
FTS November 2007
European Aviation Safety Agency
Fuel Tank Safety - Training
Typical questions raised further to publication of
decisions:
Which aircraft are affected?
Why they was no consultation on Annexes to
Decisions?
what training programme, schedule, approval?
why are there hard rules in the text:
“The training shall be carried out at the earliest for the
personnel needing level 1 training.
Nevertheless, the training for the personnel needing level 2
training has to be carried out before they perform any
continuing airworthiness management activity,” or
“Nevertheless, the training for the personnel needing level 2
training has to be carried out before any maintenance task
is commenced on an aircraft or a component.”
FTS November 2007
European Aviation Safety Agency
Fuel Tank Safety - Training
Further to questions, the Agency issued a letter to
NAAs, to address the following issues:
- the form of training to be provided,
- approval by NAA of training programme
- schedule to build and conduct the training,
- possibility of doing differently than what is
stated in the decisions.
Letter 52380
FTS November 2007
European Aviation Safety Agency
Definition of AMC and of
Guidance Material (GM)
Acceptable Means of Compliance (AMC):
Illustrate a means, but not the only means, by
which a requirement contained in an EASA
airworthiness code or an implementing rule of
the Basic Regulation, can be met.
Guidance material
Non-binding material that helps to illustrate
the meaning of an implementing rule or a
certification specification and which does not
provide presumption of compliance when used
in the certification process.
FTS November 2007
European Aviation Safety Agency
Who can issue AMC?
EASA can issue AMC and is instructed to
do so (see article 13 of regulation
1592/2002)
This should not prevent NAA to issue AMC
and they should feel encouraged to do so
when necessary.
An applicant may propose an AMC to
EASA or an NAA
FTS November 2007
European Aviation Safety Agency
EASA AMC (I)
An applicant correctly implementing an
AMC issued by EASA is assured of
acceptance of compliance.
As such published acceptable means of
compliance are not the only means to show
compliance, the applicant may decide to show
compliance by other means. When so doing it
does not need to justify why an alternative is
used, but the onus of proof that the
requirement is met relies entirely with it.
FTS November 2007
European Aviation Safety Agency
EASA AMC (II)
EASA AMCs must be accepted by the
competent authorities if the applicant
decides to use them and implements them
correctly
FTS November 2007
European Aviation Safety Agency
NAA AMC (I)
If a National Aviation Authority decides to issue
its own national AMCs, such AMCs only commit
itself.
It is the role of the EASA standardisation inspection
system to monitor that the NAAs manage this process in
a correct manner.
There is no obligation to submit such alternative
means of compliance to EASA
Ideally NAA should publish such AMC
Even more ideally EASA, after agreeing with them,
should publish them following a rulemaking procedure
and issue them as EASA AMC
FTS November 2007
European Aviation Safety Agency
NAA AMC (II)
NAA can not impose the use of their own
AMC:
NAAs must accept other means of compliance
when they are the competent authority
themselves, provided such means of
compliance ensure full compliance with the
applicable certification requirement.
It is the role of the EASA standardisation
inspection system to monitor that the NAAs
manage this process in a correct manner.
FTS November 2007
European Aviation Safety Agency
NAA AMC (III)
Translation of NAA AMC is an internal
issue related to each national
administrative order.
FTS November 2007
European Aviation Safety Agency
Fuel Tank Safety - Training
Possibility of doing differently:
The legal status of an AMC :
http://www.easa.europa.eu/home/r_faq_the5.html
will not result in changes to the Decisions;
Aircraft affected, refer to EASA policy statement:
this shall be added to the Decisions:
FTS November 2007
European Aviation Safety Agency
Fuel Tank Safety - Training
Levels of training described in decisions:
Level 1 Familiarisation training
Level 2 Detailed training
but in the letter:
As training may be provided over a relatively long period,
it should not be permitted that maintenance be carried out,
or continued airworthiness be managed, on aircraft during
the interim period by personnel having not been instructed
on the nature and specificities of ALI and CDCCL related to
Fuel Tank Safety. This is why the competent authorities
should require that such personnel receive prior to any
airworthiness management or maintenance action, a
familiarisation course on these issues.
so, possible confusions between statements and
courses.
FTS November 2007
European Aviation Safety Agency
Fuel Tank Safety - Training
New training schematic for amending the Decisions:
Short term familiarisation training;
- duration of the course: 2 to 3 hours,
- to be conducted as soon as the organisation is
ready for providing the training, and preferably
before maintenance actions or management of FTS
ALI,
- restricted to CAMO personnel directly involved in
CA of FTS ALI and AMO maintenance personnel
directly involved in maintenance of FTS ALI,
- may be a self study course;
FTS November 2007
European Aviation Safety Agency
Fuel Tank Safety - Training
New training schematic for amending the Decisions:
Long term training course;
- level 1 basic training, syllabus to meet Decisions
Appendixes;
- level 2 detailed training, syllabus to meet
Decisions Appendixes;
- to be conducted when the organisation are ready,
- restricted to all CAMO personnel involved in CA of
FTS ALI and all AMO maintenance personnel
involved in maintenance of FTS ALI;
- to be conducted in a training class;
FTS November 2007
European Aviation Safety Agency
Fuel Tank Safety - Training
New training schematic for amending the Decisions:
Continuation training on:
- level 1 basic training
- level 2 detailed training
period to be set by CAMO and AMO
but not to exceed 2 years.
FTS November 2007
European Aviation Safety Agency
Fuel Tank Safety - Training
New training schematic for amending the Decisions:
Short term familiarisation course – Syllabus
to be provided by AEA
Long term basic and detailed courses – to be set by
organisations themselves but syllabus should
meet the instructions in the Decisions.
No need of approval by authorities.
FTS November 2007
European Aviation Safety Agency
Fuel Tank Safety - Training
Next changes to Decisions:
Modification of the Decisions to add:
Aircraft affected
Presentation of this new training schematic
No approval of training courses
and to adapt the wording of Decisions to
AMC status–
FTS November 2007
European Aviation Safety Agency
Fuel Tank Safety - Training
Other changes to regulatory documents:
Modification of the Appendix I to Part-66 “Basic
knowledge requirements” to add concept of Fuel
Tanks Safety definition and limitations in:
 module 7 Maintenance practices,
 and module 11A Turbine aeroplanes structures
and systems
To be introduced at next change of Appendix I.
FTS November 2007
European Aviation Safety Agency
Fuel Tank Safety - Training
NAA views – notes from the conference
FTS November 2007
European Aviation Safety Agency
Fuel Tank Safety - Training
Manufacturers views – notes from the
conference
FTS November 2007
European Aviation Safety Agency
Fuel Tank Safety - Training
AEA views – notes from the conference
FTS November 2007
European Aviation Safety Agency
Fuel Tank Safety - Training
Conclusions– notes from the conference
FTS November 2007