European Aviation Safety Agency

1
European Aviation Safety Agency

• Fuel Tank Safety Training
• November 23, 2007
• EASA presentation

2
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.

3
Fuel Tank Safety - Training

• 09.30 10.00
• 10.00 10.15
• 10.15 11.00
• 11.00 - 12.30
• 12.30 13.30
• 15.00 15.15
• 15.15 16.00
• 16.00

• Welcome and Registration
• Opening of the seminar and welcoming speech
  Background
• Legal status of decisions/ Summary of decision
• Aircraft applicability / Short term / final
  training
• NAA views / Manufacturers Views / AEA views
• Lunch time
• Conclusions revision to EASA documents
• Questions and answers
• Closure

4
Background
Fuel Tank Safety

• 23rd of November 2007

5
EASA and fuel tank safety

• Ignition prevention
• Flammability reduction
• Instruction for continued airworthiness

6
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.

7
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.

8
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.

9
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).

10
Instructions for Continued Airworthiness (ICA)

• 1. For ignition prevention related actions,
  TC/STC Holders have published by 31-12-2005 (or
  beginning of 2006)
• - all maintenance instructions, warnings and
  procedures necessary to ensure the ongoing
  integrity of the critical design feature of the
  identified ALIs and CDCCLs to be approved before
  31/12/2005. This should also include enhanced
  fuel tank entry and exit procedures.

11
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.

12
Instructions for Continued Airworthiness (ICA)

• 3. Due to CDCCLs 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 ALIs) that would need including into
  operator and maintenance organisation training
  syllabi.

13
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)

14
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 TC-Holder.
  Appropriate text is highlighted in the CMM.

15
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

16
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.

17
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

18
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.

19
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

20
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.

21
EASA AMC (II)

• EASA AMCs must be accepted by the competent
  authorities if the applicant decides to use them
  and implements them correctly

22
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

23
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.

24
NAA AMC (III)

• Translation of NAA AMC is an internal issue
  related to each national administrative order.

25
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

26
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.

27
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

28
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

29
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.

30
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.

31
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

32
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.

33
Fuel Tank Safety - Training

• NAA views notes from the conference

34
Fuel Tank Safety - Training

• Manufacturers views notes from the conference

35
Fuel Tank Safety - Training

• AEA views notes from the conference

36
Fuel Tank Safety - Training

• Conclusions notes from the conference