Informal meeting Airlines/Boeing/JAA on SFAR 88

1
Fuel Tank System Safety JAA MAINTENANCE
SECTORIAL TEAM
Len Arnot-Perrett Joint Aviation Authorities,
United Kingdom Section Leader, Maintenance
Requirements Policy Section
2
Fuel Tank Safety Implementation

• JAA fuel tank system safety policy set out in JAA
  policy letter INT/POL/25/12
• INT/POL/25/12 harmonised with FAA SFAR 88
• JAA/FAA policy for implementation of corrective
  actions to address unsafe conditions and non
  compliant items harmonised principles

3
Fuel Tank Safety Implementation

• Implementation of corrective actions guidance
  material drafted
• Guidance material comprehensive addresses
  TC/STC holders as well as operators and
  maintenance organisations
• JAA temporary guidance leaflet to be drafted and
  harmonised with FAA/JAA jointly developed FAA
  draft
• Harmonised implementation will facilitate
  transfer of aircraft between States

4
Fuel Tank Safety Implementation

• Corrective actions required to address unsafe
  conditions will be AD
• Corrective actions identified to address
  non-compliance will be dealt with through
  existing processes
• Possible revisions to
• Maintenance Manuals aircraft/component (MM/CMM)
• Wiring Practices
• Maintenance Procedures
• Fault Isolation Manuals
• MRB report
• MPD

5
Fuel Tank Safety Implementation

• Operator responsible for in-service compliance
• Scheduled/un-scheduled maintenance
• Modification
• Operation
• Component Maintenance
• JAR 145.35 continuation training programme will
  need to address fuel tank safety topics

6
Fuel Tank Safety Implementation

• In-service aircraft fleet survey provides
  indications that inspection standards and
  maintenance standards do not address fuel tank
  safety issues
• Loose articles in tanks
• Lack of preparation for inspection
• Lack of awareness
• Maintenance induced damage
• Survey of one representative fleet showed that
  16 of mandatory occurrence reports for ATA 28/73
  had maintenance error contributing factors

7
Fuel Tank Safety Implementation

• Corrective actions will require additional
  maintenance and modification
• Fuel tank system intrusions should be kept to a
  minimum consistent with maintaining certification
  standard
• Future design should take into account, issues
  associated with maintainability

8
Fuel Tank Safety Implementation

• JAA policy will require each JAA member state
  intervention prior to EASA each State will need
  to raise AD for corrective actions
• Harmonisation of implementation time frames will
  require co-ordination