European Aviation Safety Agency Fuel Tank Safety Training November 23, 2007 EASA presentation FTS November 2007 DGINT/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. FTS November 2007

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 FTS November 2007 DGINT/2

Fuel Tank Safety Background 23rd of November 2007 DGINT/2 FTS November 2007 DGINT/2

EASA and fuel tank safety Ignition prevention Flammability reduction Instruction for continued airworthiness FTS November 2007 DGINT/2

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 DGINT/2

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 DGINT/2

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 DGINT/2

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 DGINT/2

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 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

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

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

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

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. FTS November 2007

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 DGINT/2

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 DGINT/2

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 DGINT/2

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

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

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

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

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

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

NAA AMC (III) Translation of NAA AMC is an internal issue related to each national administrative order. FTS November 2007

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 DGINT/2

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 DGINT/2

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 DGINT/2

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 DGINT/2

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 DGINT/2

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 DGINT/2

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 DGINT/2

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 DGINT/2

Fuel Tank Safety - Training NAA views – notes from the conference FTS November 2007 DGINT/2

Fuel Tank Safety - Training Manufacturers views – notes from the conference FTS November 2007 DGINT/2

Fuel Tank Safety - Training AEA views – notes from the conference FTS November 2007 DGINT/2

Fuel Tank Safety - Training Conclusions– notes from the conference FTS November 2007 DGINT/2