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Fuel Tank Safety - JAA TO

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					                         JAA/FAA


Fuel Tank Safety

 Mike Kaszycki, FAA
 Dave Gibbons, JAA



          20th Annual JAA/FAA International Conference
                                        JAA/FAA
            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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                                                JAA/FAA
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.

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                                                     JAA/FAA
           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

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                                                JAA/FAA
         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).

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                                        JAA/FAA
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.


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                                             JAA/FAA
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.
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                                                   JAA/FAA
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.
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                                                  JAA/FAA
                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.          20th Annual JAA/FAA International Conference   9
                                    JAA/FAA
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.
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