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here. I was referring to WG 6 and the progress so far in that group as
of when I wrote the reply. It had appeared to me to be accepting that
present practices were good enough and no changes
were needed. I disagreed, what was the point in doing the Intrusive
Inspection if we did not make some changes based on the
information we garnered. I understand there has been some
movement on these issues lately. I hope they address the concerns I
had earlier voiced on wire separation issues
[COMMENT 2] Although this Recommendation is aimed at aircraft
manufacturers, the incorporation plan does not include an entry
covering OEM responses. Also my comment against 4.a.2 applies
(see below)
ATSRAC has spent a great deal of time debating the issues
surrounding the treatment of flammable materials in zones, without
reaching a firm conclusion on whether materials that meet the
regulations extant at the time of original certification should
automatically be considered adequately fire resistant. I do not want
to restart that debate here, but I would like to put down a marker that
ATSRAC’s conclusion on that issue should determine how
vigorously design modifications to replace non fire retardant
materials should be pursued. That, in turn, will determine whether
the responses to Recommendation 4.a.2 can be considered acceptable
or not.
OWNER REMARKS: WG6 P1
WG 6 discussed the issue of non fire retardant material and
separation from EWIS components. Separation of EWIS
components from various airplane systems such as fuel systems,
oxygen systems and others are adequately covered by the new
FAR/JAR 25.1705 requirements and the new AC/ACJ for EWIS. As
far as the replacing the non fire retardant material – it was
determined that this item is beyond the scope of Task group 6.
6d2 WG8 Use additional precautions when performing maintenance in the
vicinity of wire bundles supporting multiple flight-critical systems
WG8 - Because of the difficulty of identifying flight critical wire
bundles, all wire bundles are to be treated identically. ESPM data
will be used at all times as covered in Wiring Practices
Documentation Module B and Wire Module E3, 4 & 6; Inspection
Criteria and Standards of Wire and Wire Bundles, Wire Bundle
Installation Practices, and Maintenance and Repair Procedures
[COMMENT] Task 8 WG comments that it must treat all wire
bundles identically since there currently is difficulty in identifying
flight critical wire bundles. I was expecting to find some mention
here that in the future an identification standard would be phased in
on new aircraft that will make this task easier for operators
maintaining wiring systems of newer generation aircraft. Does WG
6 have this task and has it made a determination of whether it will
8 April 19 2002 12
have requirements to specifically identify flight critical system
wiring differently for future operators maintenance programs. If so,
could comments be added to this section of the Intrusive
Recommendations report? As it shows now, it leaves me with the
impression that I will always have to inspect every bundle on the
aircraft the same, when I believe the recommendation's intent is for
more scrutiny to be applied against flight critical wiring. We need to
move to help in identifying these wire systems on future aircraft.
OWNER REMARKS: WG8 P1
Identification of flight critical systems is assigned to WG 6. They
are working to finalize this process. When this process is identified,
it will be included in WG 8 Curriculum and Lesson
8 April 19 2002 13
PRIORITY 2 ITEMS
1.1 WG 7/0EM Update splicing practices as necessary. Consider procedure to tag
locations of splices to aid in future visual inspection
Boeing - Boeing has reviewed our present splicing practices in light
of the results of the intrusive inspection and believe that no changes
are necessary at this time
Airbus - Airbus - All production splices are covered in the Airbus standard
documentation. While the ESPM stipulates the maximum permitted
number of splices per wire. Airbus will include in ESPM guidelines
to inform operators of the need to tag locations of splices
Lockheed: Per the original design, production splices are addressed
in the WDM's and are physically marked on the aircraft wire bundles
[COMMENT 1] This recommendation arose from the finding, albeit
infrequently, of degraded splice repairs. The original
recommendation anticipated the need for updated splicing practices
and procedures as a means to reduce the instances of degraded
splices in the fleet. The only OEM response received up to now has
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