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that visual inspection is the “preferred NDT inspection method”
knowing that it does not work to discern the majority of wiring flaws
including and especially detecting flaws, nicks and cuts within a wire
bundle or under clamps, loss of continuity problems, and sometimes
does not reveal heat or arcing damage in wire insulation.
Though detailed visual inspections are an improvement, there are
many testing procedures and devices available today that go beyond
that. There should be no further delay in evaluating and incorporating
proven NDTs in wire inspection and maintenance programs
Furthermore, ALPA raises the issue that not all aircraft in need have
drip shields. Is this a manufacturer issue or an operator issue? Does
the OEM agree with this assessment?
[COMMENT 2] From the various comments, I do not see an effort to
include in the Task 6 report Part 25 Design guidelines that govern
where heat shields/drip shields are to be installed. While definition
by each OEM as to where such items are to be installed on a type
certified airframe are provided through the maintenance delivery
documentation, there is nothing for operators/STC agencies to use for
after delivery changes to the aircraft. Of concern are the various
interior changes done by many carriers that move galley and
lavatories throughout the cabin. With these interior changes, location
of wiring, potable water, and waste water lines are changing. I
presently see no guidance coming that instructs when to use heat
shields/drip shields when an electrical disconnect panel is now too
close to the rerouted plumbing components.
OWNER REMARKS: OEM P2
The use of general and detailed visual inspections of wiring installed
in airplanes remains the preferred method of detecting actual or the
potential for damage to wiring. This preference accounts for the
present level of diagnostic equipment available to the industry, and
the needs of the industry. The OEMs vehemently disagree that this
preference is either negligent or wrong given the present options.
With regard to the comment regarding wiring protection, as with any
component installed on the airplane, except as cited within the
Configuration Deviation List contained within the Dispatch
Deviations Procedures Guide, protective shields and guards are
required to be installed on the airplane during revenue service. The
OEMs provide wiring protection in specific cases and expect that that
protection will remain on the airplane indefinitely. The reinstallation
of removed equipment is a standard practices and a regulatory
requirement. It is the responsibility of each operator to ensure that
the design integrity of the airframe is properly maintained and to
incorporate maintenance and inspection programs that follow
industry best maintenance practices. The OEM’s believe that,
8 April 19 2002 20
although there exists the possibility that some protection may have
been inadvertently omitted on airlines undergoing extensive
modification, we believe that the existing maintenance procedures in
place at the airlines would dictate that such omissions would be rare.
We also believe that the effects of such an omission would be minor
in scope but still recognizable through normal or enhanced
maintenance activities.
Operators should use the guidance provided in the forthcoming
enhanced wiring inspection programs, coupled with the guidance
contained within the OEM standard wiring practices documents to
either identify damage caused from missing drip or heat shields, or
identify the conditions that would necessitate protection. The OEMs
believe that any wiring systems training program should emphasize
the purpose and necessity of wiring protection systems
Finally, with regard to the comment concerning the installation of
post-delivery modifications, OEM design practices, and the resulting
guidance used to maintain those designs, are proprietary to the OEM.
The requirement to use these practices and procedures for designs
created by entities other than the OEM is inappropriate. Although
the ESWPM is not considered to be a wiring standards document for
designs of new installations, operators and STC applicants may refer
to these guidelines in development of their installations.
As far as post-delivery modifications are concerned, Airbus is
currently reviewing the ESPM content related to wire routing and
segregation and will include in the ESPM guidance and
recommendations in case of new wiring installation after delivery to
the aircraft. Boeing will conduct a similar review based upon the
forthcoming HWG6 recommendations.
[COMMENT] Not all aircraft that need such shields have them: Ref
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