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it into their maintenance programs. The revision of the LMCO
SWPM will provide reference to ATA 117. Additionally, review of
our Maintenance Manuals shows that more notes should be added,
regarding proper techniques and the use of suggested references.
4.2 OEM Boeing - Implementation of any new technology will be evaluated as
it is being developed and with the input of the operators
Boeing - Implementation of any new technology will be evaluated as
it is being developed and with the input of the operators.
Airbus - Implementation for in-service aircraft will be dependant on
the result of the test program
Lockheed - As AFCB technology is developed LMCO will continue
to evaluate, with operators, the applicability for individual systems.
[COMMENT directed at Boeing] I appreciate Boeing’s commitment
to examining the potential of Arc-Fault Circuit Breakers. Boeing’s
efforts in this area have encouraged other OEMs, circuit breaker
manufacturers, and operators to take seriously this technology.
4.3 OEM Research and develop nondestructive testing techniques capable of
identifying and locating insulation cracks. Consider using these
techniques for both inspection and troubleshooting of suspect wires.
Consider utilization of such techniques to establish on-condition
criteria for replacement of endemic cracking wire
Boeing - We are presently conducting testing of wiring removed
from service airplanes with the intent of identifying techniques to
replace suspect wiring. This testing is ongoing and may result in the
identification of and limits to insulation cracking
Airbus -Airbus is currently investigating possible non-destructive
testing methods that will detect wire insulation damage
Lockheed - Currently, visual inspection techniques are the method
utilized in determining wiring discrepancies. As new technology is
developed LMCO will evaluate and recommend the use of proven,
viable techniques in an effort to improve the detection of suspect
wiring.
[COMMENT directed at Boeing] Wire cracking was identified as
one of the most critical issues to address. Boeing’s efforts in this area
are appropriate and welcome
4a2 OEM Consider local design modification to replace non-fire-retardant
materials
8 April 19 2002 41
Boeing - Specification and use of materials in the manufacture of an
airplane, especially the ability of the material to self-extinguish,
comply with federal regulations at the time of certification. Service
experience or a change in the use of the airplane would be used to
determine whether an original material should be replaced by a
material meeting a different flammability standard
Airbus - Specification and use of materials in the manufacture of an
airplane, comply with federal regulations at the time of the
certification. The results of the ongoing studies aimed at identifying
acceptable materials will be used to determine the use of these
materials in present and future airplanes
Lockheed - Materials met the current FAA flammability
requirements at the time of design
[COMMENT 1 directed at Boeing] This does not address the
question about current design mods.
[COMMENT 2 directed at Boeing] 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.
[COMMENT 3 directed at Boeing] The ATSRAC is well aware that
materials used in airplane manufacturing comply with federal
regulations at the time of certification. However, service experience,
as illustrated by the intrusive inspections, show that some original
material should be replaced with materials meeting a more current
flammability standard. This is the basis for this series of
recommendations that design modifications be considered to
eliminate non-fire retardant materials. Boeing’s comments are non
responsive to the recommendations.
[COMMENT 4 directed at Boeing] The point of ATSRAC is to
identify systemic safety issues with aging systems, not to write
model-specific airworthiness directives. The airworthiness directive
process is quite adequate for addressing unique problems with unique
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