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The commenter has stated an opinion.
e. The lack of wire performance testing is what allowed the dangerous condition of the fleet's
wiring, along with a fit and forget maintenance attitude. We need wire performance now, as
called for by the TSB in Aug 2001 and Advisory Circular 25.16 "Demonstrations of arcing on
wire insulation should be allowed to progress to the point of "insulation flashover". The tests
may be supported by any relevant analysis. If laboratory tests are conducted instead of
airplane tests, compliance should be with FAR 25.1363".
FAA Remarks
The title of 25.1363 is “Electrical System Tests.” The purpose of this requirement is to
simulate the aircraft electrical generating and distribution system by using the same
equipment used in the airplane. The reason for this is to monitor the functional characteristics
of the electrical system including system components and wiring under foreseeable operating
conditions.
f. This report highlights what is wrong with the Intrusive Inspection Group Report. "The
conclusions are not sufficiently specific to serve as mandatory design or maintenance
requirements". The conclusions should have been specific in order to disallow the report
received from Boeing on the recommendations.
FAA Remarks
The commenter has stated an opinion
g. Visual inspections don't work and yet we continue to call for them in enhanced zonal (visual)
inspections.
FAA Remarks
Visual inspections are an important part of inspection/maintenance programs that also include
wire integrity tests. To further enhance the effectiveness of inspection programs better and
improved detection devices such as arc-fault circuit and enhanced fault isolation tools are
being developed for future use.
[COMMENT 2]
8 April 19 2002 54
The responses from the working groups are, in general, detailed and well researched. There was clearly
much effort put into developing proactive responses to the recommendations. Most of the manufacturerspecific
comments refer to Boeing because Boeing’s comments are the most complete. The absence of
comments referring to other organizations should not be construed as a specific endorsement of their
current practice.
In general, the responses by Boeing are too generic and dismissive. Boeing is justifiably proud of its
products and processes, and, if fed the appropriate data, existing Boeing processes may be sufficient to
safely manage the fleet of aging Boeing aircraft. There is, however, reluctance on the part of Boeing to
accept the recommendations of the IIWG as data to drive those processes. The IIWG recommendations
were not the random musings of working group members, but the considered analysis of data from real
aircraft – albeit few aircraft. If the IIWG observed a phenomenon and recommended a course of action, it
is incumbent on the responsible parties – using their existing fleet management processes where applicable
– to determine the prevalence of that phenomenon, assess the specific consequences, make specific changes
to the service literature (or directly implement changes to aircraft), and alert other affected parties. Instead
the majority of Boeing responses simply state that generic or specific Boeing processes and standards are
currently adequate.
A proper response to recommendations would, of course, require concerted, long-term effort on the part of
all parties affected. It is not likely, for instance, that any aircraft manufacturer could specify nondestructive
testing for specific at-risk circuits by the conclusion of ATSRAC’s current mandate.
Identification of the specific circuits alone would take more time than is available. Development of the
testing systems and processes would take even longer. ATSRAC is not, however, mandated to define and
fully implement comprehensive solutions to aging wiring problems: It need only define and commit to an
approach – full implementation (compliance new rules) may take years.
I find it hard to believe that Boeing saw fit to close all of its actions (approximately 50) with only a few
generic changes to the SWPM (mainly concerning good housekeeping practice). I would like to have seen:
1) Some commitment to intensify the frequency, intensity, or focus of their in-service evaluations,
2) Specific field assessments of issues identified by the IIWG,
3) More commitment to R&D (in addition to their degradation study).
While a fully adequate response to the IIWG recommendations would be a lot of work, it is not impossible
or even impractical. The IIWG recommendations are focused specifically. The conditions associated with
each recommendation should allow the OEMs and operators to restrict their efforts to specific areas of the
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