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European Aviation Safety Agency


... that would need including into operator and maintenance organisation training syllabi. Instructions for Continued Airworthiness (ICA) - All TC ... – PowerPoint PPT presentation

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Title: European Aviation Safety Agency

European Aviation Safety Agency
  • Fuel Tank Safety Training
  • November 23, 2007
  • EASA presentation

Health warning
  • This presentation was given to set the scene and
    launch discussions
  • It is presented un-modified to reflect accurately
    the workshop.
  • This presentation must be read in conjunction
    with the conclusions slides.

Fuel Tank Safety - Training
  • 09.30 10.00
  • 10.00 10.15
  • 10.15 11.00
  • 11.00 - 12.30
  • 12.30 13.30
  • 15.00 15.15
  • 15.15 16.00
  • 16.00
  • Welcome and Registration
  • Opening of the seminar and welcoming speech
  • Legal status of decisions/ Summary of decision
  • Aircraft applicability / Short term / final
  • NAA views / Manufacturers Views / AEA views
  • Lunch time
  • Conclusions revision to EASA documents
  • Questions and answers
  • Closure

Fuel Tank Safety
  • 23rd of November 2007

EASA and fuel tank safety
  • Ignition prevention
  • Flammability reduction
  • Instruction for continued airworthiness

Ignition prevention (1/3)
  • TWA 800 accident (July 1996) prompted FAA to
    launch a review of in-service record.
  • Another significant event had occurred in 1990
    (PAL 737-400) and other events have occurred
    since (THA 737-300 in 2001, cargo 727-200 in
  • FAA and JAA decided to launch design reviews to
    identify any shortcomings in the transport
    aircraft fleet.

Ignition prevention (2/3)
  • JAA INT/POL/25/12 published in 2000 to set the
    technical criteria, based upon 25.1309 (no single
    failure or combination of failures not shown to
    be extremely improbable).
  • Corresponding requirement introduced in CS 25
    Amendment 1 at the end of 2005.
  • FAA had previously released corresponding SFAR 88
    and FAR 25 Amdt 102.

Ignition prevention (3/3)
  • Outcome of the design reviews showed issues of
    various importance on nearly all projects ADs
    were issued.
  • No significant margin available when establishing
    compliance with 25.1309.
  • Flat fault tree design reviews typically
    identified combination of 2 failures that could
    cause fuel tank ignition many failures are
  • Very close from critical part concept.

Flammability reduction
  • Past certification and design reviews were
    conducted assuming a flammable air/fuel vapor
    mixture with the hullage space.
  • FAA sponsored a nitrogen system changing the
    paradigm. Introduction of such system would allow
    adding a further layer of protection.
  • FAA is promoting retrofit while EASA would be
    happy to rely on forward fit (at least, for
    product the agency is primary certificating

Instructions for Continued Airworthiness (ICA)
  • 1. For ignition prevention related actions,
    TC/STC Holders have published by 31-12-2005 (or
    beginning of 2006)
  • - all maintenance instructions, warnings and
    procedures necessary to ensure the ongoing
    integrity of the critical design feature of the
    identified ALIs and CDCCLs to be approved before
    31/12/2005. This should also include enhanced
    fuel tank entry and exit procedures.

Instructions for Continued Airworthiness (ICA)
  • 2. For all other instructions for continued
    airworthiness, e.g. the development of additional
    scheduled maintenance tasks
  • TC/STC Holders have developed those instructions
    by 31/12/2006 (some were delayed till beginning
    of 2007). To our knowledge all MRBR have been
    EASA approved.
  • In accordance with Part M.A.302, Operators will
    be required to take into account the above into
    their approved maintenance programmes within 12
    months of receipt of the updates.

Instructions for Continued Airworthiness (ICA)
  • 3. Due to CDCCLs being a new concept EASA
    recommends that TC/STC Holders consider assisting
    their operators by providing guidance on the
    unique aspects of their identified CDCCLs (and
    possibly ALIs) that would need including into
    operator and maintenance organisation training

Instructions for Continued Airworthiness (ICA)
  • - All TC (EU and non EU) have agreed to the EASA
    time frames for ALI, CDCCL and MRBR revision
  • All ALI and CDCCL have been published by the
    manufacturers beginning of 2006. All ALI and
    CDCCL for European products have been mandated by
    EASA AD in 2006.
  • all ALI and CDCCL for non EU products are in the
    phase of being mandated by EASA AD (December 2007)

Instructions for Continued Airworthiness (ICA)
  • Interesting difference between EASA and FAA EASA
    Part M.A.302 (12 months) and FAA needs an
    Airworthiness Directive to mandate ALI and CDCCL
    (for in service aircraft FAA planning date is 8
    December 2008). So implementation on EU side is
    more than 18 months ahead from FAA
  • Component Maintenance Manual will be FAA approved
    (no deviations allowed unless approved by FAA)
    EASA leaves CMM under control of TC-Holder.
    Appropriate text is highlighted in the CMM.

Fuel Tank Safety - Training
  • Publication of Decisions 2007/001/002 and 003
  • 2007-001 to add AMC to Part-M and training to
    personnel of CAMO organisations,
  • 2007-002 to add AMC to Part-145 and training of
    personnel in AMO organisations,
  • 2007-003 to add AMC to Part-66 and training to
    personnel holding a 66 licence.
  • http//

Fuel Tank Safety - Training
  • Typical questions raised further to publication
    of decisions
  • Which aircraft are affected?
  • Why they was no consultation on Annexes to
  • what training programme, schedule, approval?
  • why are there hard rules in the text
  • The training shall be carried out at the
    earliest for the personnel needing level 1
  • Nevertheless, the training for the personnel
    needing level 2 training has to be carried out
    before they perform any continuing airworthiness
    management activity, or
  • Nevertheless, the training for the personnel
    needing level 2 training has to be carried out
    before any maintenance task is commenced on an
    aircraft or a component.

Fuel Tank Safety - Training
  • Further to questions, the Agency issued a letter
    to NAAs, to address the following issues
  • the form of training to be provided,
  • approval by NAA of training programme
  • schedule to build and conduct the training,
  • possibility of doing differently than what is
    stated in the decisions.
  • Letter 52380

Definition of AMC and of Guidance Material (GM)
  • Acceptable Means of Compliance (AMC)
  • Illustrate a means, but not the only means, by
    which a requirement contained in an EASA
    airworthiness code or an implementing rule of the
    Basic Regulation, can be met.
  • Guidance material
  • Non-binding material that helps to illustrate the
    meaning of an implementing rule or a
    certification specification and which does not
    provide presumption of compliance when used in
    the certification process.

Who can issue AMC?
  • EASA can issue AMC and is instructed to do so
    (see article 13 of regulation 1592/2002)
  • This should not prevent NAA to issue AMC and they
    should feel encouraged to do so when necessary.
  • An applicant may propose an AMC to EASA or an NAA

  • An applicant correctly implementing an AMC issued
    by EASA is assured of acceptance of compliance.
  • As such published acceptable means of compliance
    are not the only means to show compliance, the
    applicant may decide to show compliance by other
    means. When so doing it does not need to justify
    why an alternative is used, but the onus of proof
    that the requirement is met relies entirely with

  • EASA AMCs must be accepted by the competent
    authorities if the applicant decides to use them
    and implements them correctly

  • If a National Aviation Authority decides to issue
    its own national AMCs, such AMCs only commit
  • It is the role of the EASA standardisation
    inspection system to monitor that the NAAs manage
    this process in a correct manner.
  • There is no obligation to submit such alternative
    means of compliance to EASA
  • Ideally NAA should publish such AMC
  • Even more ideally EASA, after agreeing with them,
    should publish them following a rulemaking
    procedure and issue them as EASA AMC

  • NAA can not impose the use of their own AMC
  • NAAs must accept other means of compliance when
    they are the competent authority themselves,
    provided such means of compliance ensure full
    compliance with the applicable certification
  • It is the role of the EASA standardisation
    inspection system to monitor that the NAAs manage
    this process in a correct manner.

  • Translation of NAA AMC is an internal issue
    related to each national administrative order.

Fuel Tank Safety - Training
  • Possibility of doing differently
  • The legal status of an AMC
  • http//
  • will not result in changes to the Decisions
  • Aircraft affected, refer to EASA policy
  • this shall be added to the Decisions

Fuel Tank Safety - Training
  • Levels of training described in decisions
  • Level 1 Familiarisation training
  • Level 2 Detailed training
  • but in the letter
  • As training may be provided over a relatively
    long period, it should not be permitted that
    maintenance be carried out, or continued
    airworthiness be managed, on aircraft during the
    interim period by personnel having not been
    instructed on the nature and specificities of ALI
    and CDCCL related to Fuel Tank Safety. This is
    why the competent authorities should require that
    such personnel receive prior to any airworthiness
    management or maintenance action, a
    familiarisation course on these issues.
  • so, possible confusions between statements and

Fuel Tank Safety - Training
  • New training schematic for amending the
  • Short term familiarisation training
  • duration of the course 2 to 3 hours,
  • to be conducted as soon as the organisation is
    ready for providing the training, and preferably
    before maintenance actions or management of FTS
  • restricted to CAMO personnel directly involved in
    CA of FTS ALI and AMO maintenance personnel
    directly involved in maintenance of FTS ALI,
  • may be a self study course

Fuel Tank Safety - Training
  • New training schematic for amending the
  • Long term training course
  • level 1 basic training, syllabus to meet
    Decisions Appendixes
  • level 2 detailed training, syllabus to meet
    Decisions Appendixes
  • to be conducted when the organisation are ready,
  • restricted to all CAMO personnel involved in CA
    of FTS ALI and all AMO maintenance personnel
    involved in maintenance of FTS ALI
  • to be conducted in a training class

Fuel Tank Safety - Training
  • New training schematic for amending the
  • Continuation training on
  • level 1 basic training
  • level 2 detailed training
  • period to be set by CAMO and AMO
  • but not to exceed 2 years.

Fuel Tank Safety - Training
  • New training schematic for amending the
  • Short term familiarisation course Syllabus
  • to be provided by AEA
  • Long term basic and detailed courses to be set
    by organisations themselves but syllabus should
    meet the instructions in the Decisions.
  • No need of approval by authorities.

Fuel Tank Safety - Training
  • Next changes to Decisions
  • Modification of the Decisions to add
  • Aircraft affected
  • Presentation of this new training schematic
  • No approval of training courses
  • and to adapt the wording of Decisions to AMC

Fuel Tank Safety - Training
  • Other changes to regulatory documents
  • Modification of the Appendix I to Part-66 Basic
    knowledge requirements to add concept of Fuel
    Tanks Safety definition and limitations in
  • module 7 Maintenance practices,
  • and module 11A Turbine aeroplanes structures
    and systems
  • To be introduced at next change of Appendix I.

Fuel Tank Safety - Training
  • NAA views notes from the conference

Fuel Tank Safety - Training
  • Manufacturers views notes from the conference

Fuel Tank Safety - Training
  • AEA views notes from the conference

Fuel Tank Safety - Training
  • Conclusions notes from the conference
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