European Aviation Safety

Agency

Fuel Tank Safety Training

November 23, 2007
EASA presentation

FTS November 2007

 European Aviation Safety Agency

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.
 European Aviation Safety Agency

Fuel Tank Safety - Training

09.30 10.00 Welcome and Registration

10.00 10.15 Opening of the seminar and welcoming speech

Background
10.15 11.00 Legal status of decisions/ Summary of decision
Aircraft applicability / Short term / final
training
11.00 - 12.30 NAA views / Manufacturers Views / AEA views

12.30 13.30 Lunch time

15.00 15.15 Conclusions: revision to EASA documents

15.15 16.00 Questions and answers

16.00 Closure
European Aviation Safety Agency

Fuel Tank Safety

Background

23rd of November 2007

 European Aviation Safety Agency

EASA and fuel tank safety

Ignition prevention
Flammability reduction

Instruction for continued airworthiness

 European Aviation Safety Agency

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 2006).

FAA and JAA decided to launch design reviews to

identify any shortcomings in the transport aircraft
fleet.
 European Aviation Safety Agency

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.
 European Aviation Safety Agency

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 dormant.
Very close from critical part concept.
 European Aviation Safety Agency

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 authority).
 European Aviation Safety Agency

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.
 European Aviation Safety Agency

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.
 European Aviation Safety Agency

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 syllabi.
 European Aviation Safety Agency

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)
 European Aviation Safety Agency

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.
 European Aviation Safety Agency

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://www.easa.europa.eu/home/rg_agency_desc_main.html
 European Aviation Safety Agency

Fuel Tank Safety - Training

Typical questions raised further to publication of

decisions:
Which aircraft are affected?
Why they was no consultation on Annexes to
Decisions?
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 training.
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.
 European Aviation Safety Agency

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
 European Aviation Safety Agency

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.
 European Aviation Safety Agency

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
 European Aviation Safety Agency

EASA AMC (I)

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 it.
 European Aviation Safety Agency

EASA AMC (II)

EASA AMCs must be accepted by the

competent authorities if the applicant
decides to use them and implements them
correctly
 European Aviation Safety Agency

NAA AMC (I)

If a National Aviation Authority decides to issue

its own national AMCs, such AMCs only commit
itself.
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
 European Aviation Safety Agency

NAA AMC (II)

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 requirement.
It is the role of the EASA standardisation
inspection system to monitor that the NAAs
manage this process in a correct manner.
 European Aviation Safety Agency

NAA AMC (III)

Translation of NAA AMC is an internal

issue related to each national
administrative order.
 European Aviation Safety Agency

Fuel Tank Safety - Training

Possibility of doing differently:

The legal status of an AMC :

http://www.easa.europa.eu/home/r_faq_the5.html

will not result in changes to the Decisions;

Aircraft affected, refer to EASA policy statement:

this shall be added to the Decisions:
 European Aviation Safety Agency

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
courses.
 European Aviation Safety Agency

Fuel Tank Safety - Training

New training schematic for amending the Decisions:

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
ALI,
- 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;
 European Aviation Safety Agency

Fuel Tank Safety - Training

New training schematic for amending the Decisions:
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;
 European Aviation Safety Agency

Fuel Tank Safety - Training

New training schematic for amending the Decisions:

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.
 European Aviation Safety Agency

Fuel Tank Safety - Training

New training schematic for amending the Decisions:

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.

 European Aviation Safety Agency

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 status
 European Aviation Safety Agency

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.

 European Aviation Safety Agency

Fuel Tank Safety - Training

NAA views notes from the conference

 European Aviation Safety Agency

Fuel Tank Safety - Training

Manufacturers views notes from the

conference
 European Aviation Safety Agency

Fuel Tank Safety - Training

AEA views notes from the conference

 European Aviation Safety Agency

Fuel Tank Safety - Training

Conclusions notes from the conference