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Safety Recommendation Details

Safety Recommendation A-00-103
Details
Synopsis: .In this letter, the national transportation safety board recommends that the Federal Aviation Administration (FAA) take action to address the following safety issues: air carrier pilot training in landing techniques and bounced landing recovery, training tools and policies that promote proactive decision-making to go around if an approach is unstabilized, the use of on board computers to determine the required runway length for landing, md-11 handling characteristics and structural integrity requirements, and hard landing inspection requirements. The safety board identified these issues in its investigation of the 1997 accident involving Federal Express flight 14 in Newark, NJ. This letter summarizes the Board's rationale for issuing these recommendations
Recommendation: TO THE FEDERAL AVIATION ADMINISTRATION: Require manufacturers of 14 Code of Federal Regulations Part 23 and part 25 airplanes and Part 121 operators to revise their hard landing inspection and reporting criteria to account for all factors that can contribute to structural damage; instruct principal maintenance and operations inspectors assigned to Part 121 operators to ensure that these changes have been made to operator maintenance manuals and flight operations quality assurance exceedence monitoring programs.
Original recommendation transmittal letter: PDF
Overall Status: Closed - Acceptable Alternate Action
Mode: Aviation
Location: Newark, NJ, United States
Is Reiterated: No
Is Hazmat: No
Is NPRM: No
Accident #: DCA97MA055
Accident Reports: Crash During Landing Federal Express, Inc., McDonnell Douglas MD-11, N611FE
Report #: AAR-00-02
Accident Date: 7/31/1997
Issue Date: 8/25/2000
Date Closed: 9/16/2015
Addressee(s) and Addressee Status: FAA (Closed - Acceptable Alternate Action)
Keyword(s): Hard Landing

Safety Recommendation History
From: NTSB
To: FAA
Date: 9/16/2015
Response: We are pleased to learn that you have confirmed maintenance manuals for all Part 25 airplanes have been revised as necessary to include hard landing inspection and reporting criteria consistent with the recommendations that an industry working group developed as part of a Best Practices Guide. This action satisfies Safety Recommendation A-00-103 for Part 25 airplanes and Part 121 operators. Your review of numerous maintenance manuals for Part 23 airplanes and your finding that revisions to the hard landing inspection criteria is not warranted satisfy the recommendation in an acceptable alternate way for Part 23 airplanes. Accordingly, Safety Recommendation A-00-103 is classified CLOSED—ACCEPTABLE ALTERNATE ACTION.

From: FAA
To: NTSB
Date: 7/30/2015
Response: -From Michael P. Huerta, Administrator: The Federal Aviation Administration• s (FAA) evaluation of maintenance manuals is now complete, and we accepted the evaluations and changes made by each of the manufacturers we contacted. We believe that the manufacturers• review of their maintenance manuals, in light of the previously discussed working group recommendations and best practices guide (BPG), has resulted in significant improvements in these manuals. We note that reviewing and updating of maintenance manuals is a continual process by manufacturers and operators. Accordingly, these are also continually reviewed by the FAA. To support those reviews, all parties may use Advisory Circular (AC) 120-16F, Air Carrier Maintenance Programs, dated November 15, 20 12. This AC outlines the appropriate information that maintenance manuals should contain, including the unscheduled maintenance necessary following high load events. This AC follows the findings of the working group and the guidelines in the BPG. I believe that the FAA has effectively addressed these safety recommendations and consider our actions complete.

From: NTSB
To: FAA
Date: 11/20/2014
Response: We continue to believe that your review of maintenance manuals of numerous Part 23 airplanes, and your finding that these manuals are adequate, constitutes an acceptable alternate response to the recommendation as it concerns Part 23 airplanes. Pending completion of the maintenance manual evaluations of the current transport category airplane fleet as well, Safety Recommendation A-00-103 remains classified OPEN—ACCEPTABLE ALTERNATE RESPONSE.

From: FAA
To: NTSB
Date: 9/23/2014
Response: -From Michael P. Huerta, Administrator: As noted in our previous responses, the Federal Aviation Administration (FAA) convened a working group to review maintenance manual inspection processes and develop a standard for the utilization of flight data in these processes. The result was Aerospace Industries Association Publication 05-01 , "Best Practices Guide - Inspection Processes following High Load Events," dated September 1, 2005. While this guide is aimed at new airplanes, the working group also developed four recommendations for the current fleet (previously provided). We asked transport category airplane manufacturers to evaluate their maintenance manuals relative to these four recommendations. We have received several responses and are awaiting information from one large transport category airplane manufacturer. We expect to have all the responses by October 31, 2014. These maintenance manual evaluations will result in improved aircraft maintenance manuals for in-service airplanes, which will address A-00-1 03 and A-03-41. I will keep the Board informed of the FAA's progress on these recommendations and provide an update by August 31, 2015.

From: NTSB
To: FAA
Date: 2/11/2013
Response: In its current letter, the FAA responded to two questions we have previously asked about the FAA’s response to this recommendation: (1) Were the evaluations of transport category AMMs [aircraft maintenance manuals] that were being conducted specifically considering hard landing inspection and reporting criteria? (2) Would inspection criteria following hard landings for Part 23 airplanes be developed, given that few Part 23 airplanes have the FDR capabilities typically found on Part 25 airplanes? With regard to the first question, regarding the current fleet, the FAA replied that the evaluations are based on the four recommendations of the BPG for current aircraft, described above in response to Safety Recommendation A-03-41. The four recommendations do not specifically refer to hard landings, but cover all high load events, including hard landings. The FAA believes that the first of the BPG’s recommendations (to ensure that the inspection processes for all high load events are adequate) includes hard landings. With regard to the second question, the FAA reiterated that the actions it has been taking for transport category airplanes would not be appropriate for Part 23 airplanes, given their more limited capability for recording flight data. The FAA does not believe that additional criteria are needed for small airplanes, based on a survey that it conducted of the maintenance manuals of numerous small airplane models. The FAA considers these manuals to be adequate and believes that requiring revisions to the hard landing inspection criteria in these manuals is not warranted. We have considered the information the FAA provided and agree that the first of the BPG’s recommendations for evaluations of current airplane maintenance manuals addresses hard landing criteria as one of the high load events that must be considered. We also agree with the FAA that, in view of the more limited flight data recording capability of Part 23 airplanes, the actions being taken for transport category airplanes are not appropriate. The review conducted by the FAA of the maintenance manuals of numerous Part 23 airplanes, and its finding that these manuals are adequate, constitutes an acceptable alternate response to the part of this recommendation concerning Part 23 airplanes. Pending completion of the maintenance manual evaluations of the current transport category airplane fleet, Safety Recommendation A-00-103 is classified OPEN—ACCEPTABLE ALTERNATE RESPONSE.

From: FAA
To: NTSB
Date: 11/8/2012
Response: -Michael P. Huerta, Acting Administrator: We note that the Board previously classified this recommendation as "Open-Acceptable" but raised some concerns. First, the Board is concerned about the extent to which the BPG addresses hard landings. 'The Board asked the FAA to clarify that the maintenance manual evaluations of the current fleet will consider hard landing inspection and reporting criteria. The maintenance manual evaluations of the current fleet are based on the four working group recommendations, which do not specifically refer to hard landings. The evaluations are comprehensive and cover all high load events, including hard landings. All maintenance manuals currently include hard landings as an event requiring follow-on inspections. The first of the working group recommendations is to ensure that the inspection processes for all high load events, including hard landings, are adequate. The BPG states that hard landing declarations are normally initiated by the flight crew, although it is also common for accelerometer data to be examined and used to confirm that a hard landing has in fact occurred. Additional objective criteria, in some cases based on multiple data parameters, could be established by the manufacturers and incorporated into the AMM to improve confidence that high landing load events will be identified, and to provide additional information on the level of load experienced. These criteria would consider one or more of the following factors: • Sideload; • Aerodynamic lift; • Landing Weight; or • Un-symmetrical Load Distribution. Another concern raised by the Board relates to part 23 airplanes. The FAA previously stated that our actions are focused on transport category airplanes, and that the same actions would not be appropriate on part 23 airplanes, given their more limited flight data recording capability. The Board acknowledges that many part 23 airplanes have less flight data recording capability, but believes that the FAA should consider what criteria should be used for airplanes with limited or no such capability. We do not believe that additional criteria are needed for a pilot of a small airplane to realize that a hard landing has occurred, and to report it. Where available, FDR data can be used to verify that a hard landing has occurred and to provide additional information for the inspection. The FAA surveyed the maintenance manuals of numerous small airplane models. We consider these manuals to be adequate and believe that requiring revisions to the hard landing inspection criteria in these manuals is not warranted. Manufacturers of recently type certificated small airplanes have adopted industry best practices for maintenance manuals (Air Transport Association (ATA) iSpec 2200: Information Standards for Aviation Maintenance, and Associated Standards). These standards include inspections for unusual flight and ground events. Service history of hard landings on the small airplane fleet does not indicate unsafe conditions that would justify an industry-wide mandate to update aircraft maintenance manuals. As noted in this response, maintenance manual evaluations of the current transport fleet are ongoing. I will keep the Board informed of the FAA's progress on Safety Recommendation A-00-103 and provide an update by June 2013.

From: NTSB
To: FAA
Date: 4/6/2011
Response: In its December 3, 2007, letter, the FAA stated that it would ask manufacturers and type certificate holders of transport-category airplanes to conduct a comprehensive review of their current AMMs, including inspections specified for a hard landing. In replying on May 2, 2008, the NTSB stated that we assumed this would be part of the same review being conducted in response to Safety Recommendation A-03-41. Although this review was responsive to the recommendation, we were concerned that the BPG working group report had stated that “the BPG does not provide specific recommendations on which data parameters should be used for evaluating the severity of a hard landing.” The NTSB asked the FAA to clarify that the review would consider hard landing inspection and reporting criteria. The FAA also indicated in its December 3, 2007, letter that its work in response to this recommendation had focused on transport-category airplanes only and that it did not believe that the same actions would be appropriate for Part 23 airplanes because they are more limited in their FDR capability. In our May 2, 2008, response, we acknowledged that many Part 23 airplanes either do not have an FDR or the FDR’s capabilities are more limited than those of FDRs found on Part 25 airplanes. Although use of FDR data is an excellent way to determine whether an airplane has experienced a hard landing that causes structural concerns, the NTSB believed that the FAA needed to consider what criteria should be used for airplanes without an FDR. In its current letter, the FAA indicated that transport category aircraft manufacturers and type certificate holders have either completed or are in the process of reviewing their AMMs for existing airplanes. The FAA did not respond to the two concerns that we described in our previous letter. Although the reviews of transport category aircraft AMMs are responsive to this recommendation, they will not be fully responsive unless the FAA (1) specifically states that the reviews considered hard landing inspection and reporting criteria and (2) provides inspection criteria for Part 23 airplanes following hard landings. Pending completion of those actions, Safety Recommendation A-00-103 remains classified OPEN – ACCEPTABLE RESPONSE.

From: FAA
To: NTSB
Date: 1/20/2011
Response: CC# 201100038: - From J. Randolph Babbitt, Administrator: As discussed in our December 3, 2007 letter, we have asked certain transport category airplane manufacturers to evaluate their maintenance manuals against the recommendations put together by the Best Practices Guide Working Group. These maintenance manual evaluations are now being conducted. The FAA asked Airbus, Aerospatiale, BAE, Boeing, Bombardier, Cessna, Dassault, Embraer, Gulfstream, Learjet, Raytheon, and Saab to evaluate their maintenance manuals for each transport category airplane they manufacture or hold the type certificate on, if there is an active fleet size greater than 100 or the aircraft is currently in production. Some of the manufacturers have completed the evaluations. We expect these evaluations, and the FAA review, to be completed by May 2011. We would like to clarify the objective of our maintenance manual reviews. We are not asking manufacturers to ensure that existing maintenance manuals be updated to meet the processes outlined in the Best Practices Guide. The Best Practices Guide is aimed at new airplane programs. The working group that developed the Best Practices Guide for new airplanes also developed four recommendations for the existing fleet. We are asking manufacturers to evaluate their manuals to these four recommendations, which are as follows: 1. Ensure that Phase I inspections are adequate to detect damage or to indicate properly the need for Phase 2 inspections, following a high load event. The inspections specified in current maintenance manuals generally follow a two-phase approach. Phase 1 inspections, which are more external in nature, are intended to indicate whether the more detailed Phase 2 inspections are necessary. This process relies heavily on the adequacy of the Phase 1 inspection, especially if there is no data review included in the process. Therefore, in lieu of adding data review to the process, the Phase 1 inspections should be made sufficiently robust and comprehensive to ensure that these inspections either detect damage to the airplane, or indicate the need for Phase 2 inspections. For example, in some cases, it may be appropriate to move some of the more thorough inspections from Phase 2 to Phase 1. 2. Ensure that the inspection process used for composite structure includes data review wherever damage could otherwise go undetected by a practical Phase I inspection. Hidden damage within composite structure may not always be apparent through external inspections, and so the traditional two phase inspection process used for aluminum structure may be inadequate. Therefore, when some damage can go undetected by a practical Phase I inspection, some level of data review should be included in the inspection process, depending upon the airplane's data recording and downloading capability. If this capability exists, then it should be utilized as outlined in the Best Practices Guide. 3. Ensure that inspection procedures are included for severe turbulence and extreme in-flight maneuvers that result in positive and negative vertical accelerations, as well as lateral accelerations. 4. Ensure that inspection procedures are included for occurrences of rapidly alternating control inputs that could result in locally significant loads even if the primary thresholds for aircraft center of gravity acceleration are not exceeded. In the FAA's December 2007 letter, we stated that current reporting requirements are adequate to address the concerns raised by the Board in Safety Recommendations A-03-43 and -44. In a May 2, 2008 letter the Board asked the FAA to reconsider. We will reconsider our position as part of the maintenance manual review noted above. I will keep the Board informed of the FAA's progress on these recommendations and provide an updated response by December 2011.

From: NTSB
To: FAA
Date: 5/2/2008
Response: The FAA stated that it would ask manufacturers and type certificate holders of transport-category airplanes to conduct a comprehensive review of their current AMMs, including inspections specified for a hard landing. The Safety Board assumes this will be part of the same review being conducted in response to Safety Recommendation A-03-41. This planned review is responsive to the recommendation; however, the Board is concerned that the working group report stated that the BPG does not provide specific recommendations on which data parameters should be used for evaluating the severity of a hard landing. The Board asks the FAA to clarify that the review will consider hard landing inspection and reporting criteria. The FAA indicated that its work in response to this recommendation focused on transport-category airplanes and that it does not believe that the same actions would be appropriate on Part 23 airplanes. The FAA stated that because Part 23 airplanes are more limited in their FDR capability, it would not be possible, in many cases, to use FDR readouts as part of the hard landing inspection and reporting criteria. The Safety Board acknowledges that many Part 23 airplanes either do not have an FDR or the FDR’s capabilities are more limited than those of FDRs found on Part 25 airplanes. Although use of FDR data is an excellent way to determine whether an airplane has experienced a hard landing that causes structural concerns, the FAA needs to consider what criteria should be used for airplanes without an FDR. To fully address this recommendation, the FAA will need to review and possibly revise the hard landing inspection and reporting criteria to account for all factors that can contribute to structural damage for Part 23 airplanes. Pending completion of the review being conducted in response to A-03-41, inclusion of hard landing criteria in this review, and a review and revision of the hard landing inspection and reporting criteria for Part 23 airplanes, Safety Recommendation A-00-103 remains classified OPEN -- ACCEPTABLE RESPONSE.

From: FAA
To: NTSB
Date: 12/3/2007
Response: Letter Mail Controlled 1/2/2008 8:27:33 AM MC# 2070725: - From Robert A. Sturgell, Acting Administrator: We agree with the overall objective of these recommendations, which is to ensure that no airplane is returned to service with undetected damage following a high load event. Implementation of these recommendations as written would drive a strategy that includes the following main concepts: 1.Manufacturers would establish explicit criteria for high load events that are based on g- loads; 2.The operators would have a means to determine if any given flight has experienced the g-loads identified by the manufacturer. This approach would replace the current practice of reliance on pilot subjective identification of high load events; and 3.For any airplane that had experienced these high loads, the airplane would be held on the ground until it is fully inspected and a loads analysis performed by the manufacturer to ensure there is no hidden structural damage prior to return to service. Explicit and practical (e.g., measurable with current data recording systems) high load event criteria would need to be established for each airplane by manufacturers. Implementation of this strategy across the fleet poses significant challenges, such as: ·Manufacturers would need to design alerting systems that would notify the pilot and/or maintenance that a high load event had occurred (using criteria developed by manufacturers), so that inspections or other analysis would be initiated only for those flights that had experienced a high load event. In order to retrofit such systems into the existing fleet, the FAA would have to determine the existence of an unsafe condition and issue an Airworthiness Directive; ·Without an alerting system, g-load data would have to be downloaded and reviewed from every airplane after every flight; ·Only more recent models have quick access recorders to facilitate the data download; ·It would be undesirable to remove and replace flight data recorders after every flight; ·Even if quick access recorders are available, requiring download and review would likely cause significant delays, nearly all of which would be for airplanes that had not experienced a high load event or suffered any damage; and ·A requirement for a loads analysis, performed by the manufacturer, for each high load event would likely ground airplanes for extended periods of time, even in cases where inspections found no evidence of damage. While we agree with the objective of the recommendations, we don’t believe that rulemaking is the best option at this time. We believe that by working with industry, we can achieve these objectives without rulemaking. We asked the Aerospace Industries Association and the Air Transport Association to convene a working group to review current maintenance manual inspection processes for high load events and to develop an advisory best practices standard for the utilization of flight data in these processes. That group developed the Best Practices Guide - Inspection Processes Following High Load Events, and a working group report. Copies of both documents are enclosed. The Best Practices Guide (BPG) outlines a process that can be implemented within the current framework of regulations and industry practice. It also recognizes the practical limitations and demands of day-to-day operations, as well as the operators’ ability to perform inspections and to make the return-to-service decision. The BPG focuses on new transport category airplanes whose data systems can be designed to meet the BPG recommendations in terms of increased capability and integration with maintenance actions. Much of the current fleet, whose flight data recorders have limited capability depending on the size of airplane and date of manufacture, do not have adequate systems to fully incorporate the BPG recommended process regarding the review of flight data. The BPG outlines recommended inspection processes following certain high load events. This document also recommends increased use of flight data to determine the severity of these events and recommends a process for manufacturer review of flight data for those few events nearing ultimate load (and exceeding the high thresholds). The BPG would be used by airplane manufacturers when developing maintenance manuals or by operators when adapting those manuals for their operation. While the recommendations made in the BPG are intended for use in the development of maintenance manuals on future transport category airplane programs, manufacturers and operators may use portions of this document to enhance their existing maintenance manuals. The FAA will inform all affected operators and manufacturers of the availability of the BPG. The FAA also plans to reference the BPG and include its key provisions in a revision to Advisory Circular 120-16D, “Air Carrier Maintenance Programs. We plan to work with each manufacturer to ensure that the BPG recommendations are met and then to re-evaluate our overall response to the Board recommendations. We expect the manufacturer evaluation to be completed within 1 year, and to provide our next response within 6 months of its completion. With regard to the specific recommendations we have the following comments. The BPG is primarily aimed at the development of maintenance manuals on future airplane models. For the current fleet, the FAA plans to ask manufacturers and TC holders of transport category airplanes to conduct a comprehensive review of their current maintenance manuals. This review will include those inspections specified for a hard landing. We expect to complete this evaluation within one year. The FAA action, the BPG, and the working group report focus on transport category airplanes. We do not believe that the same actions would be appropriate on Part 23 airplanes, given their more limited flight data recording capability and their current FAA operational requirements.

From: NTSB
To: FAA
Date: 1/12/2005
Response: On November 20, 2003, the FAA indicated that it would work with industry to develop a plan to address issues such as pilot reporting, operations manuals, maintenance manuals, flight data recorder capabilities, and operator/manufacturer/authority interface. The FAA now reports that it asked the Aerospace Industries Association (AIA) and the Air Transport Association (ATA) to convene a working group to review current maintenance manual inspection processes for high load events and to develop an advisory "best practices" standard for using flight data in these processes. The FAA further states that AIA and ATA have agreed to charter this working group and are in the process of identifying participants and developing a meeting schedule. The FAA anticipates that this effort should be completed within 1 year. The creation of this industry group and its consideration of the issues in these recommendations is responsive. The Safety Board would appreciate the opportunity to review the resulting report and recommendations of this group. Pending the results of the AIA/ATA working group and appropriate FAA actions in response to the recommendations, Safety Recommendations A-03-41, -42, and -44 remain classified "Open--Acceptable Response," and Safety Recommendation A-00-103 is classified OPEN -- ACCEPTABLE RESPONSE.

From: FAA
To: NTSB
Date: 8/23/2004
Response: Letter Mail Controlled 9/2/2004 11:27:15 AM MC# 2040536 - From Marion C. Blakey, Administrator: On November 20,2003, the Federal Aviation Administration (FAA) informed the Board that it would work in partnership with industry to address these safety recommendations. Subsequently, the FAA has asked Aerospace Industries Association (AIA) and the Air Transport Association (ATA) to convene a working group to review current maintenance manual inspection processes for high load events and to develop an advisory "best practices" standard for using flight data in these processes. The AIA and ATA have agreed to charter this working group and are in the process of identifying participants and developing a meeting schedule. It is anticipated that the working group activity will be completed within one year from commencement. I will inform the Board of the outcome of the working group's effort upon completion.

From: NTSB
To: FAA
Date: 7/29/2002
Response: The Safety Board issued this recommendation based on its concern that neither the subjective criteria used by pilots to determine a hard landing nor the data evaluated by operators adequately address the potential for aircraft damage to escape reporting and notice by maintenance procedures. Although the Board understands the FAA's position on the importance of pilot reports to determine whether a hard landing has occurred, it remains the Safety Board's belief that reliable identification of structural damage after hard landings would be well served if the FAA required manufacturers to publish scientific criteria that operators can use to help recognize when a hard landing occurs. Boeing's submission to the Safety Board at the conclusion of the investigation of the FedEx MD-11 accident in Newark, New Jersey, contained two suggestions relevant to this recommendation: · Manufacturers should revise their Maintenance Manual (MM) hard landing definition and inspection criteria to include information on the effects of reduced lift and adverse aircraft attitude on loads into the landing gear. Data developed during the FedEx Newark investigation shows that the absolute recorded vertical acceleration during landing is not the only criterion for determining if a hard landing has occurred. The recorded vertical acceleration at the beginning of touchdown can also be very important. Specifically, if the recorded vertical acceleration at the beginning of the landing is less than 1.0 g, then aircraft weight that is normally accommodated by 1.0g wing lift is instead transmitted into the landing gear in addition to the loads required to decelerate the airplane vertically to oppose the sink rate. The effects of non-routine pitch and roll attitudes on energy introduced into a singular landing gear should also be part of a hard landing evaluation. For example, nose landing gear first firm landings, or firm landings in a significant wing down roll attitude, or with a rapid roll rate may warrant a hard landing inspection if most of the landing energy absorption is accomplished by one landing gear. Boeing is in the process of revising the MD-11 MM to incorporate this type of information. · Operators should be made aware of issues discussed in this recommendation so that they can more thoroughly evaluate the severity of a hard landing from available data. The Safety Board continues to believe that Safety Recommendation A-00-103 is both valid and important to the overall safety of commercial aviation. The Board does not concur with the FAA's conclusion regarding hard landing inspection criteria and asks the FAA to reconsider its position. Pending completion of the recommended action, Safety Recommendation A-00-103 is classified OPEN -- UNACCEPTABLE RESPONSE.

From: FAA
To: NTSB
Date: 11/13/2001
Response: Letter Mail Controlled 11/19/2001 10:56:51 AM MC# 2010909: - From Jane F. Garvey, Administrator: The FAA has completed a preliminary evaluation of existing hard landing inspection and reporting criteria to determine if the inclusion of pertinent airplane flight data, other than sink rate, is needed. The findings of the evaluation are as follows: Hard Landing Reporting: There is no regulation that specifically addresses the reporting of hard landings. However, Advisory Circular (AC) 120-16C provides information on continued airworthiness maintenance programs for operators subject to 14 CFR Parts 121 and 135. The AC includes the following information: Unscheduled Maintenance. This element provides procedures, instructions, and standards for the accomplishment of maintenance tasks generated by the inspection and scheduled maintenance elements, pilot reports, failure analyses, or other indications of a need for maintenance. Procedures for reporting, recording, and processing inspection findings, operational malfunctions, or abnormal operations like hard landings are essential parts of this element. The reporting guidance in the AC applies not only to hard landings but also to any other event that might affect the airworthiness of the airplane, like overweight landings, flight through severe turbulence, bird strike, etc. The FAA is not aware of any major problems in the area of pilot reporting, and FAA guidance adequately describes pilot reporting as an essential element of an operator's maintenance program. Therefore, the FAA does not believe that any further action is necessary in this regard. Hard Landing Inspection Criteria: Certain structural and other inspections are necessary in the event of a hard landing (or severe turbulence, bird strike, etc.). Inclusion of these unscheduled maintenance procedures in an operator's maintenance program is the operator's responsibility as outlined in AC 120-16C. Operators normally use the procedures that are developed by the manufacturer and included in the aircraft maintenance manual. Most maintenance manuals indicate the need for inspections based solely on a pilot report that a hard landing has occurred. Some maintenance manuals, like that of the MD-11, include procedures for further analysis of the landing using sink rate and/or vertical acceleration obtained from the flight data recorder. Still others have systems in place that automatically detect a hard landing and provide a fault message indicating the need for maintenance action. The Board is concerned that, regardless of the means by which an inspection is deemed necessary, all of the factors that could contribute to structural failure may not be considered, and thus certain structural failures may go undetected. In the case of maintenance manuals that indicate the need for inspections based solely on a pilot report, the Board is concerned that a superficial exterior inspection by flightcrew or maintenance personnel might indicate that no further inspection is necessary when, in fact, structural damage may have occurred. In the case of maintenance manuals that employ flight data recorder data to determine the need for inspection or for airplanes for which an inspection is determined automatically, the Board is concerned that, in addition to sink rate and/or vertical acceleration, other factors like roll rate, pitch rate, and airplane attitude should also be considered in this determination. The FAA has evaluated the Board's concerns and concluded that current aircraft maintenance manuals adequately define both the need for inspections and the actual inspections following a hard landing. Whether these inspections are precipitated by a pilot report or by a pilot report supplemented by additional data, the critical step in the process is the pilot report. Provided that the pilot report is made properly, there is no evidence to suggest that the actions outlined in existing maintenance manuals have allowed structural failures to go undetected. Furthermore, in the event of a hard landing significant enough to cause structural failure, the pilot will certainly know that a hard landing has occurred. That is, no additional information, whether flight data recorder data or other, would be necessary in order for a pilot to make this determination. Consequently, the FAA does not believe any further action is necessary with regard to hard landing inspection criteria. I believe that the FAA has addressed the full intent of this safety recommendation, and I consider the FAA's action to be completed.

From: NTSB
To: FAA
Date: 6/13/2001
Response: Pending notice of the FAA's plans to revise existing hard landing inspection and reporting criteria, Safety Recommendation A-00-103 is classified OPEN -- ACCEPTABLE RESPONSE.

From: FAA
To: NTSB
Date: 11/13/2000
Response: Letter Mail Controlled 11/15/2000 3:27:59 PM MC# 2001695 - From Jane F. Garvey, Administrator: The FAA plans to evaluate the existing hard landing inspection and reporting criteria to determine if the inclusion of pertinent airplane flight data, other than sink rate, is needed. In addition, the FAA plans to monitor the activity of the Loss of Control JSAT formed under the Safer Skies Safety Initiative to determine if the interventions and eventual implementation plans will address the concerns raised by the Board. It is anticipated that this effort will be completed by April 2001. I will inform the Board of the FAA's course of action as soon as the evaluation is completed.