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Safety Recommendation Details

Safety Recommendation A-00-108
Details
Synopsis: On 7/17/96, about 2031 eastern daylight time, Trans World Airlines, Inc. (TWA) Flight 800, a Boeing 747-131, N93119, crashed into the Atlantic Ocean near East Moriches, New York. TWA Flight 800 was operating under the provisions of 14 Code of Federal Regulations (CFR) Part 121 as a scheduled international passenger flight from John F. Kennedy International Airport (JFK), New York, NY, to Charles de Gaulle International Airport, Paris, France. The flight departed JFK about 2019, with 2 pilots, 2 flight engineers, 14 flight attendants, and 212 passengers on board. All 230 people on board were killed, and the airplane was destroyed. Visual meteorological conditions prevailed for the flight, which operated on an instrument flight rules flight plan.
Recommendation: TO THE FEDERAL AVIATION ADMINISTRATION: Regardless of the scope of the aging transport systems rulemaking advisory committee's eventual recommendations, address (through rulemaking or other means) all of the issues identified in the aging transport non-structural systems plan, including: the need for improved training of maintenance personnel to ensure adequate recognition and repair of potentially unsafe wiring conditions; the need for improved documentation and reporting of potentially unsafe electrical wiring conditions; and the need to incorporate the use of new technology, such as arc-fault circuit breakers and automated wire test equipment. To determine whether adequate progress is being made in these areas, the Safety Board believes that, within 90 days, the FAA should brief the Safety Board on the status of its efforts to address all of the issues identified in the aging transport non-structural systems plan.
Original recommendation transmittal letter: PDF
Overall Status: Closed - Acceptable Action
Mode: Aviation
Location: EAST MORICHES, NY, United States
Is Reiterated: No
Is Hazmat: No
Is NPRM: No
Accident #: DCA96MA070
Accident Reports: In-flight Breakup Over the Atlantic Ocean Trans World Airlines Flight 800, Boeing 747-141, N93119
Report #: AAR-00-03
Accident Date: 7/17/1996
Issue Date: 9/19/2000
Date Closed: 1/13/2011
Addressee(s) and Addressee Status: FAA (Closed - Acceptable Action)
Keyword(s): Maintenance, Records, Rulemaking, Training and Education, Wiring

Safety Recommendation History
From: NTSB
To: FAA
Date: 1/13/2011
Response: The NTSB reviewed the list of completed actions that the FAA described, including issuance of the Enhanced Airworthiness Program for Airplane Systems/Fuel Tank Safety final rule, which was published on November 8, 2007; requirements implemented regarding wiring maintenance for newly type certificated and existing airplanes; and a variety of ACs concerning training for personnel who maintain electrical and wiring systems on airplanes. Although the NTSB believes that the FAA should continue to fund research into ongoing wire problems and potential technical means to address wire-related problems, the actions described meet the intent of Safety Recommendations A-00-106 and A-00-108, which are classified CLOSED -- ACCEPTABLE ACTION.

From: FAA
To: NTSB
Date: 7/27/2010
Response: Letter Mail Controlled 8/9/2010 11:09:24 AM MC# 2100271 - From J. Randolph Babbitt, Administrator: The FAA completed the following actions to ensure the safety of wiring systems and to reduce the chance of an in-flight fuel-tank explosion on transport category airplanes: On October 22, 2007 we issued a final rulemaking package entitled the Enhanced Airworthiness Program for Airplane Systems/Fuel Tank Safety (EAPAS/FTS). The rule was published in the Federal Register on November 8, 2007 and became effective on December 10, 2007. This final rule introduced new maintenance, inspection, and design criteria for airplane wiring to address conditions that put transport airplanes at risk of wire failures, smoke, and fire. (enclosure 8) We added requirements for DAHs to develop maintenance and inspection requirements for the airplane wiring system. The DAH analyzes the zones of their airplanes for the presence of wire and for the likely accumulation of contaminant materials. The requirements are contained in section (25.1729) applicable to new type certificate and supplemental type certificate applicants, and in a new 14 CFR part 26, applicable to existing transport category airplanes. These rules require applicants to develop maintenance and inspection tasks to identify, correct, and prevent wiring conditions that introduce risk to continued safe flight. These tasks are required to be included in new lCAs for wiring and be compatible with ICAs for fuel tank systems. We also amended 14 CFR parts 91, 121, 125, and 129 operating rules to require operators to incorporate maintenance and inspection tasks for wiring into their regular maintenance programs and clarified existing requirements for fuel tanks. We updated 14 CFR part 25, subpart H to contain the majority of the certification requirements for airplane wiring systems, including new rules to improve safety in manufacture and modification. Many of the rules contained in subpart H are previously existing requirements moved from different parts of the regulations. Some areas were reworded to make it clear as it applies to wiring systems. Several of the rules in subpart H are recent. The rules in subpart H are meant to improve the safety of transport airplane wiring by ensuring a safe design. We issued guidance materials in the form of ACs that present one way, but not the only way, to comply with specific parts of these regulations. AC 120-94 presents a suggested curriculum for EWIS training. Existing § 121.375 required that certificate holders or anyone performing maintenance have a training program. This requirement ensures that anyone determining the adequacy of maintenance work (including inspectors) is fully informed about the procedures and techniques involved and is competent to perform them. AC 120-94 provides guidance for complying with § 121.375 as it applies to EWIS maintenance and inspection. In AC 120-94, we provide a suggested training program to address people who come in contact with airplane EWIS, and encouraged operators to include this training voluntarily. There are eleven other ACs associated with the EAPAS/FTS rule as guidance on different requirements contained in the rulemaking package. In all, the EAPAS/FTS rulemaking package contains over 70 new, revised, or renumbered regulations in 14 CFR parts 1,21,25,26,91, 121, 125, and 129. This comprehensive set of design, maintenance, and inspection requirements works in harmony to ensure the safety of transport category airplanes wiring systems, both in the existing and future fleets. I believe that the FAA has effectively addressed these safety recommendations, and I consider our actions complete.

From: NTSB
To: FAA
Date: 2/16/2006
Response: Notation 6788M: The National Transportation Safety Board has reviewed the Federal Aviation Administration’s (FAA) notice of proposed rulemaking (NPRM), “Enhanced Airworthiness Program for Airplane Systems/Fuel Tank Safety (EAPAS/FTS),” which was published in 70 Federal Register 58507 on October 6, 2005. The notice includes proposed regulatory changes to improve the design, installation, and maintenance of electrical wiring interconnection systems (EWIS) installed on transport-category airplanes to ensure their continued operational safety. The NPRM is in response to findings and recommendations that resulted from the Safety Board’s investigation of the July 17, 1996, accident involving Trans World Airlines, Inc., (TWA) flight 800, a Boeing 747-131, as well as the Board’s previous and subsequent investigations of electrical wiring system-related accidents and incidents. In January 1998, the Board examined more than two dozen transport-category airplanes, which ranged in age from new to retired, and documented numerous electrical wiring system hazards that demonstrated the widespread nature of these problems. The Board also assisted the Transportation Safety Board of Canada (TSB) with its investigation of the September 2, 1998, accident involving SwissAir flight 111, a McDonnell Douglas MD-11, which resulted in additional findings and TSB recommendations pertaining to aging systems and electrical wiring systems. The FAA participated in the Safety Board’s investigations and conducted airplane examinations similar to those conducted by the Board, which led to the development of the Aging Transport Nonstructural Systems Plan (ATNSP). Following release of the plan, on January 19, 1999, the FAA chartered an industry-led group called the Aging Transport Systems Rulemaking Advisory Committee (ATSRAC). ATSRAC further researched the extent of EWIS-related problems throughout the industry’s transport-category airplane fleet and proposed changes to the plan to the FAA. The Board notes that the NPRM’s proposed regulatory and guidance changes are quite similar to numerous ATSRAC proposals. The Safety Board has recommended changes to correct each of the problem issues identified in the ATNSP. Specifically, on September 19, 2000, the Board issued Safety Recommendation A-00-108, which asked the FAA to do, in part, the following: Regardless of the scope of the [ATSRAC’s] eventual recommendations, address (through rulemaking or other means) all of the issues identified in the [ATNSP], including: • the need for improved training of maintenance personnel to ensure adequate recognition and repair of potentially unsafe wiring conditions; • the need for improved documentation and reporting of potentially unsafe electrical wiring conditions; and • the need to incorporate the use of new technology, such as arc-fault circuit breakers and automated wire test equipment. Although the Safety Board believes the adoption of the NPRM would improve the safety of the transport-category airplane fleet, the Board is concerned that the NPRM still does not adequately address all of the individual deficiencies identified by the ATNSP and Safety Recommendation A-00-108. The Board therefore believes the NPRM must be amended to address these additional issues to achieve the appropriate level of safety that the Board has recommended. Maintenance Personnel Training The NPRM discusses the need for EWIS-related training of maintenance personnel. The Safety Board commends the FAA for proposing a definition of the components that constitute the EWIS, for recognizing the industry movement toward electronic documentation, and for proposing guidelines to adequately address EWIS maintenance and inspection issues. The NPRM, however, provides only guidance and recommendations for operators to implement; it does not propose mandatory training. Further, even though the FAA and ATSRAC members have recognized that, historically, most wiring system damage observed in transport-category airplanes was the result of inadvertent contamination and/or damage incurred during unrelated maintenance, the NPRM does not thoroughly address this problem. The NPRM refers repeatedly to the need for improved training for maintenance technicians who directly handle EWIS components, but it fails to recognize that such training should apply to all maintenance personnel and not just EWIS technicians. Since non-EWIS maintenance actions often compromise the safety of the EWIS, the Board continues to believe that the training of all maintenance personnel on EWIS maintenance and inspection is critical. The Board believes the NPRM must be amended to specifically state that all maintenance personnel must receive EWIS training and that such training must be made mandatory. Data Collection and Reporting The Board’s recommendation also called for improved reporting of potentially unsafe electrical wiring conditions, which the NPRM does not address. Although the NPRM clearly holds manufacturers and operators responsible for the proper maintenance and inspection of EWIS, there can be no quantitative measurement of how well the maintenance and inspection system is performing without an effective mechanism to collect basic data, examine the findings, and provide reporting about performance. Industry does not have a sufficient data collection and retrieval system in place that would enable the FAA to ensure that its proposed regulatory actions are effective. In fact, a review of ATSRAC records revealed the extensive difficulties that the industry-led group encountered in its attempt to quantify existing problems in EWIS maintenance. The feedback mechanisms currently in place are the FAA’s Service Difficulty Reporting System (SDRS) and the Continued Airworthiness Surveillance System (CASS) requirement for operators. The Safety Board’s report on the TWA flight 800 accident discussed how the Board, the FAA, and industry have all found that the SDRS was ineffective. Although industry established a unique subcode to identify EWIS problems in service difficulty reports, the use of the subcode has been blunted because of the FAA’s failure to revise the SDRS. Although the Safety Board has supported the FAA’s two previous NPRMs to revise and improve the SDRS, the FAA has withdrawn both NPRMs. Even though CASS has been effective in compiling and organizing data, CASS data are not typically accessible outside of the individual FAA-operator relationships; researching the data requires sending queries to each individual program and then manually integrating the results. Although the FAA has been attentive to operators’ concerns about public access to internal data, the existing method of researching service problems is unsatisfactory. Restricted access to existing data, as well as the inability to effectively search available data, inhibits research into recurring or potential problems that may exist across operators; such research is an important tool in the prevention of accidents and incidents. The Board strongly encourages the FAA to amend the NPRM to address this critical issue and revise the SDRS, regardless of any potential industry opposition. Nonvisual Inspection Techniques With regard to the need to incorporate the use of new technology, both the Safety Board and ATSRAC have recommended that the FAA identify and implement technologies that continue to enhance airworthiness of aircraft systems. Although the Enhanced Zonal Analysis Procedure (EZAP) described in the NPRM would provide for a specific visual inspection of the EWIS within the specified general inspection zones, it does not call for the maximum possible use of new technologies and nondestructive test equipment. In situations in which general visual inspections of the EWIS may not be sufficient, the NPRM only calls for the development of detailed visual inspections and simply allows for the use of nonvisual inspection techniques. The need for nonvisual techniques, however, was demonstrated by FAA and industry tests that showed that visual inspection methods failed to detect more than half of breaches in electrical insulation for accessible wiring, and the results were even worse for the examination of wires that were routed through conduits, within wire bundles, or in other concealed areas. Moreover, visual methods were found to be inadequate for the identification of insulation degradation or embrittlement, which could lead to short circuits. The Safety Board recognizes that the development and implementation of new nonvisual inspection technology, such as the widespread use of automated wire test equipment, will enhance safety as the technology itself continues to mature. The Board notes that some operators have already successfully implemented automated wire inspection techniques in certain applications, such as braking systems, in which an EWIS failure would pose a significant cost impact to the operator. Further, the electrical industry has created new methods of packaging arc-fault detection into circuit breakers, and a limited number of applications have been implemented in non-essential systems, such as galley equipment, which allow for the collection of in-service data. The NPRM provides an opportunity for the FAA to expand the use of new inspection technology. While the benefits of these technologies have been demonstrated, further research and development of nonvisual inspection techniques should continue in order to create more mature technology and reduce its cost. While recommendation A-00-108 provides examples of inspection technologies such as arc-fault circuit breakers and automated wire test equipment, it was not intended to be limited only to these technologies. The Board believes that the NPRM should be amended to require the adoption of those techniques that are identified through research as effective. Cost-Benefit Analysis The Board is concerned that the NPRM’s cost-benefit analysis does not account for indirect EWIS-initiated accident causes, such as those that occurred during the June 6, 1992, accident involving COPA flight 201, a Boeing 737-204 that crashed near Tucuti, Panama, resulting in 47 fatalities. For that accident, an instrument’s gyroscope wire was believed to have frayed and shorted, which led to erroneous instrument indications and the pilots’ loss of control of the airplane. The Board believes that the number of EWIS-related accidents and incidents that can be prevented will exceed that predicted by the FAA. Summary Although more than 5 years have passed since Safety Recommendation A-00-108 was issued, the Safety Board believes that the NPRM is a positive step toward addressing its concerns. The Board commends the FAA for introducing several potential improvements, including standards for the separation of types of wire materials and the separation of vulnerable systems from potential sources of short-circuit power and standards concerning electrical shock and burn protection. The Board supports the proposed rulemaking, encourages amendments that will address all of the individual deficiencies identified by the ATNSP and Safety Recommendation A-00-108, and looks forward to the expeditious implementation of these regulations and guidance materials. The Board appreciates the opportunity to comment on this important safety issue.

From: NTSB
To: FAA
Date: 12/10/2003
Response: The Safety Board notes and commends the FAA for the wide variety of activities it has initiated in response to these recommendations, many of which have been included in the work of ATSRAC and activities related to the Enhanced Airworthiness Program for Airplane Systems (EAPAS). Safety Board staff attend ATSRAC meetings to discuss progress with FAA staff and regularly review ATSRAC products. However, although the FAA has initiated numerous actions, most of the efforts to date provide only guidance, rather than the needed changes to FAA requirements. The Safety Board is also concerned that some of the FAA's proposed regulatory revisions are inadequate. For example, the Board has learned that the proposed aircraft wiring systems inspection requirements will only mandate a visual inspection, despite FAA-sponsored studies that have shown that visual inspections may miss half (or more) of wiring defects. Visual inspections are inappropriate where access is not possible, and they may not detect stiffened insulation that is easily cracked or other changes in material properties. In addition, visual inspections cannot detect corroded pins in wire connectors, or systems in which the electrical resistance is increasing to unacceptable levels. With regard to the need for improved documentation and reporting of potentially unsafe electrical wiring conditions, the Board notes that the Air Transport Association (ATA) has established a new Subchapter 97 for wiring, and the FAA proposed that the code in Subchapter 97 be used as the second two digits included in the four-digit ATA code in service difficulty reports (SDR) whenever the problem identified relates to wiring. The FAA is developing guidance to identify the use of Subchapter 97 in its SDR system and is also developing an automated tool for the SDR system that will support trend analysis. The Safety Board believes these are positive steps in response to Safety Recommendation A-00-108 but notes that (1) the FAA's SDR system has not yet been rebuilt and (2) although the Subpart 97 code may be in the SDR system, the rest of the SDR system remains difficult to use to monitor electrical wiring system problems. Without accurate and usable data, underreporting of defects will hamper any cost-benefit analysis used to evaluate regulatory changes being considered as a result of these recommendations. With regard to the need to incorporate the use of new technology, such as arc-fault circuit breakers (AFCB) and automated wire test equipment, the Safety Board is disappointed that the productive research efforts in these areas will not result in new requirements to more broadly incorporate this technology into new and existing airplanes. For example, although the FAA cites the implementation of AFCB technology, this implementation will be limited. The Board also notes that 5 1/2 years after the FAA identified aging mechanical systems as an issue in the ATNSSP, the FAA has not yet completed research, let alone translated that research into changes in maintenance. The Board understands that by December 2003, the FAA plans to issue a notice of proposed rulemaking (NPRM) for all EAPAS regulatory revisions. When it is published, the Board will review the NPRM and provide comments. The Board's review of the NPRM and the final regulatory changes following the NPRM's issuance will provide the basis for the Board's determination of whether the FAA's action is responsive to the recommendations. In the interim, Safety Recommendations A-00-106 and -108 remain classified OPEN -- ACCEPTABLE RESPONSE.

From: FAA
To: NTSB
Date: 4/8/2003
Response: Letter Mail Controlled 4/21/2003 4:53:44 PM MC# 2030213: - From Marion C. Blakey, Administrator: The following is an update on the EAPAS program. The enhancements developed as part of the FAA’s EAPAS program specifically related to the issues identified in this safety recommendation are addressed by the Aging Transport Non-Structural Systems Plan Tasks 3,4, and 5 described in detail below: Task 3. Enhance airplane maintenance to better address aging airplane svstems. This task involves developing improvements to maintenance programs, training programs, and maintenance documentation to provide the needed focus on and awareness of the issues regarding aging systems. Following are the major components of this task. L Improve inspection criteria for wiring. Define acceptance criteria for corrosion on flight control actuators and associated linkages, and for hydraulic fittings. Revise the Air Transportation Association (ATA) Maintenance Steering Group (MSG)-3 process to address catastrophic events associated with wire failures as MSG-3 review items. Identify maintenance tasks and inspection intervals for wire failures with catastrophic consequences. Establish a means to minimize contamination of wiring from metal shavings. Review air carrier and repair station inspection and repair training programs to ensure that they adequately address aging wiring system components (wire, connectors, brackets, shielding, clamps, grounds). Develop guidance material to address electromagnetic compatibility, lightning, and high intensity radiated field protection features in the maintenance programs. Review and update Chapter 20, “Standard Practices for Wiring.” The above components were assigned to the ATSRAC and were accomplished by task groups for maintenance, standard wiring practices, and training. The Maintenance Task Group developed a process to enhance existing maintenance programs for systems for inclusion in the MSG-3 guidelines, which establishes the baseline for maintenance programs. The task group, whose members represented major manufacturers and operators, worked closely with the MSG-3 Working Group to develop this new process called the "Enhanced Zonal Analysis Procedure." The Performance of the Enhanced Zonal Analysis Procedure consists of: l Zonal analysis (traditional MSG-3 logic). L An enhanced logic and procedure that address wiring and consists of: - identifying cleaning and inspection tasks that reduce the likelihood of combustible materials, and - a wiring task definition (inspection-level definition, verification of inspection level, and definition of interval). This task group also clarified definitions and expectations of general visual inspection criteria and developed recommendations to minimize contamination and accidental damage to wiring. 5 The ATSRAC Maintenance Task Group strongly believes that the adoption of the recommendations developed through its activity will lead to a significant improvement in: l the attention paid to wiring during maintenance program development; l the quality of the guidance material supporting scheduled inspections; l the scope of inspections and consistency of the application of those inspections; l standard practices to minimize wiring contamination and accidental damage; and l the awareness of the importance of good housekeeping. The FAA will propose the adoption of Operations Specifications (OpSpecs) that would require operators to add Aging Wiring System Maintenance Training into their systems. These OpSpecs will support and implement the EAPAS final rule. The FAA will produce guidance material that describes the Enhanced Zonal Inspection Program using the Enhanced Zonal Analysis Procedure. The ATSRAC Maintenance Task Group also established a means to minimize contamination of wiring from metal shavings through scheduled maintenance tasks and improvement of maintenance practices. The FAA has requested airplane manufacturers, operators, and supplemental type certificate holders to include specific instructions in service bulletins and engineering orders to take necessary actions to minimize contamination of wiring from metal shavings and other maintenance-related damage. The ATSRAC Training Task Group developed an advisory circular containing curriculum and lesson plans to address inspection and repair of aging wiring system components that are intended to be incorporated into manufacturer, operator, and repair station training programs. The curriculum and lesson plans were designed following feedback from two surveys of industry. The curriculum and lesson plans take into account the results of the Non-Intrusive Inspection Program, the Intrusive Inspection Program, the Maintenance Task Group, the Standard Wiring Practices Task Group, and ATA Specification 117 (Wiring Maintenance Practices/Guidelines). The Training Task Group is accomplishing the training portion of the tasking for the Standard Wiring Practices Task Group. The curriculum and lesson plans for air carrier and repair station inspection and repair training programs ensure that aging wiring system components (wire, connectors, brackets, shielding, clamps, and grounds) are adequately addressed. The FAA will develop rulemaking to require updates to air carrier and repair station training programs to include the intent of the curriculum and lesson plans. The FAA will also develop guidance material that supports the rulemaking effort. In support of the short-range actions identified in the EAPAS Implementation Plan published in August 2001, the FAA’s Flight Standards Service will develop OpSpecs that require the addition of aging systems maintenance and training programs to support and implement the EAPAS final rule. Most ATA member airlines have already begun incorporating ATA Specification 117, Wiring Maintenance Practices/Guidelines, into their training programs. Additionally, the following improvements have been developed as part of EAPAS l In a proactive approach to increase awareness of wire installation and separation requirements and to deal with general issues of wiring maintenance practices, the FAA produced two training aids. An S-hour aviation video training course, entitled "Aircraft Wiring Practices," was developed for FAA engineers, designated engineering representatives, aviation safety inspectors, and principal inspectors. The FAA also produced an intemet-based job aid entitled, "Aircraft Wiring Practices (Job Aid)," which is available to everyone dealing with wire installation issues. The job aid can be found at http://www.academy.jccbi.gov/AIRDL/wiringcourse. L The FAA published a policy statement (ANM-01-04 dated July 2, 2001) entitled "System Wiring Policy for Certification." The policy statement addresses wire installation drawings, safety analyses of wiring and wire bundles, and continued airworthiness considerations for wiring. In the policy statement, the FAA outlined requirements for improving installation drawings so that installers obtain an unambiguous definition of airplane wiring configurations. Modifiers to the original airplane manufacturer’s wiring system should demonstrate that installation specifications and routing practices for the wiring used is either the same as, or compatible with, originally approved standards. Specifically, wiring separation, wire types, wire bundle sizes, brackets, and clamping should be consistent with the original manufacturer’s approved standards. Task 4. Add aging systems tasks to the aging airplane research program. This task involves developing specific research and development programs for aging electrical systems and aging mechanical systems that support the objectives of the EAPAS. The research and development programs have been developed with the assistance of the FAA Technical Community Representation Groups for aging electrical and mechanical systems. These programs take advantage of various findings of the ATSRAC. Actions and additional research and development tasks needed to meet the objectives of the EAPAS are discussed below. The following subtasks were identified in the original Aging Transport Non-Structural Systems Plan: Determine if a service life for airplane wire is appropriate. If appropriate, establish the service life of all types of airplane wire used in transport airplanes. Establish the condition of aging system wiring components and validate the adequacy of visual inspections. L Develop nondestructive testing tools for inspection of wiring systems. L Establish aging effects on aircraft lightning and high intensity radiated field protection systems. L Develop arc fault circuit breakers. L Conduct destructive testing of flight control linkages Since the original Aging Transport Non-Structural Systems Plan was published in 1998, research and development programs that address the original subtasks have been identified. New subtasks have been identified to address issues encountered during the initial 2 years of investigation. The major components of the research and development program for aircraft wiring are: l Characterization of wire degradation in the aging process; l Establishment of the condition of aging wiring components based on laboratory analysis and testing; l Effects of related and unrelated maintenance operations on aircraft wiring; l Establishment of the condition of aging circuit protection components based on laboratory analysis and testing; and l Effect of mixed wire types on wire degradation. The outcome of the research programs will likely result in additions and revisions to advisory material and regulations. The data from the Intrusive Inspection Program are being considered in developing rulemaking for maintenance and training programs. When the inspection tools for wiring systems have been fully tested and approved for use in service, maintenance programs may be revised to provide incorporation of these tools into operator and repair station programs. The components of the Arc Fault Circuit Breaker development are: l Development of 4OOHz arc fault circuit breakers; l Development of 2%volt arc fault circuit breakers; and l Development of miniaturized arc fault circuit breakers. The Society of Automotive Engineers (SAE) is developing a design requirement document for arc fault circuit breakers. The FAA is participating in the development of that document and is in the process of developing an associated advisory circular and technical standard order for arc fault circuit breakers. The SAE specification for Arc Fault Circuit Breakers is nearing completion. The FAA has developed an issue paper that is currently being used for installation of Arc Fault Circuit Breakers on airplanes. As the first step, Arc Fault Circuit Breakers are currently being certified and installed on airplanes in non-essential systems to gain experience, collect data, and monitor their performance. The following is a list of additional research and development programs currently underway as part of EAPAS: l Development of advanced circuit protection devices. L Core wiring safety technologies. The components of this subtask are: Validation of wire inspection and test systems; Risk assessment methods for aircraft wiring; Wire separation/segregation; Performance requirements, test criteria and procedures for aircraft wire; and Long-term evaluation of environmental effects on in-service wiring. The airplane mechanical systems are being considered in the aging study. Currently, the FAA, the Joint Airworthiness Authorities, Transport Canada, and the manufacturers of large transport airplanes (Boeing and Airbus), together with a contractor, are studying the effects of aging on mechanical systems. The study includes evaluation of design and maintenance requirements and procedures for the mechanical systems. Physical inspections and destructive tests will also be preformed on the mechanical systems components such as single element, dual path components (as recommended by ATSRAC). The mechanical systems study will be performed in phases. Each phase will concentrate on study of one aircraft mechanical system (e. g. flight control system, hydraulic system, fuel system, etc.). Phase one is currently underway which involves evaluation of Boeing 757 and Airbus A320 control systems and testing of the critical components on aged airplanes (Beoing 737,747, and A300). A 2-year contract has been awarded for completion of Phase I, and the FAA expects to complete Phase I by June 30, 2003. Based on lessons learned from Phase I, it is anticipated that evaluation of other systems will be accomplished at a much faster rate. The FAA plans to add small transport airplane mechanical systems to this study. Task 5. Improve reporting of accident/incident and maintenance actions involving wiring system components. The major components of this task are to: l Establish codes to better identify wiring system component failures and maintenance actions; l Improve reporting formats of incident/accidents and maintenance data to make the integration and analysis of databases more efficient for assessing aging trends and problems; l Add additional data to the National Aviation Safety Data Analysis Center databases to better address aging systems; and Recommend that aging airplane components like wiring, circuit breakers, connectors, pumps, motors, and harnesses that are removed from airplane during maintenance be examined by airline or repair station facilities for safety implications of the failure. ATA has established a new Subchapter 97 for wiring. It is being proposed that Subchapter 97 be used as the second two digits included in the four-digit ATA code in service difficulty reports whenever the problem identified relates to wiring. The FAA is in the process of developing guidance to identify the use of Subchapter 97, an update of the JASC code, and an addition to zonal codes. In addition, the FAA is also in process of developing an automated service difficulty reporting system that will support trend analysis. As part of this activit, an integrated aging wiring database coupled with an on-line analytical process methodology are being developed that will also be useful in the certification process. The FAA organized an internal rulemaking team to develop an NPRM for all EAPAS regulatory enhancements when the ATSRAC recommendations are received and reviewed by the FAA. The FAA plans to publish the EAPAS NPRM by December 2003. The FAA regularly provides the EAPAS program updates to the ATSRAC public meetings. The Board’s staff participates in these meetings and is aware of FAA’s progress.

From: NTSB
To: FAA
Date: 5/17/2002
Response: The Safety Board has closely followed the progress of ATSRAC and EAPAS. In the past, the Board has expressed concern that referral of issues to rulemaking advisory committees results in considerable delays with little or no added benefit. Because of these concerns, the Board issued this recommendation specifically asking the FAA to act on major safety issues, regardless of ATSRAC actions. The Board noted that ATSRAC has been heavily constituted by vested parties and now finds that the products of ATSRAC are a key part of the FAA EAPAS. In response to the portion of this recommendation concerning wire system training, the Safety Board notes that ATSRAC members have developed the Air Transport Association Spec-117 video and a training course that is available as a series of slides. Further, while a member of ATSRAC, Boeing developed a wire maintenance and awareness training curriculum that the company has offered for sale to operators. The FAA has stated in EAPAS that training changes will become mandatory. However, the Board is aware that unresolved issues include who should be required to have training and what training will be required. The Safety Board has been following ATSRAC discussions pertaining to the need for improved standard wire practices manuals and other wire documentation. The high-level discussion of this subject in the EAPAS plan notes that the review is continuing, and an AC is not expected until the first quarter of 2003, with implementation to follow. Safety Recommendation A-00-108 specifically cited the need for improved reporting of potentially unsafe wiring conditions that are found; the Safety Board continues to investigate aircraft fires, short circuits, and other incidents that are not always reported in the FAA's existing service difficulty reporting (SDR) system. The Board discussed concerns about the SDR system in the TWA flight 800 accident report and has issued several safety recommendations concerning the incomplete reporting of service difficulty information. The FAA has also acknowledged inadequacies in the SDR system and has been working toward a system revision. However, following receipt of industry comments at a December 11, 2000, meeting, the effective date of the final rule that would amend the reporting requirements was delayed first until July 16, 2001, then until January 16, 2002. On November 19, 2001, the FAA delayed the effective date to January 16, 2003. The Board notes that during investigations of aircraft fires, short circuits, and other hazardous events, it continues to find failures in maintenance and inspection. The Board is awaiting the FAA's development of an objective method to measure the relative safety of systems in the air transport fleet and its use to measure and evaluate improvements. The development and application of new technology, such as AFCBs and automated wire test equipment (ATE), were emphasized in Safety Recommendation A-00-108. The Safety Board is aware that the FAA has worked with the U.S. Navy and with industry to develop AFCBs, which have the potential to overcome trade-offs inherent in traditional thermal circuit breaker designs. These devices have now been flown on various naval and transport category airplanes. Although the Board has not been assured that the microprocessors will be able to discriminate arc-failures and satisfactorily function in bundles of varying types of wire, the development of this new technology is highly encouraging. The Board looks forward to learning how the FAA will certificate and implement these devices. The FAA has also tested various types of ATE, and the Safety Board is pleased with the progress of this program. The Board has reviewed the FAA plan that will move from ATE demonstration toward development, implementation, and requirements for ATE that overcome the limitations of visual inspections. We look forward to learning of final developments and ultimate use. In summary, the FAA's development of EAPAS and support for development of sub-components, such as AFCBs, are responsive to this recommendation. The Safety Board remains concerned primarily about the details of the implementation that may miss the issues identified in the ATNSSP and about the length of time for implementation of the individual issues in the EAPAS plan. The Board believes that the FAA could initiate some if not all of the action items that have been scheduled for industry action. Pending implementation of the recommended actions, Safety Recommendation A-00-108 remains classified OPEN -- ACCEPTABLE RESPONSE.

From: FAA
To: NTSB
Date: 9/17/2001
Response: Letter Mail Controlled 09/25/2001 11:37:52 AM MC#2010766: - From Jane F. Garvey, Administrator: The Federal Aviation Administration's (FAA) staff met with the Board's staff on January 4, 2001, to discuss the TWA 800 safety recommendations. During the meeting, a detailed status of the Aging Transport Non-Structural Systems Plan was provided. The presentation included a description of all accomplishments to date and future (near- and long-term) enhancement plans. On June 13, 2001, the FAA issued a report entitled "Enhanced Airworthiness Program for Airplane Systems." The report institutionalizes the near- and long-term enhancements and is being used as a tool to manage the tasks required for implementation of the safety enhancements. I have enclosed a copy of the report for the Board's information. I will keep the Board informed of the FAA's progress on this safety recommendation.

From: FAA
To: NTSB
Date: 5/24/2001
Response: Letter Mail Controlled 05/31/2001 9:08:49 PM MC# 2010450: - From Jane F. Garvey, Administrator: The FAA's staff met with the Board's staff on January 4, 2001, to discuss the TWA 800 safety recommendations. During the meeting, a detailed status of the Aging Transport Non-Structural Systems Plan was provided. The presentation included a description of all accomplishments to date and future enhancement plans. The future enhancement plans include near- and long-term safety enhancements. Examples of near-term enhancements are training on aircraft wiring practices for engineers, designees, and inspectors and new policies for approving wire installation drawings. These enhancements will be accomplished rapidly. The long-term safety enhancements will include: ??Development of new wire training requirements for manufacturers, operators, and repair station personnel. ??Development of requirements for using Air Transport Association's Subchapter 97 in the problem-reporting system for inclusion of information for wiring failures. ??Development of data collection for trend analysis system for failures in wiring. ??Development of arc fault circuit breakers and the required standard. ??Development of wiring inspection tools. ??Proposed rulemaking to improve wiring requirements in 14 CFR Part 25 and improved inspection, training, and maintenance in 14 CFR Parts 91, 121, 125, and 129. Improvements in FAA regulations and guidance material have also been identified to address the findings of the FAA Aging Transport Non-Structural Systems Plan. The FAA will propose rulemaking and guidance material regarding certification, training, maintenance, and inspection programs for the enhanced airworthiness for transport airplane systems. The Aging Transport Systems Rulemaking Advisory Committee will be retasked to assist in this proposed rulemaking effort. The FAA is also continuing work on an outreach program for airworthiness authorities worldwide to improve documentation and reporting of problems in wiring, studies, and evaluations for the use of new technologies. This outreach program will provide airworthiness authorities with the FAA's aging system findings and inform them of possible FAA actions. The FAA also mentioned to the Board during the meeting on January 4, 2001, that the smaller transport airplanes, like commuters and business jets, will also be reviewed under the Aging Transport Non-Structural Systems Plan. The near-term and long-term enhancements will be institutionalized by the Enhanced Airworthiness Program for Airplane Systems, and a plan has been developed as a tool to manage the tasks required for implementation of the safety enhancements. I will keep the Board informed of the FAA's progress on this safety recommendation.

From: NTSB
To: FAA
Date: 12/5/2000
Response: FAA and Safety Board staff met on 10/17/00, to discuss these recommendations. The meeting initiated a dialogue that will lead to mutually agreeable actions for each of these recommendations by 1/31/01. Pending submission of that complete response, A-00-105 through -108 are classified OPEN – ACCEPTABLE RESPONSE.

From: FAA
To: NTSB
Date: 10/12/2000
Response: Letter Mail Controlled 10/16/2000 3:58:40 PM MC# 2001542 - From Jane F. Garvey, Administrator: Your staff has agreed to meet with FAA technical specialists on 10/17/00, to discuss these recommendations. This meeting will offer an opportunity to begin a dialogue between our agencies that can lead to mutually agreeable actions for each of these recommendations. After this meeting, the FAA will have a better understanding of the intent of these recommendations and be in a better position to provide detailed response to these recommendations. We anticipate providing the Board with a complete response to these recommendations by 1/31/01.