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Safety Recommendation Details

Safety Recommendation A-02-001
Details
Synopsis: This safety recommendation letter addresses an industry-wide safety issue involving ommissions in pilot training on transport-category airplanes. Specifically, the National Transportation Safety Board has learned that many pilot training programs do not include information about the structural certification requirements for the rudder and vertical stabilizer on transport-category airplanes. Further, the Safety Board has learned that sequential full opposite rudder inputs (sometimes colloquially referred to as "rudder reversals")--even at speeds below the design maneuvering speed--may result in structural loads that exceed those addressed by the requirements. In fact, pilots may have the impression that the rudder limiter systems installed on most transport-category airplanes, which limit rudder travel as airspeed increases to prevent a single full rudder input from overloading the structure, also prevent sequential full opposite rudder deflections from damaging the structure. However, the structural certification requirements for transport-category airplanes do not take such maneuvers into account; therefore, such sequential opposite rudder inputs, even when a rudder limiter is in effect, can produce loads higher than those required for certification and that may exceed the structural capabilities of the aircraft.
Recommendation: TO THE FEDERAL AVIATION ADMINISTRATION: Require the manufacturers and operators of transport-category airplanes to establish and implement pilot training programs that: (1) explain the structural certification requirements for the rudder and vertical stabilizer on transport-category airplanes; (2) explain that a full or nearly full rudder deflection in one direction followed by a full or nearly full rudder deflection in the opposite direction, or certain combinations of sideslip angle and opposite rudder deflection can result in potentially dangerous loads on the vertical stabilizer, even at speeds below the design maneuvering speed; and (3) explain that, on some aircraft, as speed increases, the maximum available rudder deflection can be obtained with comparatively light pedal forces and small pedal deflections. The FAA should also require revisions to airplane and pilot operating manuals that reflect and reinforce this information. In addition, the FAA should ensure that this training does not compromise the substance or effectiveness of existing training regarding proper rudder use, such as during engine failure shortly after takeoff or during strong or gusty crosswind takeoffs or landings.
Original recommendation transmittal letter: PDF
Overall Status: Closed - Acceptable Action
Mode: Aviation
Location: Belle Harbor, NY, United States
Is Reiterated: Yes
Is Hazmat: No
Is NPRM: No
Accident #: DCA02MA001
Accident Reports: In-Flight Separation of Vertical Stabilizer American Airlines Flight 587, Airbus Industrie A300-605R, N14053
Report #: AAR-04-04
Accident Date: 11/12/2001
Issue Date: 2/8/2002
Date Closed: 12/26/2013
Addressee(s) and Addressee Status: FAA (Closed - Acceptable Action)
Keyword(s): Flightcrew,

Safety Recommendation History
From: NTSB
To: FAA
Date: 5/12/2014
Response: The National Transportation Safety Board (NTSB) has reviewed the Federal Aviation Administration’s (FAA) draft Advisory Circular (AC) 120-UPRT, “Upset Prevention and Recovery Training,” which was posted for comment on the FAA’s website on March 12, 2014. Draft AC 120-UPRT describes the philosophy and recommended training for airplane upset prevention and recovery. The purpose of the AC is to provide recommended practices and guidance regarding academic and flight simulation device training for pilots to prevent the development of airplane upset conditions and ensure correct and consistent recovery responses to upsets. The AC was created from recommended practices developed by major airplane manufacturers, labor organizations, air carriers, training organizations, simulator manufacturers, and industry representative organizations. Although this AC is directed to air carriers in implementing 14 Code of Federal Regulations (CFR) Part 121 regulations, the FAA encourages all airplane operators, pilot schools, and training centers to implement upset prevention and recovery training and to use the guidance contained in the AC, as applicable to the type of airplane in which training is conducted. We generally support the draft AC (with specific suggestions below). On November 12, 2013, the FAA published a final rule titled “Qualification, Service, and Use of Crewmembers and Aircraft Dispatchers.” Draft AC 120 UPRT and draft revised AC 120-109A provide the guidance necessary for operators and FAA inspectors to implement the requirements in the final rule. In addition, we are pleased to note that draft AC 120-UPRT contains several prominent warnings against the use of excessive rudder inputs and recommends the use of the Airplane Upset Recovery Training Aid in developing upset recovery training programs. Safety Recommendations A-02-1 and -2 and A-04-59 and -61, which are all classified as “Closed?Acceptable Action,” addressed these issues.

From: NTSB
To: FAA
Date: 12/26/2013
Response: On November 12, 2013, the FAA published a final rule titled, “Qualification, Service, and Use of Crewmembers and Aircraft Dispatchers” which contained a number of provisions that address these recommendations. Among these provisions are proposed requirements for training flight crews to avoid inappropriate rudder use to recover from adverse attitudes and authority for FAA principal operations inspectors to compel revisions to training programs when necessary, rather than their simply having to accept these programs. Accordingly, Safety Recommendations A 02 1 and 2 are classified CLOSED—ACCEPTABLE ACTION.

From: NTSB
To: FAA
Date: 8/3/2010
Response: Notation 8216: On November 12, 2001, about 0916 eastern standard time, an Airbus A300-605R, N14053, operated as American Airlines flight 587, crashed into a residential area of Belle Harbor, New York, shortly after takeoff from John F. Kennedy International Airport, Jamaica, New York. Following an encounter with wake turbulence from a preceding Boeing 747 (747), the first officer made a series of full alternating rudder pedal inputs before the airplane’s vertical stabilizer and rudder separated in flight; both were found in Jamaica Bay about 1 mile north of the main wreckage site. The National Transportation Safety Board (NTSB) determined that the probable cause of the American Airlines flight 587 accident was the in-flight separation of the vertical stabilizer as a result of the loads beyond ultimate design that were created by the first officer’s unnecessary and excessive rudder pedal inputs. Contributing to these rudder pedal inputs were characteristics of the Airbus A300-600 rudder system design and elements of the American Airlines Advanced Aircraft Maneuvering Program (AAMP). The circumstances of the American Airlines flight 587 accident are similar to a more recent accident involving an Airbus model A319. On January 10, 2008, about 0848 central standard time, an Airbus Industrie A319, Canadian registration C-GBHZ, operated as Air Canada flight 190, experienced an in-flight upset after encountering wake turbulence from a 747 while climbing from flight level (FL) 360 to FL370. The flight crew declared an emergency and diverted the flight to Calgary, where it landed uneventfully. Of the 5 crewmembers and 83 passengers on board, 2 crewmembers and 8 passengers sustained minor injuries, and 3 passengers sustained serious injuries. Visual meteorological conditions prevailed, and an instrument flight rules flight plan was filed for the scheduled domestic passenger flight from Victoria International Airport, British Columbia, Canada, to Toronto Pearson International Airport, Ontario, Canada. The Transportation Safety Board of Canada (TSB) investigated this accident; the NTSB and Bureau d’Enquêtes et d’Analyses provided accredited representatives and technical advisors to the investigation. Data from the flight data recorder (FDR) indicate that, during the upset, the airplane experienced several roll and vertical load factor oscillations and lost about 1,000 feet of altitude. Although the autopilot was engaged during the start of the wake vortex encounter, after about 3 seconds, the autopilot was disengaged, and there was a series of large oscillatory inputs on the left side stick controller. In addition, the FDR recorded a series of three to four alternating rudder pedal inputs (right pedal, then left pedal) over the next 15 seconds. During these inputs, the airplane continued to oscillate in roll, reaching a maximum roll of 55º. At the same time, the recorded acceleration was also oscillating, with peaks of -0.46 G to +0.49 G of lateral load factor and peaks of -0.76 G to +1.57 G of vertical load factor. Because of the severity of the upset, following the emergency landing at Calgary, the airplane was grounded pending an inspection by Airbus engineers. During an extensive inspection, the vertical stabilizer was removed from the airplane and scanned ultrasonically to inspect for damage to the stabilizer’s composite components. No damage was found, and the stabilizer was reattached and the airplane returned to service. Although no damage to the stabilizer was found, an analysis of the accident performed by Airbus indicated that the rear vertical stabilizer attachment fitting sustained loads 29 percent above its design limit load. Simulation work performed by Airbus revealed that these high loads were primarily the result of the flight crew’s series of alternating rudder pedal inputs and were not the result of the wake turbulence. Information and animations provided by Airbus showed that if the pilots had not made any control inputs after the wake encounter, the airplane would have righted itself with minimum altitude loss and g-loading. Pilot Rudder Pedal Inputs, Yaw Axis Certification, and Rudder Pedal Sensitivity In both the American Airlines flight 587 and Air Canada flight 190 accidents, the vertical stabilizer limit loads were exceeded by a large margin as a result of the alternating full scale rudder inputs. The NTSB’s investigation of the American Airlines flight 587 accident revealed that the Airbus A320 airplane family, which includes the A319, and the Airbus A300/A310 airplane family both use a variable-stop rudder travel limiter, which mechanically limits available rudder pedal deflection as airspeed increases. Consequently, at high airspeeds, these systems require lighter pedal forces and smaller pedal displacements to obtain maximum available rudder than at low airspeeds. Investigation of the American Airlines flight 587 accident revealed that variable-stop systems produce dramatically larger aircraft responses to the same rudder input at higher airspeeds than at lower airspeeds, which can surprise a pilot and serve as a trigger for an aircraft pilot coupling (APC) event. As a result of findings from the American Airlines flight 587 investigation, the NTSB issued Safety Recommendation A-04-58, which asked the Federal Aviation Administration (FAA) to do the following: Review the options for modifying the Airbus A300-600 and the Airbus A310 to provide increased protection from potentially hazardous rudder pedal inputs at high airspeeds and, on the basis of this review, require modifications to the A300 600 and A310 to provide increased protection from potentially hazardous rudder pedal inputs at high airspeeds. In the same report, the NTSB issued a companion recommendation, A-04-63, to the French Direction Générale de l’Aviation Civile. On April 6, 2009, the European Aviation Safety Agency (EASA) indicated that Airbus is developing a reduced pedal travel limiting unit (PTLU). On March 19, 2010, EASA further indicated that “its previously held position on the pilot training out as being an efficient and sufficient measure to avoid any new hazardous situations has to be reconsidered following more recent service experience which confirms that crew use of rudder pedal inputs in upset encounters cannot be ‘trained out.’” EASA therefore indicated that it plans to require the PTLU on Airbus A310 and A300-600 aircraft models. The NTSB will consider how the proposed changes are responsive to Safety Recommendation A 04 58 when the FAA provides further details about the PTLU. In the report on the American Airlines flight 587 accident, the NTSB also issued Safety Recommendations A-04-56 and -57, which asked the FAA to do the following: Modify 14 Code of Federal Regulations [CFR] Part 25 to include a certification standard that will ensure safe handling qualities in the yaw axis throughout the flight envelope, including limits for rudder pedal sensitivity. (A-04-56) After the yaw axis certification standard recommended in Safety Recommendation A-04-56 has been established, review the designs of existing airplanes to determine if they meet the standard. For existing airplane designs that do not meet the standard, the FAA should determine if the airplanes would be adequately protected from the adverse effects of a potential [APC] after rudder inputs at all airspeeds. If adequate protection does not exist, the FAA should require modifications, as necessary, to provide the airplanes with increased protection from the adverse effects of a potential APC after rudder inputs at high airspeeds. (A-04-57) On March 1, 2005, the FAA indicated that the current standards governing the performance and design of yaw control systems may need to be redefined. The FAA added that it was evaluating the existing standards and conducting a study to identify critical rudder control system parameters and human interaction with those controls. The FAA further indicated that, based on the results of the study, it would determine whether the current standards need to be updated and would work with industry to develop rudder control standards. On August 3, 2005, the NTSB classified Safety Recommendations A-04-56 and -57 “Open—Acceptable Response.” The similarities between the Air Canada flight 190 and American Airlines flight 587 crewmembers’ responses to wake encounters indicate that the Airbus A320 family is also susceptible to potentially hazardous rudder pedal inputs at higher airspeeds. In both events, the vertical stabilizer limit loads were exceeded by a large margin as a result of the alternating rudder inputs. In the Air Canada flight 190 accident, the pilot applied three alternating rudder inputs and exceeded the limit load by 29 percent. In the American Airlines flight 587 accident, the pilot applied four full alternating rudder inputs; after the fourth input, the aerodynamic loads on the vertical stabilizer exceeded the vertical stabilizer’s ultimate design load (at about twice the maximum load), and it separated from the airplane. In a January 14, 2010, meeting, the FAA informed NTSB staff that the study of rudder control systems was complete and should be published in the first half of 2010. Furthermore, the FAA indicated that, as a result of the study, it may initiate rulemaking to revise certification standards for large airplane yaw control systems. The NTSB looks forward to the opportunity to review the results of the study and to further FAA action to develop yaw axis handling qualities standards as envisioned in Safety Recommendation A-04-56. The Air Canada flight 190 accident demonstrates that the need remains to revise the certification standards for transport-category aircraft regarding yaw sensitivity to rudder pedal inputs and that these revised standards need to be applied to current in-service aircraft. As discussed above, the Airbus A320 rudder control system design characteristics are comparatively similar to those of the Airbus A300-600 and A310 and may serve as a trigger for an APC event at high airspeeds. The NTSB believes that the yaw axis handling qualities standard envisioned by Safety Recommendation A-04-56 will preclude such characteristics. Further, the NTSB notes that, if the FAA had performed the review of existing airplane designs as asked for in Safety Recommendation A-04-57 to see if they meet new yaw characteristic standards developed for A 04-56, the FAA may have noted that the A320 airplane also needed increased protection from potentially hazardous rudder inputs at high airspeeds. Therefore, the NTSB reiterates Safety Recommendations A-04-56 and -57. Because of the FAA’s delay in responding to Safety Recommendation A-04-56, which asked the FAA to modify 14 CFR Part 25 to include a certification standard that will ensure safe handling qualities in the yaw axis throughout the flight envelope, including limits for rudder pedal sensitivity, the NTSB is uncertain that the PTLU that Airbus is developing in response to A-04-58 will ensure that the A300/A310 airplanes will pass any yaw characteristic standards that the FAA develops. Because of the amount of time that has passed since the issuance of A-04-58 and the limited work that has been accomplished to date, the NTSB reiterates Safety Recommendation A-04-58. Pilot Training for Upset Recovery As a result of the Air Canada flight 190 accident investigation, on November 18, 2008, the TSB issued Aviation Safety Advisory A08W0007 D1 A1, “Pilot Training for Upset Recovery in Transport Category Aircraft,” to Transport Canada. In the advisory letter, the TSB noted that the accident “pilots were exposed to the material contained in the Airbus Flight Crew Operations (FCOM) No. 828/1” during Air Canada’s initial type training and recurrent ground school instruction every 24 months. However, although the pilots received upset training in the simulator, according to the letter, the training “concentrated on recovery from unusual attitudes in the pitch axis, with limited attention to proper rudder pedal usage during recoveries from large roll axis excursions.” The letter concluded by indicating that “Transport Canada may wish to communicate to transport category operators in Canada, the necessity to include roll scenarios in upset training and the appropriate use of rudder control during recoveries.” The NTSB has advocated upset recovery training since it issued Safety Recommendation A-96-120 on October 18, 1996, asking the FAA to do the following: Require 14 CFR Part 121 and 135 operators to provide training to flight crews in the recognition of and recovery from unusual attitudes and upset maneuvers, including upsets that occur while the aircraft is being controlled by automatic flight control systems, and unusual attitudes that result from flight control malfunctions and uncommanded flight control surface movements. On August 11, 1999, the FAA indicated that it was developing a notice of proposed rulemaking (NPRM) to revise 14 CFR Part 121, subparts N and O, to include training in recognition and recovery from unusual attitudes and upset maneuvers. However, by October 26, 2004, the FAA had not yet issued the NPRM and was unable to indicate when it would be published. Because of the lack of progress towards requiring air carrier pilots to participate in unusual attitude training, the NTSB reclassified Safety Recommendation A 96 120 “Open—Unacceptable Response.” On January 12, 2009, the FAA issued an NPRM titled “Qualification, Service, and Use of Crewmembers and Aircraft Dispatchers” to revise 14 CFR Parts 65, 119, 121, 135, and 142. The NTSB reviewed this NPRM and, on May 7, 2009, provided comments to the FAA. The NTSB noted that, in response to Safety Recommendation A 96 120, the NPRM includes training on recognizing and recovering from “special hazards,” which are sudden or unexpected aircraft upsets. The NTSB noted that this proposal would also include a requirement giving FAA principal operations inspectors (POIs) the authority to review and require changes to training programs that do not adequately address a special hazard. Lack of such authority was a concern identified during the American Airlines flight 587 accident investigation, in which the NTSB learned that the POI knew that aspects of the American Airlines training program had undesirable effects but lacked the authority to require American Airlines to change its program. In addition, the NPRM addresses recovery from loss of control due to airplane design, airplane malfunction, human performance, and atmospheric conditions. The “Upset Recognition and Recovery” section of the NPRM lists a number of items that should be covered, including noting that catastrophic damage may result from rapidly alternating full flight control inputs and that, on some airplanes, progressively lighter pedal forces and smaller pedal movements will command the maximum rudder deflection as speed increases. The NTSB notes that although this NPRM is responsive to Safety Recommendation A-96-120, it proposes requirements for Part 121 operators only; similar action for Part 135 operators will be needed before the recommendation can be closed. The FAA plans to issue the final rule in 2010. Early in its investigation of the American Airlines flight 587 accident, the NTSB determined that the first officer’s series of full alternating rudder pedal inputs resulted in excessive loads on the airplane’s vertical stabilizer and rudder, leading to their in-flight separation. As a result, on February 8, 2002, the NTSB issued Safety Recommendation A-02-01, which asked the FAA to do the following: Require the manufacturers and operators of transport-category airplanes to establish and implement pilot training programs that: (1) explain the structural certification requirements for the rudder and vertical stabilizer on transport category airplanes; (2) explain that a full or nearly full rudder deflection in one direction followed by a full or nearly full rudder deflection in the opposite direction, or certain combinations of sideslip angle and opposite rudder deflection can result in potentially dangerous loads on the vertical stabilizer, even at speeds below the design maneuvering speed; and (3) explain that, on some aircraft, as speed increases, the maximum available rudder deflection can be obtained with comparatively light pedal forces and small pedal deflections. The FAA should also require revisions to airplane and pilot operating manuals that reflect and reinforce this information. In addition, the FAA should ensure that this training does not compromise the substance or effectiveness of existing training regarding proper rudder use, such as during engine failure shortly after takeoff or during strong or gusty crosswind takeoffs or landings. On April 15, 2002, the FAA stated that it reviewed several Airbus operators’ training programs and found that none of the operators conduct training on the rudder in a way that could result in dangerous combinations of sideslip angles and rudder position. The FAA also indicated that it issued a notice directing POIs to notify their air carriers that sequential full opposite rudder inputs may result in structural loads that exceed those addressed by the 14 CFR Part 25 requirements; that the rudder limiter systems installed on most transport-category airplanes will not prevent sequential full opposite rudder deflections from damaging the structure; and that on some airplane types, full available rudder deflections can be achieved with small pedal movements and comparatively light pedal forces. The FAA stated that manufacturers would prepare and distribute to their operators flight technical operations bulletins that address the concerns of this recommendation. Finally, the FAA indicated that it was considering implementing the changes in the approved sections of the airplane flight manuals (AFM) of affected aircraft by the airplane manufacturers. On July 22, 2002, the NTSB responded that the FAA’s plan to use nonregulatory means to meet the intent of Safety Recommendation A-02-01 might represent an acceptable alternative; however, the NTSB would assume, until the FAA indicated otherwise, that the FAA would develop some regulatory changes in pilot training programs in response to Safety Recommendation A 02 01. Pending completion of changes to pilot training programs and the determination of whether these revisions will be implemented through AFM and technical operations bulletin changes or through regulatory changes, Safety Recommendation A-02-01 was classified “Open—Acceptable Response.” However, in the 8 years since the FAA’s April 15, 2002, letter, the FAA has not provided any additional information about its activities in response to Safety Recommendation A-02-01. The NTSB notes that the January 12, 2009, NPRM is partially responsive to the requirement to explain that catastrophic damage may result from rapidly alternating full flight control inputs and that on some airplanes, progressively lighter pedal forces and smaller pedal movements will command the maximum rudder deflection as speed increases. However, the FAA has yet to issue the final rule and respond to the first part of Safety Recommendation A-02-01, which seeks pilot training programs that explain the structural certification requirements for the rudder and vertical stabilizer on transport-category airplanes. In its final report on the American Airlines flight 587 accident, the NTSB also issued Safety Recommendation A-04-59, which asked the FAA to do the following: Develop and disseminate guidance to transport-category pilots that multiple full deflection, alternating flight control inputs should not be necessary to control a transport-category airplane and, thus, should be avoided. In response to this recommendation, on October 25, 2005, the FAA issued Safety Alert for Operators (SAFO) 05002, “Multiple full deflection, alternating flight control inputs.” This SAFO urges directors of safety, directors of operations, fractional ownership program managers, and pilots of transport-category airplanes to (1) familiarize themselves with the location, availability, and content of the “Airplane Upset Recovery Training Aid” and (2) pay particular attention to the cautions against control reversals and pilot-induced oscillations that are repeated throughout the training aid. Following issuance of SAFO 05002, the NTSB classified Safety Recommendation A-04-59 “Closed—Acceptable Action” on June 9, 2006. The NTSB is concerned that, despite Safety Recommendations A-96-120, A-02-01, and A-04-59; FAA SAFO 05002; Airbus FCOM No. 828/1; and the wide distribution of the “Airplane Upset Recovery Training Aid,” pilots may still resort to unnecessary alternating control inputs—including rudder pedal inputs—in an attempt to control their airplanes during a perceived or actual upset, as evidenced by the Air Canada flight 190 accident. The actions taken by the FAA to date, including reviews by POIs, issuance by manufacturers of technical operations bulletins, and distribution of other guidance material, do not appear to have been effective in informing pilots of proper rudder use during upset recovery. Guidance in training aids cautioning against such control inputs and pilot-induced oscillations was not effective in preventing the Air Canada pilots from using alternating rudder inputs in an attempt to control their airplane. The NTSB notes that pilot training regarding rudder system sensitivity and structural certification requirements for the rudder and vertical stabilizer on transport-category airplanes would have provided the accident pilots with additional information about the specific hazard of alternating rudder inputs on these airplanes and the sensitivity of the A320 rudder system at high airspeeds. The actions of the Air Canada flight 190 pilots demonstrate that the need remains for the actions in Safety Recommendation A-02-01. In the 8 years since this recommendation was issued, the FAA has not taken the actions recommended. Therefore, the NTSB reiterates Safety Recommendation A-02-01 and reclassifies it OPEN—UNACCEPTABLE RESPONSE. Therefore, the National Transportation Safety Board reiterates the following recommendations to the Federal Aviation Administration: Modify 14 Code of Federal Regulations Part 25 to include a certification standard that will ensure safe handling qualities in the yaw axis throughout the flight envelope, including limits for rudder pedal sensitivity. (A-04-56) After the yaw axis certification standard recommended in Safety Recommendation A-04-56 has been established, review the designs of existing airplanes to determine if they meet the standard. For existing airplane designs that do not meet the standard, the FAA should determine if the airplanes would be adequately protected from the adverse effects of a potential aircraft-pilot coupling (APC) after rudder inputs at all airspeeds. If adequate protection does not exist, the FAA should require modifications, as necessary, to provide the airplanes with increased protection from the adverse effects of a potential APC after rudder inputs at high airspeeds. (A-04-57) Review the options for modifying the Airbus A300-600 and the Airbus A310 to provide increased protection from potentially hazardous rudder pedal inputs at high airspeeds and, on the basis of this review, require modifications to the A300 600 and A310 to provide increased protection from potentially hazardous rudder pedal inputs at high airspeeds. (A-04-58) In addition, the National Transportation Safety Board reiterates and reclassifies as “Open—Unacceptable Response” the following recommendation to the Federal Aviation Administration: Require the manufacturers and operators of transport-category airplanes to establish and implement pilot training programs that: (1) explain the structural certification requirements for the rudder and vertical stabilizer on transport category airplanes; (2) explain that a full or nearly full rudder deflection in one direction followed by a full or nearly full rudder deflection in the opposite direction, or certain combinations of sideslip angle and opposite rudder deflection can result in potentially dangerous loads on the vertical stabilizer, even at speeds below the design maneuvering speed; and (3) explain that, on some aircraft, as speed increases, the maximum available rudder deflection can be obtained with comparatively light pedal forces and small pedal deflections. The FAA should also require revisions to airplane and pilot operating manuals that reflect and reinforce this information. In addition, the FAA should ensure that this training does not compromise the substance or effectiveness of existing training regarding proper rudder use, such as during engine failure shortly after takeoff or during strong or gusty crosswind takeoffs or landings. (A-02-01) The National Transportation Safety Board issued two safety recommendations and reiterated one safety recommendation (A 04 63) to the European Aviation Safety Agency.

From: NTSB
To: FAA
Date: 7/22/2002
Response: The Safety Board thanks the FAA for the actions it has taken in response to these recommendations. The Board notes that the FAA's review of training programs was limited to the programs of operators of Airbus airplanes. The Board believes that the training programs of operators of other manufacturers' airplanes should also be reviewed. The FAA's plan to use nonregulatory means to meet the intent of Safety Recommendation A-02-01 may represent an acceptable alternative; however, the FAA also indicates that it may ultimately make a regulatory change. The Board will assume, until the FAA indicates otherwise, that the FAA will develop some regulatory changes in pilot training programs in response to Safety Recommendation A-02-01. Pending completion of changes to pilot training programs in response to the recommendations, the determination of whether these revisions will be implemented through the procedures in HBAT 99-07 or through regulatory changes, and the FAA's consideration of reviewing the training programs of operators of other manufacturers' airplanes, Safety Recommendations A-02-01 and A-02-02 are classified OPEN -- ACCEPTABLE RESPONSE.

From: FAA
To: NTSB
Date: 4/15/2002
Response: Letter Mail Controlled 05/07/2002 10:58:22 AM MC# 2020458 - From Jane F. Garvey, Administrator: The Federal Aviation Administration (FAA) agrees with the intent of these safety recommendations and has taken the following action based on the results of the accident investigation to date. The FAA immediately sent several aviation safety inspectors to review the three main Airbus operators' training programs. This review showed that none of the operators conduct training on the rudder in a way that could result in dangerous combinations of sideslip angles and rudder position or other flight parameters. Based upon the review and the FAA's familiarity with other air carrier training programs, the FAA is confident that the operators are not training their pilots to use dangerous combinations of sideslip angles and rudder position or other flight parameters. On February 15, 2002, the FAA issued Notice N8400.28, Transport Category Airplanes--Rudder and Vertical Stabilizer Awareness, to notify principal operations inspectors (POI) of air carriers that operate transport-category airplanes of the operational use of rudder pedals and the potential subsequent effects on the vertical stabilizer. The notice discusses the current facts related to the ongoing accident investigation and discusses the Board's concerns outlined in these safety recommendations. The notice directs POIs to bring the following points to the attention of their air carriers that operate transport-category airplanes: · Sequential full opposite rudder inputs (sometimes referred to as "rudder reversals"), even at speeds below the design. Maneuvering speed, may result in structural loads that exceed those addressed by the 14 CFR Part 25 requirements. In fact, pilots may have the impression that the rudder limiter systems installed on most transport-category prevent sequential full opposite rudder deflections from damaging the structure. However, the 14 CFR Part 25 structural certification requirements for transport-category airplanes do not take such maneuvers into account; therefore, such sequential opposite rudder inputs, even when a rudder limiter is in effect, can produce loads higher than those required for certification and may exceed the structural capabilities of the aircraft. · Pilots may not be aware that, on some airplane types, full available rudder deflections can be achieved with small pedal movements and comparatively light pedal forces. In these airplanes, at low speeds the rudder pedal forces required to obtain full available rudder may be three times greater than those required to obtain full available rudder at higher airspeeds. · Notwithstanding the concerns noted above regarding the potential danger or large and/or sequential rudder inputs in flight, it should be emphasized that pilots should not become reluctant to command full rudder when required and when appropriate, like during an engine failure shortly after takeoff or during strong or gusty crosswind takeoffs or landings. The instruction of proper rudder use in such conditions should remain intact, but should also emphasize the differences between aircraft motion resulting from a single, large rudder input and that resulting from a series of full or nearly full opposite rudder inputs. The notice directs POI's to provide a copy of the notice to representatives of each transport airplane operator for information and voluntary implementation as deemed appropriate by the operator. I have enclosed a copy of the notice for the Board's information. In addition, on February 15, 2002, the FAA contacted selected manufacturers and industry organizations to inform them that it shares the Board's concern regarding pilot training on the use of the rudder in transport-category airplanes. A letter was subsequently sent to raise awareness of the Board's safety recommendations. The FAA will work together with a cross-section of airplane manufacturers, operators, pilot groups, and industry associations in a collaborative process to initiate actions in regard to this safety issue. The FAA's objective is to develop a common approach across all transport-category airplane types to address the intent of the Board's safety recommendations. Based on the aforementioned letter from the FAA and request from transport operators, the selected manufacturers have committed to addressing the issues identified in these safety recommendations. These manufacturers have prepared flight technical operations bulletins that address the Board and FAA shared concerns and will be distributed to all of their operators. FAA Notice N8400.28 is an interim step to ensure that the shared concerns of the Board and the FAA are known to the operators of transport-category airplanes and that they are conveyed to those operators' pilots as quickly as possible. Similarly, the distribution of the technical operations bulletins proposed by the manufacturers will convey the best information available from each manufacturer in respect to those concerns. Changing training program requirements by rulemaking is usually a time-consuming process with no guarantee of final passage into rule. However, by the procedures contained in HBAT 99-07, Flight Standards Policy - Company Operating Manuals and Company Training Program Revisions for Compliance with Current Airplane [or Rotorcraft] Flight Manual Revisions (AFM), certain changes in the approved sections of the Airplane Flight Manual are more readily captured into pilot training programs. As pertinent safety information is developed by the manufacturers, changes in the respective Airplane Flight Manuals may be appropriate. Training programs may also be changed by mutual agreement of the operator and the FAA based on technical operations bulletins. The FAA will continue to review the information developed by manufacturers and the information resulting from the Board's ongoing accident investigation. The FAA may consider. Initiating rulemaking to change training program requirements as appropriate as more information is available.