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Safety Recommendation Details

Safety Recommendation A-09-119
Details
Synopsis: On June 4, 2007, about 1600 central daylight time, a Cessna Citation 550, N550BP, impacted Lake Michigan shortly after departure from General Mitchell International Airport, Milwaukee, Wisconsin (MKE).1 The two pilots and four passengers were killed, and the airplane was destroyed. The airplane was being operated by Marlin Air under the provisions of 14 Code of Federal Regulations (CFR) Part 135 and departed MKE about 1557 with an intended destination of Willow Run Airport (YIP), near Ypsilanti, Michigan. At the time of the accident flight, marginal visual meteorological conditions prevailed at the surface, and instrument meteorological conditions prevailed aloft; the flight operated on an instrument flight rules flight plan.
Recommendation: TO THE FEDERAL AVIATION ADMINISTRATION: Require airplane manufacturers to develop guidance on the identification of circuit breakers that pilots need to identify quickly and pull easily during abnormal or emergency situations and to provide such guidance, once developed, to operators of those airplanes.
Original recommendation transmittal letter: PDF
Overall Status: Open Acceptable Alternate Response
Mode: Aviation
Location: Milwaukee, WI, United States
Is Reiterated: No
Is Hazmat: No
Is NPRM: No
Accident #: CHI07MA160
Accident Reports: Loss of Control and Impact with Water, Marlin Air Cessna Citation 550, N550BP
Report #: AAR-09-06
Accident Date: 6/4/2007
Issue Date: 10/27/2009
Date Closed:
Addressee(s) and Addressee Status: FAA (Open Acceptable Alternate Response)
Keyword(s):

Safety Recommendation History
From: FAA
To: NTSB
Date: 9/6/2019
Response: -From Steve Dickson, Administrator: On May 4, 2018, the Federal Aviation Administration (FAA) issued Advisory Circular (AC) 25-7D, Flight Test Guide for Certification of Transport Category Airplanes. Paragraph 34.4.3.3 of the AC includes the following new guidance, previously discussed in our earlier responses for non-normal or emergency procedures involving flight crew use of circuit breakers: 34.4.3.3. The applicant should minimize the use of non-normal or emergency procedures involving flightcrew use of circuit breakers. Non-normal or emergency procedures should not call for pulling circuit breakers or resetting or replacing circuit protective devices in flight, except as part of an approved fault-clearing and isolation procedure. The applicant should evaluate, during ground and/or flight tests, the location and identification of circuit protective devices whose actuation is called for in non-normal or emergency procedures to confirm their accessibility as part of the review and approval of those procedures. The AC can be found at the following website: https://www.faa.gov/regulations_policies/advisory_circulars/index.cfm/go/document.information/documentID/1033309. Based on the actions noted above, and with the publication of the AC and the SAFO, I believe the FAA has effectively addressed these recommendations and our actions meet the original intent, and consider our actions complete.

From: NTSB
To: FAA
Date: 10/5/2016
Response: We have reviewed your proposed revisions to Advisory Circular (AC) 25-7C, “Flight Test Guide for Certification of Transport Category Airplanes,” which address evaluating circuit breaker accessibility on future airplane certification programs. We continue to believe that your plan to update AC 25-7C will constitute an acceptable alternative means, in part, of addressing Safety Recommendation A-09-119, as the AC will apply only to future airplane certification programs and not to airplanes that are currently in service. Pending issuance of AC 25-7D, Safety Recommendation A-09-119 remains classified OPEN--ACCEPTABLE ALTERNATE RESPONSE.

From: FAA
To: NTSB
Date: 7/12/2016
Response: -From Michael P. Huerta, Administrator: The Federal Aviation Administration (FAA) intends to update the current language in Advisory Circular (AC) 25-7C, Flight Test Guide for Certification of Transport Category Airplanes, to include the following guidance: "Non-normal or emergency procedures involving flightcrew use of circuit breakers should be minimized and should not call for pulling circuit breakers or resetting or replacing circuit protective devices in flight, except as part of an approved fault-clearing and isolation procedure. The location and identification of circuit protective devices whose actuation is called for in non-normal or emergency procedures should be evaluated during ground and/or flight tests to confirm their accessibility as part ofthe review and approval of those procedures." This proposed guidance for AC 25-7D would apply to future certification programs, and would thus provide the "lasting value" the Board mentioned in its January 10,2012, letter. However, due to increased workload and resource prioritization, the publication of AC 25-7D for public comment has been delayed until late 2016. Once AC 25-7D is published, we intend to address the existing fleet of aircraft through the issuance of a Safety Alert for Operators to recommend effective identification of all circuit breakers specifically called out in the Airplane Flight Manual during an emergency or abnormal procedure. I will keep the Board informed of the FAA's progress on this safety recommendation and provide an update by July 31,2017.

From: NTSB
To: FAA
Date: 11/7/2013
Response: The FAA previously informed us that its review of Part 25 requirements found that current standards regarding the marking and accessibility of circuit breakers are appropriate and that no revisions are warranted. However, the FAA agrees with us that accessibility of flight deck circuit breakers, specifically those called out in the AFM abnormal or emergency procedures, should be assessed during certification flight tests. Consequently, the agency plans to include, in its revisions to Advisory Circular (AC) 25-7C, “Flight Test Guide for Transport Category Airplanes,” guidance regarding evaluation of circuit breaker accessibility on future airplane certification programs. The inclusion of this information in AC 25-7C will constitute an acceptable alternative means, in part, of addressing Safety Recommendation A-09-119, as the AC will apply only to future airplane certification programs and not to airplanes that are currently in service. Pending issuance of AC 25-7C, Safety Recommendation A-09-119 is classified OPEN—ACCEPTABLE ALTERNATE RESPONSE. Because the guidance contained in the AC will not apply to in-service airplanes nor will operators be required to incorporate the guidance, pending a requirement for the development of guidance for operators of in-service airplanes specifying which circuit breakers pilots need to identify quickly and pull easily during abnormal or emergency situations, and incorporation of this guidance by operators, Safety Recommendation A-09-120 is classified “Open?Unacceptable Response.”

From: FAA
To: NTSB
Date: 8/8/2013
Response: -From Michael P. Huerta, Administrator: The FAA reviewed part 25 certification requirements to determine if more specific guidance for the marking and accessibility of circuit breakers was needed. Our review confirmed that current standards, including the marking requirements of section 25.1555(a), provide appropriate certification standards regarding identification and accessibility of flight deck circuit breakers. We also reviewed a sample of transport category AFM with regard to the use of circuit breakers in managing aircraft abnormal or emergency conditions. While circuit breaker use is mentioned in a small number of procedures, their use is not time-critical. Circuit breaker manipulation is typically a later step in the procedure after the initial malfunction or failure has been controlled. Circuit breakers are most often used to de-energize or render a system safe after the immediate effects of the malfunction have been managed by other means. In response to the Board's most recent letter dated January 10, 2012, we agree that accessibility of flight deck circuit breakers should be assessed during certification flight test, specifically those called out in the APM abnormal or emergency procedures. We anticipate publishing the revisions to FAA Advisory Circular 25-7C, Flight Test Guide for Transport Category Airplanes, in the summer of2014. The revised Advisory Circular incorporates guidance regarding evaluation of circuit breaker accessibility associated with abnormal and emergency procedures to ensure application on future certification programs. We find that the revision addresses the intent of these recommendations and will provide the "lasting value" the Board mentioned in its January 10, 2012, letter. I will keep the Board informed of our progress on Safety Recommendations A-09-119 and -120 and provide an update by August 30, 2014.

From: NTSB
To: FAA
Date: 1/10/2012
Response: We note that the FAA’s review of the Part 25 certification requirements regarding the marking and accessibility of circuit breakers found that the current standards are appropriate. The FAA also agrees that it is a best practice to use collars or other means of identifying circuit breakers that must be quickly located and easily pulled as part of a flightcrew’s response to some abnormal or emergency situations. Although the FAA does not plan to revise the Part 25 standards, it is currently evaluating the most appropriate means of communicating the intent of this recommendation to manufacturers and operators. The issuance of such guidance may represent an acceptable alternative response to this recommendation. We believe that a consideration of crewmembers’ ability to quickly locate and pull a circuit breaker should be part of the review and approval of any abnormal or emergency response procedure that involves pulling a circuit breaker. We are concerned that any guidance that the FAA develops may be lost or forgotten several years into the future, when a new airplane is type certificated. We ask the FAA to describe how it will ensure that the guidance it develops has lasting value. Pending issuance of the guidance, Safety Recommendation A-09-119 is classified OPEN—ACCEPTABLE ALTERNATE RESPONSE.

From: FAA
To: NTSB
Date: 10/4/2011
Response: From J. Randolph Babbitt, Administrator: We have reviewed our part 25 certification requirements to determine if further, more specific guidance for the marking and accessibility of circuit breakers is needed. We believe our current standards, in conjunction with the marking requirements of § 25.1555(a), provide an appropriate certification standard regarding the identification and accessibility of flight deck circuit breakers. Some operators add collars or other additional identification as an operational aid to pilots. When used appropriately, these means of identification represent a best practice and can improve the flightcrew's ability to locate a specific circuit breaker that may be called out by in-night non-normal procedures. We are evaluating the most appropriate means of communicating the intent of this recommendation to manufacturers and operators; however, we do not plan to change our requirements. I will keep the Board informed of the FAA’s progress and provide an updated response to this recommendation by August 2012.

From: NTSB
To: FAA
Date: 11/15/2010
Response: The FAA's planned review of its current policy to determine whether further guidance is needed related to the marking and accessibility of circuit breakers needed during abnormal and emergency procedures is a first step in the FAA's response to this recommendation. After this guidance is revised, the FAA will need to require manufacturers to make appropriate revisions to their abnormal and emergency procedures and to provide this revised guidance to operators. Pending completion of the recommended action, Safety Recommendation A-09-119 is classified OPEN – ACCEPTABLE RESPONSE.

From: FAA
To: NTSB
Date: 4/28/2010
Response: Letter Mail Controlled 5/5/2010 12:17:19 PM MC# 2100167 - From J. Randolph Babbitt, Administrator: The FAA concurs with the intent of this recommendation, specifically that any control required to handle abnormal or emergency situations must be clearly marked and easily accessible to the flightcrew from their normal seated position. It is also the FAA's current policy that circuit breakers should not be used as the primary means to remove or reset power unless specifically designed as a switch. The FAA will review current policy to determine if further, more specific guidance related to the marking and accessibility of circuit breakers related to abnormal or emergency procedures is needed. I will provide an update on the progress of this safety recommendation by March 2011.