Skip Ribbon Commands
Skip to main content
Safety Recommendation Details

Safety Recommendation A-14-122
Details
Synopsis: On January 7, 2013, about 1021 eastern standard time, smoke was discovered by cleaning personnel in the aft cabin of a Japan Airlines (JAL) Boeing 787-8, JA829J, which was parked at a gate at General Edward Lawrence Logan International Airport (BOS), Boston, Massachusetts. About the same time, a maintenance manager in the cockpit observed that the auxiliary power unit (APU) had automatically shut down. Shortly afterward, a mechanic opened the aft electronic equipment bay and found heavy smoke coming from the lid of the APU battery case and a fire with two distinct flames at the electrical connector on the front of the case. None of the 183 passengers and 11 crewmembers were aboard the airplane at the time, and none of the maintenance or cleaning personnel aboard the airplane was injured. Aircraft rescue and firefighting personnel responded, and one firefighter received minor injuries. The airplane had arrived from Narita International Airport, Narita, Japan, as a regularly scheduled passenger flight operated as JAL flight 008 and conducted under the provisions of 14 Code of Federal Regulations (CFR) Part 129.
Recommendation: TO THE FEDERAL AVIATION ADMINISTRATION: Once the guidance requested in Safety Recommendation A-14-121 has been issued, provide training to your certification engineers and engineering designees on the subjects discussed in the guidance.
Original recommendation transmittal letter: PDF
Overall Status: Open - Acceptable Response
Mode: Aviation
Location: Boston, MA, United States
Is Reiterated: No
Is Hazmat: No
Is NPRM: No
Accident #: DCA13IA037
Accident Reports: ​Auxiliary Power Unit Battery Fire Japan Airlines Boeing 787-8, JA829J
Report #: AIR-14-01
Accident Date: 1/7/2013
Issue Date: 12/1/2014
Date Closed:
Addressee(s) and Addressee Status: FAA (Open - Acceptable Response)
Keyword(s): Hazmat

Safety Recommendation History
From: NTSB
To: FAA
Date: 8/9/2017
Response: We previously said that your plan to improve traceability documentation guidance for applicants in FAA Order 8110.4, “Type Certification,” and a new advisory circular (AC) that you are developing would satisfy these recommendations if the documents provided sufficient guidance for FAA engineers and designees reviewing systems safety assessments. We note that, because of other safety priorities and changes within your organization, the revisions to FAA Order 8110.4 and the complimentary AC have been delayed from June 2016 to a new planned completion date of December 2018. Pending completion of these revisions and development of the complementary AC, Safety Recommendation A-14-121 remains classified “Open—Acceptable Response.” Pending incorporation of this guidance into your training programs for FAA certification engineers and engineering designees, Safety Recommendation A-14-122 remains classified OPEN--ACCEPTABLE RESPONSE. Pending the revisions to FAA Order 8110.4 and the creation of policy documents related to applicant responsibilities to show compliance with the order, Safety Recommendation A-14-123 remains classified “Open—Acceptable Response.”

From: FAA
To: NTSB
Date: 6/19/2017
Response: -From Michael P. Huerta, Administrator: FAA Comment. In our previous letter to the Board on May 20, 2016, the Federal Aviation Administration (FAA) noted that we were developing a revision to FAA Order 8110.4C, Type Certification, as well as a new complimentary advisory circular (AC) that will provide procedural guidance to the applicant. However, due to other safety priorities and changes within our organizations, the draft revision to FAA Order 8110.4C and the draft complimentary AC are still in the early stages of development. The development process, which requires field and public comment periods, can be lengthy. Based on current priorities, we expect to complete the revision to Order 8110.4C and the AC by December 2018. Once the procedural guidance for the applicant is incorporated into an AC, as described in our response to A-14-121, the FAA will incorporate a discussion, as appropriate, of the expectation of the applicant's showing of compliance into the training programs for our certification engineers and engineering designees. I will keep the Board informed of the FAA's progress on these recommendations and provide an update by June 2018.

From: NTSB
To: FAA
Date: 11/15/2016
Response: We continue to believe that your plan to improve traceability documentation guidance for applicants may provide the needed information for FAA engineers and designees reviewing systems safety assessments. However, we believe that you also need to (1) acknowledge the FAA’s role in reviewing for traceability and (2) ensure that the planned revisions to FAA Order 8110.4C and draft Advisory Circular (AC) 25.1309 (“Arsenal”) provide sufficient guidance for thoroughly evaluating an applicant’s systems safety assessment. Pending our review of your proposed revisions to FAA Order 8110.4C and AC 25.1309, which should address our concerns, as discussed above, Safety Recommendation A 14 121 remains classified “Open—Acceptable Response.” Until you incorporate guidance into training programs for FAA certification engineers and engineering designees about how to review an applicant’s systems safety analysis to ensure compliance with traceability requirements, Safety Recommendation A 14 122 remains classified “Open—Acceptable Response.” Pending our review of your proposed revisions to FAA Order 8110.4C and the creation of policy documents related to applicant responsibilities to show compliance with the order, Safety Recommendation A-14-123 remains classified OPEN—ACCEPTABLE RESPONSE.

From: FAA
To: NTSB
Date: 5/20/2016
Response: -From Michael P. Huerta, Administrator: As previously stated in our February 24, 2015, letter to the Board, once the procedural guidance for the applicant is incorporated into an AC, as described in our response to A-14-1 21, the FAA will incorporate a discussion, as appropriate, of the expectation of the applicant's showing of compliance into the training programs for our certification engineers and engineering designees.

From: NTSB
To: FAA
Date: 5/12/2016
Response: CC# 201600220, dated May 12, 2016: The National Transportation Safety Board (NTSB) has reviewed the Federal Aviation Administration’s (FAA) notice of proposed rulemaking (NPRM) titled “Revision of Airworthiness Standards for Normal, Utility, Acrobatic, and Commuter Category Airplanes,” which was published at 81 Federal Register (FR) 13451 on March 14, 2016. The NPRM proposes to amend airworthiness standards for normal, utility, acrobatic, and commuter-category airplanes by removing prescriptive design requirements and replacing them with performance based airworthiness standards. The proposed standards would also replace the current weight and propulsion divisions in small airplane regulations with performance- and risk based divisions for airplanes with a maximum seating capacity of 19 passengers or less and a maximum takeoff weight of 19,000 lbs. or less. In addition, the NPRM proposes to adopt additional airworthiness standards to address certification for flight in icing conditions, enhanced stall characteristics, and minimum control speed to prevent departure from controlled flight for multiengine airplanes. On April 8, 2016, the FAA also published on its website draft Advisory Circular (AC) 23.10 titled “FAA Accepted Means of Compliance Process for 14 [Code of Federal Regulations] CFR Part 23.” The draft AC provides guidance on how to submit a proposed means of compliance (MOC) with Part 23 for acceptance by the Administrator in accordance with proposed section 23.10, “Accepted Means of Compliance,” in the NPRM. This letter provides comments on the NPRM. We will submit separate comments regarding draft AC 23.10. Related Safety Recommendations and Investigations We issued safety recommendations to the FAA and investigated accidents/incidents related to the following topics discussed in the NPRM: Certification One of the FAA’s stated goals in this rulemaking is to encourage the introduction of new and innovative technology. Our investigation of the January 7, 2013, fire in the aft cabin of a Japan Airlines Boeing 787-8, JA829J, which was parked at a gate at General Edward Lawrence Logan International Airport, Boston, Massachusetts, focused on issues related to the safety of new technology introduced to aviation (specifically, new lithium-ion battery applications). Manufacturers and subtier vendors developed design and oversight criteria to be applied and then presented the criteria to the FAA. We found that there was insufficient guidance and education for FAA certification engineers during the type certification process to ensure compliance with applicable requirements. As a result, on December 1, 2014, we issued the following safety recommendations to the FAA: A-14-119 Provide your certification engineers with written guidance and training to ensure that (1) assumptions, data sources, and analytical techniques are fully identified and justified in applicants’ safety assessments for designs incorporating new technology and (2) an appropriate level of conservatism is included in the analysis or design, consistent with the intent of [AC] 25.1309 (Arsenal draft). [Classified “Open—Acceptable Response”] A-14-121 Develop written guidance for your certification engineers and engineering designees about the use of traceability principles to verify that the methods of compliance proposed by type certification applicants for special conditions involving new technology are correct and complete. [Classified “Open—Acceptable Response”] A-14-122 Once the guidance requested in Safety Recommendation A-14-121 has been issued, provide training to your certification engineers and engineering designees on the subjects discussed in the guidance. [Classified “Open—Acceptable Response”] A-14-123 Require applicants to discuss key assumptions related to safety-significant failure conditions, their validation, and their traceability to requirements and proposed methods of compliance during certification planning meetings for type designs involving special conditions. [Classified “Open—Acceptable Response”] We are concerned that with the revisions proposed in the NPRM, and procedures proposed in draft AC 23.10, the FAA’s certification engineering staff will face increased demands to evaluate new technologies, and the FAA may face challenges similar to those encountered with the certification of the lithium-ion batteries in the Boeing 787.

From: NTSB
To: FAA
Date: 4/16/2015
Response: We note your position that the responsibilities discussed in this recommendation should be placed on the applicant rather than on FAA certification engineers and FAA designees. We issued these recommendations because we found in our investigation of the January 7, 2013, incident on the Japan Airlines Boeing 787 that critical assumptions and conclusions made in the safety analyses of GS Yuasa’s and Thales (the suppliers of the components involved in the fire), which were used in Boeing’s electrical power system (EPS) safety assessment, were neither fully delineated nor justified with appropriate data and engineering rationale. However, multiple independent reviews of the EPS safety assessment that Boeing-authorized representatives and FAA certification engineers had conducted did not reveal these deficiencies. We believe that the review process for safety assessments should be designed to closely examine the data used to support conclusions and challenge assumptions, particularly those that could result in significant safety consequences if incorrect. We agree that the applicant has an obligation to show traceability, but when the FAA reviews and approves a systems safety assessment, that review should ensure that adequate traceability is present in the documents. Improving the guidance to applicants on the documentation of traceability needed may provide the needed guidance for FAA engineers and designees reviewing systems safety assessments. However, we believe that you also need to acknowledge the FAA’s role in reviewing for traceability and consider whether the planned revisions to FAA Order 8110.4C and AC 25.1309 (Arsenal draft) described in your letter will provide sufficient guidance for thoroughly reviewing an applicant’s systems safety assessment. Pending your making the revisions to FAA Order 8110.4C and AC 25.1309 (Arsenal draft) that you described and replying to us about the sufficiency of these documents as discussed above, Safety Recommendation A-14-121 is classified “Open—Acceptable Response.” Pending your incorporating guidance into the training programs for FAA certification engineers and engineering designees about how to review an applicant’s systems safety analysis to ensure compliance with the traceability requirements, Safety Recommendation A-14-122 is classified OPEN—ACCEPTABLE RESPONSE. Pending revisions to FAA Order 8110.4C and the creation of policy documents related to applicant responsibilities for showing compliance with the order, Safety Recommendation A-14-123 is classified “Open—Acceptable Response.”

From: FAA
To: NTSB
Date: 2/24/2015
Response: -From Michael P. Huerta, Administrator: Once the guidance for the applicant is incorporated into draft AC 25.1309-Arsenal, per the FAA response to A- 14-12 1, the FAA will evaluate the option of incorporating a discussion of the expectation of the applicant's showing of compliance into the training programs for our certification engineers and engineering designees.