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limit load excursion.
Public Hearing Exhibit 7Q, pages 5 and 6, revealed a total of 11 “high load” events.
These high load events all happened on the A300 or A310. Seven of the events exceeded
load limit and three exceeded ultimate load. Five of the high load events involved rudder
doublets. Yet, Airbus remained silent. This is peculiar since limit load, according to Part
25, is “never to be seen in operational use.” Also, Airbus was required to inform the
DGAC of these unsafe conditions in accordance with the BASA.
BASA and FAA AC 21-23A also specify requirements for continued airworthiness. The
FAA AC 21-23A states:
“When a safety concern arises, the FAA cooperates with its partner to determine the
appropriate corrective action to be taken by operators or owners of affected U.Sregistered
aircraft. The FAA expects exporting CAA’s [sic] to keep it informed of
corrective actions that they believe are required for the safety of U.S.-registered
aircraft.”
The IPA, in paragraph 3.3.0.0(a), states that the exporting authority is responsible “…for
resolving in-service safety issues related to design or production. The exporting authority
shall provide applicable information which it has found to be necessary for mandatory
modifications, required limitations and/or inspections to the importing authority to ensure
continued operational safety of the product, part or appliance.”
Paragraph 3.3.0.2 of the IPA, “Unsafe Conditions and Mandatory Continuing
Airworthiness Actions,” states in paragraph 3.3.0.1(4):
“Notifying the importing authority of the unsafe condition and the necessary corrective
actions by submitting a copy of the mandatory continuing airworthiness action….”
4 The Cooper-Harper Pilot Rating is a numerical Handling Quality Rating (1-10) scale that assigns an
empirical value, indicating the workload task and the performance that could be obtained of a pilot.
23
For U.S. operators, that airworthiness action would be issued in the form of an
Airworthiness Directive (AD).
By its failure to act, Airbus perpetuated an unsafe condition. The manufacturer is
responsible for resolving these unsafe conditions—not the airlines or the civil authorities.
In response to the NTSB recommendations, American Airlines developed policy and
procedural guidance to mitigate the hazard that had been identified. This action was too
late for the crew and passengers of AA 587.
2. Intended Rudder Usage
Airbus failed to accurately inform the aviation community about the intended purpose of
the rudder on their aircraft. Their testimony at the AA 587 Public Hearing conflicts with
their published documents and the A300-600 FCOM. Furthermore, the FAA failed to
ensure that accurate information was disseminated to the operators of the A300.
In June of 1998, Airbus published a FAST Special Technical Digest. The article,
“Aerodynamic Principles of Large-Airplane Upsets,” was authored by several people
including Bill Wainwright, Chief Test Pilot for Airbus and Larry Rockliffe, Chief Pilot
and Flight Training Director for Airbus Service Company Inc. The summary of the article
states:
“Each upset event may result from different causes, but the concepts for recovery are
similar.
· Use whatever authority is required of the flight controls” (Dempster 12).
In December of 1998, Airbus published an Airplane Upset Recovery Training Aid and
included a letter that stated the manual was “part of an industry effort to reduce loss of
control accidents and incidents” (Airplane Upset letter). The letter encouraged the user to
“use this training aid to ensure your pilots participate in an effective airplane upset
recovery training program.” In a section 2.6.2.3, titled “Use of Full Control Inputs,” the
manual reads:
“Flight control forces become less effective when the airplane is at or near its critical
angle of attack or stall. Therefore, pilots must be prepared to use full control authority,
when necessary. The tendency is for pilots not to use full control authority because they
rarely are required to do this. This habit must be overcome when recovering from severe
upsets.”
No limitations to rudder use or any prescribed intended rudder use were mentioned in
either publication, nor were any rudder qualifications published in the FCOM.
In Mr. Rockliffe’s testimony at the public hearing, he states a completely different use of
the rudder:
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“I think that we need to be clear and -- well, we need to be clear that aileron and normal
roll control is -- is through ailerons and roll spoilers conducted through the yoke or in
　
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