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used to meet the requirements outlined in FAR 25-1309 which states,
in part, that the equipment, systems and installations must be
designed so that the occurrence of any failure condition which would
prevent the continued safe flight and landing is improbable, and that
the analysis must take into account the probability of multiple and
undetected failures.
Although the OEM ESWPM provide guidelines on proper wire
separation and segregation, it does not provide the reasons for these
guidelines, nor does it provide the design standards for postmanufacture
modifications. STC applicants can and should refer to
the OEM guidelines when developing their modifications, but they
are cautioned that the ESWPM is not intended as a design standard
but, rather, for use in maintenance and repair of the OEM wiring
installations.
In addition to the above, any new requirements which may arise from
HWG 6 Sub-tasks 6.7 (Wire Separation Requirements), 6.6 (Wire
System Safety Assessment Requirements) and 6.8 (Wiring
Identification Requirements) will be analyzed and documentation
will be updated if appropriate.
2b4 FAA (b) Investigate segregation and separation of wire installed after
manufacture of the aircraft
[COMMENT, also applies to 2d4] The aircraft operators would not
be best suited to accomplish this recommendation. While there may
be some talent at the carriers to tap, this is by and far, not one of our
core competencies. I would put forth that the FAA Technical Center
talent that we have been fortunate to see be assigned to this issue.
This group is a better talent base to investigate this recommendation.
Operators would be able to assist with access to aircraft, carrying out
testing/evaluations that technical experts deem helpful to the
investigation.
OWNERS REMARKS: FAA P3
MJN – subsequent to these comments were received, the FAA have
taken ownership of this item
8 April 19 2002 32
2c2 OEM Review design practices regarding the use of drip guards for this
specific situation. Investigate the use of nondestructive testing to
troubleshoot suspect wire installations
Boeing - Moisture ingression prevention guidelines are specified in
the SWPM and are commonly used during the production of new
airplanes. Detailed visual inspection is the preferred NDT inspection
method to identify the presence of or indications of moisture
ingression.
Airbus - Moisture ingression prevention is presently taken into
consideration during the design of the electrical system. Airbus will
include in the ESPM guidance and practices to maintain the design
provisions for the prevention of moisture contamination to wiring
Lockheed - The Lockheed SWPM manual provides practices specific
to SWAMP locations. Detailed Visual Inspection is the suggested
inspection method for detecting moisture ingression. Drip shields are
used throughout the SWAMP areas exclusively for the protection of
wiring. It is the responsibility of the operator to ensure the design
integrity of the airframe and to incorporate maintenance and
inspection programs that follow industry best maintenance practices
[COMMENT 1 directed at Boeing response] Are visual inspections
sufficient to give a complete picture of whether moisture is or has
been present in wiring? The intrusive inspections showed that visual
inspections do not work to discern the majority of wiring flaws.
With this is mind it seems negligent and wrong to take the position
that visual inspection is the “preferred NDT inspection method”
knowing that it does not work to discern the majority of wiring flaws
including and especially detecting flaws, nicks and cuts within a wire
bundle or under clamps, loss of continuity problems, and sometimes
does not reveal heat or arcing damage in wire insulation.
Though detailed visual inspections are an improvement, there are
many testing procedures and devices available today that go beyond
that. There should be no further delay in evaluating and incorporating
proven NDTs in wire inspection and maintenance programs
Furthermore, ALPA raises the issue that not all aircraft in need have
drip shields. Is this a manufacturer issue or an operator issue? Does
the OEM agree with this assessment?
[COMMENT 2] From the various comments, I do not see an effort to
include in the Task 6 report Part 25 Design guidelines that govern
where heat shields/drip shields are to be installed. While definition
by each OEM as to where such items are to be installed on a type
certified airframe are provided through the maintenance delivery
documentation, there is nothing for operators/STC agencies to use for
　
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