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aircraft, to specific applications, or in response to specific conditions. Nondestructive testing is not, for
example, recommended for indiscriminant application – its recommended application is restricted to ensure
both practicality and utility. Furthermore the recommendations are identified as options, not all of which
must be implemented simultaneously to ensure safety.
Boeing Remarks.
As the commenter states, Boeing is justifiably proud of its products and processes. It is also committed to
making air travel, the safest mode of transportation, even safer. That is why Boeing has aggressively
supported, and will continue to support the efforts of the aging systems non-structural plan. It is the right
thing to do.
With respect to the comments the process used by to formulate responses to recommendations, Boeing
carefully considered each and every recommendation, not just those assigned to OEMs, and formulated an
appropriate reply given the information presented in both the intrusive and non-intrusive inspection reports.
In many cases Boeing felt that reassignment of recommendations aimed toward the airlines were more
appropriately addressed by the OEMs. In each case the Boeing responses accounted for the results
emanating from the working groups, from years fleet experience, and from inputs directly from our
operators. We diligently evaluated our processes when such a recommendation was made and carefully
considered the need for additional research and development. The merits of each recommendation were
assessed before formulating our response.
Our responses and the actions we have committed to undertake were not taken lightly. The Boeing
commitment to enhance the safety of the fleet, both older airplanes and those just entering service drove
our responses. We believe we are adjusting our processes, modifying our recommended actions, and
8 April 19 2002 55
undertaking additional tasks as a result of the IIWG recommendations that will further enhance the safety
of wiring within the in-service fleet. Although not a complete list, Boeing is:
! Implementing changes to our wiring designs
! Developing and providing new procedures for the maintenance and repair of wiring
! Making changes to our certification standards
! Developing and implementing a wiring training course
! Updating our scheduled wiring maintenance programs, and voluntarily implementing this change
on out-of-production airplanes
! Conducting research on wire testing and wiring protection devices
! Actively advocating the removal of flammable contaminants
! Promoting all the recommendations to our operators
! Providing fleet experiences and specific examples to the industry
! Preempting the industry by collecting wiring information separate from systems effects
[COMMENT 3]
(1) I don’t know how to interpret the lack of comments under the Airbus and Lockheed Titles where OEMs
are tasked as the owner of the particular recommendation. Is the Boeing position agreed upon by all three
OEM participants or are we waiting for Airbus and Lockheed positions? I would be interested in seeing
any position differences between the major aircraft suppliers surfaced for ATSRAC review.
(2) The work done in the development of Arc Fault Circuit Breakers thus far is very encouraging. Should
this technology continue to the point of successfully detecting arcing in aircraft wiring systems and NOT
cause excessive troubleshooting problems from nuisance tripping, future aircraft designs will operate with
an added level of protection from on board electrical fire events? As an operator, selective installation on
certain critical or problematic circuits may prove valuable in the future after case by case assessment of an
airworthiness concern through the ATA’s Airworthiness Concern Coordination Process.
FAA Remarks
(1) All three OEMs have now supplied comments for the majority of the recommendations. The separate
OEMs positions will be consolidated into one position/plan for action and reviewed and accepted by the
FAA.
(2) AFCBs appear to have the potential to be a valuable tool in the detection of arcs and prevention of
damage typically associated with arching events. Currently AFCBs are being considered for non-essential
systems only in order to gain service experience, collect data, and monitor their operation. When the
design, installation, and operation of AFCBs reach maturity they will be considered for installation to
protect wiring on all airplane systems.
Pan American
Aviation Safety Team
(PAAST):
Regional Initiative to
Achieve a Global Safety Goal
GEASA/3
Cartagena, Colombia
March 24 – 26 2004
Raymond Ybarra
Regional Director
　
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