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12. The last paragraph is intended to cover the whole of the preceding Sections
2.14.1 to 2.14.5 and not just the topic of “insurance”. It may be misleading to put this
paragraph immediately after Section 2.14.5 without another heading. We suggest
adding a new heading “2.14.6 Overall Comments on Section 2.14 ” before this
paragraph.
Appendix I - Professional Events in the PIC's Career during 1997
13. In the item against the date of 1 August in this Appendix, it is stated that (on 1
August) the PIC met with the Flight Operations Manager and indicated then that he did
not accept the decision of the company's inquiry and asked about further avenues of
appeal. SilkAir wishes to state that both the Flight Operations Manager and the Fleet
Manager B737 who met with the PIC on that day cannot recall him saying that he did
not accept the decision. They do, however, recall that he was not happy with it and
Attachment to MCIT/CA/MI185
dated 8 December 2000
M-7
asked if a meeting with the General Manager to appeal his case was appropriate. We
propose to amend the second sentence of this item to read as “During the meeting, the
PIC was not happy with the decision and asked if a meeting with the General Manager
to appeal his case was appropriate.”
Recommendation
14. We propose the addition of the following recommendation:
“To facilitate the recovery of flight recorders after impact into water, it is recommended
that a review of the flight recorders design philosophy be undertaken by the equipment
manufacturers to ensure that the underwater locator beacons (ULB) are fitted to the
flight recorders in such a manner that the ULB would not be separated from the
recorders in an accident.”
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Appendix N
USA Accredited Representative’s Comments on
Draft Final Report
Note: - For ease of reference by readers, NTSC’s comments (in
courier) are printed onto the attached comments by the USA
Accredited Representative.
- Legend :
Times New Roman, Italics – Draft Final Report
Times New Roman, Bold – NTSB’s Comments
Times New Roman, Normal – NTSB’s Comments
Courier New, Italics – NTSC’s Comments
N-1
N-2
N-3
N-4
Comments on Draft Final Report of Aircraft Accident
Submitted by the Accredited Representative of the
United States National Transportation Safety Board
SUMMARY
Introduction
As the state of Design and Manufacture of the Boeing 737 airplane, a United
States Accredited Representative and advisors1 participated in all aspects of the Republic
of Indonesia’s National Transportation Safety Committee (NTSC) investigation into the
December 19, 1997, crash of SilkAir flight MI185 in the Musi River, Palembang,
Indonesia. On October 17, 2000, the Safety Board received the NTSC’s draft Final
Report. These comments are submitted pursuant to Section 6.9 of Annex 13 to the
Convention on International Civil Aviation, which provides that the State conducting the
investigation “shall either amend the draft Final Report to include the substance of the
comments received, or append the comments to the Final Report.”
Review of the draft Final Report revealed that several sections require correction,
clarification, or the inclusion of additional information. Of greatest concern are the
statements in the draft Final Report that the “NTSC is unable to find the reasons for the
departure of the aircraft from its cruising level of FL350 and the reasons for the stoppage
of the flight recorders” and the “investigation has yielded no evidence to explain the
cause of the accident.”
A significant amount of pertinent factual information developed during the 3-year
investigation is either not discussed in the draft Final Report or not fully considered in
analyzing the cause of the accident. In particular, the draft Final Report does not take into
account all of the investigative findings of the Human Performance Group (HPG), which
were documented in a report produced July 30, 1999, and identified as version 6.0. This
version of the HPG report was the only version that was developed through consensus
agreement among the group members, which included representatives from the
Indonesian AAIC (who served as Group Chairman), the Singapore CAA, the United
States NTSB, and the Australian BASI.2 Relevant content from version 6.0 of the HPG
1 Advisors to the U.S. Accredited Representative included representatives from the Federal Aviation
Administration, Boeing Commercial Airplane Group, United Technologies, and Pratt and Whitney.
　
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