European Aviation Safety Agency

Flammability Reduction

Purpose of the meeting

Review of conclusions from June 2004 workshop
Background
Fuel tank safety Rulemaking framework for FTS
Rulemaking task for FRS
Ignition prevention
Novelty for civil aviation – reducing flammability
Flammability Reduction The FAA NPRM
Issues
Comments to FAA
Open discussion
Summary-conclusions

February 6th, 2006 Cologne Laurent Gruz February 6, 2006 Flammability Reduction Slide 2

European Aviation Safety Agency European Aviation Safety Agency

Review of conclusions from

Purpose of the meeting June 2004 workshop

Purpose is to exchange views on The RIA dated June 2004 will be published on the
web-site in July.
flammability reduction systems.
Status: Done

Three presentations are scheduled: The revision of this RIA to take into account new
elements brought by the FAA NPRM consultation
EASA will done by an EASA Rulemaking Group
Mr des Clers (independant expert)
Status: Rulemaking group yet to be set-up
The EASA will review the results of the study
Airbus
done, at the request of FAA, by the Sandia
Any other? Laboratory relative to the efficiency of SFAR-88
• Status: Study is not yet available. EASA does not have the
Presentations will be followed by a resource to commission an independent one and is not convinced
such study be able to provide definitive conclusions. EASA agrees
discusion and summary-conclusions that the influence of the efficiency of SFAR-88 actions is a key
issue of cost-benefit analysis.

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Review of conclusions from

June 2004 workshop
Background

Keep the communication channels open: Following the Boeing 747 in flight explosion

This is likely to take the form of another information which occurred in July 1996 (‘TWA 800’),
meeting with a wider audience including national failures within the fuel system that could
Authorities after summer.

Status: Today’s meeting. Meeting information was put on
result in explosion have attracted a lot of
EASA web-site at events attention.
AEA offered a Fuel tank Safety focal Since 1990, there has been 3 events (a PAL
points for discussions with EASA 737-400 in Manila, 1990, TWA 747 in 1996,

Status: offer is acknowledged with thanks. Such focal point and a Thai 737-300 in 2001).
would find its natural place in the rulemaking group
mentioned above. Subsequently, actions were launched into
two directions: ignition prevention and
flammability reduction system.

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European Aviation Safety Agency European Aviation Safety Agency

Rulemaking framework for FTS Rulemaking task for FRS

The rulemaking framework for such issues is Task 25.056 Inerting/Fuel Tank Safety:
somewhat complex because they need to address updated proposal
generally speaking the following items:
Amendment to certification specifications to improve the Specific tasks:
standards for fuel tank systems. This will address the
Evaluate need to revise the impact assessment in order to take
case of future TC and future amendments to TC/ future into account new elements brought by the results of the FAA
STC in accordance to the changed product rule. consultation (e.g. economics)
Requirement to Design Approval Holders (e.g. TC, STC
Prepare modifications to CS-25 to include requirements for FRS for
holders) to review their existing design to identify future airplanes
compliance with the amended certification specification
Prepare technical elements for production cut-in around 2008
Requirements for operators to introduce resulting Schedules
modifications in individual aircraft and maintenance
TOR drafting under progress.
programme

NPA and draft technical elements for production cut-in 3Q 2006
Requirement to install certain systems in aircraft in

CS Final and technical elements for production cut-in available by
production and possibly in aircraft in service
Attachment 1 3Q 2007

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Rulemaking task for FRS Ignition prevention

An ignition prevention effort was launched, re-enforcing the

Task 25.056 Inerting/Fuel Tank traditional certification approach: keep hazardous sparks
Safety: and energy sources out of the fuel system.
Reactions are welcome on these updated FAA published a revised requirement – 25.981 – in FAR 25
Amdt 102, EASA in CS 25 Amdt 1; those requirements have
proposals similar intent but differ in some respects.
Using those revised requirements, FAA and EASA conducted
design reviews of in-service aircraft. Those reviews are now
nearly finished; the last certification and maintenance
issues (including the ‘CDCCL’ – Critical Design Control
Configuration Limitation) are currently being closed.
EASA has promoted an aggressive AD publication schedule,
and is generally ahead of FAA by 18-24 months.

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European Aviation Safety Agency European Aviation Safety Agency

The novelty : flammability The novelty : flammability

reduction (1/3) reduction (2/3)
The risk of an ignition source appearing in the tanks prompted FAA to In the course of 2003, Boeing decided to propose this system on
investigate reducing the flammability exposure of the air / fuel vapours new production airplanes, and to make a similar system available
mixture present within the fuel system, in line with NTSB for retrofit to in-service aircraft.
recommendations.
In 1998 FAA tasked an ARAC Working Group with studying various On 17th February 2004, the FAA Administrator announced that
alternatives. The ARAC group concluded that at this stage the only viable the FAA intended to develop rulemaking that would propose
alternative could be based upon ground inerting, and further research was requiring the introduction of flammability reduction measures on
necessary if FAA wanted to mandate another option. all affected large transport airplane. The press release also stated
In 2000 FAA tasked another group to investigate the detail of ground that the FAA proposal would also prompt a retrofit of 3 800 Airbus
inerting – it was then judged impractical. and Boeing airplanes (the US fleet) over 7 years.
FAA undertook some research with the intention was to develop a simple FAA finally published the corresponding NPRM on 18th of
system from the existing technology, tailored for civil aviation needs. By November 2005.
assuming that a 12% oxygen concentration prevents ignition and flame
propagation into explosion with a pressure rise sufficient to damage EASA had taken a much simpler view, considering that most of
aircraft structure, and minimizing (not eliminating) the exposure time to the problem is due to heat transfer to the fuel tank. The
concentrations greater than 12%, in 2002 the FAA was able to propose a necessary energy for ignition to cause an explosion decreases
more realistic system concept. when temperature increases and all recent events occurred on
This system concept was disclosed to the industry in the spring of 2002. heated tanks. The requirement to minimize flammability by
The system concept was evaluated in flight by both Airbus and Boeing, eliminating unnecessary heat transfer into the tanks was induced
respectively on an Airbus A320 and a Boeing 747-400. into CS-25 by Amdt 1.

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The novelty : flammability

reduction (3/3)
The FAA NPRM (1/2)
In 2004, EASA/JAA drafted a Regulatory Impact Assessment (RIA) The NPRM introduces into Part 25 the certification requirements
on the subject, extract of the conclusion:- for the Flammability Reductions Means (FRM) in a new Appendix K
and rules permitting the determination of the flammability
“On the basis of this RIA, it is considered that a production exposure (Appendix L). Those requirements are generally similar
cut-in is justified, with regard to the safety benefit. It is, to the Special Condition used to certify similar systems on the
therefore, recommended that the necessary rulemaking be Boeing 747 and 737, which is harmonised with EASA.
initiated, as quickly as possible, to require the introduction of
FRS into all new production aircraft with high flammability Those requirements would be applicable to future designs,
fuel tanks by 2008. At this time, a full retrofit is not basically requiring a FRM on anything except for aluminium wing
considered justified. The additional costs to industry (in tanks. Fuel tanks installed within the fuselage contour or made of
addition to the production cut-in costs of FRS) are high when non conductive material (composite) would be required to have a
compared to the additional safety benefit in terms of hull FRM.
losses prevented. However, in the absence of a case for
mandating a full retrofit programme, further consideration For in-service aircraft, the NPRM is introducing requirement for
could be given to a solution based on each affected operators through changes in Part 91, 121, 125 and 129 (for N-
manufacturer’s position for their individual models.” registered airplanes), basically preventing them from operating
aircraft with high flammability exposure tanks beyond a certain
date. An alternative to the FRM is offered, as fuel tanks can be
Note : the RIA did not take into account the FAA NPRM and some of made ‘explosion proof’ (able to withstand the effect of an
its consequences on costs and benefits. explosion) by embodiment of an Ignition Mitigating Means (IMM)
– an unlikely solution.

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European Aviation Safety Agency European Aviation Safety Agency

The FAA NPRM (2/2) Issues raised

As for SFAR 88, this retrofit is applicable to aircraft carrying more The main question is probably: should EASA take a
than 30 pax or a payload of 7 500 lbs; however, this rule different course from FAA?
apparently excludes ‘airplane designed solely for all-cargo
operations’. This affects the centre tanks of Boeing 707, 727, 737,
747, 757, 767, 777 and Airbus A300, A310, A320 and A330/340. Are the implementation costs justified by the expected safety
enhancement?
The NPRM defines the date for having the modification, ranging
from December 2012 to December 2014. To avoid the classical Are there any alternatives (e.g. limiting heat input, by reducing
asymptotic curve toward the final date characterizing retrofits, it pack running on ground)?
is also required that each operator will have retrofitted 50% of its
fleet at mid-term. Is the efficiency of the FAA proposed measure sufficient to deal
with the risk?
TC holders are required to develop design solutions, through a
new Subpart I introduced into Part 25, dealing with continued Could a different course by EASA lead to additional liability /
airworthiness and safety improvement (not suitable for CS 25). responsibility questions?

All TC holders are required to submit a flammability exposure Are the applicability criteria sufficiently justified?:
analysis.

passenger versus cargo aeroplanes

30 pax or 7500 lbs payload
Other intermediate conditions apply for current certification
projects.
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Comments to FAA Summary-conclusions

Industry regrets that EASA does not launch a study on the effectiveness of
EASA will write to FAA to present its SFAR 88, but maybe industry can commission study itself
Effectiveness of many aspects of FAA NPRM proposed measures is
position taking into account the questioned
Self-ignition is an issue to be considered in validating the effectiveness
outcome of this meeting FAA NPRM generates considerable comments
Cost estimates
Ground effect
Accident rates
Effectiveness of SFAR 88
Exclusion of freighters
Etc.
RIA should also consider safety of mechanics
EASA RIA should be updated before closing date of NPRM
Industry regrets that EASA does not formally comment the FAA NPRM
EASA will establish its final position towards the extend of retrofit based on
the updated RIA
Harmonisation is essential
EASA will discuss industry concerns with FAA colleagues
Industry will formally request EASA to comment on NPRM

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European Aviation Safety Agency European Aviation Safety Agency

The regulatory framework for

Attachment 1
fuel tank safety issues
Outline of EASA rulemaking framework for Design Approval Holder rules:
Fuel tank Safety Long term: included in the proposed
revision of 1592/2002 to extend EASA
scope

Proposed revision to article 5 would include in the
TC: Syllabus for Maintenance certifying staff type
rating, syllabus of pilot type rating, MMEL, additional
airworthiness specifications for a given type of
operations

Task 21.039 of rulemaking inventory: Incorporation
of ‘operational’ issues in Type certificate.

NPA scheduled 3 quarter 2006

Opinion scheduled 3 quarter 2007.

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The regulatory framework for The regulatory framework for

fuel tank safety issues fuel tank safety issues

Design Approval Holder rules: Maintenance rules:

In the meantime: Maintenance programmes

Use of letters or Airworthiness Directives to request
Part-M M.A.302 requires maintenance programmes to be
‘reviews’ by Design Approval Holders. based on data produced by TC holders, STC holders or
organisations required to by Part-21.

Anything else requires the approval by the competent
authority. In the case of ALIs this is EASA.
Maintenance Data

Part-145 145.A.45 requires AMOs to hold and use current
maintenance data.

The maintenance instructions can only be modified with the
approval of the competent authority.

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European Aviation Safety Agency European Aviation Safety Agency

The regulatory framework for The regulatory framework for

fuel tank safety issues fuel tank safety issues
Maintenance rules: Maintenance rules:
Maintenance Training

Part-145 145.A.30(e) and Part-M M.A.706 require Shared responsibility
personnel to be competent and this competence to be In the EU system, the responsibility is
evaluated in view of their tasks.

This is part of the organisation’s expositions that is shared between the operators, the
approved by the competent authority. maintenance organisations and the design
Control of aircraft configuration organisations.

Part-M M.A.301 requires operators to control the
configuration of their aircraft and to have an embodiment The safeguards are already built into the
policy for non mandatory modifications and for repairs European structure and it is not planned

Furthermore, M.A.304 requires modifications and repairs to
be accomplished in compliance with Part-21. The resulting
to redistribute the responsibilities.
maintenance data will then become maintenance data that
needs approval to be changed.

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