EAPAS
EAPAS
Participant Guide
Enhanced Airworthiness Program for Airplane Systems/Fuel Tank Safety Training for Part 26 DAH Requirements
HQ-006907.INDD
PARTICIPANT GUIDE
Version 1.1 Note: The information contained in this Participant Guide is presented by the instructors through captioned video and audio. A transcript of the captioning is also available with each with each video segment.
GENERAL INTRODUCTION TO COURSE.............................................1 Instructor Introductions .......................................................................1 Receiving Credit for this Course .........................................................2 COURSE INTRODUCTION .....................................................................3 Introduction To Wiring Safety Concerns and IVT ...............................3 Commentary By Peggy Gilligan, AVS-2 .............................................4 What the IVT and Training Will Provide..............................................5 IVT OBJECTIVES AND OUTLINE .........................................................6 Objectives for the IVT .........................................................................6 Outline of the EAPAS/FTS IVT...........................................................7
Course Introduction
EAPAS OVERVIEW
EAPAS/FTS: Training for Part 26 DAH Requirements Module 1: EAPAS IVT Overview
Course Number: 24910 Course Manager: Massoud Sadeghi Version Date: May, 2007 Version Number: 1.0
Instructor Introductions
Massoud Sadeghi, ANM-117. Stephen Slotte, ANM-111. Fred Sobeck, AFS-308.
Course Introduction
COURSE INTRODUCTION
Introduction to Wiring Safety Concerns and IVT
Introduction
Late 1980s, wiring safety concerns raised due to accidents & incidents Investigations found common degrading factors in airplane electrical wiring systems Investigation into wiring issues done by industry, civil aviation authorities, other government agencies
EAPAS IVT, Course 24910, Mod 1 Federal Aviation Administration
Safety concerns about wiring systems in airplanes were reinforced by the TWA accident in 1996.
Course Introduction
The existing fleet will have to comply with the new 14 CFR part 26 requirements, while new applicants will be complying with new and revised part 25 requirements. This shift also relies heavily on communication between the affected parties.
Course Introduction
EAPAS IVT
Overview of new rulemaking package Focus on specific aspect of package: design approval holder (DAH) requirements
EAPAS IVT, Course 24910, Mod 1 Federal Aviation Administration
IVT Objectives
Upon completion of IVT, you will be able to:
Describe origin and goal of EAPAS program. (Mod. 2) Identify the improvements that result from EAPAS rulemaking. (Mod. 2) Describe new and revised electrical wiring interconnections systems (EWIS) certification requirements of part 25 subparts D, E, F, H, and Appendix H and part 26, and the operational requirements of parts 91, 121, 125 and 129. (Mod. 2)
EAPAS IVT, Course 24910, Mod 1 Federal Aviation Administration
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11
IVT Outline
Mod 2: Overview of EAPAS and EWIS Mod 3: EAPAS DAH Requirements of Part 26 Mod 4: Roles and Responsibilities
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PARTICIPANT GUIDE
Version 1.1 Note: The information contained in this Participant Guide is presented by the instructors through captioned video and audio. A transcript of the captioning is also available with each with each video segment.
INTRODUCTION TO MODULE 2
INTRODUCTION TO MODULE 2 ....................................................1
LESSON 2: ELECTRICAL WIRING INTERCONNECTION SYSTEMS (EWIS) CERTIFICATION AND OPERATIONAL RULES
INTRODUCTION TO EWIS ...........................................................17 Module 2, Lesson 2, Objectives ...............................................17 Lesson Outline .........................................................................18 EWIS DEFINED.............................................................................19 EWIS is a System ....................................................................19 Existing Regulatory Shortcomings ...........................................23 A New Approach to Wiring .......................................................29 EAPAS RULEMAKING PACKAGE ..............................................31 Overview ..................................................................................31 Parts 1 and 21..........................................................................38 Part 25 .....................................................................................39 Part 25 Appendix H ..................................................................50 Part 26 .....................................................................................53 Parts 91, 121, 125, and 129 .....................................................54 EAPAS Advisory Circulars .......................................................56 LESSON 2 SUMMARY .................................................................58
Introduction to Module 2
Introduction to Module 2
Overview of enhanced airworthiness program for airplane systems (EAPAS) rulemaking package and electrical wiring interconnection systems (EWIS)
Background & goal of EAPAS rulemaking EWIS certification & operation regulations
Appendix A of this Participant Guide has definitions of key terms for the IVT.
Mod 2, Lesson 1
Introduction
INTRODUCTION
Lesson Objectives
Lesson 1 Objectives
Describe why and how EAPAS came into being State the goal of EAPAS rulemaking Identify 3 safety improvements resulting from EAPAS rulemaking
Mod 2, Lesson 1
Introduction
Lesson Outline
Lesson 1 Outline
History and products of aging systems program Goal and benefits of EAPAS rulemaking
Mod 2, Lesson 1
Introduction
3 Aging Non-Structural Systems Study Team Formed 4a R & D Projects Wiring Mechanical Systems 4b Wire Installation Policy 4 Aging Transport Non-Structural Systems Plan Developed (1998) Documented Recommendations - Plan Designs R&D Maintenance Reporting Training Fuel System Drawings ATSRAC (1999) Implementation of Rulemaking Recommendations
(Box 1): Aging issues in aircraft electrical wire were brought to the forefront by the TWA 800 accident in 1996. The plane crashed off Long Island due to a fuel tank explosion, killing all aboard. (Box 2): Recommendations were made to the FAA by the White House Commission on Safety and Security (WHCSS) to expand the aging program to include non-structural systems. Box 3 shows the task teams formed by the FAA to investigate the condition of electrical wiring on existing aircraft to address aging concerns. In 1998, the teams completed documenting their recommendations to enhance design, maintenance, and training, and for the development of new technologies for aircraft wiring and components. Box 4 lists the recommendations; EAPAS came into being at this stage. (Box 4a): The FAA joined with industry and other governmental agencies to perform research studies to develop advanced techniques and components for detecting and preventing electrical faults in wiring. Box 4b is another recommendation developing a wire installation policy to address problems associated with wiring installation.
Mod 2, Lesson 1
Introduction
(Box 5): In order to ensure that the recommendations made by the NonStructural Systems Task Force were fully addressed, in 1999 the FAA Administrator formed a rulemaking advisory committee called ATSRAC [Aging Transport Systems Rulemaking Advisory Committee]. It was comprised of the FAA, JAA, DoD, TCCA, Industry, and aviation associations. Box 6 is a result of FAA independent studies, ATSRAC recommendations, and R & D projects. The FAA developed and will issue the EAPAS final rule with associated ACs in the summer of 2007. Fuel tank safety (FTS) is identified in Box 6 because the FAA is modifying existing FTS ops rules in the EAPAS rulemaking package (ref. Module 3 of this IVT).
Mod 2, Lesson 1
Introduction
ATSRAC formed working groups with members throughout industry based on the expertise needed for each assignment. ATSRACs meetings were open to the public.
Mod 2, Lesson 1
Introduction
ATSRAC Taskings
Phase I identified issues and solutions Phase II, ATSRAC working groups proposed regulatory enhancements Phase III, ATSRAC groups assisted in implementing enhancements in regulations and technologies
EAPAS IVT, Course 24910, Mod 2 Federal Aviation Administration
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Mod 2, Lesson 1
Introduction
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All ATSRAC activities were accomplished by different harmonization working groups (HWG) comprised of the FAA, other civil aviation authorities, and industry. The goal was to develop harmonized recommendations. Additional information on ATSRAC is in Appendix B of this Participant Guide.
Mod 2, Lesson 1
Introduction
13
Examples of what was found during the ATSRAC airplane inspection: improper routing and chafing of wires. Chafing problems due to lack of proper wiring installation and lack of adequate support have been main causes of wire failure and fire and smoke.
14
Improper bend radius installation of electrical wire was also found. This does not reflect standard industrial practice and standards in AC 43.13-1b and Standard Wiring Practices Manual (SWPM).
EAPAS: Part 26 DAH Public Version 1.1, Aug 2007 Participant Guide page 2-9
Mod 2, Lesson 1
Introduction
over time .
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Its not just strictly the age of the wire that were addressing. It is possible that wire damage occurs during the manufacturing stage.
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Mod 2, Lesson 1
EAPAS Rulemaking
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2. Maintenance 3. Training
Clamp
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Mod 2, Lesson 1
EAPAS Rulemaking
Results in improved
Public confidence Economics
S PA EA
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Mod 2, Lesson 1
EAPAS Rulemaking
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Mod 2, Lesson 1
Lesson 1 Summary
LESSON 1 SUMMARY
Summary
Summary
Aging systems history
Issues in aging aircraft wiring systems brought to forefront in late 1980s TWA 800 accident in 1996 Aging Systems Program created to resolve wiring systems issues
22
Summary
ATSRAC recommendations
Phase I identified issues in aging wiring Phase II, ATSRAC proposed II regulatory solutions Phase III, ATSRAC assisted FAA with III implementing rulemaking and developing new technologies
23
Mod 2, Lesson 1
Lesson 1 Summary
Summary, cont.
Which item below is NOT a factor in the degradation of airplane wiring?
a. Environment b. Maintenance c. Size d. Time e. Training
EAPAS IVT, Course 24910, Mod 2 Federal Aviation Administration
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Summary, cont.
EAPAS goal
25
Mod 2, Lesson 1
Lesson 1 Summary
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Aircraft Wiring Practice Job Aid can be downloaded as a pdf file of slides with speaker notes.
Mod 2, Lesson 2
Introduction to EWIS
LESSON 2: ELECTRICAL WIRING INTERCONNECTION SYSTEMS (EWIS) CERTIFICATION AND OPERATIONAL RULES
Module 2: EAPAS & EWIS Overview
Lesson 2: Electrical Wiring Interconnection Systems (EWIS) Certification and Operational Rules
EAPAS IVT, Course 24910, Mod 2 Federal Aviation Administration
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INTRODUCTION TO EWIS
Module 2, Lesson 2 Objectives
30
Mod 2, Lesson 2
Introduction to EWIS
The purpose of this lesson is to give you a high-level, big-picture view of all of the different requirements that make up the EAPAS rulemaking package.
Lesson Outline
Lesson 2 Outline
Definition and description of electrical wiring interconnection system Overview of EAPAS rulemaking package Part 25 revised and new EWIS requirements
Part 25 Appendix H25.5, that supports part 26 DAH requirements, that support
operator maintenance programs Advisory material
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Mod 2, Lesson 2
EWIS Defined
EWIS DEFINED
EWIS is a System
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Mod 2, Lesson 2
EWIS Defined
34
25.1701 , continued from slide: . . . This includes: (1) Wires and cables. (2) Bus bars. (3) The termination point on electrical devices, including those on relays, interrupters, switches, contactors, terminal blocks and circuit breakers, and other circuit protection devices. (4) Connectors, including feed-through connectors. (5) Connector accessories. (6) Electrical grounding and bonding devices and their associated connections. (7) Electrical splices. (8) Materials used to provide additional protection for wires, including wire insulation, wire sleeving, and conduits that have electrical termination for the purpose of bonding. (9) Shields or braids. (10) Clamps and other devices used to route and support the wire bundle. (11) Cable tie devices. (12) Labels or other means of identification. (13) Pressure seals. (14) EWIS components inside shelves, panels, racks, junction boxes, distribution panels, and back-planes of equipment racks, including, but not limited to, circuit board back-planes, wire integration units, and external wiring of equipment.
Mod 2, Lesson 2
EWIS Defined
(b) Except for the equipment indicated in paragraph (a)(14) of this section, EWIS components inside the following equipment, and the external connectors that are part of that equipment, are excluded from the definition in paragraph (a) of this section: (1) Electrical equipment or avionics that are qualified to environmental conditions and testing procedures when those conditions and procedures are (i) appropriate for the intended function and operating environment, and (ii) acceptable to the FAA. (2) Portable electrical devices that are not part of the type design of the airplane. This includes personal entertainment devices and laptop computers. (3) Fiber optics.
35
Mod 2, Lesson 2
EWIS Defined
A B
36
EWIS Question
Which of the following is not considered an EWIS component?
a. Pressure seals b. Cable tie devices c. Termination point on electrical devices d. Connector thats an integral part of an LRU
37
Mod 2, Lesson 2
EWIS Defined
38
Why is the FAA issuing these new electrical wiring interconnection systems requirements?
39
Mod 2, Lesson 2
EWIS Defined
40
Example from an in-service airplane of wire contamination and wire touching structure, which can lead to accelerated wire degradation.
41
Mod 2, Lesson 2
EWIS Defined
42
This is a picture from an airplane prior to leaving the factory. Note the wire harness that is riding on the metallic tube.
43
Photo from behind sidewall in passenger cabin. Contaminants can carbonize when subjected to heat, leading to arcing events, burning, or smoldering.
Mod 2, Lesson 2
EWIS Defined
44
Picture of an in-flight entertainment (IFE) system installed and certified by a designated alteration station.
Existing regulations fall short of providing specific wiring-related requirements that we now recognize should be included in certification and operational regulations
EAPAS IVT, Course 24910, Mod 2 Federal Aviation Administration
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Mod 2, Lesson 2
EWIS Defined
46
Mod 2, Lesson 2
EWIS Defined
ew N er w Po ires W
47
Illustration of need for more stringent EWIS separation and safety assessments. An STC applicant obtained an STC to install a new in-flight entertainment system on board a large transport category airplane. IFE system comprised of over 750 LRUs distributed throughout passenger cabin. IFE had relatively high power requirements. Applicant used existing wire bundle to route new signal and power wires (new power wires are white, blue, and orange). Existing bundle had many wires insulated with aromatic polyamide insulation. Applicant had no idea what airplane systems were associated with the wires in the existing bundle. Part 25 rules when STC was certified didnt require physical separation between non-essential system high-powered wires and other wiring. When FAA asked applicant what type of 25.1309 safety assessment was performed on IFE, applicant said assessment was a qualitative analysis. 25.1309 was not adequate to require the type of safety assessment that should have been conducted on such a complex system. IFE was considered a non-essential passenger convenience system and its continued operation was not necessary to continued safe flight. However, a failure of this wire bundle could have caused a fire or the failure of a number of airplane systems that could have been critical to continued safe flight. New EWIS rules require addressing EWIS separation and EWIS safety assessment.
EAPAS: Part 26 DAH Public Version 1.1, Aug 2007 Participant Guide page 2-28
Mod 2, Lesson 2
EWIS Defined
NEW
The traditional ways of addressing airplane wiring no longer provide the level of safety that we now expect Wire damage or degradation can be result of successive and interactive factors introduced over time
Inadequate design, improper maintenance, poor training, hostile environments, abuse, and time
EAPAS IVT, Course 24910, Mod 2 Federal Aviation Administration
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49
Analytical logically assessing possibilities for a wire failure. Multilayered addressing multiple layers of stressors. Proactive addressing conditions affecting safe flight before they happen.
Mod 2, Lesson 2
EWIS Defined
Contactor
50
Result of 6 to 7 fires over 6 months due to moisture that came in contact with an electrical contact below the pilots seat.
Improperly Tied Wires: riding on hydraulic lines, contaminated with caustic fluid
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Mod 2, Lesson 2
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53 53
EAPAS/FTS rulemaking package contains a total of 73 new, revised, renumbered certification and operational requirements.
Mod 2, Lesson 2
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Mod 2, Lesson 2
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Mod 2, Lesson 2
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see AC 26-XX
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Mod 2, Lesson 2
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EZAP, cont.
From EZAP analysis, maintenance tasks in the form of ICA can be developed to
Prevent ignition sources and Minimize the possibilities for combustion by minimizing accumulation of combustible materials
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Mod 2, Lesson 2
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Example of where the EZAP would define a maintenance task to inspect and clean the EWIS components in this wheel well.
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Mod 2, Lesson 2
Requires operators to incorporate SFAR 88 maintenance instructions into their approved maintenance or inspection programs
Applies to parts 91, 121, 125, & 129
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Mod 2, Lesson 2
Parts 1 and 21
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14 CFR part 1 has a definition for EWIS, and part 21 gives the FAA the authority to carry out the regulations.
Part 1
1.2 Abbreviations and symbols
Part 21
21.4 Continued airworthiness and safety improvements for transport category airplanes
67
Added a new regulation and revised several requirements within part 21 to clarify the relationship between the existing part 21 and the new part 26, which contains the DAH requirements.
Mod 2, Lesson 2
68
Sections 21.31 and 21.50 revised to clarify that Airworthiness Limitations section of ICA is part of the type design, so changes to the ICA generated under part 26 must be made available as part of the total ICA. Revised 21.101 says an applicant may not use the Changed Product Rule to avoid complying with the DAH requirements of part 26.
Part 25
69
Mod 2, Lesson 2
A B C D E F G
App H
D E F H
App H
A B C D E F G H
App App H H
25.1203
25.1701 25.1703 25.1705 25.1707 25.1709 25.1711 25.1713 25.1715 25.1717 25.1719 25.1721 25.1723 25.1725 25.1727 25.1729 25.1731 25.1733 70
Revised many rules in part 25 by removing wire-specific references and moving them into the new rules within part 25 subpart H. The rules on the slide in black are the existing rules. The ones in orange and a different, larger font are new. (In the black and white version, the existing rules are in black, while the new rules are in dark gray.) There are changes to part 25 subparts D, E, and F; there is a new subpart H; and there are a number of changes to Appendix H. Rules in D and H also contain some new rules that were harmonized with the European Aviation Safety Agency (EASA). The FAA also added new Instructions for Continued Airworthiness requirements in Appendix H. There will be additional training on the revised and new ACs, the rules, and subpart H.
Mod 2, Lesson 2
71
For amended TCs and amended STCs, the applicability of the new rules will be decided as it is done today Changed Product Rule.
Mod 2, Lesson 2
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Household wire or the type of wire used on consumer electronics is not acceptable unless it is shown to meet all part 25 certification requirements.
Mod 2, Lesson 2
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Mod 2, Lesson 2
Mod 2, Lesson 2
(1) An EWIS component failure will not create a hazardous condition. (i) EWIS must be designed and installed with adequate physical separation between the EWIS and flight or other mechanical control systems cables and associated system components, so that: (1) Chafing, jamming, or other interference are prevented. (2) An EWIS component failure will not create a hazardous condition. (3) Failure of any flight or other mechanical control systems cables or systems components will not damage the EWIS and create a hazardous condition. (j) EWIS must be designed and installed with adequate physical separation between the EWIS components and heated equipment, hot air ducts, and lines, so that: (1) An EWIS component failure will not create a hazardous condition. (2) Any hot air leakage or heat generated onto EWIS components will not create a hazardous condition. (k) For systems for which redundancy is required, by certification rules, by operating rules, or as a result of the assessment required by 25.1709, EWIS components associated with those systems must be designed and installed with adequate physical separation. (l) Each EWIS must be designed and installed so there is adequate physical separation between it and other aircraft components and aircraft structure, and so that the EWIS is protected from sharp edges and corners, to minimize potential for abrasion/chafing, vibration damage, and other types of mechanical damage
Mod 2, Lesson 2
76
Catastrophic failure condition extremely improbable; not result of single failure Hazardous failure condition extremely remote
Functional and physical failures of EWIS must be assessed to demonstrate compliance
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Mod 2, Lesson 2
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Example of where the new system safety assessment requirement would prevent this type of failure from occurring because it requires an assessment of the physical environment within which the EWIS is installed, and a review for functional failures and physical failures.
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Mod 2, Lesson 2
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Mod 2, Lesson 2
Loose hardware
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Loose clamp isnt a design issue; should be caught during inspection. Routing of metallic cable through wire bundle clamp should never be allowed.
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Mod 2, Lesson 2
84
Section 25.1729 is a parallel requirement to the existing ICA requirement of 25.1529. The key difference is that in 25.1529, ICA must be acceptable to the FAA, not approved by, which is whats required in 25.1729.
Part 25 Appendix H
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Mod 2, Lesson 2
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Titles of the revised and new rules in Appendix H. Section 26.11 requires the DAH to develop EWIS ICA in accordance with certain sections of H25.5.
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Mod 2, Lesson 2
H25.5 Electrical Wiring Interconnection System (EWIS) Instructions for Continued Airworthiness. (a) The applicant must prepare Instructions for Continued Airworthiness applicable to EWIS as defined by 25.1701 that are approved by the FAA and include the following: (1) Maintenance and inspection requirements for the EWIS developed with the use of an enhanced zonal analysis procedure that includes: (i) Identification of each zone of the airplane. (ii) Identification of each zone that contains EWIS. (iii) Identification of each zone containing EWIS that also contains combustible materials. (iv) Identification of each zone in which EWIS is in close proximity to both primary and back-up hydraulic, mechanical, or electrical flight controls and lines. (v) Identification of (A) tasks, and the intervals for performing those tasks, that will reduce the likelihood of ignition sources and accumulation of combustible material, and (B) procedures, and the intervals for performing those procedures, that will effectively clean the EWIS components of combustible material if there is not an effective task to reduce the likelihood of combustible material accumulation. (vi) Instructions for protections and caution information that will minimize contamination and accidental damage to EWIS, as applicable, during performance of maintenance, alteration, or repairs. (2) Acceptable EWIS maintenance practices in a standard format. (3) Wire separation requirements as determined under 25.1707. (4) Information explaining the EWIS identification method and requirements for identifying any changes to EWIS under 25.1711. (5) Electrical load data and instructions for updating that data. (b) The EWIS Instructions for Continued Airworthiness developed in accordance with the requirements of H25.5(a)(1) must be in the form of a document appropriate for the information to be provided, and they must be easily recognizable as EWIS Instructions for Continued Airworthiness. This document must either contain the required EWIS ICA or specifically reference other portions of the ICA that contain this information.
Mod 2, Lesson 2
Part 26
88
26.1 Purpose and scope 26.3 Definitions 26.5 Applicability Table 26.11 Electrical wiring interconnection systems (EWIS) maintenance program
EAPAS IVT, Course 24910, Mod 2 Federal Aviation Administration
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Part 26 will ultimately contain requirements for a number of safety initiatives, such as widespread fatigue damage and flammability reduction means. Right now, it contains just the requirements for EWIS maintenance programs for certain existing transport category airplanes.
Mod 2, Lesson 2
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Mod 2, Lesson 2
92
For the details of these requirements, refer to the draft final rule.
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Mod 2, Lesson 2
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The FAA has issued 12 Advisory Circulars that support the EAPAS rulemaking package.
NEW
EWIS certification (part 25, subpart H) Standard wiring practices manual (part 25, App. H) EWIS training program (satisfies 121.375) EWIS maintenance development (part 25, appendix H, parts 121 & 129)
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Mod 2, Lesson 2
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Mod 2, Lesson 2
Lesson 2 Summary
LESSON 2 SUMMARY
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The EAPAS rulemaking package contains: Revisions of existing wire-related requirements, The addition of enhanced wire requirements, The adoption of new continued airworthiness requirements for EWIS, and design holder approval requirements, and The requirements for operators to include new maintenance instructions into their maintenance programs. The traditional way of designing, installing, and maintaining wires no longer works. Electrical wires need to be treated as a system.
Mod 2, Lesson 2
Lesson 2 Summary
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100
For this IVT, if you have questions for Massoud, Stephen, or Fred, fax them to 405-954-9507.
EAPAS: Part 26 DAH Public Version 1.1, Aug 2007 Participant Guide page 2-59
PARTICIPANT GUIDE
Version 1.1 Note: The information contained in this Participant Guide is presented by the instructors through captioned video and audio. A transcript of the captioning is also available with each with each video segment.
LESSON 1: PART 26 AND PART 25 APPENDIX H EWIS ICA REQUIREMENTS INTRODUCTION .............................................................................3 PART 26 AND PART 25 APPENDIX H DAH RULES .....................4 What Are the Part 26 Rules? 26.11(a) (g) ..............................4 26.11(a): Applicability ................................................................4 26.11(b): What Do You Have To Do If 26.11(a) Applies?..........6 26.11(c): Imposes What We Did in 26.11(b) On Applicants For Amendments to TCs and STCs ..........................8 Applicable Part 25 Appendix H Requirements: H25.5 EWIS ICA.........................................................................9 SUMMARY OF LESSON 1............................................................13
LESSON 2: PRODUCING AN EWIS ICA INTRODUCTION ...........................................................................14 Lesson 2 Objectives.................................................................14 Introduction to Lesson 2 ...........................................................15 EZAP BASICS ..............................................................................16 What is an EZAP?....................................................................16 Why Do You Need an EZAP? ..................................................17 How is an EZAP Done? ...........................................................18 PERFORMING AN EZAP USING AC 120-XX FLOWCHART ......20 Introduction of the Flowchart ....................................................20 Step 1: Identify Aircraft Zones .................................................23 Step 2: List Details of Zone .....................................................23 Step 3: Does Zone Contain Wiring?........................................24 Step 4: Are There Likely To Be Combustible Materials in the Zone? .............................................................................24 Step 7: Is Wiring Close to Both Primary AND Backup Hydraulic, Mechanical, or Electrical Flight Controls? ...............24 Step 5: Is There An Effective Task To Significantly Reduce the Likelihood of Accumulation of Combustible Materials? ......26 Step 6: Define Task and Assign an Interval for Performing It..28 Step 8: Wiring Inspection Task Determination ........................28 Step 9: Task Consolidation .....................................................29 Introduction of the Worksheets.................................................34 Worksheet 1: Details of Zone ..................................................35 Worksheet 2: Assessment of Zone Attributes .........................36 Worksheet 3A: Inspection Level Determination.......................37 Worksheet 4: Inspection Interval .............................................43 Worksheet 5: Task Summary ..................................................51 PRODUCING THE EWIS ICA DOCUMENT..................................52 Regulatory Requirements.........................................................52 Key Points about the EWIS ICA Document..............................52 SAMPLE EWIS ANALYSIS OF AN ENGINE ZONE.....................54 Background Information about the Engine ...............................54 EZAP Steps..............................................................................56 SUMMARY OF LESSON 2 ...........................................................61
LESSON 3: APPROVAL AND INTEGRATION OF EWIS ICA INTRODUCTION ...........................................................................62 Lesson 3 Objectives .................................................................62 Focus of Lesson 3 ....................................................................63 EWIS ICA FAA APPROVAL .........................................................64 Why Is EWIS ICA Approval Necessary? ..................................64 The Process for Approving EWIS ICA ......................................68 How FAA Oversight Office Indicates Approval .........................72 INTEGRATION OF EWIS AND FTS ICA INTO PART 121 AND 129 AIR CARRIERS MAINTENANCE PROGRAMS AND INTEGRATION OF FTS ICA INTO PART 91 AND 125 OWNER/OPERATORS INSPECTION PROGRAMS ..............73 Introduction...............................................................................73 Operator Changes to EWIS ICA ...............................................74 Identification of Actions Necessary to Implement EWIS ICA Approval ..................................................................75 SUMMARY OF LESSON 3............................................................76
Mod 3, Overview
Module 3 Focus
Module 3 Focus
The goal of EAPAS rulemaking is to enhance safety by addressing electrical wiring system deterioration and wire contamination. Within EAPAS, a requirement for design approval holders to develop and make available to operators maintenance and inspection instructions for EWIS.
Mod 3, Overview
Module 3 Focus
Focus of Module 3
The process DAHs use to develop electrical wiring interconnection system (EWIS) maintenance & inspection procedures by an enhanced zonal analysis procedure (EZAP)
Ensure compatibility & minimize redundancy between EAPAS and SFAR 88 ICA
Module Lessons
Module 3 Lessons
1. Part 26 & part 25 Appendix H regulations for DAH to produce EWIS ICA 2. Using AC 120-XX flowchart to produce an EWIS ICA 3. Process for FAA approval of EWIS and SFAR 88 ICA and their integration into operator maintenance and inspection programs
EAPAS IVT, Course 24910, Mod 3 Federal Aviation Administration
Mod 3, Lesson 1
Introduction
INTRODUCTION
Lesson 1 Introduction
Objective:
Be able to identify the 14 CFR part 26 DAH requirements and relevant part 25 Appendix H requirements for a DAH to produce an EWIS ICA
Mod 3, Lesson 1
Slide is a list of the paragraphs within section 26.11. 26.11(a): 26.11(b): 26.11(c): 26.11(d): 26.11(e): 26.11(f): 26.11(g): Applicability. What do you have to do if 26.11(a) applies? EZAP. Imposes what we did in 26.11(b) on applicants for amendments to TCs & STC. When does this have to be accomplished? we have a chart that will show this in Module 4. Compliance Plan development. Compliance Plan implementation. List of exceptions to the rule.
Mod 3, Lesson 1
26.11(a): Applicability
26.11(a): Applicability
a) . . . applies to transport category, turbine-powered airplanes with a TC issued after January 1, 1958, that, as a result of the original certification, or later increase in capacity, have (1) A maximum type-certificated passenger capacity of 30 or more or (2) A maximum payload capacity of 7,500 pounds or more.
EAPAS IVT, Course 24910, Mod 3 Federal Aviation Administration
Paragraph is below and in Appendix E of this Guide. 26.11(a) Except as provided in paragraph (g) of this section, this section applies to transport category, turbine-powered airplanes with a type certificate issued after January 1, 1958, that, as a result of the original certification, or later increase in capacity, have (1) A maximum type-certificated passenger capacity of 30 or more or (2) A maximum payload capacity of 7,500 pounds or more.
Mod 3, Lesson 1
Paragraph is below and in Appendix E of this Guide. 26.11(b) Holders of, and applicants for, type certificates, as identified in paragraph (d) of this section must develop Instructions for Continued Airworthiness (ICA) for the representative airplanes EWIS in accordance with part 25, Appendix H paragraphs H25.5(a)(1) and (b) of this subchapter in effect on [effective date of this final rule] for each affected type design, and submit those ICA for review and approval by the FAA Oversight Office. For purposes of this section, the representative airplane is the configuration of each model series airplane that incorporates all variations of EWIS used in production on that series airplane, and all TC-holder-designed modifications mandated by airworthiness directive as of the effective date of this rule. Each person specified in paragraph (d) of this section must also review any fuel tank system ICA developed by that person to comply with SFAR 88 to ensure compatibility with the EWIS ICA, including minimizing redundant requirements.
Mod 3, Lesson 1
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11
Mod 3, Lesson 1
26.11(c): Imposes What We Did In 26.11(b) On Applicants For Amendments To TCs and STCs
26.11(c): Amended TCs and STCs
Applicants for amended TCs and STCs must evaluate if design change requires revision to EWIS ICA, and, if it does
Develop and submit ICA revisions for approval by FAA Oversight Office Ensure revised EWIS ICA compatible with SFAR 88 ICA and that redundant requirements are minimized
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26.11(c) Applicants for amendments to type certificates and supplemental type certificates, as identified in paragraph (d) of this section, must: (1) Evaluate whether the design change for which approval is sought necessitates a revision to the ICA required by paragraph (b) of this section to comply with the requirements of Appendix H, paragraphs H25.5(a)(1) and (b). If so, the applicant must develop and submit the necessary revisions for review and approval by the FAA Oversight Office. (2) Ensure that any revised EWIS ICA remain compatible with any fuel tank system ICA previously developed to comply with SFAR 88 and any redundant requirements between them are minimized.
STC applicants. When an STC applicant proposes changes to existing EWIS ICA, ACO and Transport Standards Staff engineers need to coordinate proposed changes with the appropriate AEG office. STC applicant obtains existing EWIS ICA data so a determination can be made on whether revisions are necessary. You should make this clear to the applicant as soon as the final rule is issued to assist them in complying with the requirements by the compliance date.
Mod 3, Lesson 1
13
Applicable Part 25 Appendix H Requirements: H25.5 Electrical Wiring Interconnection System (EWIS) Instructions for Continued Airworthiness
14
Mod 3, Lesson 1
15
Paragraph is below and in Appendix E of this Guide. H25.5(a)(1): (a) The applicant must prepare Instructions for Continued Airworthiness applicable to EWIS as defined by 25.1701 that are approved by the FAA and include the following: (1) Maintenance and inspection requirements for the EWIS developed with the use of an enhanced zonal analysis procedure (EZAP) that includes: (i) Identification of each zone of the airplane. (ii) Identification of each zone that contains EWIS. (iii) Identification of each zone containing EWIS that also contains combustible materials. (iv) Identification of each zone in which EWIS is in close proximity to both primary and back-up hydraulic, mechanical, or electrical flight controls and lines. (v) Identification of (A) tasks, and the intervals for performing those tasks, that will reduce the likelihood of ignition sources and accumulation of combustible material, and (B) procedures, and the intervals for performing those procedures, that will effectively clean the EWIS components of combustible material if there is not an effective task to reduce the likelihood of combustible material accumulation. (vi) Instructions for protections and caution information that will minimize contamination and accidental damage to EWIS, as applicable, during performance of maintenance, alteration, or repairs.
Mod 3, Lesson 1
Document must
Contain required EWIS ICA or Specifically reference other portions of the ICA that contain this information
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Paragraph is below and in Appendix E of this Guide. H25.5(b): The EWIS Instructions for Continued Airworthiness developed in accordance with the requirements of H25.5(a)(1) must be in the form of a document appropriate for the information to be provided, and they must be easily recognizable as EWIS Instructions for Continued Airworthiness. This document must either contain the required EWIS ICA or specifically reference other portions of the ICA that contain this information.
17
Mod 3, Lesson 1
18
Mod 3, Lesson 1
Summary of Lesson 1
SUMMARY OF LESSON 1
On your keypads, choose the correct answer for this question.
19
Mod 3, Les 1
Part 26 reqs.:
Develop & doc. EWIS ICA Ensure EWIS ICA compatible with SFAR 88 ICA
Mod 3, Les 2
Develop & doc. EWIS ICA
Mod 3, Les 3
FAA approval & operator integration of EWIS ICA
Mod 4
Roles & responsibilities of FAA and DAH to comply with part 26 requirements
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Mod 3, Lesson 2
Introduction
21
INTRODUCTION
Lesson 2 Objectives
Lesson 2 Objectives
You will be able to:
Explain the EZAP process for developing EWIS ICA Review EWIS ICA with SFAR 88 ICA to identify that redundancy & compatibility issues are satisfactorily addressed Identify the components of EWIS ICA Document
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Mod 3, Lesson 2
Introduction
Introduction to Lesson 2
Introduction to Lesson 2
Two sections
How EWIS ICA is developed via EZAP How EWIS ICA document for operators is produced
AC 120-XX, Program To Enhance Transport Category Airplane EWIS Maintenance, use EZAP flowchart
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You do not perform an EZAP, the DAH does. However, you will be reviewing and making decisions on whether the DAH data and reports are compliant with the ICA requirements.
Mod 3, Lesson 2
EZAP Basics
EZAP BASICS
What is an EZAP?
What is an EZAP?
A process to develop EWIS ICA
Identifies physical and environmental conditions in each airplane zone and their effects on electrical wiring Assesses possibilities for smoke and fire
Helps to ensure proper attention given to EWIS during maintenance, and to define inspection tasks and intervals
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Mod 3, Lesson 2
EZAP Basics
Fewer EWIS failures due to cleaning and inspection lead to safer operation
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26
EZAP-derived EWIS ICA will: Minimize the accumulation of combustible materials, Make it easier to detect wire degradation, and as a result Lead to fewer failures and safer operation.
Mod 3, Lesson 2
EZAP Basics
27
28
Mod 3, Lesson 2
EZAP Basics
EWIS Is . . .
29
EWIS is not
[25.1701(c)]
Electrical equipment or avionics qualified to acceptable environmental conditions and testing procedures Portable electrical devices not part of airplanes type design Fiber optics
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Mod 3, Lesson 2
Mod 3, Lesson 2
Mod 3, Lesson 2
Focus on this
PROGRAMS WITH ZONAL INSPECTION PROGRAM PROGRAMS WITHOUT ZONAL INSPECTION PROGRAM
Using worksheets, assess zone attributes to determine appropriate level of inspection (examples provided in Appendix B of this AC)
Is zonal GVI alone effective for all wiring in the zone? YES List zone description and boundaries for zonal GVI
Is GVI of all wiring in the zone at same interval effective for all wiring in the zone?
YES
List zone description and boundaries for GVI of all wiring in the zone
NO Define specific wiring in the zone for which stand-alone GVI is justified
NO
Define specific wiring in the zone for which GVI at more frequent interval is justified
Zonal GVI must be augmented with stand-alone GVI and/or DET inspection Define specific wiring in the zone for which DET is justified
Some wiring requires GVI at more frequent interval and/or DET inspection Define specific wiring in the zone for which DET is justified
Using rating tables, assess likelihood of damage to wiring in the zone to determine an appropriate interval for each inspection task identified (example provided in Appendix B of this AC)
Mod 3, Lesson 2
EZAP uses zones defined by DAH for original maintenance program Zones: actual physical boundaries (e.g., wing spars, cabin floor) and include access provisions for each zone
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32
With respect to power levels, the DAH needs to know whether the wire bundle consists primarily of main generator feeder cables, low voltage instrumentation wiring, or standard bus wiring. This information will be used in determining potential effects of failure of wires within the zone.
Mod 3, Lesson 2
33
Definitions: Combustible
Ability of any solid, liquid, or gaseous material to cause a fire to be sustained after removal of the ignition source Term used in place of inflammable/ flammable NOT material that requires a continuous source of heat to burn
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Mod 3, Lesson 2
35
NO
YES
36
Consider commonly-used liquids such as oils, hydraulic fluids, corrosion prevention compounds, and deicing fluids. Forced air ventilation tends to blow dust and lint through the air, causing it to lodge on wiring surfaces. Wet or oily surfaces attract more dust and lint, which impacts assessing possibility of a buildup of combustibles in the zone.
Mod 3, Lesson 2
Step 7: Is Wiring Close To Both Primary And Backup Hydraulic, Mechanical, or Electrical Flight Controls?
NO
37
If there are no combustibles in the zone, DAH must ask question for Step 7. Step 7 addresses the concern that segregation between primary and back-up flight controls may not have been consistently achieved in the design of airplanes. Even in the absence of combustible material, a localized wire arcing could prevent continued safe flight and landing if hydraulic pipes, mechanical cables, or wiring for fly-by-wire controls are routed in close proximity to a wiring harness. In consideration of the redundancy in flight control systems, this question should be answered yes if both the primary AND back-up system might be affected by wire arcing. The question should also be answered yes in zones where a fire might be sustained by combustible materials.
Mod 3, Lesson 2
Step 5: Is There An Effective Task To Significantly Reduce The Likelihood Of Accumulation Of Combustible Materials?
NO
YES
38
Step 5 evaluates whether accumulation on or adjacent to wiring can be significantly reduced. Task effectiveness criteria should include considering the potential for damaging the wiring for either accessing or cleaning the wiring. Though restoration tasks such as cleaning are the most likely applicable tasks, the possibility of identifying other tasks is not eliminated. DAH will always answer this question no in the case of fuel vapors, as there is never an effective task to rid the zone of fuel vapors.
Mod 3, Lesson 2
Cleaning tasks should not be so aggressive that they damage wiring; however . . . They should be applied to a level that significantly reduces likelihood of combustion
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40
On Figure 1, Step 8 says to go to Figure 2 to make the determination about the wiring inspection task and its interval. Once the wiring inspection task and its interval have been determined, we move on to task consolidation, as depicted in Step 9.
Mod 3, Lesson 2
41
Mod 3, Lesson 2
42
43
For cleaning considered necessary, operator should use airplane manufacturers procedures or other equivalent methods and practices acceptable to the FAA.
Mod 3, Lesson 2
44
45
Mod 3, Lesson 2
Consider consolidation with existing inspection tasks in systems and powerplant and/or zonal programs *
GVI Stand-alone Assign task to EWIS ICA GVI Maintenance program systems DET and powerplant section Recommend inclusion in ATA 20
Assign task to EWIS ICA Maintenance program zonal section Aircraft with ZIPs
* Section 26.11(b) requires consolidation of EWIS ICA with fuel tank ICA where possible
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Application of the EZAP may identify some GVIs that are adequately covered by existing zonal GVIs in the zone. No change or addition to the existing zonal GVI is required, thus reducing the number of new GVIs that must be introduced into a program that already includes a zonal inspection program (ZIP). Consolidation of GVI tasks should consider access requirements and intervals. EWIS ICA must be compatible with any SFAR 88 ICA. 26.11(b) requires any fuel tank system ICA developed to comply with SFAR 88 be compatible with EWIS ICA, including minimizing any redundant requirements between the two. Compatibility check ensures EWIS ICA dont invalidate previously developed SFAR 88 ICA, and ensures inspection tasks between the two arent redundant. Typically, fuel tank systems contain elements of electrical wiring interconnection systems. Certain EWIS elements within the fuel tank system contribute to prevention of ignition sources and therefore would require a more in-depth inspection, possibly at a more frequent interval, than what may result from only applying EZAP. In some cases, the EZAP may have been carried out independently of considerations for fuel tank system safety.
Mod 3, Lesson 2
Two examples to help illustrate what we mean by this requirement. 1. Consider fuel quantity indication system (FQIS) wires that are relying on specific shielding to prevent transient voltages in the fuel tank may have been identified under SFAR 88 as requiring a DET every 3,600 flight hours, while the EZAP analysis may have identified a stand-alone GVI of the same wires and shielding every 7,200 flight hours. 2. Consider an EWIS ICA that requires a DET every 72 months. The SFAR 88 ICA for same wire bundle requires a GVI every 36 months.
The result of Step 9 is a report (or multiple reports) that documents both sides of flowchart Step 9. Usually the result will be in an MRB report, but it doesnt have to be.
Mod 3, Lesson 2
47
Figure 2 documents how the actual wiring inspection tasks and intervals are developed.
The flowchart illustrates the EZAP process. Worksheets 1 5 are used to perform the EZAP analysis.
Mod 3, Lesson 2
48
Worksheet 1 documents the zone number, zone title, and zone description. This accounts for Steps 1 and 2 of the flowchart. DAH checks the boxes for all of the major components of the zone, such as electrical wiring and flight control. The large box is used for comments.
Mod 3, Lesson 2
49
Figure 1 flowchart has been replicated on the left of Worksheet 2. This worksheet records the decisions for Steps 3 through 7.
Mod 3, Lesson 2
50
Worksheet 3A is Step 8 of Figures 1 and 2 of the flowchart. It is used to select the appropriate level of inspection of the wiring in the zone based on an assessment of zone size, density, and potential effects of fire in the zone. The minimum outcome of this analysis will always be a zonal GVI of any zone where the presence of combustible materials is possible and/or wiring is located in close proximity to both primary and backup hydraulic or mechanical flight controls. The inspection level determination table allows the analyst to determine if a zonal GVI alone is adequate for all wiring in the zone or if the zonal GVI must be augmented with a stand-alone GVI or a detailed inspection of some portion of the wiring. If the zonal GVI is adequate for all wiring in the zone, the analyst must identify the inspection area as the zone itself. If the zonal GVI is not adequate for all wiring in the zone, in addition to identifying the zonal GVI, the analyst must also identify the specific items/areas in the zone where a stand-alone GVI and/or a detailed inspection is necessary.
Mod 3, Lesson 2
51
Zone Size
Based on comparing all the zones in a given airplane model and assessing them in relation to each other For purposes of EZAP analysis, zones sizes identified as small, medium or large Smaller the zone and less congested it is, the more likely that wiring degradation will be identified by GVI
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Mod 3, Lesson 2
Zone Density
Density of installed equipment within zone For purposes of EZAP analysis, density identified as low, medium, or high Consider number of components, closeness to one another, complexity of components Density of zone helps to determine level, type, and frequency of inspection required
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3
54
To begin, select zone size and zone density. The resulting number is used in the inspection level table.
Mod 3, Lesson 2
1
Zonal GVI
2
Zonal GVI
3
Zonal GVI
Medium
Zonal GVI
Zonal GVI + Stand-alone GVI of some wiring Zonal GVI + Stand-alone GVI and/or DET of some wiring
Zonal GVI + Stand-alone GVI of some wiring Zonal GVI + Stand-alone GVI and/or DET of some wiring
High
55
56
Mod 3, Lesson 2
57
1
Zonal GVI
2
Zonal GVI
3
Zonal GVI
Medium
Zonal GVI
Zonal GVI + Stand-alone GVI of some wiring Zonal GVI + Stand-alone GVI and/or DET of some wiring
Zonal GVI + Stand-alone GVI of some wiring Zonal GVI + Stand-alone GVI and/or DET of some wiring
High
58
Chart provides the appropriate inspection level for the EWIS in that zone.
Mod 3, Lesson 2
2. List zone description and boundaries for Zonal GVI 3. Define specific items/ areas in the zone for which a Stand-alone GVI is justified 4. Define specific items/ areas in the zone for which a DET is justified
Zonal GVI must be augmented with a Stand-alone GVI and/or a DET inspection If answer to Box 1 is YES, answer Box 2 only. If answer to Box 1 is NO, answer Boxes 2, 3, & 4.
59
The box on the bottom right-hand side of Worksheet 3A is for documenting the EWIS inspection details. DAH lists existing zonal GVIs that can be used, and provides details of EWIS that need to be the subject of a stand-alone GVI or a DET.
The purpose of Step 8 of Figure 1 is to select the wiring inspection level and interval. Worksheet 3A, determines the inspection level. Worksheet 4 aids in determining the inspection interval. Even if a zonal GVI is effective, DAH still needs to complete Worksheet 4.
Mod 3, Lesson 2
60
61
Ratings assigned on Worksheet 4 are based on engineering judgment and maintenance experience/history. Example: temperature in the passenger cabin, (ambient temperature) is rated 1, while temperature rating for an engine zone (outside pressure vessel and near hot engine) could be a 2 or 3.
Mod 3, Lesson 2
1 2 1 3 2 1
3
62
Each criteria is given a rating of 1, 2, or 3, with the highest number written in the bottom box. Number used with the likelihood of accidental damage number to determine the task interval.
Mod 3, Lesson 2
63
Mod 3, Lesson 2
1 3 1 2 2 1 1
3
64
As with the hostility of the environment, each characteristic is rated 1 3. The highest number is written in the bottom box. This number will be used with the hostility of environment number to determine the task interval.
Mod 3, Lesson 2
65
The hostility of environment and accidental damage numbers are used to determine the task interval.
Mod 3, Lesson 2
66
The intervals will more than likely be chosen to line up with existing maintenance intervals. That way, were not requiring EWIS maintenance tasks out of sequence, which could Cause damage just for the sake of inspecting a wire, or Put undo burden on the operator by requiring them to take an airplane out of service just to perform an EWIS task.
Mod 3, Lesson 2
2
2C 4C
7,200 14,400 FH 30 60 M
3
1C 2C
3,600 7,200 FH 15 30 M
14,400 21,600 FH 60 90 M
Hostility of Environment
2C 6C
1C 4C
3,600 14,400 FH 15 60 M
A 1C
450 3,600 FH 1 15 M
7,200 21,600 FH 30 90 M
1C 6C
1C 4C
3,600 14,400 FH 15 60 M
A 1C
450 3,600 FH 1 15 M
3,600 21,600 FH 15 90 M
RESULT
Upon completion, enter all task and interval selections onto Worksheet 5, Task Summary
67
Slide includes some intervals for illustrative purposes. The intervals will vary by airplane model. Within the interval determination box, find the intersection of environmental hostility and accidental damage. This yields a range of intervals from which to choose. Base the interval on the reasons for assigning specific rating values for hostility of environment and likelihood of accidental damage. Also use knowledge of the types of EWIS components to be inspected.
Mod 3, Lesson 2
68
DAH should consider the assigned ratings and use sound maintenance engineering judgment to assign the maintenance task interval.
2
2C 4C
7,200 14,400 FH 30 60 M
3
1C 2C
3,600 7,200 FH 15 30 M
14,400 21,600 FH 60 90 M
Hostility of Environment
2C 6C
1C 4C
3,600 14,400 FH 15 60 M
A 1C
450 3,600 FH 1 15 M
7,200 21,600 FH 30 90 M
1C 6C
1C 4C
3,600 14,400 FH 15 60 M
A 1C
450 3,600 FH 1 15 M
3,600 21,600 FH 15 90 M
RESULT
Upon completion, enter all task and interval selections onto Worksheet 5, Task Summary
69
The decision on task interval is entered into the final box on Worksheet 4.
Mod 3, Lesson 2
Worksheet 5
At this point in EZAP, required EWIS ICA and their intervals identified Final activity record all task and interval selections for all zones onto Worksheet 5
70
71
Mod 3, Lesson 2
72
The applicant produces the EWIS ICA document. Rule not prescriptive in how to identify EWIS ICA. However DAH or STC applicant determines how to identify EWIS ICA, method must be clearly communicated within ICA documentation (such as providing a legend).
73
Mod 3, Lesson 2
74
75
Mod 3, Lesson 2
60
Mod 3, Lesson 2
77
As we go through this example, look at the slides in Participant Guide if youre having a hard time reading them on the screen.
Mod 3, Lesson 2
EZAP Steps
78
Mod 3, Lesson 2
79
Mod 3, Lesson 2
80
Mod 3, Lesson 2
81
Mod 3, Lesson 2
82
Mod 3, Lesson 2
Summary of Lesson 2
SUMMARY OF LESSON 2
Summary of Lesson 2
Purpose of EZAP
Ensures proper attention given to EWIS during maintenance Defines inspection tasks and intervals for EWIS ICA
DAH develops an EWIS ICA by performing an EZAP (AC 120-XX) EWIS ICA consolidated with SFAR 88 ICA
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The major component of an EWIS ICA Document is that it contains EWIS ICA or that it references portions of other ICA that contain EWIS ICA. The Document must be in a form appropriate for the information to be provided to the operators, and it must be easily recognizable as an EWIS ICA.
Mod 3, Lesson 3
Introduction
84
INTRODUCTION
Lesson 3 Objectives
Lesson 3 Objectives
You will be able to:
Identify the need for EWIS ICA approval Describe how EWIS ICA approval is accomplished Describe how EWIS ICA are incorporated into operators maintenance or inspection programs
85
Mod 3, Lesson 3
Introduction
Focus of Lesson 3
Focus of Lesson 3
EWIS ICA must be approved by the FAA Oversight Office (different from other ICA covered by 25.1529 that require that the ICA be accepted) accepted Two sections of Lesson 3
FAA approval of EWIS ICA Incorporation of EWIS ICA into operators maintenance or inspection programs
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Mod 3, Lesson 3
87
Approval changes the minimum safety and maintenance standards, and the manner in which the FAA approaches and views the effect that improperly maintained EWIS can have on safe operation of transport category airplanes.
88
A primary objective of DAH rule is to ensure that operators have at least one source of FAA-approved data and documents to use to comply with the operational requirements.
EAPAS: Part 26 DAH Public Version 1.1, Aug 2007 Participant Guide page 3-64
Mod 3, Lesson 3
Why Is EWIS ICA Approval Needed?, cont. Historically, STC applicants for electrical modifications have not paid proper attention to identifying and developing ICA
Without review and approval, FAA wont be able to ensure that ICA developed by DAH are adequate and compatible with EWIS ICA developed by the airplanes manufacturer or previous modifiers
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Requirement for EWIS ICA approval consistent with roles & responsibilities in ICA Order 8110.54
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Mod 3, Lesson 3
91
The FAA Oversight Office is going to approve the EWIS ICA developed as a result of using the EZAP discussed earlier in this module.
Mod 3, Lesson 3
Mod 3, Lesson 3
92
For an understanding of the MRB process, talk with your AEG representative and refer to AC 121-22A.
93
Applicants will have to submit the EWIS ICA to the ACOs for approval. Most EWIS ICA developed by using an EZAP will be located in the MRB report. The means of compliance proposed by the DAHs may differ from that of AC 120-XX. This is addressed in Module 4 of this IVT.
Mod 3, Lesson 3
Typical Process For Developing And Approving EWIS ICA Developed by a TC Holder or an STC Applicant For Compliance To 26.11(c) EWIS ICA Requirements
The lists on the next couple of pages are meant to represent the general types of activities that should occur when EWIS ICA are developed and approved. The lists may not contain all of the necessary actions or be listed in the exact sequential order. The processes listed are consistent with the Maintenance Review Board procedures outlined in AC 121-22A.
Mod 3, Lesson 3
Typical Process For Developing & Approving EWIS ICA Developed by a DAH for Compliance to the Part 26 EWIS ICA Requirements
Typical Process for EWIS ICA Development & Approval
Preliminary EZAP reviewed at the ISC MRB meeting (FAA Oversight Office participates) DAH updates EZAP as necessary based on ISC MRB meeting results
DAH incorporates EWIS ICA into MRBR & submits it to AEG Chairperson for approval
After MRBR approval, DAH submits ICA source document to FAA Oversight Office for approval
FAA Oversight Office approves EWIS ICA source document [part 25, App H H25.5(b)]
94
ISC
MRB Maintenance Review Board MRBR Maintenance Review Board Report 1. 2. 3. 4. 5. 6. 7. 8. 9. DAH conducts preliminary EZAP analysis DAH presents EZAP analysis results at the Industry Steering Committee (ISC) meeting ACO personnel working with AEG and ISC members review and identify modifications to the EZAP analysis results as necessary EZAP derived EWIS maintenance and inspection requirements are included in the MRB report DAH prepares instructions for continued airworthiness which include EWIS ICA MRB Chairman (AEG) approves the MRB report DAH receives approved MRB report DAH produces source document [required by H25.5(b)] identifying the location of the EWIS ICA DAH submits source document and referenced ICA documents to ACO for approval
10. ACO reviews and approves the source document, which indicates their approval of the EWIS M&IR referenced or contained in that document
Mod 3, Lesson 3
Typical Process For Developing & Approving EWIS ICA Developed By An STC Applicant For Compliance To 26.11(c) EWIS ICA Requirements
Typical Process for STC EWIS ICA Development & Approval STC applicant conducts an EZAP to generate EWIS ICA for proposed modification ACO works with AEG to determine any impact to existing EWIS ICA for airplane undergoing modification
ACO approves EWIS ICA source document [part 25, App H H25.5(b)]
95
ISC
MRB Maintenance Review Board MRBR Maintenance Review Board Report 1. 2. 3. 4. STC applicant conducts EZAP analysis STC applicant presents EZAP analysis results to ACO ACO personnel work with AEG to determine any impact to existing airplane ICA STC applicant produces source document [required by H25.5(b)] identifying the location of the EWIS ICA that were developed using an EZAP (or the source document would contain the EWIS ICA its the applicants choice) STC applicants submits the source document to the ACO for approval ACO reviews and approves the source document, which indicates their approval of the EWIS ICA referenced or contained in that document, and other ICA documentation
5. 6.
Mod 3, Lesson 3
96
The reason for sending the copies is that these individuals are either on the Standardization Team or involved in the development of the EWIS ICA through the industry steering committee meetings. They need to be aware of the progress of the DAHs in complying with the part 26 requirements.
Name
Massoud Sadeghi Stephen Slotte Fred Sobeck MRB Chairperson
Routing Number
ANM-110 ANM-110 AFS-308 AEG: varies depending on model
Email
[email protected] [email protected] [email protected]
Phone
425-227-2117 425-227-2315 202-267-7355
Fax
425-227-1320 425-227-1320 202-267-5115
Even once the ICA are delivered, the FAA Oversight Office is still involved because certain changes to the ICA will have to come back thru the Oversight Office for approval.
Mod 3, Lesson 3
INTEGRATION OF EWIS AND FTS ICA INTO PART 121 AND 129 AIR CARRIERS MAINTENACE PROGRAMS AND INTEGRATION OF FTS ICA INTO PART 91 AND 125 OWNER/OPERATORS INSPECTION PROGRAMS
Introduction
97
EAPAS rule contains requirements for the operators to incorporate Fuel Tank System ICA that were developed under 25.1529 and Appendix H. The EAPAS/FTS NPRM has details of this specific requirement.
Mod 3, Lesson 3
98
FAA PIs have guidance on what deviations to FAA-approved data and documents need to be coordinated with the FAA Oversight Office.
99
For the EWIS ICA developed using EZAP, PI will review and approve changes to operators maintenance program by applying the same criteria as they would in accepting other maintenance program changes.
Mod 3, Lesson 3
100
Mod 3, Lesson 3
Summary of Lesson 3
SUMMARY OF LESSON 3
This lesson discussed why and how EWIS ICA are approved by the FAA Oversight Office. We also discussed the integration of the EWIS ICA into the operators maintenance or inspection programs.
Module 3
Module 3 Summary
MODULE 3 SUMMARY
Summary of Module 3
New part 26 requirements for EAPAS DAH Goal of EAPAS to enhance safety by addressing electrical wiring system deterioration and wire contamination Within EAPAS, requirement for DAH to develop EWIS ICA and make them available to operators
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103
Module 3
Module 3 Summary
Mod 3, Les 2
Develop & doc. EWIS ICA
Mod 3, Les 3
FAA approval & operator integration of EWIS ICA
Mod 4
Roles & responsibilities of FAA and DAH to comply with part 26 requirements
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PARTICIPANT GUIDE
Version 1.1 Note: The information contained in this Participant Guide is presented by the instructors through captioned video and audio. A transcript of the captioning is also available with each with each video segment.
INTRODUCTION TO MODULE 4 INTRODUCTION TO MODULE 4 ....................................................1 Overview ....................................................................................2 October 2005 IVT and DAH Documents.....................................4 Why New DAH Approach Developed .........................................5 Culture Shift................................................................................6
LESSON 1: AC 28.XX AND ORDER 8110.26-X ROLES AND RESPONSIBILITIES INTRODUCTION .............................................................................7 Lesson Purpose and Objective...................................................7 Overview of Standardization and Compliance Teams and DAHs ...................................................................................8 TEAM ROLES AND RESPONSIBILITIES ....................................10 Standardization Team ..............................................................10 Compliance Team ....................................................................18 DAH Responsibilities ................................................................27 COMPLIANCE AND ENFORCEMENT PROGRAM......................30 General Enforcement Information ............................................30 SUMMARY OF LESSON 1............................................................31
LESSON 2: KEY ELEMENTS OF AN EWIS ICA COMPLIANCE PLAN INTRODUCTION ...........................................................................33 Lesson Purpose and Objective ................................................33 REQUIRED ELEMENTS OF A COMPLIANCE PLAN..................34 Regulatory Overview................................................................34 26.11(e)(1): Milestone Schedule .............................................35 26.11(e)(2): Means of Compliance and Required Submittals..36 26.11(e)(3): Proposal for Submitting Draft of all Compliance Items Required by Paragraph (e)(2).....................38 26.11(e)(4): Proposal for Distribution Process and Schedule for Making Data and Documents Available ..............39 GOOD PRACTICE TO INCLUDE IN A COMPLIANCE PLAN......42 Elements from AC 26.XX and Order 8110.26-X.......................42 LESSON 2 CONCLUSION............................................................44 Final Point about the Compliance Plan ....................................44 Lesson 2 Summary ..................................................................45
LESSON 3: CRITICAL COMPLIANCE PROCESS ELEMENTS INTRODUCTION ...........................................................................48 Lesson Overview ......................................................................48 Lesson Objectives ....................................................................49 Introduction to Flowchart from DAH Order 8110.26-X ..............49 COMPLIANCE PROCESSES OF DAH ORDER 8110.26-X .........58 Paragraphs 5-2.a and b, Activities Prior to Final Rule ..............58 Paragraph 5-3, Familiarization of DAH .....................................59 Paragraphs 5-4 through 5-6, Compliance Plan Development and Approval ......................................................61 Paragraphs 5-6 through End of Page 1, Compliance Plan Implementation .........................................................................68 Paragraph 5-7.a, Review and Approval of Draft Data and Documents ........................................................................71 Paragraph 5-8.a, Review and Approval of Final Data and Documents ........................................................................75 Paragraph 6-2.e and f, Operator Implementation of Data and Documents ........................................................................80 LESSON 3 SUMMARY..................................................................82
Introduction to Module 4
Course Number: 24910 Course Manager: Massoud Sadeghi Version Date: May, 2007 Version Number: Version 1.0
Introduction to Module 4
Overview
Overview of Module 4
FAA requirements drive compliance with design approval holder (DAH) rules and development of a compliance plan Compliance plan schedules support complimentary requirements for DAHs & operators; change in how FAA/DAH work AC 26.XX and Order 8110.26-X support this change
EAPAS IVT, Course 24910, Mod 4 Federal Aviation Administration
Major Goal
Achieve on-time compliance with objectives & requirements of EAPAS Safety Initiatives Implementation strategy will
Involve a structured, proactive project management approach Ensure early awareness of risks to acceptable compliance and Allow FAA to facilitate resolution of issues to ensure on-time compliance
EAPAS IVT, Course 24910, Mod 4 Federal Aviation Administration
The implementation strategy does identify enforcement actions to help obtain compliance. However, enforcement would be used only as a last resort, if collaborative, proactive approach with DAHs fails to facilitate timely compliance.
Introduction to Module 4
Purpose of Module
Provide you with information on
Your role and responsibilities, and How you can facilitate the processes to implement the EAPAS DAH rules
Introduction to Module 4
There are ACs, Orders, and, the NPRMs that contain information regarding rulemaking and processes to follow for compliance and implementation. The DAH Order will be finalized and issued concurrently with the EAPAS final rule. While references to Orders or guidance information may be to draft material, we do not anticipate any substantial change in the finalized versions of these references.
Introduction to Module 4
The FAA believes that DAH support of operators in complying with operational rules has occasionally been lacking. The FAAs historic approach of adopting rules with compliance times only for operators may cause economic impact to operators, with no consequences for design approval holders.
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Introduction to Module 4
Culture Shift
Culture Shift
Complementary DAH and operational rules a policy and culture shift
Requires shared responsibility between DAHs and operators Requires culture shift in relationship between the FAA and DAHs
DAH rules, AC 26-XX, & Order 8110.26-X help achieve the safety benefits
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FAA teams need to be up and running before the final rule is out to ensure these teams have the necessary information to facilitate the DAH activity. FAA teams need to be knowledgeable of rules and associated guidance, as well as roles and responsibilities in promoting acceptable on-time compliance.
Which is NOT a reason for using DAH rules to support certain rulemaking initiatives, including EAPAS?
a. Achieve safety benefits in a timely manner. b. Ensure operators have information needed to comply with the operational rules. c. Provide the FAA with mechanisms to facilitate compliance. d. Ensure consistency and standardization in how initiatives are implemented.
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Mod 4, Lesson 1
Introduction
13
INTRODUCTION
Lesson Purpose and Objective
Lesson Purpose
AC 26.XX and Order 8110.26-X define roles & responsibilities of FAA Standardization Team & Compliance Teams, and DAHs for EAPAS Main difference from current certification process, is that FAAs mandate for continued airworthiness of fleet is driving the schedule, not the DAH These initiatives require DAHs support to help operators implement safety actions
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Mod 4, Lesson 1
Introduction
Lesson 1 Objective
Upon completion of this lesson, you will be able to describe, as defined in AC 26.XX, Order 8110.26-X, and Order 2150.3A
Key roles and responsibilities of the Standardization and Compliance Teams Responsibilities of the DAH General process for enforcement
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Standardization Team
Interface with all Compliance Teams and other civil aviation authorities Serve as resource on technical requirements of rules and compliance methodology to help ensure standardized application of rules Assist Compliance Teams and other authorities, and keep management informed of issues and compliance status
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Mod 4, Lesson 1
Introduction
Compliance Teams
(FAA Oversight Office)
Familiarize DAHs with rules & guidance for developing compliance plan Monitor DAHs progress Review and approve data & documents Provide status updates and coordinate issues with Standardization Team
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The Compliance Team is part of the FAA Oversight Office referenced in the DAH rules.
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Mod 4, Lesson 1
19
Standardization Team
(formed for each safety initiative)
Composed of representatives from (per Order 8110.26-X: 4-3b)
Transport Standards Staff (including
international & standardization branch offices)
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Mod 4, Lesson 1
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Communication
The Standardization Team will be in frequent communication with the Compliance Teams
Helpful for areas not addressed in policy Standardization Team will identify key information for Compliance Teams to provide to support standardization
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Mod 4, Lesson 1
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Mod 4, Lesson 1
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Mod 4, Lesson 1
Technical Guidance
Serve as resource regarding technical requirements of rules and compliance methodology Help to determine if DAHs applying rule correctly
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Standardization
Ensure technical standardization, standardized issue resolution, and standardized enforcement activities
Standardized familiarization briefing for Compliance Teams to use with DAHs Review alternate methods of compliance Review proposals by DAHs outside U.S.
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Standardization Team will review the proposed means to confirm compliance to ensure that it is both appropriate to the type design and consistently applied. This role is conducted with input from the Compliance Teams on the acceptability of the DAH-proposed compliance methodology.
EAPAS: Part 26 DAH Public Version 1.1, Aug 2007 Participant Guide page 4-14
Mod 4, Lesson 1
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FAA Order 8110.26-X outlines the responsibilities of the Compliance Teams to coordinate DAH issues with the Standardization Team and the FAA Oversight Office management. The frequency and content of communication to ANM-100/AFS-300 management must be prompt to avoid unnecessary delays. Significant deviations to the approved compliance plan or lack of communication or responsiveness from the DAH will be raised to ANM-100/AFS-300 management.
If necessary, the Flight Standards Service will alert affected operators of a compliance risk. This will enable the operators to pursue alternate means of compliance with the requirements of the DAH regulations in support of the operators compliance with the operational rules. If a DAH were to surrender their type certificate, the FAA could not share the technical type design data. However, interested parties may contact the DAH to obtain permission to use the type design data.
Mod 4, Lesson 1
Standardization Team
Summary of Roles
1. Technical guidance for Compliance Teams 2. Technical standardization, standardized issue resolution & enforcement activities 3. Monitor compliance status, resolve issues, & ensure communication with management (ANM-100 & AFS-300)
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Mod 4, Lesson 1
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Mod 4, Lesson 1
Compliance Team
June 1, 2006
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Mod 4, Lesson 1
34
Compliance Team members are selected depending on the model airplane and the DAH. It is up to each ACO manager to determine an appropriate team based on resources and the complexity of the project. This team will work directly with the DAHs to: Familiarize them with the safety initiative rule requirements and associated guidance, Review and approve the DAH compliance plan, Monitor the implementation of the plan, and Make the final determination of DAH compliance with requirements.
The Compliance Teams have two main roles: Performing project management tasks by overseeing DAH activities. Determining compliance.
Mod 4, Lesson 1
Project Management
Oversee DAH activities
Have familiarization meetings with DAHs Monitor development and achievement of compliance plan Work closely with DAHs to resolve issues in a timely manner
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36
Familiarization meetings are needed for existing TC holders as well as pending TC, ATC and STC applicants, since these affected DAHs will need to comply with all of the related part 26 requirements. Future applicants with the part 26 technical requirements as part of their certification basis will show compliance with those requirements as part of their certification program. They will not be required to submit compliance plans or draft data and documents.
EAPAS: Part 26 DAH Public Version 1.1, Aug 2007 Participant Guide page 4-20
Mod 4, Lesson 1
37
Although early drafts of data and documents are not required submittals, they are strongly recommended for successful projects).
Mod 4, Lesson 1
38
Documentation may be in the form of a letter, in particular, the approval of the compliance plan or the identification of deficiencies in the plan or the implementation of an approved plan. Emails, records of meeting, or telecons with the DAH, are essential information to document for any potential enforcement actions the FAA may take because of DAH non-compliance. Compliance status information must include a summary of the actions taken by the Standardization and Compliance Teams to facilitate compliance and, if compliance appears to be still at risk, the Teams recommendations for resolution. It is important to accurately know and document the DAHs progress towards compliance.
Mod 4, Lesson 1
39
Determine Compliance
Review and approval of DAH compliance data and documents
Similar to review and approval of compliance plan
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Mod 4, Lesson 1
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42
Response times ensure prompt FAA responses to DAHs, and support DAHs achieving timely compliance.
Mod 4, Lesson 1
Compliance Team
Summary of Roles
1. Oversee DAH compliance activities (project management) 2. Determine compliance with DAH rules
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Mod 4, Lesson 1
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Mod 4, Lesson 1
DAH Responsibilities
June 1, 2006
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DAH Responsibilities
DAH has legal obligation to:
1. Comply with part 26 requirements
If doesnt comply, Compliance Teams identify and document by notifying DAH and Standardization Team, and submit recommendations for FAA action
2. Submit compliance plan within 90 days after effective date of the rule [26.11(e)]
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Mod 4, Lesson 1
4. Submit draft compliance data & documents 60 days before final data and documents are required [26.11(e)] 5. Submit final data and documents within 24 months after effective date of rule [26.11(d)]
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Mod 4, Lesson 1
Question #1 on DAHs
DAHs do NOT have a legal responsibility to:
a. Submit compliance plan for approval. b. Implement compliance plan. c. Make data & documents available to operators. d. Include operators in ICA development activity.
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Mod 4, Lesson 1
Lesson 1 Summary
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Mod 4, Lesson 1
Lesson 1 Summary
LESSON 1 SUMMARY
Lesson 1 Summary
DAH rules
Are intended to ensure data & documents are available in a timely manner to support operator compliance with operational rules Drive the schedule for compliance actions, which is different from certification projects where DAHs drive the schedule
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Mod 4, Lesson 1
Lesson 1 Summary
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Mod 4, Lesson 2
Introduction
65
INTRODUCTION
Lesson Purpose and Objective
Lesson Objective
Upon completion of this lesson, you will be able to describe and recognize key elements of a DAHs EWIS ICA compliance plan
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Mod 4, Lesson 2
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26.11(e) is shown below this slide, and its in Appendix E of this Guide.
26.11(e): Each person identified in paragraphs (d)(1), (d)(2), and (d)(4) of this section must submit to the FAA Oversight Office for approval a compliance plan by [insert date 90 days after effective date of final rule]. The compliance plan must include the following information: (1) A proposed project schedule, identifying all major milestones, for meeting the compliance dates specified in paragraph (d) of this section. (2) A proposed means of compliance with this section, identifying all required submissions, including all compliance items as mandated in part 25, Appendix H paragraphs H25.5(a)(1) and (b) of this subchapter in effect on [effective date of this final rule], and all data to be developed to substantiate compliance. (3) A proposal for submitting a draft of all compliance items required by paragraph (e)(2) of this section for review by the FAA Oversight Office not less than 60 days before the compliance time specified in paragraph (d) of this section. (4) A proposal for how the approved Instructions for Continued Airworthiness will be made available to affected persons.
Mod 4, Lesson 2
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For EWIS ICA development, DAHs may use the MSG-3 process, which includes operators. However, other processes that may not inherently include operators may be acceptable for compliance. For these situations, DAHs should indicate coordination with operators as part of their milestones.
Mod 4, Lesson 2
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Some DAHs have developed EWIS ICA using EZAP. Two different processes: MSG-3 v2003, and MSG-3 v2005.1. DAHs may not have fully considered using a representative airplane configuration. The Standardization Team needs to be consulted in these cases.
Mod 4, Lesson 2
DAH may propose to use alternative compliance methods to those in the guidance material. The Compliance Teams must coordinate with the Standardization Team on the acceptability. This coordination must include the teams recommendations on the acceptability of the DAH compliance methodology.
A proposed means of compliance with this section, identifying all required submissions, including all compliance items as mandated in part 25, Appendix H paragraphs H25.5(a)(1) and (b) of this subchapter in effect on [effective date of this final rule], and all data to be developed to substantiate compliance.
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Mod 4, Lesson 2
26.11(e)(3): Proposal for Submitting Draft of all Compliance Items Required by Paragraph (e)(2)
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If the DAH has not previously addressed or conducted an EZAP analysis with FAA involvement, then the Compliance Team needs to get involved with review of the analysis as early as possible, therefore sooner than 60 days. The purpose of these early reviews is to ensure the data and documents will be appropriate for compliance.
Mod 4, Lesson 2
26.11(e)(4): Proposal for Distribution Process and Schedule for Making Data and Documents Available
The review and approval by the FAA of the final EWIS ICA need to be made expeditiously so that the DAH can get the information to the operators quickly. This gives the operators as much time as possible to incorporate changes into their maintenance or inspection programs.
// 24 months
3 months 60 days 24 months from effective date of rule
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Mod 4, Lesson 2
//
3 months
24 months FAA approves EWIS ICA Pending STC applicants: 30 months from effective date of rule or date certification is issued, whichever occurs later
Federal Aviation Administration
24 months from effective Pending date of rule, or date TC/ATC certificate is issued, applicants whichever occurs later
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Future applicants for ATCs and STCs who filed their applications on or after the effective date of the rule and for which compliance with 25.1729 was not required or elected, would comply with the part 26 requirements as part of their certification program. They would not be required to submit a specific compliance plan or draft data and documents, as would be required for existing or pending DAHs.
Mod 4, Lesson 2
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Mod 4, Lesson 2
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Compliance Team
Ensure DAH knows FAA contact
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Mod 4, Lesson 2
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If the Compliance Team agrees with the delegation plan, the designee has the responsibility for finding compliance, or recommending approval, with all the requirements of the DAH regulations, as appropriate. FAA policy does address designees and airworthiness representative (ODA).
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Mod 4, Lesson 2
Lesson 2 Conclusion
LESSON 2 CONCLUSION
Final Point about the Compliance Plan
Lack of expected content or an unacceptable plan does NOT stop compliance clock!
DAH expected to comply by final date in rule If no acceptable compliance plan submitted, FAA may pursue enforcement action
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Mod 4, Lesson 2
Lesson 2 Conclusion
Lesson 2 Summary
Lesson 2 Summary
Elements of compliance plan required by 26.11(e)(1)(2)(3)(4):
1. Proposed project schedule 2. Proposed means of compliance and required compliance submittals
ACs 25.17XX & 120-XX acceptable means MSG-3 processes need to address using a representative airplane configuration
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Mod 4, Lesson 2
Lesson 2 Conclusion
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Mod 4, Lesson 2
Lesson 2 Conclusion
If the DAH-proposed method of compliance is different from published material, what is NOT a Compliance Team action?
a. Request DAH identify differences from published guidance b. Evaluate acceptability of method c. Coordinate with Standardization Team d. Require DAH to use AC methodology
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Mod 4, Lesson 3
Introduction
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INTRODUCTION
Lesson Overview
Lesson 3 Overview
Covering processes essential to
Facilitating DAH compliance and compliance standardization, and Identifying when compliance at risk
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Mod 4, Lesson 3
Introduction
Lesson Objectives
Lesson 3 Objectives
You will be able to:
Describe critical process elements used in:
Approval of the compliance plan, Resolution of deficiencies, Monitoring DAHs plan implementation, and Review/approval of final data & documents
Identify required review, approval, and response times needed to support various compliance activities
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Mod 4, Lesson 3
Introduction
1 2 3 4
Mod 4, Lesson 3
Introduction
Mod 4, Lesson 3
Introduction
F AA S tan dard izat ion Tea m - p ara grap h 5- 2.a. Fa m ilia rize all C om plianc e T ea m s w ith re gulat ions , guida nc e , and ex pe cta tion s fo r c om plianc e p lan , a naly ses , da ta , a nd doc u m e nts .
F A A C om plianc e T ea m - paragraph 5-2 . b. Organ ize t eam , d evelo p p lan , defin e roles & resp ons ib ilities , part icipa te in trainin g a nd p rep ara tion act iv itie s .
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For the most part, the processes focus on Compliance Team activities with the DAH and indicate coordination with the Standardization Team as necessary. However, the Standardization Team will be carrying out their roles and responsibilities as well.
Mod 4, Lesson 3
Introduction
F AA S tan dard iz at ion Tea m - p ara grap h 5- 2.a. Fa m ilia riz e all C om plianc e T ea m s w ith re gulat ions , guida nc e , and expe cta tion s fo r c om plianc e p lan , a naly ses , da ta , a nd docu me nts .
1 2 3
F A A C om plianc e T ea m - paragraph 5-2 . b. Organ iz e t eam , d evelo p p lan , defin e roles & resp onsib ilities , part ic ipa te in trainin g a nd p rep ara tion ac t iv itie s .
F A A C o mplia nc e T eam - pa rag raph 5 -3 F am iliariz e a ssig ned D A H w ith reg ulat ions , guid ance , an d expe cta tion s fo r c om plianc e p lan , a naly ses , da ta , a nd docu me nts .
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The first two boxes (numbers 1 and 2 on the right) deal with activities to be done by the Standardization and Compliance Teams prior to the final DAH rule. The third box addresses the Compliance Team activity to familiarize the DAH with the rules, procedures, and expectations.
Mod 4, Lesson 3
Introduction
4 5
* C oord inat e w ith S t and ardiz atio n T eam .
FA A C om plian c e and S tan dardiz at ion Te ams p ara grap h 5 -5 T he Tea ms re v iew the propos ed D A H c om plian ce p lan .
Yes
C om plian c e t eam a ppro v es co mplia nc e pla n an d m on itors D A H c o m plia nc e pla n im plem en tatio n . C o ordin ate s w it h S t and ardiz atio n T eam .
Yes
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The remaining boxes and decision points on the first page of the flowchart concern: Overseeing DAH development of the compliance plan, Approving the compliance plan, and Monitoring DAH compliance plan implementation.
Mod 4, Lesson 3
Introduction
No
A c cept able ?
Yes
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The top third of the second page of the flowchart centers on the draft data and documents.
Mod 4, Lesson 3
Introduction
R ev iew s D A H final dat a and docu me nts and ap pro ves if a cce ptab le . C o ordin ate s w ith S t andardization T eam .
R esolve in time?
No
FA A a pprove d ?
Yes
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The middle third deals with the final data and documents and approval of this material.
Mod 4, Lesson 3
Introduction
R eview operators proposed programs and approve if ac ceptable . C oordinat es w ith C om pliance Team if necessary .
R esolve in time?
F A A A pproved ?
Yes
No
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And the final section of the flowchart shows the transition of data and documents to the operators and working with the FAA Principal Inspector.
Mod 4, Lesson 3
Preparatory Activities
FAA Standardization Team paragraph 5-2.a.
Familiarize all Compliance Teams with regulations, guidance, and expectations for compliance plan, analyses, data, and documents
Set up structured communication process & discuss expectations for how Teams work together
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The slide shows paragraphs 5-2.a and 5-2.b. They represent the activities of the Standardization and Compliance Team prior to the issuance of the final rule. This preparation involves close coordination even before the EAPAS final rule is issued.
The Standardization Team will: Discuss what key information it needs from the Compliance Teams so it can conduct the standardization activities, and Provide the Compliance Teams with standardized briefing materials to conduct familiarization briefings with the affected DAHs.
The Teams will also develop plans to carry out their roles and responsibilities. This will include participating in necessary training activities and reviewing all of the available documents on the EAPAS rulemaking initiative.
Mod 4, Lesson 3
Familiarization of DAH
FAA Compliance Team paragraph 5-3
Familiarize assigned DAH with regulations, guidance, & expectations for compliance plan, analyses, data, & documents.
Letter to DAH
States final rule issued Identifies EAPAS contact in Oversight Office Provides regulatory references & guidance Provides training information, if appropriate Requests DAH schedule familiarization meeting with FAA
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Compliance Teams will send a letter to each affected DAH as soon as the final rule has been issued. That letter should be sent within 2 weeks after the issuance of the final rule.
Due to ex parte concerns, you may not hold the familiarization meeting before the final rule is issued. However, you may coordinate with the DAH to let them know that you will be in contact as soon as the final rule is issued to schedule a familiarization meeting.
A sample form letter will be developed by the Standardization Team and provided to all Compliance Teams. The letter will be provided once the Standardization and Compliance Teams begin preparing for the final rule issuance.
Mod 4, Lesson 3
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The FAA would like to have the familiarization meetings occur within a month after the issuance of the final rule to support the DAHs development of a compliance plan, which is to be submitted 90 days after the effective date of the rule.
Mod 4, Lesson 3
4 5
* C oord inat e w ith S t and ardiz atio n T eam .
FA A C om plian ce and S tan dardizat ion Te am s p ara grap h 5 -5 T he Tea ms re v iew the propos ed D A H c om plian c e p lan .
Yes
C om plian ce t eam a ppro v es co m plia nc e pla n an d m on itors D A H c o m plia nce pla n im plem en tatio n . C o ordin ate s w it h S t and ardiz atio n T eam .
Yes
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Paragraphs 5-4 through 5-6 focus on compliance plan development and approval activities.
Mod 4, Lesson 3
DAHs have 90 days from effective date of EAPAS rule to submit compliance plan for FAA approval Compliance Teams work closely with DAH and coordinate with Standardization Team, especially for compliance methods that differ from existing guidance materials
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The Compliance Team must be proactive in carrying out its oversight responsibilities and facilitating compliance.
Mod 4, Lesson 3
FA A C om plian ce and S tan dardizat ion Teams p ara grap h 5 -5 T he Tea ms review the propos ed D A H com plian ce p lan .
5
* C oord inat e w ith S t and ardiz atio n T eam .
Yes
C om plian ce t eam a ppro ves co mplia nce pla n an d m on itors D A H co mplia nce pla n im plem en tatio n . C oordin ate s w it h S t and ardiz atio n T eam .
Yes
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There is a process for recognizing and dealing with deficiencies in the compliance plan. The Compliance Team will follow the steps and milestones in the DAH Order for reviewing the plan and responding to DAH, and coordinating with the Standardization Team.
Mod 4, Lesson 3
Communication Summary
Appendix N of Participant Guide:
Communication Schedule: Minimum Requirements For Documented Communication With DAH 1st table: Review/Approval of Compliance Plan (Ref. Order 8110.26-X chap. 5, section 5)
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Mod 4, Lesson 3
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1. Preliminary review within 1 week of receipt (identify major deficiencies in the plan and contact DAH). 2. Complete review within 4 weeks of receipt (contact DAH immediately to identify deficiencies). 3. Send letter stating approval or non-approval of plan within 6 weeks of receipt. 4. If a plan is not acceptable, the DAH must submit a revised plan as soon as possible. The Compliance Team will review the revised areas of the plan and, if acceptable, will send a letter approving the plan to the DAH within 3 weeks of receipt of the revised plan.
Mod 4, Lesson 3
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The earlier management is aware of the potential for non-compliance, the greater the opportunity for management to take action to resolve the issues and facilitate timely compliance. In the final DAH Order, we will revise the flowchart to indicate an enforcement option if the DAHs compliance plan is not submitted by the required date.
Mod 4, Lesson 3
Which is NOT a preparatory activity for the EAPAS DAH rule implementation?
a. Development of structured communication process between the Standardization Team and Compliance Teams b. Team members attend EAPAS rule training c. Team members review EAPAS rulemaking and guidance materials d. Compliance Teams conduct familiarization meetings with DAHs
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The Compliance Teams must work closely with DAHs during compliance plan development activities to ensure an acceptable plan will be submitted by the compliance plan due date specified in the EAPAS rule
a. True b. False
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Mod 4, Lesson 3
C om plian ce t eam a ppro v es co m plia nc e pla n an d m on itors D A H c o m plia nce pla n im plem en tatio n . C o ordin ate s w it h S t and ardiz atio n T eam .
Yes
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Once the DAHs compliance plan is approved, then the Compliance Team will actively monitor the DAHs implementation of that plan. It is expected the Compliance Team will schedule regular status reviews with the DAH to discuss the progress toward these DAH milestones. If there is no plan, or the plan is lacking, the Compliance Team must institute frequent discussions with the DAH to determine if compliance is on-track. Also, the FAA may pursue enforcement action, but the Compliance Team should continue to work with the DAH to monitor progress toward compliance. If it appears that compliance is not on track, it is important to notify the DAH of the concern as soon as possible, and within a week. These notifications should be documented.
Mod 4, Lesson 3
Communication Summary
Appendix N of Participant Guide:
Communication Schedule 2nd table: Monitor Implementation of Compliance Plan (Ref. Order 8110.26-X chap. 5, section 6)
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Mod 4, Lesson 3
109
26.11(e) requires DAH to submit draft data and documents at least 60 days prior to compliance date Review and communication process similar to that for compliance plan
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A formal letter is not necessary for communicating outcomes of the FAA review of draft data and documents.
Mod 4, Lesson 3
Communication Summary
Appendix N of Participant Guide:
Communication Schedule 3rd table: Draft Data and Documents Submittal and Review (Ref. Order 8110.26-X chap. 5, section 7)
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Mod 4, Lesson 3
Note that if draft data and/or documents are unacceptable, Compliance Team must continue to work with DAH to help ensure that deficiencies are corrected prior to the submittal of the final compliance data and documents.
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Mod 4, Lesson 3
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Mod 4, Lesson 3
FA A C om pliance Team paragraph 5- 8.a. R ev iew s D A H final dat a and documents and approves if acceptable . C oordinates w ith S t andardization T eam .
R esolve in time?
No
FA A approved ?
Yes
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Compliance Team actions associated with the review and approval of the final data and documents are similar to those for compliance plan and draft data and documents.
Mod 4, Lesson 3
Communication Summary
Appendix N of Participant Guide:
Communication Schedule 4th table: Final Data and Documents Submittal, Review, and Approval (Ref. Order 8110.26-X, chap. 5, section 8)
117
Mod 4, Lesson 3
118
The approval letter to DAH will be copied to Massoud Sadeghi and Stephen Slotte (ANM-117/111) and Fred Sobeck (AFS-308), and chair of the MRB so the TAD and AFS policy divisions are aware of the approval. The appropriate AEG will then alert their affected PIs of the approval. Routing Number ANM-110 ANM-110 AFS-308 AEG: varies depending on model
Mod 4, Lesson 3
The actions in this final table must be expedited to the greatest extent possible, as any delays will impact the operators ability to comply on time. Raise any issues that are not resolved quickly to management. Enforcement action may be taken as a result of deficient documents as appropriate.
Mod 4, Lesson 3
If the DAH is not meeting the compliance milestones outlined in their compliance plan, the Compliance Team should
a. Work with DAHs to resolve deficiencies b. Request FAA Oversight Office management support if quick resolution is not likely c. Alert Standardization Team to deficiencies and status of resolution d. All of the above
EAPAS IVT, Course 24910, Mod 4 Federal Aviation Administration
119
If the final data and documents are not acceptable, the Compliance Team must send a letter to the DAH within
a. 1 week of receipt b. 4 weeks of receipt c. 5 weeks of receipt d. 6 weeks of receipt
120
Mod 4, Lesson 3
Once data/documents are approved, DAH must make available information to support operator compliance
Done in accordance with schedule in FAA-approved compliance plan Compliance Teams should ensure DAHs complete this activity
EAPAS IVT, Course 24910, Mod 4 Federal Aviation Administration
121
Operators may propose program changes that differ from the data and documents approved by the FAA, such as different inspection intervals than the those developed by the DAH. In these cases, it would be important for the Principle Investigator to work with the Compliance Team to ensure the proposal is acceptable. The need for this type of coordination is outlined in policy under development by AFS-300 for the PIs (this policy was developed in conjunction with AIR).
Mod 4, Lesson 3
R eview operators propo sed programs and approve if ac ceptable . C oordinat es w ith C om pliance Team if necessary .
R esolve in time?
F A A A pproved ?
Yes
No
122
These boxes show the AFS/PI activity to work with operators to ensure they have complied with the related operational rules by their compliance date. If not, AFS will take appropriate enforcement action.
Mod 4, Lesson 3
Lesson 3 Summary
LESSON 3 SUMMARY
Lesson 3 Summary
Flowchart processes include
Approval of compliance plan Resolution of deficiencies Monitoring compliance plan implementation by the DAH Review and approval of data and documents
No
Start
FAA Standardization Team - paragraph 5- 2.a. Familiarize all C omplianc e Teams with regulations , guidance , and expectations for c om plianc e plan , analy ses , data , and documents .
FAA C omplianc e Team - paragraph 5-2.b. Organize team , develop plan , define roles & responsibilities , participate in training and preparation act ivities .
FAA Compliance Team - paragraph 5-3 Fam iliariz e assigned DAH with regulations , guidance , and expectations for c om plianc e plan , analy ses , data , and documents .
FAA Compliance & Standardization Teams - paragraph 5-4 Compliance Team ov ersees DAH development and s ubmittal of compliance plan . Coordinates w ith Standardization Team . Standardization Team ensures standardiz ation . DAH submits c ompliance plan.
DAH revises plan, see para. 5-5.d
FAA Compliance and Standardization Teams paragraph 5 -5 The Teams review the propos ed DAH compliance plan .
Yes
C ompliance team approves compliance plan and monitors DAH compliance plan im plementation . Coordinates w ith St andardiz ation Team .
Yes
F A A C omp lianc e T eam par agra ph 5 - 7 .a . R ev ie w s dra ft D A H d ata and do c um ent s , c o ord inate s w ith S ta ndar diz a tion T eam . I f a c c ep tab le , notif ies D A H o f d ec is ion.
R e s o lve in ti m e ?
No
No
A c c ept able ?
Ye s
FA A C om plian c e Tea m pa ragraph 5- 8.a . R ev iew s D A H fina l dat a a nd doc u m e nts and ap pro v es if a c c e ptab le . C o ordin ate s w ith S t and ard iz atio n T ea m .
R e so lv e in tim e?
No
FA A a ppr ove d ?
Ye s
O p era tors propo s e c han ges to m a inte nan c e o r o per ation al p rog ram s
R ev ie w op era tors propo sed pro gra ms and ap pro v e if ac c ep tab le . C o ord inat es w ith C om plian c e Tea m if n ece s s ary .
R e so l ve in tim e?
F A A A pp rove d ?
Ye s
A FS polic y d iv is ion s
No
No
FA A E nfo rc e m e nt A c t ion
E nd
123
124
Mod 4, Lesson 3
Lesson 3 Summary
125
Module 4
Module 4 Summary
DAH rule - timely implementation of ops rules of EAPAS safety initiative Standardization & Compliance Teams support implementation of EAPAS DAH rule Order 8110.26-X & AC 26-XX processes to facilitate DAH compliance to part 26 rules
EAPAS IVT, Course 24910, Mod 4 Federal Aviation Administration
126
127
Module 4
128
129
Module 4
130
PARTICIPANT GUIDE
Version 1.1 Note: The information contained in this Participant Guide is presented by the instructors through captioned video and audio. A transcript of the captioning is also available with each with each video segment.
Module 5, Summary
Course Number: 24910 Course Manager: Massoud Sadeghi Version Date: May, 2007 Version Number: 1.0
Module 5, Summary
Change due to
Influence of accidents, investigations, and follow-on recommendations from the collaboration of the FAA, industry, and others.
Module 5, Summary
It All Resulted In
1. Development of enhancements in EWIS design, certification, installation, maintenance requirements, and new technologies 2. FAA EAPAS rulemaking package: enhanced and new requirements and guidance material for design and operational rules
EAPAS IVT, Course 24910, Mod 5 Federal Aviation Administration
EAPAS
EAPAS rulemaking package contains: Revisions of existing EWIS-related requirements, Additions of enhanced EWIS requirements, Adoption of new continued airworthiness requirements for EWIS, New design approval holder requirements, and Requirements for operators to include new EWIS maintenance instructions into their maintenance or inspection programs.
Module 5, Summary
Module 5, Summary
P EA
AS
Module 5, Summary
10
Module 5, Summary
Technical focals and authors of EAPAS airworthiness & ops rules & guidance materials
Federal Aviation Administration
11
Contact Information for the Technical Focals of the EAPAS Standardization Team Name
Massoud Sadeghi Stephen Slotte Fred Sobeck MRB Chairperson
Routing Number
ANM-110 ANM-110 AFS-308 AEG: varies depending on model
Email
[email protected] [email protected] [email protected]
Phone
425-227-2117 425-227-2315 202-267-7355
Fax
425-227-1320 425-227-1320 202-267-5115
Module 5, Summary
12
13
Module 5, Summary
14
15
Module 5, Summary
16
17
Module 5, Summary
18
19
Module 5, Summary
20
There will be follow-on training for part 25 rule changes. Flight Standards Division will provide additional training for implementation of the operational rules.
Module 5, Summary
Fred, Massoud, and Stephen Thank the Following for Their Great Support & Help in Developing This Training!
Doug Anderson Ali Bahrami Angelique Berry Kay Christiansen Steve Edgar Nedra Loveridge
EAPAS IVT, Course 24910, Mod 5
Diane Pagel Dionne Palermo Dan Poblete Brett Portwood Margie Sanders Mike Zielinski
Federal Aviation Administration
22
VERSION 1.1
Note: The information contained in this Participant Guide is presented by the instructors through captioned video and audio. A transcript of the captioning is also available with each with each video segment.
EAPAS APPENDIX
A: B: C: D E: F: G: H: I: J: K: L: M: N: O:
Definitions and Acronyms ........................................................1 Additional ATSRAC Background Information...........................8 List of Final EWIS 14 CFR Regulations .................................15 EWIS Advisory Circulars........................................................19 14 CFR Part 26.11 Rule and Part 25 Appendix H..................20 Worksheets from AC 120-XX to Record Responses to the Flowchart ..................................................24 No Plan Submitted Template .................................................30 Unacceptable Plan Template.................................................31 Unacceptable Implementation Template (Approved Plan).....................................................................32 Unacceptable Implementation Template (No Approved Plan) ...............................................................33 Unacceptable Draft Template ................................................34 No Drafts Submitted Template...............................................35 Sample Letters of Investigation..............................................36 Communication Schedule: Minimum Requirements For Documented Communication With DAH .........................38 EWIS Part 26 Sample Compliance Plan ................................41
Appendix-i
EAPAS
Appendix-1
EAPAS
Compliance Teams. Composed of representatives from the FAA Oversight Office; that is, the ACO or TAD office with responsibility for the relevant TC or STC and representatives from affected Aircraft Evaluation Group offices. Main focus is with DAHs: familiarizing them with the new rules and guidance materials, monitoring their progress, reviewing and approving data and documents, and providing status updates and coordination of issues with the Standardization Team. Part of the FAA Oversight Office. Contamination. For the purposes of this AC, wiring contamination refers to either of the following: Presence of a foreign material likely to cause degradation of wiring. Presence of a foreign material that is combustible, or capable of sustaining a fire after removal of ignition source. Continued Airworthiness. Certified aircraft, engines, propellers, and appliances are safe to operate for the intended purpose; they are maintained safely throughout their service life; the product meets its type design and is in a condition for safe operation. Design Approval Holder (DAH). The holder of any design approval, including TC, amended TC, STC, amended STC, parts manufacturer approval, TSO authorization, letter of TSO design approval, and field approvals. DAH can be an airplane manufacturer or an operator if they hold design approvals. Required to create, submit to FAA for approval, and implement a compliance plan. Also must submit draft and final data and documents for FAA approval. Makes data and documents available to affected operators. Detailed Inspection (DET). An intensive examination of a specific item, installation, or assembly to detect damage, failure, or irregularity. Available lighting is normally supplemented with a direct source of good lighting at an intensity deemed appropriate. Inspection aids such as mirrors, magnifying lenses, or other means may be necessary. Surface cleaning and elaborate access procedures may be required. May include tactile assessment in which a component or assembly is checked for tightness/security. This is of particular significance when identifying applicable and effective tasks to ensure the continued integrity of installations such as bonding jumpers, terminal connectors, etc.
Appendix-2
EAPAS
Effective Task/Task Interval. An inspection or maintenance task, performed at defined intervals, that will ensure that the desired outcome of the task is achieved. To be effective the task must reduce the risk of wire failure, to ensure safe operation. For example, a cleaning task to remove contaminants that have accumulated on a wire bundle would be considered effective if it cleaned the bundle sufficiently to minimize the potential of contaminantinduced failure of the bundle, and allow an inspection for wire defects to be performed. The methods and intervals for performing an effective task are developed using a combination of standard industry practices, expert opinion, and engineering judgment from operators, manufacturers, and regulatory authorities. The document ATA MSG-3 Operator/Manufacturer Scheduled Maintenance Development, discusses the various criteria for the effectiveness of a task based on safety and operational and economic considerations. Refer to Table 2-3-7.1 Criteria for Task Selection of that document for further information. Electrical wiring interconnection system (EWIS). Any wire, wiring device, or combination of these, including termination devices, installed in any area of the airplane for the purpose of transmitting electrical energy between two or more intended termination points. See 25.1701 for full definition. Wiring and its associated components are now being treated as a system. Enhanced Airworthiness Program for Airplane Systems (EAPAS). Goal is to enhance safety by addressing electrical wiring system deterioration and wire contamination. Designed to enhance current airplane systems airworthiness programs at operator facilities, repair stations, and manufacturing plants, including improving design, installation, certification, maintenance, and training requirements for aircraft electrical wiring. See Module 2, Lesson 1 of EAPAS IVT for details on how EAPAS history. TWA 800 accident in 1996 was the impetus, and subsequent recommendations by the Aging Transport Systems Rulemaking Committee (ATSRAC). There are 73 new, revised, renumbered certification and operational requirements, and 12 new Advisory Circulars in the EAPAS/FTS rulemaking package. New approach is analytical, multilayered, and proactive.
Appendix-3
EAPAS
Enhanced zonal analysis procedure (EZAP). An analytical procedures that identifies the physical and environmental conditions contained in each zone of an airplane, analyzes the effects of the conditions on electrical wiring and components, and assesses the possibilities for smoke and fire. See AC 120-XX. Used to develop EWIS ICA. From the EZAP, maintenance tasks can be developed to prevent ignition sources and minimize the possibilities for combustion by minimizing accumulation of combustible materials. FAA Oversight Office. The aircraft certification office or office of the Transport Airplane Directorate with oversight responsibility for the relevant TC or STC, as determined by the Administrator. Flight Standards Service Offices. Offices located in FAA headquarters responsible for developing guidance and policy applicable to transport category airplanes for AEG personnel and AFS field personnel (airworthiness and operations Aviation Safety Inspectors) in the conduct of their responsibilities. Fuel Tank Safety (FTS). Rulemaking, including SFAR 88, resulted from TWA 800 accident and resulting NTSB recommendations. Addresses fuel tank wiring concerns and flammability issues. SFAR 88 includes maintenance actions and design changes.
Appendix-4
EAPAS
General Visual Inspection (GVI). A visual examination of an interior or exterior area, installation, or assembly to detect obvious damage, failure, or irregularity. This level of inspection is made from within touching distance unless otherwise specified. A mirror may be necessary to enhance visual access to all exposed surfaces in the inspection area. This level of inspection is made under normally available lighting conditions such as daylight, hangar lighting, flashlight, or droplight and may require removal or opening of access panels or doors. Stands, ladders, or platforms may be required to gain proximity to the area being checked. When performing a GVI, there is usually no need to remove equipment or displace wire unless the access instructions specifically call for it. The area to be inspected should be clean enough to minimize the possibility that collected dirt or grease might hide unsatisfactory conditions that would otherwise be obvious. For any cleaning considered necessary, you should use the airplane manufacturers procedures or other equivalent methods, techniques, and practices acceptable to the FAA. The cleaning process itself should not compromise the integrity of EWIS. In general, the person performing a GVI is expected to identify degradation from wear, vibration, moisture, contamination, excessive heat, aging, etc.
Instructions for Continued Airworthiness (ICA). The information developed in accordance with applicable airworthiness requirements that includes the applicable methods, inspections, processes, procedures, and airworthiness limitations to keep the product airworthy throughout its operational life. Ref. 14 CFR 26.11(e). Maintenance Instructions. Information that includes recommended periods for cleaning, inspection, adjustment, testing, lubrication, degree of inspection, applicable wear tolerances, and recommended work necessary for each part of the airplane and its engine auxiliary power units, propellers, accessories, instruments, and equipment to provide for continued airworthiness of the airplane. Recommended overhaul periods and necessary cross-references to the Airworthiness Limitations section of the maintenance manual are also included. (See Appendix A of AC 26-XX for additional information.) MRB. Maintenance Review Board.
Appendix-5
EAPAS
Maintenance Review Board Report. This report is intended for use by air carriers and contains the initial minimum scheduled maintenance and inspection requirements for a particular transport category aircraft and onwing engine program. Air carriers use the MRB report, and its associated requirements, to develop maintenance programs. See AC 121-22A, Maintenance Review Board Procedures, for additional information. Operator. Person who uses, or is authorized to use, aircraft for air navigation, including piloting the aircraft. PI. Principle Inspector (this may include any or all of the affected Airworthiness or Operations). Products. Products are certified aircraft, aircraft engines, or propellers. Stand-Alone GVI. A general visual inspection, which is not performed as part of a zonal inspection. Even in cases where the interval coincides with the zonal inspection, the stand-alone GVI remains an independent step on the work card. Standardization Team. Composed of representatives from the Transport Standards Staff, including the international and standardization branch offices and representatives from the AFS policy division. Interfaces with all Compliance Teams, other civil aviation authorities, and affected DAHs implementing new EWIS ICA rules. Serves as a resource for technical requirements of the rules and compliance methodology to help ensure rules and guidance materials are applied in a standardized way. Communicates with and assists Compliance Teams and other civil aviation authorities, and keeps management informed of issues and compliance status. TAD. Transport Airplane Directorate. TSO. Technical Standard Order.
Appendix-6
EAPAS
Zone Density. Refers to the density of installed equipment, including wiring and other EWIS components, within a zone. It is assessed in relation to the size of the zone and for the purposes of the EZAP analysis is identified as low, medium, or high. Zonal Inspection. A collective term comprising selected general visual inspections and visual checks that are applied to each zone of the airplane, defined by access and area, to check system and powerplant installations and structure for security and general condition. A zonal inspection is essentially a GVI of an area or zone to detect obvious unsatisfactory conditions and discrepancies. Unlike a stand-alone GVI, it is not directed to any specified component or assembly. Zone Size. Based on comparing all the zones in a given airplane model and assessing them in relation to each other. For purposes of the EZAP analysis, zone sizes are identified as small, medium, or large.
Appendix-7
EAPAS
Review and Update Standard Wiring Practices Manual Review Air Carrier & Repair Station Inspection & Repair Training Programs
EAPAS IVT, Course 24910, Mod 2, Les 1
In Phase I, ATSRAC formed five different Harmonization Working Groups (HWG).. Harmonization was the term selected because the work was conducted with the participation and support of the JAA/EASA and TCCA, and all agreed that recommendations would be fully embraced by the FAA, JAA/EASA, and TCCA. Each rectangle on the left of the slide represents an HWG. The rectangles on the right of the slide show the main deliverable that came out of the Working Groups efforts. The first HWG was tasked to inspect electrical wiring on sample airplanes representative of the aging fleet. This HWG completed its task and developed recommendations for enhancements in the design and operation of airplane wiring. The second group also identified enhancements for design and operation of airplane wiring, however instead of inspecting representative airplanes, they reviewed the fleet service history. The third HWG was tasked to identify issues in the maintenance of airplane electrical wiring. This effort resulted in the enhanced zonal analysis procedure (EZAP). The fourth Working Group worked on the Standard Wiring Practices Manual (SWPM). This resulted in standardizing the format and content of SWPM. The review of training for personnel working on and around the airplane electrical wiring by the fifth HWG lead to new criteria for electrical wiring interconnection systems training.
Appendix-8
EAPAS
Appendix-9
EAPAS
Appendix-10
EAPAS
The Phase I Harmonization Working Groups completed their tasks and the reports were approved by ATSRAC and submitted to the FAA in January 2001. FAA tasked ATSRAC to begin development, in Phase II, of the necessary rulemaking recommendations to completely and properly address the issues identified in Phase I.
Advisory Circular
17
In Phase II, ATSRAC formed another five Harmonization Working Groups to develop enhancements based on the recommendations developed in Phase I and to make recommendations to the FAA for rulemaking. The first HWG focused on developing enhancements to the wiring design regulations and developing associated advisory circulars. Another HWG focused on developing enhancements to the Standards Wiring Practice Manual that led to rulemaking and an advisory circular. Two more advisory circulars came out of the next two Working Groups. One group focused on enhanced training criteria in an advisory circular, and the other focused on developing enhanced maintenance procedures for airplane electrical wiring. Then, based on an NTSB recommendation, a final HWG was formed in Phase II to assess the applicability of all of the developed enhancements to the electrical wiring on small transport airplanes. Phase II Status: These tasks were completed and the reports were approved by ATSRAC in January 2003.
Appendix-11
EAPAS
Assist in Developing Strategies to Implement and Transfer New Technologies for EWIS
New Recommendations
Identify and Develop Criteria for Upgrading/ Developing Enhanced Wiring on Small Transport Airplanes
New Recommendations
18
And for the final phase, Phase III, after developing and recommending rulemaking enhancements to the FAA, the FAA tasked ATSRAC with the three major tasks shown on the slide. First to promote efficient rulemaking, provide technical & economic data, assist disposition NPRM comments, Second to assist in developing strategies to implement and transfer new technologies for EWIS; And third, to identify and develop criteria for upgrading and/or developing enhanced wiring on small transport airplanes. Phase III Status: These tasks were completed in January 2005.
Appendix-12
EAPAS
Technology Development
The following information is on the major EAPAS-related research and developments. Some of the research and development is on-going, while other efforts have been completed and are enhancing mitigation of the aging issues in aircraft wiring today.
Appendix-13
EAPAS
The circuit breaker on the left shows the normal overload indication of a white ring, which is the fault detected by the conventional fault detection part of the arc fault detection. On the right, the arc fault is visually indicated by the red ring.
Appendix-14
EAPAS
Part 21Certification Procedures For Products And Parts 21.4 Continued airworthiness and safety improvements for transport category airplanes. Designation of applicable regulations Type design. Instructions for continued airworthiness and manufacturer's maintenance manuals having airworthiness limitations sections. Designation of applicable regulations.
PART 25Airworthiness Standards: Transport Category Airplanes Subpart D Design and Construction 25.611 25.855 Accessibility provisions. Cargo or baggage compartments.
Subpart E Powerplant 25.869 Fire protection: systems. 25.899 Electrical bonding and protection against static electricity. 25.1203 Fire detector system. Subpart F Equipment 25.1301 25.1309 25.1310 25.1353 25.1357 25.1360 25.1362 25.1365 Function and installation. Equipment, systems, and installations. Power source capacity and distribution. Electrical equipment and installations. Circuit protective devices. Precautions against injury. Electrical supplies for emergency conditions. Electrical appliances, motors, and transformers.
Appendix-15
EAPAS
Subpart HElectrical Wiring Interconnection Systems (EWIS) 25.1701 25.1703 25.1705 25.1707 25.1709 25.1711 25.1713 25.1715 25.1717 25.1719 25.1721 25.1723 25.1725 25.1727 25.1729 25.1731 25.1733 Definition. Function and installation: EWIS. Systems and Functions: EWIS. System separation: EWIS. System safety: EWIS. Component identification: EWIS. Fire protection: EWIS. Electrical bonding and protection against static electricity: EWIS. Circuit protective devices: EWIS. Accessibility provisions: EWIS. Protection of EWIS. Flammable fluid fire protection: EWIS. Powerplants: EWIS. Flammable fluid shutoff means: EWIS. Instructions for Continued Airworthiness: EWIS. Powerplant and APU fire detector system: EWIS. Fire detector systems, general: EWIS.
Appendix H to Part 25Instructions for Continued Airworthiness H25.1 H25.4 H25.5 General. Airworthiness Limitations section. Electrical Wiring Interconnection System (EWIS) Instructions for Continued Airworthiness.
Part 26Continued Airworthiness And Safety Improvements For Transport Category Airplanes Subpart AGeneral 26.1 26.3 26.5 26.11 Purpose and scope Definitions Applicability Table Electrical wiring interconnection systems (EWIS) maintenance program
Appendix-16
EAPAS
Part 91General Operating And Flight Rules 91.1 91.1501 91.1503 91.1505 91.1507 91.1505 91.410 Applicability. Purpose and definition. [Reserved] [Reserved] Fuel tank system inspection program. Repairs assessment for pressurized fuselages. [Reserved] Subpart LContinued Airworthiness and Safety Improvements
Part 121Operating Requirements: Domestic, Flag, And Supplemental Operations 121.1 Applicability Subpart AAContinued Airworthiness And Safety Improvements 121.1101 Purpose and definition. 121.1111 Electrical wiring interconnection systems (EWIS) maintenance program. 121.1113 Fuel tank system maintenance program. 121.368 [Reserved] 121.1107 Repairs assessment for pressurized fuselages. 121.370 [Reserved] 121.370a [Reserved] Part 125Certification And Operations: Airplanes Having A Seating Capacity Of 20 Or More Passengers Or A Maximum Payload Capacity Of 6,000 Pounds Or More; And Rules Governing Persons On Board Such Aircraft 125.1 125.501 125.503 125.505 125.507 125.505 125.248 Applicability. Purpose and definition. [Reserved] [Reserved] Fuel tank system inspection program. Repairs assessment for pressurized fuselages. [Reserved] Subpart MContinued Airworthiness and Safety Improvements
Appendix-17
EAPAS
Part 129Operations: Foreign Air Carriers And Foreign Operators Of U.S.Registered Aircraft Engaged In Common Carriage Subpart AGeneral 129.1 129.101 129.103 129.105 129.107 129.109 129.111 Applicability and definitions. Subpart BContinued Airworthiness and Safety Improvements Purpose and definition. [Reserved] [Redesignated from 129.33] [Redesignated from 129.32] [Redesignated from 129.16] Electrical wiring interconnection systems (EWIS) maintenance program. 129.113 Fuel tank system maintenance program.
Appendix-18
EAPAS
Appendix-19
EAPAS
Appendix-20
EAPAS
(d) The following persons must comply with the requirements of paragraph (b) or (c) of this section, as applicable, before the dates specified. (1) Holders of type certificates (TC): [insert date 24 months after effective date] (2) Applicants for TCs, and amendments to TCs (including service bulletins describing design changes), if the date of application was before [effective date of final rule] and the certificate was issued on or after [effective date of final rule]: [insert date 24 months after effective date], or the date the certificate is issued, whichever occurs later. (3) Unless compliance with 25.1729 of this subchapter is required or elected, applicants for amendments to TCs, if the application was filed after [effective date of final rule]: [insert date 24 months after effective date], or the date of approval of the application, whichever occurs later. (4) Applicants for supplemental type certificates (STC), including changes to existing STCs, if the date of application was before [effective date of final rule] and the certificate was issued on or after [effective date of final rule]: [insert date 30 months after effective date], or the date of approval of the application, whichever occurs later. (5) Unless compliance with 25.1729 of this subchapter is required or elected, applicants for STCs, including changes to existing STCs, if the application was filed after [effective date of final rule], [insert date 30 months after effective date], or the date of approval of the application, whichever occurs later. (e) Each person identified in paragraphs (d)(1), (d)(2), and (d)(4) of this section must submit to the FAA Oversight Office for approval a compliance plan by [insert date 90 days after effective date of final rule]. The compliance plan must include the following information: (1) A proposed project schedule, identifying all major milestones, for meeting the compliance dates specified in paragraph (d) of this section. (2) A proposed means of compliance with this section, identifying all required submissions, including all compliance items as mandated in part 25, Appendix H paragraphs H25.5(a)(1) and (b) of this subchapter in effect on [effective date of this final rule], and all data to be developed to substantiate compliance. (3) A proposal for submitting a draft of all compliance items required by paragraph (e)(2) of this section for review by the FAA Oversight Office not less than 60 days before the compliance time specified in paragraph (d) of this section.
EAPAS: Part 26 DAH Public Version 1.1, Aug 2007 Appendix-21
EAPAS
(4) A proposal for how the approved Instructions for Continued Airworthiness will be made available to affected persons. (f) Each affected person must implement the compliance plan, or later approved revisions, as approved in compliance with paragraph (e) of this section. (g) This section does not apply to the following airplane models: (1) Convair CV-240, 340, 440, 580, if modified to include turbine engines. (2) Lockheed L-188 (3) Vickers Armstrong Viscount (4) Douglas DC-3, if modified to include turbine engines (5) Bombardier CL-44 (6) Mitsubishi YS-11 (7) British Aerospace BAC 1-11 (8) Concorde (9) deHavilland D.H. 106 Comet 4C (10) VFW-Vereinigte Flugtechnische Werk VFW-614 (11) Illyushin Aviation IL 96T (12) Bristol Aircraft Britannia 305 (13) Handley Page Herald Type 300 (14) Avions Marcel Dassault - Breguet Aviation Mercure 100C (15) Airbus Caravelle
Appendix-22
EAPAS
H25.5
(a) The applicant must prepare Instructions for Continued Airworthiness applicable to EWIS as defined by 25.1701 that are approved by the FAA and include the following: (1) Maintenance and inspection requirements for the EWIS developed with the use of an enhanced zonal analysis procedure that includes: (i) Identification of each zone of the airplane. (ii) Identification of each zone that contains EWIS. (iii) Identification of each zone containing EWIS that also contains combustible materials. (iv) Identification of each zone in which EWIS is in close proximity to both primary and back-up hydraulic, mechanical, or electrical flight controls and lines. (v) Identification of (A) tasks, and the intervals for performing those tasks, that will reduce the likelihood of ignition sources and accumulation of combustible material, and (B) procedures, and the intervals for performing those procedures, that will effectively clean the EWIS components of combustible material if there is not an effective task to reduce the likelihood of combustible material accumulation. (vi) Instructions for protections and caution information that will minimize contamination and accidental damage to EWIS, as applicable, during performance of maintenance, alteration, or repairs. (2) Acceptable EWIS maintenance practices in a standard format. (3) Wire separation requirements as determined under 25.1707. (4) Information explaining the EWIS identification method and requirements for identifying any changes to EWIS under 25.1711. (5) Electrical load data and instructions for updating that data. (b) The EWIS Instructions for Continued Airworthiness developed in accordance with the requirements of H25.5(a)(1) must be in the form of a document appropriate for the information to be provided, and they must be easily recognizable as EWIS Instructions for Continued Airworthiness. This document must either contain the required EWIS ICA or specifically reference other portions of the ICA that contain this information.
Appendix-23
EAPAS
Appendix-24
EAPAS
Appendix-25
EAPAS
Appendix-26
EAPAS
Appendix-27
EAPAS
Appendix-28
EAPAS
Appendix-29
EAPAS
Appendix-30
EAPAS
Appendix-31
EAPAS
Appendix-32
EAPAS
Appendix-33
EAPAS
Appendix-34
EAPAS
Appendix-35
EAPAS
Appendix-36
EAPAS
No compliance plan submitted [To be used if we conclude more than just template letter is needed] [Company], as the holder of [supplemental] type certificate number XXX, was required to submit a compliance plan to this office describing its proposed means of compliance with 14 CFR 26.XX, by m/d/yr. To date, we have not received this plan. This letter is to inform you that this matter is under investigation by the Federal Aviation Administration. We would appreciate receiving any evidence or statements you might care to make regarding this matter within 10 days of receipt of this letter. Any discussion or written statements furnished by you will be given consideration in our investigation. If we do not hear from you within the specified time, our report will be processed without the benefit of your statement. No draft data and documents submitted [To be used if we conclude more than just template letter is needed] [Company], as the holder of [supplemental] type certificate number XXX, was required to submit draft data and documents to this office, showing compliance with 14 CFR 26.XX, by m/d/yr. To date, we have not received these drafts. This letter is to inform you that this matter is under investigation by the Federal Aviation Administration. We would appreciate receiving any evidence or statements you might care to make regarding this matter within 10 days of receipt of this letter. Any discussion or written statements furnished by you will be given consideration in our investigation. If we do not hear from you within the specified time, our report will be processed without the benefit of your statement.
Appendix-37
EAPAS
Appendix N Communication Schedule: Minimum Requirements For Documented Communication With DAH
REVIEW/APPROVAL OF COMPLIANCE PLAN (ORDER 5-5) Item 1 Schedule Within 1 week from receipt of plan. Compliance Team Action Conduct preliminary review of DAH submitted compliance plan to determine any major deficiencies. Complete review of DAH submitted compliance plan. Comment If deficiencies found immediately contact DAH. Documented form of Communication Email, telecom or meeting
Within 4 weeks from receipt of plan. Within 6 weeks from receipt of plan.
See Item #3
Letter stating approval or disapproval (templates available). Informally document efforts to resolve deficiencies with the DAH. Letter stating approval or disapproval (templates available). Informally document efforts to resolve deficiencies with the DAH.
Complete review of revised plan and formally inform DAH of approval or disapproval.
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EAPAS
MONITOR IMPLEMENTATION OF COMPLIANCE PLAN (ORDER 5-6) Item 5 Schedule Within 1 week from identification of deficiencies. Compliance Team Action Inform the DAH of deficiencies and monitor DAH efforts to resolve deficiencies. Comment This action occurs irrespective of the DAH having an approved compliance plan or not. Documented form of Communication If significant deficiencies are identified that put timely compliance at risk, inform DAH by letter. If deficiencies are identified and an acceptable recovery plan is developed that does not put compliance at risk, informally document efforts with the DAH.
DRAFT DATA AND DOCUMENTS SUBMITTAL AND REVIEW (ORDER 5-7) Item 6 Schedule Within 1 week from receipt of draft data and documents. Within 5 weeks from receipt of draft data and documents. Compliance Team Action Conduct preliminary review of DAH submittal to determine any major deficiencies. Complete review of draft data and documents and coordinate with Standardization Team as required. Notify the DAH of acceptability or nonacceptability of draft data and documents. Comment If deficiencies found immediately contact DAH. Documented form of Communication Email, telecom or meeting
If draft data and documents are unacceptable, continue to work with DAH. If impasse inform management.
Appendix-39
EAPAS
FINAL DATA AND DOCUMENTS SUBMITTAL, REVIEW, AND APPROVAL (ORDER 5-8) Item 8 Schedule Within 1 week from receipt of final data/ documents. Within 4 weeks from receipt of final data /documents. Compliance Team Action Conduct preliminary review of final data/ documents to determine any major deficiencies. Complete review of final data and documents and coordinate with Standardization Team as required. If significant deficiencies are identified in the final data coordinate action with Standardization team and inform DAH If final data and documents are acceptable, inform the DAH of FAA approval and notify affected operators and PIs/Flight Standard District Offices (FSDO) of the availability of the approved data/ documents that can show compliance with the operational rules. If revised final data/ documents are acceptable inform the DAH of FAA approval and notify affected operators and PIs/Flight Standard District Offices (FSDO) of the availability of the approved data that can show compliance with the operational rules. This action needs to be expedited if possible to maximize time for operator compliance with operational rules. Comment If deficiencies found immediately contact DAH. This action needs to be expedited if possible to maximize time for operator compliance with operational rules. Documented form of Communication Email, telecom or meeting
10
11
12
This action needs to be expedited if possible to maximize time for operator compliance with operational rules.
Appendix-40
EAPAS
Appendix-41
EAPAS
An example for EAPAS DAH requirements training. This is provided for training purposes only and is not meant to be used as advisory or policy guidance. Although we are using a fictitious airplane manufacturer for illustrative purposes, this example compliance plan can also be applied to STC applicants who are required to submit a compliance plan. Revised 4/25/2007
Appendix-42
EAPAS
Table of Contents
Subjects I. II. III. IV. DAH: Excellent Airplane Manufacturer Description: Airplane Model E123 Relevant Part 26 Requirements Means of Compliance a. Deviations for FAA Relations and Policies b. Proposed Alternate Means of Compliance V. Model E123 Part 26 Compliance Team a. Team Focal VI. Delegation Plan VII. Required Documents VIII. Compliance Schedule IX. Communication Processes X. Operators Involvement/Inputs XI. Understanding/Agreements Page 44 44 45 47 47 47 49 49 50 51 52 52 53 53
List of Figures
Figure 1 - E123-P Airplane Configuration for Enhanced Zonal Analysis Figure 2 Compliance Schedule for E123 Airplane Model 45 47
List of Tables
Table 1 Part 26 Means of Compliance for E123 Airplane Models 52
Appendix-43
EAPAS
I.
The Excellent Airplane Company (EAC) is a specialized well-established airplane manufacturer which has been designing and manufacturing only one airplane model E123 to the best design and manufacturing standards since 1977. The EAC is using the stateof-the-art and highly advanced wiring fabrication processes with the advanced tooling, testing, and inspection techniques. Our airplane electrical wiring interconnection systems (EWIS)are designed and built in house with teams of very knowledgeable and capable engineers and technicians with vast and diverse skills of many years.
II.
The E123 is designed and built in two configurations; E123-P passenger version with a total capacity of 325 passenger in a single class seating and 285 in a three class configuration, and E123-C, a cargo version. We are currently working on design of our third version which will offer an option of cargo and passenger combination for our airplanes (E123-PC). Figure 1., below, depicts the passenger version of our E123-P airplane model. We used this version as the representative configuration for performing Enhanced Zonal Analysis (EZAP) because this version includes the most complex wiring configuration of this model due to the features included/offered for the passengers comfort such as galleys and in-flight entertainment systems. In other words, the model of airplane we used as the basis for the performing the EZAP incorporates all variations of EWIS used in production and all of our design modifications that have been mandated by airworthiness directive as of {effective date of the final EAPAS rule}. Variations in the EWIS ICA due to configurations differences between the passenger and cargo version of the E123, are clearly noted in the final EWIS ICA documentation required by Part 25, Appendix H, paragraph H25.5(b). The Excellent Airplane Model E123 is owned and operated by two operators: The Safe Airlines Incorporated (SAI) operates 500 of Model E123-P and On-time Jet Cargo (OJC) operates 400 of E123-C cargo version. The Excellent Aircraft Company is in process of installing a new in-flight entertainment (IFE) system on E-123-P under Supplemental Type Certificate (STC) No. STC777HACO. The application for installation of the new IFE was made to the FAA at the Honolulu Aircraft Certification Office on January 1, 2006 and it is expected to be completed one day after the effective date of the EAPAS/FTS rule. The EAC will develop ICA for the new IFE EWIS as part the ICA required for the E123-P model. (NOTE to students: Since the STC was applied for before the effective date of the final rule and will be issued after the effective date, EAC is required per 26.11(e) to submit a compliance plan.)
Appendix-44
EAPAS
Zones:
Zone 4
Zone 6
---------- Size Popul. Severity Zone 1: H H H Zone 2: M H L Zone 3: L L H Zone 4: H L H Zone 5: H L Zone 6: L L L
1: EE Bay (wiring, combustible material) 2: FWRD Cargo, dedicated to Eel. Equipment (wiring, no combustible material) 3: Front Wing Cargo (wiring, combustible material) 4: Left Wing Fuel Tank (wiring, flammable) 5: Left Wing Faring (no wiring) 6: Aft Cargo (wiring, no combustible material, Prim. & Bkup Mech. Control within 2 of wiring)
III.
Relevant Requirements
Part 26 Requirements 26.11 Electrical wiring interconnection systems (EWIS) maintenance program (a) Except as provided in paragraph (g) of this section, this section applies to transport category, turbine-powered airplanes with a type certificate issued after January 1, 1958, that, as a result of the original certification, or later increase in capacity, have (1) A maximum type-certificated passenger capacity of 30 or more or (2) A maximum payload capacity of 7,500 pounds or more. (b) Holders of, and applicants for, type certificates, as identified in paragraph (d) of this section must develop Instructions for Continued Airworthiness (ICA) for the representative airplanes EWIS in accordance with part 25, Appendix H paragraphs H25.5(a)(1) and (b) of this subchapter in effect on [effective date of this final rule] for each affected type design, and submit those ICA for review and approval by the FAA Oversight Office. For purposes of this section, the representative airplane is the configuration of each model series airplane that incorporates all variations of EWIS used in production on that series airplane, and all TC-holder-designed modifications mandated by airworthiness directive as of the effective date of this rule. Each person specified in paragraph (d) of this section must also review any fuel tank system ICA developed by that person to comply with SFAR 88 to ensure compatibility with the EWIS ICA, including minimizing redundant requirements.
Appendix-45
EAPAS
(c) Applicants for amendments to type certificates and supplemental type certificates, as identified in paragraph (d) of this section, must: (1) Evaluate whether the design change for which approval is sought necessitates a revision to the ICA required by paragraph (b) of this section to comply with the requirements of Appendix H, paragraphs H25.5(a)(1) and (b). If so, the applicant must develop and submit the necessary revisions for review and approval by the FAA Oversight Office. (2) Ensure that any revised EWIS ICA remain compatible with any fuel tank system ICA previously developed to comply with SFAR 88 and any redundant requirements between them are minimized. (d) The following persons must comply with the requirements of paragraph (b) or (c) of this section, as applicable, before the dates specified. (1) Holders of type certificates (TC): [insert date 24 months after effective date] (2) Applicants for TCs, and amendments to TCs (including service bulletins describing design changes), if the date of application was before [effective date of final rule] and the certificate was issued on or after [effective date of final rule]: [insert date 24 months after effective date], or the date the certificate is issued, whichever occurs later. (3) Unless compliance with 25.1729 of this subchapter is required or elected, applicants for amendments to TCs, if the application was filed after [effective date of final rule]: [insert date 24 months after effective date], or the date of approval of the application, whichever occurs later. (4) Applicants for supplemental type certificates (STC), including changes to existing STCs, if the date of application was before [effective date of final rule] and the certificate was issued on or after [effective date of final rule]: [insert date 30 months after effective date], or the date of approval of the application, whichever occurs later. (5) Unless compliance with 25.1729 of this subchapter is required or elected, applicants for STCs, including changes to existing STCs, if the application was filed after [effective date of final rule], [insert date 30 months after effective date], or the date of approval of the application, whichever occurs later. (e) Each person identified in paragraphs (d)(1), (d)(2), and (d)(4) of this section must submit to the FAA Oversight Office for approval a compliance plan by [insert date 90 days after effective date of final rule]. The compliance plan must include the following information: (1) A proposed project schedule, identifying all major milestones, for meeting the compliance dates specified in paragraph (d) of this section. (2) A proposed means of compliance with this section, identifying all required submissions, including all compliance items as mandated in part 25, Appendix H paragraphs H25.5(a)(1) and (b) of this subchapter in effect on [effective date of this final rule], and all data to be developed to substantiate compliance. 3) A proposal for submitting a draft of all compliance items required by paragraph (e)(2) of this section for review by the FAA Oversight Office not less than 60 days before the compliance time specified in paragraph (d) of this section. (4) A proposal for how the approved ICA will be made available to affected persons. (f) Each affected person must implement the compliance plan, or later approved revisions, as approved in compliance with paragraph (e) of this section.
Appendix-46
EAPAS
IV.
Means of Compliance
The proposed compliance means chosen by EAC to comply with the requirements of Part 26 are provided in Table 1. Table 1 Part 26 Means of Compliance for E123 Airplane Models
Part 26.11 Sections (a) (b) H25.5(a)(1) Requirements Applicability Means / Alternative Products: Data/Document Remarks The rule applies to Models E123P and E123C Using guidance of AC 120-XX and MSG-3 process conducted via MRB ICA MSG-3 version 2005.1 was used to conduct the original EZAP analysis. A follow-on analysis will be performed in order to fully address the guidance as provided by AC 120-XX. NOTE: Since ECA says that the EWIS ICA were developed using MSG-3 V2005.1, they should add a statement about how they intend to ensure compliance with H25.5(a)(1). For example, they may state that they have performed a gap analysis to state that they will account for any difference between MSG-3 V2005.1 and the requirements of H25.5(a)(1) NOTE: Since section 26.11(b) talks about the representative airplane configuration, EAC should add information that states what configuration EAC used when conducting MSG-3 V2005.1 and if that will be the same configuration used for the gap analysis.] [NOTE: A statement about how EAC intends to comply with the requirement to ensure compatibility between fuel tank system ICA developed to comply with SFAR 88 and EWIS ICA should be included in the compliance matrix.] [NOTE: A statement about the form of the EWIS ICA source document required by H25.5(b) should be included in the compliance matrix.] All required compliance documentation will be submitted to FAA for Approval.
H25.5(b)
Documentation
Appendix-47
EAPAS
(c)(1) & (2) Amendments to TC and STC N/A N/A This section is not applicable to EAC. At this time EAC does not own any STCs and has no plans for amending our Model E123 Type Certificate. If EAC applies for an ATC in the future, a compliance plan will be submitted at that time. EWIS ICA for Model E123 will be submitted by [24 months after effective date of final rule.] for review and approval by the [FAA Oversight Office] This section is not applicable to EAC. This section is not applicable to EAC. This section is not applicable to EAC. This section is not applicable to EAC. A compliance plan (this document) will be submitted to [FAA Oversight Office] by [90 days after effective date of final rule] The plan contains 1) A proposed project schedule (see paragraph XX of this document) 2) A proposed means of compliance with the requirements of section 26.11 (this compliance matrix) 3) A proposal for submitting a draft of all compliance items required by 26.11(e)(2) to the [FAA Oversight Office] by [24 months after the effective date of the final rule 60 days] (see paragraph XY of this document) 4) A proposal for how we intend to make available the EWIS ICAs to our affected operators. (See paragraph VII of this document). (f) Implementation of Compliance Plan Compliance plan implemented in accordance with 26.11(f) and AC 26-XX. Implementation of compliance plan includes submittal of draft and final data/documents and making the approved ICA available to operators. The EAC intends to follow the process and schedule outlined in this plan as agreed and approved by the [FAA Oversight Office].
(d)(1)
Effectively
N/A
N/A
N/A N/A N/A N/A Compliance Plan developed in accordance with 26.11(e) and AC 26-XX.
Appendix-48
EAPAS
Serty Fyed
Regulatory Liaison
Lead Guy
Engineering Commercial Airplanes ECA-101 Engineering Commercial Airplanes ECA-101 Engineering Commercial Airplanes ECA-101 Maintenance Commercial Airplanes ECA-201
Engineering Lead
Wing Mann
Iye C. Sparks
Technical focal for EWIS engineering support to maintenance department Maintenance Planning department focal for development of Models ECA 123P and 123C maintenance programs (including EWIS maintenance). Maintenance department focal for ECA/Customer Relations for
Keepem Happy
Appendix-49
EAPAS
VI. Delegation Plan EAC is working to expand the delegated authority/authorized areas of the following DERs in accordance with FAA Orders XXXX and YYYY. We plan to have these DERs participate in MSG-3 meetings and review the Maintenance Review Board Report (MRBR) and Source Document (required by Part 25, Appendix H, H25.5(b)) to recommend approval. Once the FAA has satisfactory experience with our DERs and the new delegated functions/authorized areas, we plan to request that the FAA grant full approval authority to these designees. We will submit a more detailed delegation plan in the near future. Our Regulatory Liaison, Mr. Serty Fyed, will contact [FAA Oversight Office] within 10 business days after submittal of this plan to request a preliminary meeting regarding our delegation plan.
Ann Analyst
Inna Staller
Aire Worthy
Appendix-50
EAPAS
VII.
Required Documents
The EAC will provide the following data/documents to the [FAA Oversight Office] for review and approval . The following table provides the name and reference number of the documents containing the regulatory required data.
Document Reference Overview Submittal Date to [FAA Oversight Office] 90 days after effective date of the final rule
26.11-CP-01
Contains details of how EAC intends to show compliance with the applicable Part 26 DAH requirements This is a reference document that details what EAC maintenance documents contain the actual EWIS ICA. It will also contain a summary of all EWIS ICA. All documents referenced by the EWIS ICA Source Document will be made available to [FAA Oversight Office] as requested. These various documents, as referenced in the EWIS ICA Source Document, EWIS-ICA01, contain the EWIS ICA and will be made available upon request. This document provides details of the how ECA intends to make the EWIS ICA available to our owners/operators. This document contains the details of our DER delegation proposal.
EWIS-ICA-01
Varies
EWIS-DIST-01
EWIS-DER-01
Appendix-51
EAPAS
VIII. Compliance Schedule In addition to the guidance provided in AC 26-XX [Note: the DAHs dont have to follow the Order], EAC will follow the timeline provided in Figure 2, below, to develop the data and documents identified in Paragraph VII of this document.
EAC Submit EAC/FAA Compliance Plan Meeting/coordination to the FAA as often as necessary EAPAS/FTS Effective Date
Et + 4m
Ed + 27m
Ed
Ed + 3m
FAA Formally notify EAC of any deficiencies
Ed + 24m
Ed + 39m
1. FAA approves ICA 2. EAC makes ICA available for operators
IX.
Communication Processes
As defined in AC 26-XX, EAC will have a very close communication with the FAA Compliance Team to ensure all the necessary data developed are of high quality and submitted to FAA in timely manner. Through frequent meetings and correspondence the EAC will work continuously with the [FAA Oversight Office]to ensure all issues are resolved in timely manner and no surprises nor any noncompliance issue will need to be dealt with close to the compliance due dates. Therefore, EAC proposes monthly status meetings with [FAA Oversight Office]. The point of contact for scheduling these meetings is Mr. Serty Fyed, who can be reached at 555-555-5555, or via e-mail at [email protected].
Appendix-52
EAPAS
X.
Operators Involvement/Inputs
As part of the MSG-3 process, EAC plans to involve E123P and E123C owners and operators during the development of the EWIS ICA. Although not required by regulation, EAC involves operators in the development of the EWIS ICA to ensure that they will be readily usable by our owners and operators once the EWIS ICA are approved by [FAA Oversight Office]. This will help fulfill, as required by part 26, the responsibility of the operators of Models E123-P and E123-C (SAI and OJC) to incorporate the FAA-approved EWIS IAC into their maintenance programs by the required date (39 months after the effective date of the EAPAS/FTS rule).
XI.
Understanding/Agreements
It is EACs intent that all data and documents identified in this plan will be developed with a high level of quality and will be acceptable to the FAA. In addition it is our intent to make all submittals in a timely manner in order to meet our regulatory requirements (refer to paragraph VIII of this document). We understand that a noncompliance issue does not stop the compliance clock. Any noncompliance issue must be acceptably resolved with the FAA as soon as possible to ensure on time compliance. We understand the FAA will perform prompt reviews of our submittals and alert us as soon as possible regarding any potential issues or concerns that could affect compliance (within the required time period; no later than 15 months after the effective date of the EAPAS/FTS rule). We also understand that as defined by the regulation, FAA may pursue an enforcement action for any unresolved issues.
Appendix-53