The Australian Transport Safety Bureau recommends that the
Australian Civil Aviation Safety Authority ensure that all Boeing
717-200 aircraft on the Australian Register are fitted with a
flight recorder system that complies with the requirements of all
applicable Australian Civil Aviation Orders.
CASA accepts the above Recommendations and will take the
following action:
1. CASA wishes to advise the ATSB that all Boeing 717-200 aircraft
presently on the Australian Civil Register are operated by the one
airline. CASA intends to forward a Civil Aviation Regulation (CAR)
38 Direction to the airline directing it to rectify the deficiency
in the flight data recorder (FDR) run/stop logic in its B717
aircraft.
2. Issue an Airworthiness Bulletin that;
(i) recommends all Certificate of Registration holders that operate
aircraft that require a FDR to be installed to:
i. Check the aircraft to ensure compliance with CAO 20.18;
ii. Advise CASA through the Service Difficulty Reporting process of
any aircraft that do not comply; iii. If the aircraft does not
comply, contact the aircraft manufacturer or a CAR 35 person to
have the aircraft modified to meet the requirements of CAO 20.18;
and
(ii) explains to those persons issuing a Certificate of
Airworthiness for an aircraft, the requirements for first of
airframe/(Flight Data Acquisition Unit (FDAU)/FD combination.
3. Update the CASA Certificate of Airworthiness and Special Flight
Permits Manual to ensure that appropriate action is taken in
relation to FDRs as part of the initial Certificate of
Airworthiness issue.
CASA undertakes to provide the ATSB with copies of the CAR 38
Direction, the Airworthiness Bulletin and details of the
Certificate of Airworthiness and Special Flight Permits Manual
amendments.
In December 2001, ATSB issued Recommendations 20010251 and
20010252 (see report 200100477) in relation to the Boeing 717 and
flight data recorders.
CASA has reviewed its earlier responses to the recommendations
and is considering a revised approach. Accordingly CASA has
initiated a small project to review COA20.18 and the current
requirements relating to flight data recorders. The review will be
primarily carried out by [NAME] of the Manufacturing, Certification
and New Technologies Office and [NAME] from the Air Transport
Operations Group.
Given the ATSB's involvement in this matter, CASA would like to
invite a representative of the Bureau to participate in a review of
CAO 20.18, para 6.3 in relation to Recommendations R20010251 and
R20010252.
ATSB correspondence to the CASA CAO 20.18 Review Panel, 3
November 2005.
The ATSB considers that CAO 20.18 Paragraph 6.3 is consistent
with the Flight Data Recorder, FDR, start/stop logic requirements
specified by The International Civil Aviation Organisation, ICAO,
and European Joint Airworthiness Authorities requirements, JAR-OPS.
The requirements of CAO 20.18 paragraph 6.3 is also consistent with
the FDR start/stop logic operation of Boeing manufactured
aircraft.
It would appear reasonable to accept that the design of new
aircraft will comply with both the European JAR-OPS requirements
and the United States Federal Aviation Regulations, FAR's.
The original response indicated that CASA would forward a
direction to the relevant airline requesting rectification. CASA
has since reviewed the original decision communicated to you in May
2005 and has decided that it would be preferable to recognise the
Federal Aviation Administration standard for the B717 flight data
recorder to ensure compliance with applicable Civil Aviation Orders
as outlined in Recommendation R20010251.
We would like to clarify the intent of CASA's response in
relation to ATSB recommendation R20010251.
Is it the intent of CASA to grant an instrument specifically to
allow the continued operation of the B717 flight data recorder
(FDR) system as currently installed?
Is it also the intent of CASA that all other aircraft types on,
and entering, the Australian register that have an FDR or cockpit
voice recorder (CVR) system fitted, will be required to have that
system installed and operated in accordance with the requirements
of CAO 20.18
ATSB Comment
The ATSB notes the decision made by CASA. The ATSB does not
agree with the decision as there are other methods of meeting the
requirements that have not been fully explored and considers that
CAO 20.18 paragraph 6.3 does not require amendment. At the time of
closing this recommendation the ATSB has not received a reply to
the letter of 24 January 2008 or advice from CASA regarding items 2
and 3 of the CASA response received 28 February 2002, therefore the
ATSB reclassifies the recommendation as Closed - Not Accepted.
