Safety Recommendation
The Australian Transport Safety Bureau recommends that the Civil
Aviation Safety Authority review the location of fire bottles on
aircraft to reduce the possibility of a premature discharge of fire
retardant where the temperature in the area that contains the fire
bottle rises above the setting of the fusible valve.
The authority's response to this Recommendation is the same as
that dated 12 September 2002, to Recommendation A of the draft
Report. A copy of that letter is enclosed for your
information.
When CASA completes its investigation and review that is referred
to in that letter, CASA will advise the Bureau of the outcomes.
ATSB Note: The response referred to was part of CASA's Directly
Involved Party response to the draft report BO/200102710. It
stated:
'Thank you for providing a copy of draft Aviation Investigation
Report 200102710 on the accident involving Embraer Banteirante
VH-OZG which occurred at Cootamundra Aerodrome, NSW on 25 June
2001.
The Report includes Recommendation A:
The Australian Transport Safety Bureau recommends that the Civil
Aviation Safety Authority review the location of fire bottles on
aircraft to reduce the possibility of a premature discharge of fire
retardant where the temperature in the area that contains the fire
bottle rises above the setting of the fusible valve.
'The Authority concurs that the installation of a fire bottle in
the same compartment that may experience a fire, can, in the event
of a fire in the compartment, render the fire extinguisher system
ineffective.
'Therefore CASA is undertaking an investigation into the fire
extinguisher system installed on this type of aircraft and its
location. CASA will also review the certification process and
whether this aircraft met the requirements of Civil Aviation Order,
CAO 101.4. The Authority will advise you of the outcome and our
full response to the Recommendation following this
investigation.
'Thank you for bringing this matter to the attention of the
Authority.'
I refer to CASA's letter of 18 November 2002 concerning ATSB
Recommendation R20020054 contained in Aviation Report 200102710 on
the accident involving Embraer Banteirante VH-OZG which occurred at
Cootamundra Aerodrome on 25 June 2001.
The Authority gave an undertaking to investigate the fire
extinguisher system installed on this type of aircraft and its
location. It was indicated, also, that a review of the
certification process and whether this aircraft met the
requirements of Civil Aviation Order CAO 101.4 would be
conducted.
CASA has reviewed the regulations regarding the location of fire
bottles, in particular the regulations regarding thermal aspects of
fire extinguisher system installation. The review considers that
existing requirements in place adequately address the correct
location of fire bottles where it is required to have such systems
fitted.
Fire extinguisher systems, where required, are determined by the
certification basis and the operational category of the aeroplane.
Where a fire extinguisher system is required to be installed, such
a fire extinguisher system will require that consideration be given
to the location of certain components. CASA requires the correct
installation of such installations be determined by FAR 25.1195,
FAR 25.1197, FAR 25.1199, and FAR 25.1201, or British
equivalent.
Aircraft certificated to FAR 25 standard will already incorporate
an appropriate system to the approved standard. For aeroplanes
certificated under FAR 23, prior to amendment 34, consideration is
based on CAO 101.4 that refers to FAR 25.1195, FAR 25.1197, FAR
25.1199, and FAR 25.1201, or British equivalent.
With reference to VH-OZG, the aeroplane was issued with a
certificate of airworthiness in the normal category. This aeroplane
did not require an appropriate fire extinguisher system fitted. The
fire extinguisher system fitted was not part of the certification
process and was not required by the aeroplanes operational
classification. The fire extinguisher system installed would not be
considered appropriate for this aeroplane operating in the
transport category. However certain models of the EMB 110 aeroplane
do have a fire extinguisher system fitted that would be compliant
with the requirements of CAO 101.4, and therefore be allowed to
operate in the transport category.
CASA is satisfied that the regulations currently in place, allow
for the correct determination of what fire extinguisher equipment
and installation of such equipment is, based on the certification
basis and the operational basis of the aeroplane. The current
standards provide the necessary information to determine the
correct installation of fire extinguishers. Correct installation
when required will prevent premature discharge of the fire
retardant.
A/g Executive Manager Aviation Safety Standards
