The ATSB received correspondence from CENIPA, Brazil that
incorporated further comment from the manufacturer relating to this
recommendation.
Although the relocation of the fire bottle may help in the
prevention of an un-commanded discharge due to bottle overheat,
this modification will not be effective if the system is to be
exposed to a fire continuously fed by fuel for a time higher than
the 5 minutes required by the existing certification
standards.
Embraer recommends an analysis to be carried out to evaluate the
benefits of adding a warning of "inadvertent fire extinguishers
depletion" since:
- Regardless of having or not fire extinguishers, the pilot
procedures are the same,
i.e shutting down the engine and closing the SOV, which will
discontinue the fire
source.
- There is already a requirement to check the extinguishing bottles
prior to each
flight.