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Monday, November 22, 2004

Significant Regulatory Activity

Hall of Flame: The MD-11 is center stage of what might be called the "Hall of Flame," with more airworthiness directives (ADs) than any other transport category aircraft to our knowledge addressing electrical wiring problems and electrically-stoked smoke and fire threats. To the more than 60 ADs issued in the years since the 1998 crash of a Swissair MD-11 from an electrical fire, the latest four are listed below. This batch is the last of a five-phase corrective action plan for the MD-11 electrical/wiring system - a direct result of the Swissair crash. The operators of those MD-11s affected by all four ADs face a minimum cost of $22,200 per airplane. Those unfortunates facing the high end of the inspect/repair estimates are looking at a cost of $269,900 per airplane.

 

Date posted on Federal Register Summary of Situation Action Date & Comments
Nov. 9 Final Rule AD 2004-22-17 Electrical system safety Action affects McDonnell Douglas MD-11 and MD-11F airplanes. Requires inspection and replacement if necessary of overhead decoder units (ODUs) in the overhead baggage stowage racks. The problem: moisture penetrating ODU could result in short circuit, damage to connector pins and consequent smoke and/or fire in the cabin. Effective date: Dec. 14 Not a trivial undertaking; the Federal Aviation Administration (FAA) estimates the cost- depending upon the inspection findings - at $21,000 to $264,000 per airplane. AD affects 114 airplanes in the worldwide fleet, 28 of which are in U.S. registry.
Nov. 9 Final Rule AD 2004-22-18 Electrical system safety Action affects McDonnell Douglas MD-11 and MD-11F airplanes. Inspect and replace autothrottle servo assemblies to prevent electrical shorting that could produce smoke in the cockpit and passenger cabin. (ASW note: recall our recent story of the threat posed by continuous smoke in the cockpit. See ASW Oct. 25. The failure cited in this AD is a pertinent example.) Effective date: Dec. 14 FAA estimated costs here are less staggering, ranging from $65 to $4,000 per aircraft. AD affects 195 airplanes in the worldwide fleet, 62 of which are in U.S. registry
Nov. 9 Final Rule AD 2004-22-19 Electrical system safety Action affects McDonnell Douglas MD-11 and MD-11F airplanes. Inspect for arcing damage in mid-cabin area, take corrective action as necessary to prevent smoke and/or fire in the cabin. AD is prompted by an incident in which arcing occurred between power feeder cable and support bracket. Effective date: Dec. 14 FAA estimated costs are $1,035 to $1,365 per airplane. AD affects 90 airplanes in the worldwide fleet, 23 of which are in U.S. registry
Nov. 9 Final Rule AD 2004-22-20 Electrical system safety Action affects McDonnell Douglas MD-11 and MD-11F airplanes. More of the same, different area of the cabin. Replace terminal boards and perform other corrective actions as necessary to prevent smoke and fire in the cabin. Same arcing incident cited above prompts this action. Effective date: Dec. 14 FAA estimated costs are $110 to $579 per airplane. AD affects 152 airplanes in the worldwide fleet, 52 of which are in U.S. registry
Aviation security: a landmark development on the air cargo scene
Nov. 10 Notice of Proposed Rulemaking (NPRM) Docket No. TSA-2004-19515 Air cargo security requirements The Transportation Security Admin-istration (TSA) proposes to formalize and tighten security throughout the air cargo supply chain. The 71-page NPRM, anticipated for some months, affects airports serving cargo operations, passenger aircraft transporting cargo, all-cargo aircraft, and freight forwarders. Foreign operators to the U.S. also are affected by the provisions outlined in this NPRM. The objective is twofold: (1) to prevent all-cargo aircraft from being seized by terrorists and used as weapons (the 9/11 scenario) and (2) to prevent placement of terrorist bombs on board aircraft (passenger and cargo) and being detonated in flight (the Pan Am 103 scenario). The NPRM imposes new background screening requirements for freight forwarder employees and for all persons with access to the sterile airport area where cargo is loaded/unloaded. The program outlined in the NPRM basically imposes stricter security requirements with an increase in take-off weight, on the notion that the larger the aircraft, the greater the threat its hijacking presents to ground targets, and the greater the loss should the aircraft be bombed in flight. There is no question that this NPRM is a landmark event on the air cargo scene - it is the most significant development for cargo security since the 9/11 attacks. Initial reactions from various sources are positive: the NPRM may well represent the best incremental set of security improvements that can be realized at this time. Comments due: Jan. 10, 2005. The TSA estimates the 10-year cost of its proposed air cargo security program at more than $800 million. While the NPRM does not contain a cost-benefit analysis, per se, it says cargo aircraft, like their passenger counterparts, are subject to hijackings, bombings, and attacks on ground targets (e.g., 9/11). In addition to the $16 billion cost of the 9/11 attacks on the World Trade Center, hijackings and bombings (Pan Am Flight 73 in 1986, KAL Flight 858 in 1987, and Pan Am 103 in 1988) involved losses of an additional $1.4 billion. Certain aspects of the NPRM bear mention: Critics will say the proposed procedures rely too heavily on the "known shipper" program, which they assert is a leaky bulwark, exploitable by wily terrorists. The proposed program does not mandate technical screening (e.g., explosives detection) of all cargo, express parcels, mail, etc. carried on passenger aircraft. The NPRM said it would be impractical to inspect every piece of cargo shipped on passenger aircraft. While Sect. IV of the NPRM calls for inspection a portion of air cargo, it does not appear to impose a minimum level of required technical screening. More importantly, the apparent absence of such a mandate may be a lost opportunity. Should TSA impose technical screening requirements now, so goes the rest of the world. Once TSA does so, everyone has to incur the same economic costs and the competitive disadvantages are negligible. Exactly this situation occurred over the past two years when the U.S. Customs Service imposed the Container Security Initiative (CSI) on the 20 seaports through which some 90% of the containers pass enroute to the U.S. The CSI mandate in turn generated the desire by hundreds of other ports worldwide to become CSI ports so their goods being shipped to the U.S. would not be at a competitive disadvantage - a good example of positive unintended consequences.
Source: U.S. Federal Register
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