In George’s Point of View
I noticed today that Bloomberg’s Andre Zajac posted an article referencing William Voss, chief executive officer of the Alexandria, Virginia-based Flight Safety Foundation, who said “If anyone wants to advance safety through regulation, it can’t be done without further loss of life.”

The point he was making is in reference the peculiar mechanism of aviation safety law.

To go into effect, an aviation safety law must pass a cost-benefit analysis. This analysis is based on how much benefits outweigh cost (i.e. the cost of human lives). Where the problem occurs the recent fatigue rules exempt freight carriers. All-cargo operations are not required to abide by part rule p. 5-6, 15, 259. This is why IPA filed a Petition for Review in the U.S. Court of Appeals for the D.C. Circuit in order to challenge FAA?s exclusion of cargo operations from the final flight and duty time rule.

Although the “FAA generally acknowledges that “factors that lead to fatigue are universal” (Rule p. 259) and that night-time operations (during pilots circadian lows) and operations that cross multiple time zones warrant stricter measures to guard against fatigue” cargo carriers are exempt.”

Surely the FAA realizes that cargo pilots get just as tired as commercial jet pilots–perhaps more so because so many cargo flights are overnight flights.

Does it really make sense to exempt all-cargo carrier pilots from fatigue regulations for financial reasons? Shouldn’t a rule governing pilot safety cover all pilots? Is an Airbus, Fokker, Antonov, Boeing 737 or 747 less destructive if it falls from the sky if it only has a payload and crew but no passengers?

IPA Points.pdf

Flight Member Duty Requirements.pdf

FRMP Checklist.pdf

George’s Point of View

The 787: Dreamliner test flight suffered from extensive smoke, fire and structural damage originating in the P100′ electrical panel, a key component that distributes power from the left generator to power vital systems

The 777: United electrical panel set the nearby insulation blankets on fire. This was initially reported as smoke. Thus no reason for the FAA to go there. And the full narrative said only “electrical fire” but did not elucidate beyond “electrical fire” to explain the electrical panel set the nearby insulation blankets on fire.

The AAIB conclusions 4,5, and 6, were:

• “The RGCB and Right Bus Tie Breaker (RBTB) suffered from severe internal arcing and short circuits which generated temperatures in excess of 1,000°C, and resulted in uncontained failures. The RGCB was probably the first to fail.”
• “ Molten copper and silver droplets from the failed contactors dropped down through the open base of the P200 panel and ignited the insulation blankets below.”
• “The insulation blanket fire spread underneath a floor panel to the opposite P205 power panel, causing heat and fire damage to structure, cooling ducts and wiring.”

The three requirements for a fire: oxygen, ignition source and fuel.

From 2000 to 2008, over 22 ADs are directed at insulation blankets that burn. Before that, from 1988 to 2010, 8 FAA Tech Center reports and 2 FAA Safety Conference Papers are directed at electrical induced fires or the insulation blankets that give fuel to the fire.

When was the latest AD ?
2008-23-09. REMOVE PET (AN-26). Boeing Model 727-200s, 737-200s, 737-300s, and 737-400, 747s, 757s, 767s Series Airplanes.from the fuselage. Such insulation blankets could ignite and propagate a fire that is the result of electrical arcing or sparking.
DATES; Issued Oct 24, 2008 -effective Dec 15, 2008 – Comply by 2014. If you read the AD, you can note that the compliance date is actually set beyond the affected planes anticipated passenger service-life. Compliance is put off until the planes will likely be converted from passenger to cargo.

2002 FAA ASTRAC Conference Conclusions

• In-flight Fires In Hidden Areas are a risk to aviation safety.
• Most hidden fires are caused by electrical problems.
• Non-compliance with Safety Regulations have been uncovered.
• Fire Safety Problems and Improvements are in various stages of correction and study.
• It is impossible to predict the relative risk of serious fires occurring in Hidden Areas or Locations.

Without being too critical or belaboring the obvious, I do have to say that the 2002 conclusions are overly obvious and simplistic. These same points will probably be as true in 2002 and 2011 as in 3011. Point by point? Consider this:

• In-flight fires are a risk to safety, whether they’re hidden or not. Certainly if one doesn’t know where they are, they have more time to be destructive before they are found. And as for being predictable-there probably is a random statistical probability that can come pretty close; but translating theory back to real life situations perfectly only happens on tv.
• Electrical problems are certainly a broad umbrella-one might even say the current problems with rogue batteries to be a form of electrical problem.
• Non compliance regarding safety is hardly an issue when a plane is in the testing phase; in fact, that is when the manufacturer is are troubleshooting to get rid of potential safety issues. The 777 electrical panel issue may or may not have a common cause; and if it does have a common cause, then, isn’t that splendid for Boeing? The detective job (i.e. finding the cause) is half of the problem already solved. What luck! But in real life, are the causes that easy to find? And in practice, how many times are non-compliance with Safety Regulations due to poor operator maintenance versus to unsafe parts?
• Fire Safety Improvements are an ongoing process. It’s the nature of the beast.

So here is the problem as it should possibly be stated:

-We need compliance now because people are on these planes now, not at some random future date. Pushing back solutions puts more people are at risk. We need feasible compliance that doesn’t put good companies out of business but still maintains the highest possible safety standards NOT the lowest possible cost. Putting off compliance over a combustible insulation blanket until 2014? Really? How is this safe?

-The lowest common denominator should not be lowest possible cost-to-the- industry. It should be the highest possible safety for the passenger. These things are not always mutually exclusive.

-If the root problem is less than ideal materials used across many manufacturer and model applications, then quit pussyfooting around.
If the boy is going to cry wolf, let it be for a real wolf. If the wolf is real, then act. If inadequate materials, composites, etc are the problem, then don’t point the finger and do nothing. Questionable materials have no place in an industry that lives under guidelines advocating and promoting safety over all.

Like Yoda said, “Do or do not. There is no try.”

Raise the standards.

Because of management issues, labor vs management issues, and the question of how much protection should pilots/crew have when they make a mistake, a number of big carriers have dropped the Aviation Safety Action Program. THe official goal of the Aviation Safety Action Program (ASAP) is “to enhance aviation safety through the prevention of accidents and incidents. Its focus is to encourage voluntary reporting of safety issues and events that come to the attention of employees of certain certificate holders.”

But pilots are being punished for their honesty.

The program that is being dropped allows pilots and other airline workers to report mistakes they’ve made and safety issues.

This enables carriers to spot trends before they become safety issues.

So..why have Delta, American, U. S. Airways and Com Air dropped the program?

Should we even FLY these carriers if they are not following ASAP?