Regarding second supplemental NPRM,
It seems that it changes not only the compliance time for the replacement but
also applicability of this NPRM.
It is mentioned that applicability is all Boeing model 737-600,-700,-700C,-800,-900
in the NPRM. On the other hand, it is mentioned that a review of airplane
maintenance records is acceptable in the NPRM.
As for IPC, Our airplanes already have post modification type seal (P/N 315A2245-
7,-8) from production and only these P/Ns can be installed.
Does it consider as maintenance records ?
This kind of part is not controlled by part control system.
If IPC does not consider as maintenance record which you mention in the NPRM,
we can only confirm stamped P/N actually by witness.
However, the stamped part number of this kind of part is often unreadable.
We have to replace it, only the way for compliance of NPRM.
It is not reasonable action.
Previous NPRM 's applicability was the same as SB which NPRM called out.
Could you please clarify this point and applicability ?
Best Regards,
Kazuto Shiramizu
This is comment on Rule
Airworthiness Directives; Boeing Model 737-600, -700, -700C, -800, -900 and -900ER Series Airplanes
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