All Nippon Airways

ANA reviewed the subject NPRM, and would like to submit the following comments: 1. From the following reasons, ANA would like FAA to reconsider this rule making: A. This failure is caused by using unapproved parts. ANA does not like FAA to release an AD for all the operators even though they use proper OEM approved parts. B. If the AD is released, a lot of operators have to spend huge man power and costs for the inspection and pin replacement. C. ANA believes it is not necessary to check the hardness of the pins if they can substantiate no utilization of non OEM pins from their maintenance record, etc. 2. The following items must be resolved if FAA release the AD: A. To get rid of unapproved parts, ANA believes that dimensional characteristics of pins also have to be checked, not only hardness and corrosion (material) of the pins. Because it is possible that unapproved parts has similar exterior shape as OEM approved parts, but has larger inner diameter (smaller cross sectional area) than OEM approved parts. B. OEM has to develop how to check the hardness of the pins. ANA believes that it is infeasible to check the value of Rockwell hardness of the pins, because the pin is cylindrical and the flat surface is too narrow to locate the probe of Rockwell hardness test. Furthermore, ANA does not believe that Boeing and OEM allow to use the pins that have a dimple of probe. C. To start the inspection per AD, sufficient amount of OEM pins must be prepared. D. To minimize the impact of inspection program for maintenance schedule, ANA would like FAA to relax the time of compliance. “6,000FH or 22 months whichever comes first” is the best way for ANA because this will concur to be equivalent to our “C” check interval. E. To perform the inspection program smoothly, ANA would like FAA to make Boeing or OEM to release a service bulletin before release of the AD.