AirTran Airways

NPRM 2007-NM-207-AD released in the Federal Register on 12/3/07 requests comments to the proposed rule to inspect the B737NG #2, #4 and #5 flight deck windows for vinyl interlayer cracking or damage to the structural inner glass panes. As stated in the proposed rule, this type of damage could lead to loss of cabin pressurization which could cause crew communication difficulties or incapacitation. AirTran Airways agrees with the proposed rule; however, the following comments are offered as recommendations to ease compliance with the rule. NPRM 2007- NM-207-AD, paragraph (f), requires using Tables 1, 2, and 3, of Boeing Service Bulletin (SB) 737-56A1022, dated July 18, 2007, to set compliance times for the inspections. The SB Tables require tracking the initial and/or repetitive inspection per the window flight hours. Tracking compliance to components is more difficult than to an aircraft due to the extra work and documentation generated for removal and installation of the component. This can lead to an increased opportunity for error due to human factors. AirTran Airways request the final rule include an option to track inspection requirements per the aircraft cycles with a mandatory inspection of any used window prior to installation on the aircraft. AirTran Airways feels this will accomplish the same actions within the same time frame as given in the proposed rule without the burden of tracking as a component. AirTran Airways also requests the NPRM paragraph (h)(4) be updated to include Boeing SB 737-56-1017, which installs the metallic window blanks, in addition to the STC as AMOC to the #4 and #5 window inspections. The SB is the document used by maintenance to install the modification, and by referencing the SB, it relieves the operator from having to confirm the SB meets the requirements of the STC for compliance.