Allied Pilots Association

February 20, 2008 U.S. Department of Transportation, Docket Operations, M-30, West Building Ground Floor, Room W12-40 1200 New Jersey Ave, SE., Washington, DC RE: NPRM-[Docket No. FAA-2008-0048; Directorate Identifier 2007-NM-276-AD] RIN 2120-AA64 Dear Sir/Madame, The Allied Pilots Association (APA) has monitored the composite-related incidents involving Airbus aircraft since the 2001 crash of AA 587. Especially in the cases of the AA 903 and Air Transat 961, incidents where the composite vertical fin attachment lugs of two Airbus aircraft were cracked yet undetected using the Airbus methods of visual and tap inspections, APA has expressed concern about the effectiveness of the Airbus inspection philosophy. On November 22, 2007, the Transportation Safety Board (TSB) of Canada issued its Final Report on the Air Transat 961 rudder disintegration incident that occurred on an Airbus 310 while en route from Cuba to Canada on March 6, 2005. According to the summary of the report: The TSB investigation found that the aircraft took off from Varadero, Cuba, most probably with pre-existing damage to the rudder. The separation of the rudder from the aircraft together with the findings of the investigation determined that the inspection programs for this model of composite rudder are not adequate for the timely detection of defects. The report stated that the damaged rudder of the subject aircraft, when exposed to the vacuum cycling that occurs in a normal ascent to altitude, caused the internal damage in the rudder to rapidly grow until (as the report says) the rudder ?exploded.? While the TSB mentioned several concerns, the most significant and broad safety concern identified is that the inspection method advocated by Airbus Industries for honeycomb sandwich composite structures (used on flight controls on the A300, A310, A330 and A340) ?are not adequate? in finding significant damage within the structures. The final TSB report re-emphasized a March 2006 urgent recommendation that repetitive Non-Destructive Inspections (NDI) be incorporated into the composite rudder inspection program: ...the European Aviation Safety Agency (EASA,) in coordination with other involved regulatory authorities and industry, urgently develop and implement an inspection program that will allow early and consistent detection of damage to the rudder assembly of aircraft equipped with part number A55471500 series rudders. (A06-06, issued March 2006). In October of 2007 we were made aware of the EASA Emergency Airworthiness Directive 2007-0266. For the first time in our knowledge, these directives order the use of ultrasonic or thermographic inspections and also direct that these methods be used in the repetitive inspection programs on applicable Airbus A-300 and A-310 rudders instead of the visual and tap test primary damage discovery program long-advocated by Airbus as sufficient for the life of the airframe. As you may know, APA and the Coalition of Airline Pilots (CAPA) have been on record since 2002, citing concerns echoed by composite and inspection industry experts that the visual and tap test inspection methods advocated by Airbus were inadequate to find hidden damage within composite materials, calling for repetitive ultrasonic or other effective inspection methods. These concerns were validated again by the November 2005 discovery of hidden disbonds on the interior of an A300 rudder at Fed Ex and again when the TSB of Canada issued their March 2006 recommendation warning that the Airbus methods were not effective in finding damage within rudders and putting out an urgent recommendation for the industry to implement Non Destructive Inspections. It is worthy to note that now the TSB of Canada is joined by the EASA and the FAA in issuing guidance that advocates or orders required and repetitive inspections of the affected rudders using ultrasound or infrared methods and declaring visual inspections used in the past as ?ineffective.? APA applauds the fact that the manufacturer and the regulatory authorities finally recognize that the visual and tap test methods of inspection on the affected rudders are ineffective. With the direction given by these ADs, it has been clearly determined that ultrasonic, infrared and other sophisticated penetrating inspection methods are effective and necessary and the ineffective visual and tap test inspection program long-advocated by Airbus is effectively invalid. With this development, APA questions the time frames for compliance issued in both the EASA 2007-0266 (Mandatory Continuing Airworthiness Information-MCAI) and the FAA 2008-0048, specifically the requirement to conduct ?a special detailed one time inspection? and ?a special detailed inspection along the rudder Z-profile? within 500 flight cycles or 6 months after the effective date of the AD. Given statements by the TSB of Canada and damage sustained by Air Transat 961 resulting in catastrophic destruction of the rudder and damage to the vertical fin due to unknown quantity and type of damage to the rudder that existed, it is unclear why any tolerance period is being considered by the FAA for repair. The affected rudders have been inspected using only visual means, meaning that the aircraft, as they sit on the ramp, have not been inspected using any effective means. The un-inspected A300s and A310s referenced in this AD are, according to this understanding, in unknown condition and are therefore presumably at risk of an in-flight incident much like what happened on Air Transat 961. Until the condition of the rudders is discovered using ultrasonic or thermographic means IAW the AD, APA is unclear of the rationale being used by the EASA and the FAA to allow these aircraft to fly in the interim. Accomplishment of the EASA and FAA directives in fact should be a requirement for any further flight. After the crash of American Airlines 587, an Airbus A-300 aircraft that was the first commercial jet to crash after losing its composite vertical fin, pilot organizations called for ultrasonic and infrared methods to be used to inspect rudders and vertical fins on all commercial jets; their concerns were echoed by composite and inspection experts from many quadrants, including former NTSB experts and a composite expert from MIT. These concerns were characterized at the time by the NTSB and Airbus as unwarranted and unnecessary; it took the near-crash of Air Transat 961, the discovery of internal damage inside the rudder of a Fed Ex A-300 later that same year and the frank report by the TSB of Canada for the EASA and the FAA to conclude that the pilots and others were right: sophisticated materials need sophisticated inspections. Given these reformed understandings about inspection methods, we must also question presumptions made by investigators and their conclusions in recent incidents and accidents. Past investigations that involved composite failures should be re-opened for further study as these directives indicate that the history of the aircraft rudder inspections used improper, ineffective methods and may have resulted in improper conclusions on what has turned out to be an inadequate rudder inspection philosophy employed by Airbus. The FAA should also insure that repetitive ultrasonic or thermographic inspection methods are required on the next-generation aircraft that are composed of an increasingly-larger percentage of composite materials. In conclusion, we are pleased that the common-sense procedures the APA and CAPA called-for in 2002 have finally been partially implemented. We urge the FAA to consider these comments seriously so that we may improve the inspection method effectiveness as rapidly as manufacturers are employing improved technologies on 21st century aircraft designs. Sincerely, First Officer Todd Wissing National Safety Committee ? Aircraft Design and Composites