Qantas Airways Ltd

Document ID: FAA-2008-0616-0007
Document Type: Public Submission
Agency: Federal Aviation Administration
Received Date: July 10 2008, at 05:08 PM Eastern Daylight Time
Date Posted: July 11 2008, at 12:00 AM Eastern Standard Time
Comment Start Date: June 6 2008, at 12:00 AM Eastern Standard Time
Comment Due Date: July 21 2008, at 11:59 PM Eastern Standard Time
Tracking Number: 8066694e
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This is comment on Rule

Airworthiness Directives; Boeing Model 767 Airplanes

View Comment

The MRBR task 28-040 was added to the 767 MRBR in June 2007. It has a Failure Effect Category (FEC) of 8, meaning that it is a hidden safety derived task. The commenter believes this task has been adequately addressed in the MRBR and related MPD. The MRBR has FAA AEG participation. There are a number of FEC 5 and 8 safety related tasks in the 767 MRBR, most of which are not the subject of ADs. Most, if not all of these could result in adverse safety outcomes if not accomplished by operators. There is an understanding within the aviation industry, including the FAA and its PMIs, that FEC 5 and 8 tasks need to be complied with and cannot be deleted or escalated without regulator acceptance. Imposition of AD for this MRBR task will generate an additional administrative burden for operators with no benefit. As a result, the commentator does not believe that an AD is necessary. If the ACO is not convinced with this argument, then consideration should be given to following the CMR approach. D. Spiritosanto Chief Engineer Maintenance Systems, Qantas