Qantas Airways Ltd

The MRBR task 28-022-04 was added to the 747-400 MRBR in May 2006. 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 over 200 FEC 5 and 8 safety related tasks in the 747-400 MRB, 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 and 747-400 ISC Chairman