Comment on Fire Fighting Enterprises Limited AD 2010-01-03 and document ID FAA-2009-1225-0002.
The Airworthiness Directive as written is all encompassing to include every virtually every portable fire extinguisher Fire Fighting Enterprises has ever manufactured, or will ever manufacture, that have not been refilled by a reputable source. I understand from the Supplementary Information Discussion that the investigations is on going, but there needs to be some practical boundaries in Actions section of the Airworthiness Directive. The part numbers and serial numbers listed in EASA AD2009-0251E would be useful and possibly the beginning and ending dates of manufacture of the portable fire extinguishers serviced with the contaminated Halon 1211 (BCF). Certainly with some margain added for safety; the dates when LyonTech Engineering Ltd provided the contaminated Halon 1211 (BCF) can be established.
Scott Lania
This is comment on Rule
Airworthiness Directives:Fire Fighting Enterprises Limited Portable Halon 1211 Fire Extinguishers as Installed on Various Transport Airplanes, Small Airplanes, and Rotorcraft
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