D. Lane

Document ID: FAA-2009-1225-0008
Document Type: Public Submission
Agency: Federal Aviation Administration
Received Date: January 14 2010, at 12:00 AM Eastern Standard Time
Date Posted: January 14 2010, at 12:00 AM Eastern Standard Time
Comment Start Date: January 5 2010, at 12:00 AM Eastern Standard Time
Comment Due Date: February 19 2010, at 11:59 PM Eastern Standard Time
Tracking Number: 80a7c65d
View Document:

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

View Comment

The US AD needs to clarify models and serial numbers that are to be affected. As presently worded, all models and serial numbers are affected and I think this is too broad of a net to cast when there is sufficient data accepted by other CAA's to be more specific. The manufacturer has published an Alert Service Bulletin ASB 26-115 that lists the affected models and serial numbers. The EASA AD's 2009-0251-E & 2009-0262 are using this data to show affected models and serial numbers. The US AD without this data or a sufficient means of affected manufacture dates will still apply to all extuinguishers manufactured by FFE from now until the end of time. This AD was not well planned and needs to incorporate the ASB from FFE to clarify and make the effort of compliance easier. As stated now, I cannot purchase a new extuinguisher that is not affected by this AD leaving no method of compliance other than a purchase from the manufacturer that provides a statement that it is not affected.