British Airways Plc

Subject: NPRM Docket FAA-2010-0379 References: /A/ NPRM Docket FAA-2010-0379 Directorate Identifier 2009-NM-210-AD /B/ FAA Airworthiness Directive 2009-23-10 /C/ Boeing Service Bulletin 737-57A1304 Revision 1, dated August 11, 2009 Discussion: The Reference /A/ NPRM advises that the FAA propose to supersede the reference /B/ Airworthiness Directive , that requires repetitive inspections of certain Flap Carriage Spindles, as listed in reference/C/. British Airways Plc note that paragraph (k) of the proposed Airworthiness Directive will require replacement of any HVOF coated carriage spindle having a serial number listed in Table 2 or 3 of Appendix A of reference /C/ with a non-HVOF coated carriage spindle, or with a serviceable HVOF-coated carriage spindle with an ‘R’ suffix on the serial number. British Airways Plc note that the proposed paragraph (k) does not allow for the fitment of a non-suspect HVOF coated carriage spindle, i.e. an HVOF-coated carriage spindle that is not listed in Table 2 or 3 of reference /C/. It is the understanding of British Airways that HVOF-coated carriage spindles that are not listed in Table 2 or 3 of Reference /C/, are not subject to inspection or recall action, and will not be issued with an ‘R’ suffix to their serial numbers. It is further noted that Tables 2 and 3 of reference /C/ specify both part numbers and serial numbers of affected carriage spindles. Request: British Airways Plc respectfully request that the FAA review the proposed Airworthiness Directive, and amend Paragraph (k) to require the replacement of any HVOF coated carriage spindle having a serial number listed in Table 2 or 3 of Appendix A of reference /C/ with a serviceable carriage spindle not listed in Table 2 or 3 of Appendix A of reference /C/, or with a serviceable HVOF-coated carriage spindle with an ‘R’ suffix on the serial number. Prepared on behalf of British Airways Plc by Jeffery Bishop, Continued Airworthiness Technical Engineer