UPS Airlines

Reference: /A/ NPRM 2010-NM-181-AD R1, Docket No. FAA-2011-0724 dated June 6, 2012 /B/ NPRM 2010-NM-181-AD, Docket No. FAA-2011-0724 dated August 24, 2011 /C/ Boeing Alert Service Bulletin 757-54A0047, R5 dated June 9, 2011 /D/ AD 2008-05-10, Docket No. FAA-2008-0226 dated March 18, 2008 UPS has reviewed the reference /A/ NPRM and has the following comments: Reference /A/, paragraph (o) mandates the replacement of horizontal and vertical flange fasteners in the strut-to-diagonal brace fitting in accordance with the work instructions and timetable in Reference /C/. It is UPS’ position, based on the rationale provided in References /A/ and /C/, that sufficient information has not been released to justify mandatory terminating action. Of all the effected aircraft, Reference /A/ indicates only a single report of damage occurring less than 3,000 flight cycles after the previous inspection. If there is fatigue test data or additional operational data that suggests otherwise, it should be made available. UPS concurs with the reduced inspection interval as directed in References /A/ and /B/, as this provides additional opportunity above that required by Reference /D/ to find and correct any damage. The reduced interval inspections allow for a sufficient level of safety without the terminating action. While UPS concurs with the technical reasons for replacement of the bolts for damaged fittings, the replacement should not be mandatory based on time or flight cycles but driven by inspection results only. UPS requests that the terminating action be optional in lieu of continued reduced interval inspections and the terminating action only be required if and when the reduced interval inspections find cracks or other damage at the fitting. United Parcel Service Co. is committed to ensuring full compliance and maintaining the highest level of safety in our operation.