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Federal Aviation Administration

Participant Guide
Enhanced Airworthiness Program for Airplane Systems/Fuel Tank Safety Training for Part 26 DAH Requirements

Public Version August 2007

HQ-006907.INDD

PARTICIPANT GUIDE
Version 1.1 Note: The information contained in this Participant Guide is presented by the instructors through captioned video and audio. A transcript of the captioning is also available with each with each video segment.

MODULE 1: EAPAS OVERVIEW

GENERAL INTRODUCTION TO COURSE.............................................1 Instructor Introductions .......................................................................1 Receiving Credit for this Course .........................................................2 COURSE INTRODUCTION .....................................................................3 Introduction To Wiring Safety Concerns and IVT ...............................3 Commentary By Peggy Gilligan, AVS-2 .............................................4 What the IVT and Training Will Provide..............................................5 IVT OBJECTIVES AND OUTLINE .........................................................6 Objectives for the IVT .........................................................................6 Outline of the EAPAS/FTS IVT...........................................................7

EAPAS: Part 26 DAH

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Module 1: EAPAS Overview

Course Introduction

EAPAS OVERVIEW
EAPAS/FTS: Training for Part 26 DAH Requirements Module 1: EAPAS IVT Overview
Course Number: 24910 Course Manager: Massoud Sadeghi Version Date: May, 2007 Version Number: 1.0

Federal Aviation Administration

GENERAL INTRODUCTION TO COURSE

Instructor Introductions
Massoud Sadeghi, ANM-117. Stephen Slotte, ANM-111. Fred Sobeck, AFS-308.

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Module 1: EAPAS Overview

Course Introduction

COURSE INTRODUCTION
Introduction to Wiring Safety Concerns and IVT

Introduction
Late 1980s, wiring safety concerns raised due to accidents & incidents Investigations found common degrading factors in airplane electrical wiring systems Investigation into wiring issues done by industry, civil aviation authorities, other government agencies
EAPAS IVT, Course 24910, Mod 1 Federal Aviation Administration

Safety concerns about wiring systems in airplanes were reinforced by the TWA accident in 1996.

Results of Wiring Investigation


1. Increased awareness & improvements in design, certification, training, installation, & maintenance aspects of aircraft electrical wiring, plus development of new technologies 2. New FAA rulemaking package for certification & operational rules related to airplane electrical wiring systems
EAPAS IVT, Course 24910, Mod 1 Federal Aviation Administration

EAPAS: Part 26 DAH

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Module 1: EAPAS Overview

Course Introduction

Culture Shift: EAPAS Safety Initiative


Recognizing importance of electrical wiring in safe operation of airplanes leads to being more proactive; FAA is
Treating wiring as a system Mandating DAH support of the initiative Integrating FAA lines of business: joint AFS/AIR activity; and cooperation with & between DAHs and operators
EAPAS IVT, Course 24910, Mod 1 Federal Aviation Administration

The existing fleet will have to comply with the new 14 CFR part 26 requirements, while new applicants will be complying with new and revised part 25 requirements. This shift also relies heavily on communication between the affected parties.

Commentary By Peggy Gilligan


Peggy Gilligan, Deputy Associate Administrator, Aviation Safety (AVS-2).

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Module 1: EAPAS Overview

Course Introduction

What the IVT and Training Will Provide

EAPAS IVT
Overview of new rulemaking package Focus on specific aspect of package: design approval holder (DAH) requirements
EAPAS IVT, Course 24910, Mod 1 Federal Aviation Administration

Training Will Provide


Overview of EAPAS/FTS-related certification, DAH, and operational requirements Roles and responsibilities for implementing DAH rule Tools and information to know how
DAH shows compliance with part 26 DAH requirements for the EAPAS/FTS rule You guide and monitor the DAHs activities
EAPAS IVT, Course 24910, Mod 1 Federal Aviation Administration

Enhanced Airworthiness Program for Airplane Systems/Fuel Tanks Safety (EAPAS/FTS).

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Module 1: EAPAS Overview

Objectives and Outline

IVT OBJECTIVES AND OUTLINE


Objectives for the IVT

IVT Objectives
Upon completion of IVT, you will be able to:
Describe origin and goal of EAPAS program. (Mod. 2) Identify the improvements that result from EAPAS rulemaking. (Mod. 2) Describe new and revised electrical wiring interconnections systems (EWIS) certification requirements of part 25 subparts D, E, F, H, and Appendix H and part 26, and the operational requirements of parts 91, 121, 125 and 129. (Mod. 2)
EAPAS IVT, Course 24910, Mod 1 Federal Aviation Administration

IVT Objectives, cont.


Identify part 26 DAH requirements. (Mod. 3) Identify how to perform an enhanced zonal analysis procedure (EZAP) to find compliance to the EWIS ICA requirements. (Mod. 3) Identify the required elements of the EWIS ICA document. (Mod. 3) Describe the roles and responsibilities of AIR, AFS and industry, as defined in AC 26.XX, Order 8110.26-X, and Order 2150.3A. (Mods. 3 & 4)
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Module 1: EAPAS Overview

Objectives and Outline

IVT Objectives, cont.


Describe key elements of an EWIS compliance plan per part 26. (Mod. 4) Describe critical process elements used in:
Approval of compliance plan, Resolution of deficiencies, Monitoring DAHs plan implementation, and Approval of final data & documents. (Mods. 3 & 4)
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Outline of EAPAS/FTS IVT

IVT Outline
Mod 2: Overview of EAPAS and EWIS Mod 3: EAPAS DAH Requirements of Part 26 Mod 4: Roles and Responsibilities

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Federal Aviation Administration

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EAPAS: Part 26 DAH

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PARTICIPANT GUIDE
Version 1.1 Note: The information contained in this Participant Guide is presented by the instructors through captioned video and audio. A transcript of the captioning is also available with each with each video segment.

MODULE 2: EAPAS AND EWIS OVERVIEW

INTRODUCTION TO MODULE 2
INTRODUCTION TO MODULE 2 ....................................................1

LESSON 1: ENHANCED AIRWORTHINESS PROGRAM FOR AIRPLANE SYSTEMS (EAPAS) OVERVIEW


INTRODUCTION .............................................................................2 Lesson Objectives ......................................................................2 Lesson Outline ...........................................................................3 Aging Systems History ...............................................................4 Aging Transport Systems Rulemaking Advisory Committee (ATSRAC) ................................................................6 Factors Affecting Wiring ...........................................................10 ENHANCED AIRWORTHINESS PROGRAM FOR AIRPLANE SYSTEMS (EAPAS) RULEMAKING .......................................11 EAPAS Rulemaking Goal and Benefits ....................................11 LESSON SUMMARY.....................................................................14 Summary ..................................................................................14 EAPAS-Related Websites and Resource Support ...................16

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Mod 2: EAPAS & EWIS Overview

LESSON 2: ELECTRICAL WIRING INTERCONNECTION SYSTEMS (EWIS) CERTIFICATION AND OPERATIONAL RULES
INTRODUCTION TO EWIS ...........................................................17 Module 2, Lesson 2, Objectives ...............................................17 Lesson Outline .........................................................................18 EWIS DEFINED.............................................................................19 EWIS is a System ....................................................................19 Existing Regulatory Shortcomings ...........................................23 A New Approach to Wiring .......................................................29 EAPAS RULEMAKING PACKAGE ..............................................31 Overview ..................................................................................31 Parts 1 and 21..........................................................................38 Part 25 .....................................................................................39 Part 25 Appendix H ..................................................................50 Part 26 .....................................................................................53 Parts 91, 121, 125, and 129 .....................................................54 EAPAS Advisory Circulars .......................................................56 LESSON 2 SUMMARY .................................................................58

EAPAS: Part 26 DAH

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Mod 2: EAPAS & EWIS Overview

Introduction to Module 2

MODULE 2: EAPAS AND EWIS OVERVIEW


Introduction to Module 2

EAPAS/FTS: Training for Part 26 DAH Requirements


Module 2: Overview of EAPAS & EWIS
Course Number: 24910 Course Manager: Massoud Sadeghi Version Date: May, 2007 Version Number: Version 1.0

Federal Aviation Administration

Introduction to Module 2
Overview of enhanced airworthiness program for airplane systems (EAPAS) rulemaking package and electrical wiring interconnection systems (EWIS)
Background & goal of EAPAS rulemaking EWIS certification & operation regulations

EAPAS IVT, Course 24910, Mod 2

Federal Aviation Administration

Appendix A of this Participant Guide has definitions of key terms for the IVT.

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Mod 2, Lesson 1

Introduction

LESSON 1: ENHANCED AIRWORTHINESS PROGRAM FOR AIRPLANE SYSTEMS (EAPAS) OVERVIEW

Module 2: EAPAS & EWIS Overview

Lesson 1: Enhanced Airworthiness Program for Airplane Systems (EAPAS) Overview


EAPAS IVT, Course 24910, Mod 2 Federal Aviation Administration

INTRODUCTION
Lesson Objectives

Lesson 1 Objectives
Describe why and how EAPAS came into being State the goal of EAPAS rulemaking Identify 3 safety improvements resulting from EAPAS rulemaking

EAPAS IVT, Course 24910, Mod 2

Federal Aviation Administration

EAPAS: Part 26 DAH

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Mod 2, Lesson 1

Introduction

Lesson Outline

Lesson 1 Outline
History and products of aging systems program Goal and benefits of EAPAS rulemaking

EAPAS IVT, Course 24910, Mod 2

Federal Aviation Administration

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

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Mod 2, Lesson 1

Introduction

Aging Systems History

Aging Systems History


1 2 White House Commission on Safety and Security Recommendation: Expand Aging Program to include non-structural systems TWA 800 Aging Wiring Issues (1996)

3 Aging Non-Structural Systems Study Team Formed 4a R & D Projects Wiring Mechanical Systems 4b Wire Installation Policy 4 Aging Transport Non-Structural Systems Plan Developed (1998) Documented Recommendations - Plan Designs R&D Maintenance Reporting Training Fuel System Drawings ATSRAC (1999) Implementation of Rulemaking Recommendations

Final EAPAS/FTS Rule, and ACs

(Box 1): Aging issues in aircraft electrical wire were brought to the forefront by the TWA 800 accident in 1996. The plane crashed off Long Island due to a fuel tank explosion, killing all aboard. (Box 2): Recommendations were made to the FAA by the White House Commission on Safety and Security (WHCSS) to expand the aging program to include non-structural systems. Box 3 shows the task teams formed by the FAA to investigate the condition of electrical wiring on existing aircraft to address aging concerns. In 1998, the teams completed documenting their recommendations to enhance design, maintenance, and training, and for the development of new technologies for aircraft wiring and components. Box 4 lists the recommendations; EAPAS came into being at this stage. (Box 4a): The FAA joined with industry and other governmental agencies to perform research studies to develop advanced techniques and components for detecting and preventing electrical faults in wiring. Box 4b is another recommendation developing a wire installation policy to address problems associated with wiring installation.

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Mod 2, Lesson 1

Introduction

(Box 5): In order to ensure that the recommendations made by the NonStructural Systems Task Force were fully addressed, in 1999 the FAA Administrator formed a rulemaking advisory committee called ATSRAC [Aging Transport Systems Rulemaking Advisory Committee]. It was comprised of the FAA, JAA, DoD, TCCA, Industry, and aviation associations. Box 6 is a result of FAA independent studies, ATSRAC recommendations, and R & D projects. The FAA developed and will issue the EAPAS final rule with associated ACs in the summer of 2007. Fuel tank safety (FTS) is identified in Box 6 because the FAA is modifying existing FTS ops rules in the EAPAS rulemaking package (ref. Module 3 of this IVT).

EAPAS: Part 26 DAH

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Mod 2, Lesson 1

Introduction

Aging Transport Systems Rulemaking Advisory Committee (ATSRAC)

Aging Transport Systems Rulemaking Advisory Committee (ATSRAC)


ATSRAC tasked with providing public recommendations to the FAA Primary task propose revisions to 14 CFRs and guidance materials to ensure that non-structural systems in transport airplanes are designed, maintained, and modified in a manner that ensures their continued operational safety throughout the service life of the airplane
EAPAS IVT, Course 24910, Mod 2 Federal Aviation Administration

ATSRAC was a federal advisory committee.

Aging Transport Systems Rulemaking Advisory Committee (ATSRAC) Members


1. 2. 3. 4. Federal Aviation Administration Department of Defense Air Line Pilot Association Air Transport Association of America 5. Aerospace Industries Association of America 6. National Aeronautics and Space Administration 7. General Aviation Manufacturers Association 8. International Federation of Airworthiness 9. Transport Canada 10. PEMCO 11. National Air Disaster Alliance/Foundation 12. AECMA (European Association of Aerospace Industries) 13. JAA (EASA) 14. Northwest Airline 15. AirTran 16. International Air Transport Association 17. Boeing Commercial Airplane Group 18. Airbus Industrie 19. Society of Automotive Engineers 20. National Electric Manufactures Association 21. International Association of Machinists

ATSRAC formed working groups with members throughout industry based on the expertise needed for each assignment. ATSRACs meetings were open to the public.

EAPAS: Part 26 DAH

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Mod 2, Lesson 1

Introduction

ATSRAC Taskings
Phase I identified issues and solutions Phase II, ATSRAC working groups proposed regulatory enhancements Phase III, ATSRAC groups assisted in implementing enhancements in regulations and technologies
EAPAS IVT, Course 24910, Mod 2 Federal Aviation Administration

The three phases have been completed.

ATSRAC Major Activities


Non-intrusive inspection of the fleet
81 large transport airplanes 20+ years old 39 small transport airplanes

Intrusive inspections of wiring systems Review of fleet service histories


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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

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Mod 2, Lesson 1

Introduction

ATSRAC Major Activities, cont.


Review and development of enhancements for
Standard wiring practices manual (SWPM) Maintenance criteria Training programs
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ATSRAC Major Activities, cont.


Development of
Rulemaking for electrical wiring Advisory circulars (ACs)

Implementation of new technologies


Appendix B of Guide
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New arc fault circuit breakers

Federal Aviation Administration

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All ATSRAC activities were accomplished by different harmonization working groups (HWG) comprised of the FAA, other civil aviation authorities, and industry. The goal was to develop harmonized recommendations. Additional information on ATSRAC is in Appendix B of this Participant Guide.

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Mod 2, Lesson 1

Introduction

Routing/Chafing In-Service Examples

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Federal Aviation Administration

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Examples of what was found during the ATSRAC airplane inspection: improper routing and chafing of wires. Chafing problems due to lack of proper wiring installation and lack of adequate support have been main causes of wire failure and fire and smoke.

Improper Bend Radius

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Improper bend radius installation of electrical wire was also found. This does not reflect standard industrial practice and standards in AC 43.13-1b and Standard Wiring Practices Manual (SWPM).
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Mod 2, Lesson 1

Introduction

Factors Affecting Wiring

Factors Affecting Wiring


Design Maintenance Operation Training Repair Installation Environment Abuse Awareness

over time .
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Its not just strictly the age of the wire that were addressing. It is possible that wire damage occurs during the manufacturing stage.

Only older airplanes have electrical wiring degradation issues.


a. True b. False

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EAPAS: Part 26 DAH

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Mod 2, Lesson 1

EAPAS Rulemaking

ENHANCED AIRWORTHINESS PROGRAM FOR AIRPLANE SYSTEMS (EAPAS) RULEMAKING


EAPAS Rulemaking Goal and Benefits

Goal of EAPAS Rulemaking


Enhance safety by improving all aspects of aircraft electrical wiring
Goal is based on
ATSRAC data-driven recommendations Maximizing harmonization
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EAPAS Rulemaking: Areas of Safety Improvement


1. Design
Wire bundle

2. Maintenance 3. Training
Clamp

Wire bundle ties

Coil & Stow Method

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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

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Mod 2, Lesson 1

EAPAS Rulemaking

Benefits of EAPAS Rulemaking

Results in improved
Public confidence Economics
S PA EA

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What Does EAPAS stand for?


a. Enhanced airworthiness program for airplane systems b. Enhanced airline participation in aviation safety c. Enhanced authority participation associated with safety d. Enhanced aging problems in avionics systems
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EAPAS: Part 26 DAH

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Mod 2, Lesson 1

EAPAS Rulemaking

Which one of the following is NOT a benefit of EAPAS?


a. Airline economics b. Passenger comfort c. Public confidence d. Safety

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EAPAS: Part 26 DAH

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Mod 2, Lesson 1

Lesson 1 Summary

LESSON 1 SUMMARY
Summary

Summary
Aging systems history
Issues in aging aircraft wiring systems brought to forefront in late 1980s TWA 800 accident in 1996 Aging Systems Program created to resolve wiring systems issues

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Summary
ATSRAC recommendations
Phase I identified issues in aging wiring Phase II, ATSRAC proposed II regulatory solutions Phase III, ATSRAC assisted FAA with III implementing rulemaking and developing new technologies

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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

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Mod 2, Lesson 1

Lesson 1 Summary

Summary, cont.
Which item below is NOT a factor in the degradation of airplane wiring?
a. Environment b. Maintenance c. Size d. Time e. Training
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Summary, cont.
EAPAS goal

Enhance safety by improving all aspects of aircraft electrical wiring


Based on
Data-driven recommendations Maximizing harmonization

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EAPAS: Part 26 DAH

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Mod 2, Lesson 1

Lesson 1 Summary

EAPAS Rulemaking: Areas of Safety Improvement


1. Design 2. Maintenance 3. Training
EAPAS

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EAPAS-Related Websites and Resource Support

EAPAS-Related Web Sites


Aircraft Wiring Practices Job Aid (pdf file): http://employees.faa.gov/org/linebusiness/avs/ offices/air_training/job_aids/ Aircraft Wiring Practices Video & Self-Study Materials, Course No. 25827: use above link and then go to Keybridge Technologies ATSRAC: http://www.mitrecaasd.org/atsrac/index.html
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Aircraft Wiring Practice Job Aid can be downloaded as a pdf file of slides with speaker notes.

EAPAS: Part 26 DAH

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Mod 2, Lesson 2

Introduction to EWIS

LESSON 2: ELECTRICAL WIRING INTERCONNECTION SYSTEMS (EWIS) CERTIFICATION AND OPERATIONAL RULES
Module 2: EAPAS & EWIS Overview

Lesson 2: Electrical Wiring Interconnection Systems (EWIS) Certification and Operational Rules
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INTRODUCTION TO EWIS
Module 2, Lesson 2 Objectives

Mod 2, Lesson 2 Objectives


Describe major areas of enhancements to wire certification requirements that lead to safer operations Define a wire system Describe the scope, applicability, and location of wire system-related certification, continued airworthiness, and operational requirements Identify which part 25 Appendix H requirements are applicable to DAHs
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EAPAS: Part 26 DAH

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Mod 2, Lesson 2

Introduction to EWIS

The purpose of this lesson is to give you a high-level, big-picture view of all of the different requirements that make up the EAPAS rulemaking package.

Lesson Outline

Lesson 2 Outline
Definition and description of electrical wiring interconnection system Overview of EAPAS rulemaking package Part 25 revised and new EWIS requirements

Part 25 Appendix H25.5, that supports part 26 DAH requirements, that support
operator maintenance programs Advisory material
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EAPAS: Part 26 DAH

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Mod 2, Lesson 2

EWIS Defined

EWIS DEFINED
EWIS is a System

32

EWIS Electrical Wiring Interconnection System.

EWIS Definition 25.1701


Why have a definition?
Current regulations do not provide a definition of a wiring system Without one, new EWIS rules could be inconsistently applied to various wire-related components There is more to a wiring system than just wire
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EAPAS: Part 26 DAH

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Mod 2, Lesson 2

EWIS Defined

EWIS Definition 25.1701, cont.


An EWIS is [per 25.1701(a)]:
Any wire, wiring device, or combination of these, including termination devices, installed in any area of the airplane for the purpose of transmitting electrical energy between two or more intended termination points . . .

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25.1701 , continued from slide: . . . This includes: (1) Wires and cables. (2) Bus bars. (3) The termination point on electrical devices, including those on relays, interrupters, switches, contactors, terminal blocks and circuit breakers, and other circuit protection devices. (4) Connectors, including feed-through connectors. (5) Connector accessories. (6) Electrical grounding and bonding devices and their associated connections. (7) Electrical splices. (8) Materials used to provide additional protection for wires, including wire insulation, wire sleeving, and conduits that have electrical termination for the purpose of bonding. (9) Shields or braids. (10) Clamps and other devices used to route and support the wire bundle. (11) Cable tie devices. (12) Labels or other means of identification. (13) Pressure seals. (14) EWIS components inside shelves, panels, racks, junction boxes, distribution panels, and back-planes of equipment racks, including, but not limited to, circuit board back-planes, wire integration units, and external wiring of equipment.

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Mod 2, Lesson 2

EWIS Defined

(b) Except for the equipment indicated in paragraph (a)(14) of this section, EWIS components inside the following equipment, and the external connectors that are part of that equipment, are excluded from the definition in paragraph (a) of this section: (1) Electrical equipment or avionics that are qualified to environmental conditions and testing procedures when those conditions and procedures are (i) appropriate for the intended function and operating environment, and (ii) acceptable to the FAA. (2) Portable electrical devices that are not part of the type design of the airplane. This includes personal entertainment devices and laptop computers. (3) Fiber optics.

EWIS Definition 25.1701, cont.


An EWIS is not [per 25.1701(c)]:
Electrical equipment or avionics qualified to acceptable environmental conditions and testing procedures Portable electrical devices not part of the airplanes type design Fiber optics

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EAPAS: Part 26 DAH

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Mod 2, Lesson 2

EWIS Defined

Which Items are Not EWIS?

A B

36

EWIS Question
Which of the following is not considered an EWIS component?
a. Pressure seals b. Cable tie devices c. Termination point on electrical devices d. Connector thats an integral part of an LRU

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EAPAS: Part 26 DAH

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Mod 2, Lesson 2

EWIS Defined

Key Point to Remember . . .


NEW

Wire and associated components now treated as an airplane system


New perspective for FAA & industry; not done in the past
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Existing Regulatory Shortcomings

Why is the FAA issuing these new electrical wiring interconnection systems requirements?

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EAPAS: Part 26 DAH

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Mod 2, Lesson 2

EWIS Defined

Contaminants & Wire Touching Structure

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Example from an in-service airplane of wire contamination and wire touching structure, which can lead to accelerated wire degradation.

Wire Routing Issues

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EAPAS: Part 26 DAH

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Mod 2, Lesson 2

EWIS Defined

Wire Harness Riding on Metallic Tube

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This is a picture from an airplane prior to leaving the factory. Note the wire harness that is riding on the metallic tube.

8-yr. Old Plane in for 1st Heavy Cleaning

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Photo from behind sidewall in passenger cabin. Contaminants can carbonize when subjected to heat, leading to arcing events, burning, or smoldering.

EAPAS: Part 26 DAH

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Mod 2, Lesson 2

EWIS Defined

IFE Wires Routed Through Sidewall: sharp edges, no grommet . . .

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Picture of an in-flight entertainment (IFE) system installed and certified by a designated alteration station.

Existing regulations fall short of providing specific wiring-related requirements that we now recognize should be included in certification and operational regulations
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EAPAS: Part 26 DAH

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Mod 2, Lesson 2

EWIS Defined

Examples of Current Shortcomings


For example current rules do not adequately address requirements for wire systems in:
Separation Safety assessments Component selection Component identification Protection in cargo and baggage compartments Accessibility for inspection, maintenance, and repair
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EAPAS: Part 26 DAH

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Mod 2, Lesson 2

EWIS Defined

Example of Current Rule Shortcoming


New EWIS rules require addressing both EWIS separation & EWIS safety assessment; will prevent similar design from being certified in the future

ew N er w Po ires W

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Illustration of need for more stringent EWIS separation and safety assessments. An STC applicant obtained an STC to install a new in-flight entertainment system on board a large transport category airplane. IFE system comprised of over 750 LRUs distributed throughout passenger cabin. IFE had relatively high power requirements. Applicant used existing wire bundle to route new signal and power wires (new power wires are white, blue, and orange). Existing bundle had many wires insulated with aromatic polyamide insulation. Applicant had no idea what airplane systems were associated with the wires in the existing bundle. Part 25 rules when STC was certified didnt require physical separation between non-essential system high-powered wires and other wiring. When FAA asked applicant what type of 25.1309 safety assessment was performed on IFE, applicant said assessment was a qualitative analysis. 25.1309 was not adequate to require the type of safety assessment that should have been conducted on such a complex system. IFE was considered a non-essential passenger convenience system and its continued operation was not necessary to continued safe flight. However, a failure of this wire bundle could have caused a fire or the failure of a number of airplane systems that could have been critical to continued safe flight. New EWIS rules require addressing EWIS separation and EWIS safety assessment.
EAPAS: Part 26 DAH Public Version 1.1, Aug 2007 Participant Guide page 2-28

Mod 2, Lesson 2

EWIS Defined

A New Approach to Wiring

New Approach to Wiring

NEW

The traditional ways of addressing airplane wiring no longer provide the level of safety that we now expect Wire damage or degradation can be result of successive and interactive factors introduced over time
Inadequate design, improper maintenance, poor training, hostile environments, abuse, and time
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New Approach to Wiring, cont.


NEW

So the approach to ensure wiring safety must be


Analytical Multilayered Proactive

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Analytical logically assessing possibilities for a wire failure. Multilayered addressing multiple layers of stressors. Proactive addressing conditions affecting safe flight before they happen.

EAPAS: Part 26 DAH

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Mod 2, Lesson 2

EWIS Defined

Fire on a Regional Jet


Oxygen supply line

Insulation burned on pneumatic duct

Contactor

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Result of 6 to 7 fires over 6 months due to moisture that came in contact with an electrical contact below the pilots seat.

Improperly Tied Wires: riding on hydraulic lines, contaminated with caustic fluid

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Chafing of the wire bundle due to contact with a hydraulic tube.

EAPAS: Part 26 DAH

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Mod 2, Lesson 2

EAPAS Rulemaking Package

EAPAS RULEMAKING PACKAGE


Overview

52

Enhanced Airworthiness Program for Airplane Systems/Fuel Tank Safety (EAPAS/FTS).

53 53

EAPAS/FTS rulemaking package contains a total of 73 new, revised, renumbered certification and operational requirements.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 2-31

Mod 2, Lesson 2

EAPAS Rulemaking Package

54

55

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 2-32

Mod 2, Lesson 2

EAPAS Rulemaking Package

EAPAS/FTS Final Rule Whats In It?


New part 25 requirements for certification of electrical wiring interconnection systems (EWIS)
Revises existing EWIS related certification requirements and relocates some of them Creates new EWIS cert. requirements and places them in a new subpart H New EWIS ICA requirements
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EAPAS/FTS Final Rule, cont.


New part 26 requires design approval holders (DAH) to develop EWIS maintenance instructions for certain transport category airplanes
Applies to existing airplanes with capacity for
30 passengers or greater, or 7500 lbs payload or greater
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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 2-33

Mod 2, Lesson 2

EAPAS Rulemaking Package

EAPAS/FTS Final Rule, cont.


New part 26 DAH regulation also requires
Development of EWIS maintenance and inspection requirements using enhanced zonal analysis procedure (EZAP) that is approved by FAA Oversight Office DAH to ensure SFAR 88 fuel tank ICA and EWIS ICA compatible with each other and minimize redundancies between them

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Design Approval Holder (DAH)


The holder of any design approval, including
Type certificate, Amended type certificate, Supplemental type certificate, Amended supplemental type certificate . . .

see AC 26-XX
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DAH can be an airplane manufacturer or an operator if they hold design approvals.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 2-34

Mod 2, Lesson 2

EAPAS Rulemaking Package

Enhanced Zonal Analysis Procedure


An analytical procedure that
Identifies the physical & environmental conditions contained in each zone of an airplane, Analyzes the effects of these conditions on electrical wiring and components, and Assesses the possibilities for smoke and fire
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EZAP, cont.
From EZAP analysis, maintenance tasks in the form of ICA can be developed to
Prevent ignition sources and Minimize the possibilities for combustion by minimizing accumulation of combustible materials

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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 2-35

Mod 2, Lesson 2

EAPAS Rulemaking Package

Contaminants in Wheel Well

62

Example of where the EZAP would define a maintenance task to inspect and clean the EWIS components in this wheel well.

FAA Oversight Office


An FAA Oversight Office is the aircraft certification office or office of the Transport Airplane Directorate with oversight responsibility for the relevant type certificate or supplemental type certificate; for example:
Boeing Puget Sound, Seattle ACO Boeing Long Beach, LA ACO Airbus Transport Standards Staff Bombardier New York ACO Embraer Transport Standards Staff
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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 2-36

Mod 2, Lesson 2

EAPAS Rulemaking Package

EAPAS/FTS Final Rule, cont.


New requirements for airlines to incorporate EZAP-developed EWIS maintenance instructions into their approved maintenance programs
Applies to part 121 and part 129

Requires operators to incorporate SFAR 88 maintenance instructions into their approved maintenance or inspection programs
Applies to parts 91, 121, 125, & 129

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65

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 2-37

Mod 2, Lesson 2

EAPAS Rulemaking Package

Parts 1 and 21

66

14 CFR part 1 has a definition for EWIS, and part 21 gives the FAA the authority to carry out the regulations.

Part 1
1.2 Abbreviations and symbols

Part 21
21.4 Continued airworthiness and safety improvements for transport category airplanes

21.17 Designation of applicable regulations


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Added a new regulation and revised several requirements within part 21 to clarify the relationship between the existing part 21 and the new part 26, which contains the DAH requirements.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 2-38

Mod 2, Lesson 2

EAPAS Rulemaking Package

Part 21, cont.


21.31 21.50 Type design Instructions for Continued Airworthiness & manufacturer maintenance manuals having Airworthiness Limitations section

21.101 Designation of applicable regulations


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Sections 21.31 and 21.50 revised to clarify that Airworthiness Limitations section of ICA is part of the type design, so changes to the ICA generated under part 26 must be made available as part of the total ICA. Revised 21.101 says an applicant may not use the Changed Product Rule to avoid complying with the DAH requirements of part 26.

Part 25

69

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 2-39

Mod 2, Lesson 2

EAPAS Rulemaking Package

Part 25 EAPAS Revisions


Post-EAPAS Part 25 Pre-EAPAS Part 25

A B C D E F G
App H

EAPAS Changes To Part 25

D E F H
App H

A B C D E F G H
App App H H

25.611 25.855 25.869 25.899

25.1203

25.1301 25.1309 25.1310 25.1353 25.1357 25.1360 25.1362 25.1365

H25.4 H 25.5(a)(1) H 25.5(a)(2) H 25.5(a)(3) H 25.5(a)(4) H 25.5(a)(5) H 25.5(b)

25.1701 25.1703 25.1705 25.1707 25.1709 25.1711 25.1713 25.1715 25.1717 25.1719 25.1721 25.1723 25.1725 25.1727 25.1729 25.1731 25.1733 70

Revised many rules in part 25 by removing wire-specific references and moving them into the new rules within part 25 subpart H. The rules on the slide in black are the existing rules. The ones in orange and a different, larger font are new. (In the black and white version, the existing rules are in black, while the new rules are in dark gray.) There are changes to part 25 subparts D, E, and F; there is a new subpart H; and there are a number of changes to Appendix H. Rules in D and H also contain some new rules that were harmonized with the European Aviation Safety Agency (EASA). The FAA also added new Instructions for Continued Airworthiness requirements in Appendix H. There will be additional training on the revised and new ACs, the rules, and subpart H.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 2-40

Mod 2, Lesson 2

EAPAS Rulemaking Package

Part 25, Subpart H


New subpart contains requirements for electrical wiring interconnection systems
New requirements Revised requirements formerly located in other part 25 subparts

Requirements are applicable to all transport category airplanes


New & amended TCs, new & amended STCs, and service bulletins
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For amended TCs and amended STCs, the applicability of the new rules will be decided as it is done today Changed Product Rule.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 2-41

Mod 2, Lesson 2

EAPAS Rulemaking Package

25.1703 Function & Installation: EWIS


Based on 25.1301; why?
25.1301 a general catch-all regulation and not applied in a standardized way 25.1301 applies to wire, but does not provide sufficient wire-specific requirements to ensure proper function and installation of EWIS 25.1703 ensures EWIS component selection is carried out safely, consistently, & standardized

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25.1703 Function & Installation: EWIS, cont.


What does 25.1703 require?
EWIS function properly when installed EWIS components qualified for airborne use Expected service life addressed; any limitations must be part of ICA (H25.4) Accounts for known characteristics in relation to each specific application, e.g., insulation susceptibility to arc tracking

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Household wire or the type of wire used on consumer electronics is not acceptable unless it is shown to meet all part 25 certification requirements.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 2-42

Mod 2, Lesson 2

EAPAS Rulemaking Package

25.1707 System Separation: EWIS


Based on 25.1353; why?
Current separation requirement is not adequate
Current regulations lack specific wording about which wiring systems are covered and which systems those wires are meant to be separated from

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25.1707 System Separation: EWIS, cont.


Applies to each EWIS on airplane Requires adequate physical separation between EWIS and systems with the potential for creating hazardous conditions, e.g.:
Fuel systems Hydraulic systems Oxygen systems Water/waste systems
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The complete text of the rule begins on the next page.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 2-43

Mod 2, Lesson 2

EAPAS Rulemaking Package

25.1707 System separation: EWIS.


(a) Each EWIS must be designed and installed with adequate physical separation from other EWIS and airplane systems so that an EWIS component failure will not create a hazardous condition. Unless otherwise stated, for the purposes of this section, adequate physical separation must be achieved by separation distance or by a barrier that provides protection equivalent to that separation distance. (b) Each EWIS must be designed and installed so that any electrical interference likely to be present in the airplane will not result in hazardous effects upon the airplane or its systems. (c) Wires and cables carrying heavy current, and their associated EWIS components, must be designed and installed to ensure adequate physical separation and electrical isolation so that damage to circuits associated with essential functions will be minimized under fault conditions. (d) Each EWIS associated with independent airplane power sources or power sources connected in combination must be designed and installed to ensure adequate physical separation and electrical isolation so that a fault in any one airplane power source EWIS will not adversely affect any other independent power sources. In addition: (1) Airplane independent electrical power sources must not share a common ground terminating location. (2) Airplane system static grounds must not share a common ground terminating location with any of the airplanes independent electrical power sources. (e) Except to the extent necessary to provide electrical connection to the fuel systems components, the EWIS must be designed and installed with adequate physical separation from fuel lines and other fuel system components, so that: (1) An EWIS component failure will not create a hazardous condition. (2) Any fuel leakage onto EWIS components will not create a hazardous condition. (f) Except to the extent necessary to provide electrical connection to the hydraulic systems components, EWIS must be designed and installed with adequate physical separation from hydraulic lines and other hydraulic system components, so that: (1) An EWIS component failure will not create a hazardous condition. (2) Any hydraulic fluid leakage onto EWIS components will not create a hazardous condition. (g) Except to the extent necessary to provide electrical connection to the oxygen systems components, EWIS must be designed and installed with adequate physical separation from oxygen lines and other oxygen system components, so that an EWIS component failure will not create a hazardous condition. (h) Except to the extent necessary to provide electrical connection to the water/waste systems components, EWIS must be designed and installed with adequate physical separation from water/waste lines and other water/waste system components, so that:

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 2-44

Mod 2, Lesson 2

EAPAS Rulemaking Package

(1) An EWIS component failure will not create a hazardous condition. (i) EWIS must be designed and installed with adequate physical separation between the EWIS and flight or other mechanical control systems cables and associated system components, so that: (1) Chafing, jamming, or other interference are prevented. (2) An EWIS component failure will not create a hazardous condition. (3) Failure of any flight or other mechanical control systems cables or systems components will not damage the EWIS and create a hazardous condition. (j) EWIS must be designed and installed with adequate physical separation between the EWIS components and heated equipment, hot air ducts, and lines, so that: (1) An EWIS component failure will not create a hazardous condition. (2) Any hot air leakage or heat generated onto EWIS components will not create a hazardous condition. (k) For systems for which redundancy is required, by certification rules, by operating rules, or as a result of the assessment required by 25.1709, EWIS components associated with those systems must be designed and installed with adequate physical separation. (l) Each EWIS must be designed and installed so there is adequate physical separation between it and other aircraft components and aircraft structure, and so that the EWIS is protected from sharp edges and corners, to minimize potential for abrasion/chafing, vibration damage, and other types of mechanical damage

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 2-45

Mod 2, Lesson 2

EAPAS Rulemaking Package

25.1709 System Safety: EWIS


Based on 25.1309; why?
Current 25.1309 practice does not lead to type of analysis that fully ensures all EWIS failure conditions that could affect airplane-level safety are considered 25.1309 only requires analysis of systems and equipment required by subchapter, so wiring for non-required equipment may be ignored
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Examples of non-required equipment are IFE or other passengerconvenience items.

25.1709 System Safety: EWIS, cont.


What does 25.1709 require?
EWIS must be designed and installed so that each

Catastrophic failure condition extremely improbable; not result of single failure Hazardous failure condition extremely remote
Functional and physical failures of EWIS must be assessed to demonstrate compliance

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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 2-46

Mod 2, Lesson 2

EAPAS Rulemaking Package

Wire Chafing Issue: In-service Condition

78

Example of where the new system safety assessment requirement would prevent this type of failure from occurring because it requires an assessment of the physical environment within which the EWIS is installed, and a review for functional failures and physical failures.

Future Chafing Issue: In-service Condition

79

Example of a preventable problem.


EAPAS: Part 26 DAH Public Version 1.1, Aug 2007 Participant Guide page 2-47

Mod 2, Lesson 2

EAPAS Rulemaking Package

EWIS Safety Assessment Question


New EWIS safety assessment requirement is necessary because
a. Current requirement does not fully ensure all EWIS failures are addressed b. EWIS is part of almost every system on an airplane c. Of the large amount of EWIS on newer generation airplanes d. Arc tracking can have catastrophic results on EWIS, leading to smoke and fire
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Harness Riding on Connector: New Airplane

81

Wire bundle riding on top of electrical connectors.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 2-48

Mod 2, Lesson 2

EAPAS Rulemaking Package

Loose hardware

82

Loose clamp isnt a design issue; should be caught during inspection. Routing of metallic cable through wire bundle clamp should never be allowed.

Wire Bundle Riding on Floor

83

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 2-49

Mod 2, Lesson 2

EAPAS Rulemaking Package

25.1729 Instructions for Continued Airworthiness: EWIS


Applicant must prepare Instructions for Continued Airworthiness (ICA) applicable to EWIS in accordance with part 25 Appendix H sections H25.4 and H25.5 ICA must be approved by the FAA

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Federal Aviation Administration

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Section 25.1729 is a parallel requirement to the existing ICA requirement of 25.1529. The key difference is that in 25.1529, ICA must be acceptable to the FAA, not approved by, which is whats required in 25.1729.

Part 25 Appendix H

85

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 2-50

Mod 2, Lesson 2

EAPAS Rulemaking Package

Part 25 Appendix H ICA


H25.1 H25.4 H25.5 General (revised) Airworthiness Limitations sections (revised) Electrical wiring interconnection systems (EWIS) Instructions for Continued Airworthiness (new)

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Titles of the revised and new rules in Appendix H. Section 26.11 requires the DAH to develop EWIS ICA in accordance with certain sections of H25.5.

Part 25 Appendix H25.5; ICA


(a) Applicant must prepare EWIS ICA using an EZAP (b) EWIS ICA developed in accordance with H25.5(a)(1) must be in the form of a document appropriate for information to be provided, and must be easily recognizable as EWIS ICA; document must either contain required EWIS ICA or specifically reference other portions of ICA that contain the information
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The full rule is on the next page.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 2-51

Mod 2, Lesson 2

EAPAS Rulemaking Package

H25.5 Electrical Wiring Interconnection System (EWIS) Instructions for Continued Airworthiness. (a) The applicant must prepare Instructions for Continued Airworthiness applicable to EWIS as defined by 25.1701 that are approved by the FAA and include the following: (1) Maintenance and inspection requirements for the EWIS developed with the use of an enhanced zonal analysis procedure that includes: (i) Identification of each zone of the airplane. (ii) Identification of each zone that contains EWIS. (iii) Identification of each zone containing EWIS that also contains combustible materials. (iv) Identification of each zone in which EWIS is in close proximity to both primary and back-up hydraulic, mechanical, or electrical flight controls and lines. (v) Identification of (A) tasks, and the intervals for performing those tasks, that will reduce the likelihood of ignition sources and accumulation of combustible material, and (B) procedures, and the intervals for performing those procedures, that will effectively clean the EWIS components of combustible material if there is not an effective task to reduce the likelihood of combustible material accumulation. (vi) Instructions for protections and caution information that will minimize contamination and accidental damage to EWIS, as applicable, during performance of maintenance, alteration, or repairs. (2) Acceptable EWIS maintenance practices in a standard format. (3) Wire separation requirements as determined under 25.1707. (4) Information explaining the EWIS identification method and requirements for identifying any changes to EWIS under 25.1711. (5) Electrical load data and instructions for updating that data. (b) The EWIS Instructions for Continued Airworthiness developed in accordance with the requirements of H25.5(a)(1) must be in the form of a document appropriate for the information to be provided, and they must be easily recognizable as EWIS Instructions for Continued Airworthiness. This document must either contain the required EWIS ICA or specifically reference other portions of the ICA that contain this information.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 2-52

Mod 2, Lesson 2

EAPAS Rulemaking Package

Part 26

88

Part 26: Continued Airworthiness and


Safety Improvements for Transport Category Airplanes

26.1 Purpose and scope 26.3 Definitions 26.5 Applicability Table 26.11 Electrical wiring interconnection systems (EWIS) maintenance program
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Part 26 will ultimately contain requirements for a number of safety initiatives, such as widespread fatigue damage and flammability reduction means. Right now, it contains just the requirements for EWIS maintenance programs for certain existing transport category airplanes.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 2-53

Mod 2, Lesson 2

EAPAS Rulemaking Package

Parts 91, 121, 125, and 129

90

EWIS Maintenance Requirements


EAPAS rulemaking package contains new and revised requirements for operators to incorporate the EWIS ICA and SFAR 88 ICA developed by the DAH into their maintenance programs

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Federal Aviation Administration

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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 2-54

Mod 2, Lesson 2

EAPAS Rulemaking Package

Changes to Parts 91, 121, 125, 129


Operators operating under these four parts required to incorporate SFAR 88 ICA Operators operating under parts 121 and 129 also required to incorporate EWIS ICA

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For the details of these requirements, refer to the draft final rule.

Question on EAPAS Rules


Why do we need these new and enhanced EWIS rules?
a. Current standards do not provide for the level of safety we now expect b. Newer airplanes require higher electrical generating capacity c. Newer airplanes have more wire on them than older airplanes
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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 2-55

Mod 2, Lesson 2

EAPAS Rulemaking Package

EAPAS Advisory Circulars

94

The FAA has issued 12 Advisory Circulars that support the EAPAS rulemaking package.

EAPAS 12 New ACs

NEW

EWIS certification (part 25, subpart H) Standard wiring practices manual (part 25, App. H) EWIS training program (satisfies 121.375) EWIS maintenance development (part 25, appendix H, parts 121 & 129)
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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 2-56

Mod 2, Lesson 2

EAPAS Rulemaking Package

EAPAS 12 New ACs, cont.


NEW

DAH requirements (part 26) + 7 more for:


25.869 25.1353 25.1360 25.1365 25.899 25.1357 25.1362

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EAPAS Rulemaking Package


Appendix C of Participant Guide: Listing of all regulations in EAPAS rulemaking package Appendix D: D Listing of all EAPAS ACs

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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 2-57

Mod 2, Lesson 2

Lesson 2 Summary

LESSON 2 SUMMARY

98
The EAPAS rulemaking package contains: Revisions of existing wire-related requirements, The addition of enhanced wire requirements, The adoption of new continued airworthiness requirements for EWIS, and design holder approval requirements, and The requirements for operators to include new maintenance instructions into their maintenance programs. The traditional way of designing, installing, and maintaining wires no longer works. Electrical wires need to be treated as a system.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 2-58

Mod 2, Lesson 2

Lesson 2 Summary

What Does EWIS stand for?


a. Electrical wiring interconnection systems b. Electrical wiring inspection systems c. Enhanced wiring inspection systems d. Enhanced wiring integrated systems

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Federal Aviation Administration

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100

For this IVT, if you have questions for Massoud, Stephen, or Fred, fax them to 405-954-9507.
EAPAS: Part 26 DAH Public Version 1.1, Aug 2007 Participant Guide page 2-59

PARTICIPANT GUIDE
Version 1.1 Note: The information contained in this Participant Guide is presented by the instructors through captioned video and audio. A transcript of the captioning is also available with each with each video segment.

MODULE 3: EAPAS DESIGN APPROVAL HOLDER REQUIREMENTS OF PART 26

MODULE 3 OVERVIEW Module Focus.............................................................................1 Module Lessons .........................................................................2

LESSON 1: PART 26 AND PART 25 APPENDIX H EWIS ICA REQUIREMENTS INTRODUCTION .............................................................................3 PART 26 AND PART 25 APPENDIX H DAH RULES .....................4 What Are the Part 26 Rules? 26.11(a) (g) ..............................4 26.11(a): Applicability ................................................................4 26.11(b): What Do You Have To Do If 26.11(a) Applies?..........6 26.11(c): Imposes What We Did in 26.11(b) On Applicants For Amendments to TCs and STCs ..........................8 Applicable Part 25 Appendix H Requirements: H25.5 EWIS ICA.........................................................................9 SUMMARY OF LESSON 1............................................................13

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-i

Module 3: EAPAS Design Approval Holder Requirements of Part 26

LESSON 2: PRODUCING AN EWIS ICA INTRODUCTION ...........................................................................14 Lesson 2 Objectives.................................................................14 Introduction to Lesson 2 ...........................................................15 EZAP BASICS ..............................................................................16 What is an EZAP?....................................................................16 Why Do You Need an EZAP? ..................................................17 How is an EZAP Done? ...........................................................18 PERFORMING AN EZAP USING AC 120-XX FLOWCHART ......20 Introduction of the Flowchart ....................................................20 Step 1: Identify Aircraft Zones .................................................23 Step 2: List Details of Zone .....................................................23 Step 3: Does Zone Contain Wiring?........................................24 Step 4: Are There Likely To Be Combustible Materials in the Zone? .............................................................................24 Step 7: Is Wiring Close to Both Primary AND Backup Hydraulic, Mechanical, or Electrical Flight Controls? ...............24 Step 5: Is There An Effective Task To Significantly Reduce the Likelihood of Accumulation of Combustible Materials? ......26 Step 6: Define Task and Assign an Interval for Performing It..28 Step 8: Wiring Inspection Task Determination ........................28 Step 9: Task Consolidation .....................................................29 Introduction of the Worksheets.................................................34 Worksheet 1: Details of Zone ..................................................35 Worksheet 2: Assessment of Zone Attributes .........................36 Worksheet 3A: Inspection Level Determination.......................37 Worksheet 4: Inspection Interval .............................................43 Worksheet 5: Task Summary ..................................................51 PRODUCING THE EWIS ICA DOCUMENT..................................52 Regulatory Requirements.........................................................52 Key Points about the EWIS ICA Document..............................52 SAMPLE EWIS ANALYSIS OF AN ENGINE ZONE.....................54 Background Information about the Engine ...............................54 EZAP Steps..............................................................................56 SUMMARY OF LESSON 2 ...........................................................61

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-ii

Module 3: EAPAS Design Approval Holder Requirements of Part 26

LESSON 3: APPROVAL AND INTEGRATION OF EWIS ICA INTRODUCTION ...........................................................................62 Lesson 3 Objectives .................................................................62 Focus of Lesson 3 ....................................................................63 EWIS ICA FAA APPROVAL .........................................................64 Why Is EWIS ICA Approval Necessary? ..................................64 The Process for Approving EWIS ICA ......................................68 How FAA Oversight Office Indicates Approval .........................72 INTEGRATION OF EWIS AND FTS ICA INTO PART 121 AND 129 AIR CARRIERS MAINTENANCE PROGRAMS AND INTEGRATION OF FTS ICA INTO PART 91 AND 125 OWNER/OPERATORS INSPECTION PROGRAMS ..............73 Introduction...............................................................................73 Operator Changes to EWIS ICA ...............................................74 Identification of Actions Necessary to Implement EWIS ICA Approval ..................................................................75 SUMMARY OF LESSON 3............................................................76

MODULE 3 SUMMARY SUMMARY ....................................................................................77

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-iii

Mod 3, Overview

Module 3 Focus

MODULE 3: EAPAS DESIGN APPROVAL HOLDER REQUIREMENTS OF PART 26 MODULE 3 OVERVIEW


EAPAS/FTS: Training for Part 26 DAH Requirements
Module 3: EAPAS DAH Requirements of Part 26
Course Number: 24910 Course Manager: Massoud Sadeghi Version Date: May, 2007 Version Number: Version 1.0

Federal Aviation Administration

Module 3 Focus
The goal of EAPAS rulemaking is to enhance safety by addressing electrical wiring system deterioration and wire contamination. Within EAPAS, a requirement for design approval holders to develop and make available to operators maintenance and inspection instructions for EWIS.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-1

Mod 3, Overview

Module 3 Focus

Focus of Module 3
The process DAHs use to develop electrical wiring interconnection system (EWIS) maintenance & inspection procedures by an enhanced zonal analysis procedure (EZAP)
Ensure compatibility & minimize redundancy between EAPAS and SFAR 88 ICA

Appendix A lists terms and definitions


EAPAS IVT, Course 24910, Mod 3 Federal Aviation Administration

Module Lessons

Module 3 Lessons
1. Part 26 & part 25 Appendix H regulations for DAH to produce EWIS ICA 2. Using AC 120-XX flowchart to produce an EWIS ICA 3. Process for FAA approval of EWIS and SFAR 88 ICA and their integration into operator maintenance and inspection programs
EAPAS IVT, Course 24910, Mod 3 Federal Aviation Administration

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-2

Mod 3, Lesson 1

Introduction

LESSON 1: PART 26 AND PART 25 APPENDIX H EWIS ICA REQUIREMENTS


Module 3: EAPAS DAH Requirements of Part 26

Lesson 1: Part 26 and Part 25 Appendix H EWIS ICA Requirements

EAPAS IVT, Course 24910, Mod 3

Federal Aviation Administration

INTRODUCTION

Lesson 1 Introduction
Objective:
Be able to identify the 14 CFR part 26 DAH requirements and relevant part 25 Appendix H requirements for a DAH to produce an EWIS ICA

EAPAS IVT, Course 24910, Mod 3

Federal Aviation Administration

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-3

Mod 3, Lesson 1

Part 26 & 25 Appendix H Rules

PART 26 AND PART 25 APPENDIX H DAH RULES


What Are the Part 26 Rules? 26.11(a) Through (g)

26.11 EWIS Maintenance Program


a. Applicability b. What do you do if 26.11(a) applies? EZAP c. Imposes what we did in 26.11(b) on applicants for amendments to TCs & STC d. When does this have to be accomplished? e. Compliance Plan development f. Compliance Plan implementation g. List of exceptions to the rule
EAPAS IVT, Course 24910, Mod 3 Federal Aviation Administration

Appendix E of Participant Guide 6

Slide is a list of the paragraphs within section 26.11. 26.11(a): 26.11(b): 26.11(c): 26.11(d): 26.11(e): 26.11(f): 26.11(g): Applicability. What do you have to do if 26.11(a) applies? EZAP. Imposes what we did in 26.11(b) on applicants for amendments to TCs & STC. When does this have to be accomplished? we have a chart that will show this in Module 4. Compliance Plan development. Compliance Plan implementation. List of exceptions to the rule.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-4

Mod 3, Lesson 1

Part 26 & 25 Appendix H Rules

26.11(a): Applicability

26.11(a): Applicability
a) . . . applies to transport category, turbine-powered airplanes with a TC issued after January 1, 1958, that, as a result of the original certification, or later increase in capacity, have (1) A maximum type-certificated passenger capacity of 30 or more or (2) A maximum payload capacity of 7,500 pounds or more.
EAPAS IVT, Course 24910, Mod 3 Federal Aviation Administration

Paragraph is below and in Appendix E of this Guide. 26.11(a) Except as provided in paragraph (g) of this section, this section applies to transport category, turbine-powered airplanes with a type certificate issued after January 1, 1958, that, as a result of the original certification, or later increase in capacity, have (1) A maximum type-certificated passenger capacity of 30 or more or (2) A maximum payload capacity of 7,500 pounds or more.

26.11(a): So Who Has to Comply With This Rule?


Existing TC Holders Pending TC Applicants Pending STC/ATC Applicants Future STC/ATC Applicants
ATC = Amended TC
EAPAS IVT, Course 24910, Mod 3 Federal Aviation Administration

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-5

Mod 3, Lesson 1

Part 26 & 25 Appendix H Rules

26.11(b): What Do You Have To Do If 26.11(a) Applies?


26.11(b): What To Do If Rule Applies? Develop EWIS ICA using an EZAP
Develop ICA for the representative airplanes EWIS in accordance with part 25, Appendix H 25.5(a)(1) and (b) Submit those ICA for review and approval by the FAA Oversight Office

EAPAS IVT, Course 24910, Mod 3

Federal Aviation Administration

Paragraph is below and in Appendix E of this Guide. 26.11(b) Holders of, and applicants for, type certificates, as identified in paragraph (d) of this section must develop Instructions for Continued Airworthiness (ICA) for the representative airplanes EWIS in accordance with part 25, Appendix H paragraphs H25.5(a)(1) and (b) of this subchapter in effect on [effective date of this final rule] for each affected type design, and submit those ICA for review and approval by the FAA Oversight Office. For purposes of this section, the representative airplane is the configuration of each model series airplane that incorporates all variations of EWIS used in production on that series airplane, and all TC-holder-designed modifications mandated by airworthiness directive as of the effective date of this rule. Each person specified in paragraph (d) of this section must also review any fuel tank system ICA developed by that person to comply with SFAR 88 to ensure compatibility with the EWIS ICA, including minimizing redundant requirements.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-6

Mod 3, Lesson 1

Part 26 & 25 Appendix H Rules

26.11(b): Key Points


Rule applies to TC holders with airplanes with passenger capacity 30, or payload capacity 7,500 , TCd after January 1, 1958 TC holder must ensure ICA for SFAR 88 compatible with EWIS ICA & minimize any redundancies
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26.11(b): Representative Airplane


Configuration of each model series airplane that incorporates all variations of EWIS used in production on that series airplane All TC-holder-designed modifications mandated by AD as of effective date of rule EZAP analysis considers all major variations/ configuration of EWIS and other systems

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Federal Aviation Administration

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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-7

Mod 3, Lesson 1

Part 26 & 25 Appendix H Rules

26.11(c): Imposes What We Did In 26.11(b) On Applicants For Amendments To TCs and STCs
26.11(c): Amended TCs and STCs
Applicants for amended TCs and STCs must evaluate if design change requires revision to EWIS ICA, and, if it does
Develop and submit ICA revisions for approval by FAA Oversight Office Ensure revised EWIS ICA compatible with SFAR 88 ICA and that redundant requirements are minimized
EAPAS IVT, Course 24910, Mod 3 Federal Aviation Administration

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Paragraph is below and in Appendix E of this Guide.

26.11(c) Applicants for amendments to type certificates and supplemental type certificates, as identified in paragraph (d) of this section, must: (1) Evaluate whether the design change for which approval is sought necessitates a revision to the ICA required by paragraph (b) of this section to comply with the requirements of Appendix H, paragraphs H25.5(a)(1) and (b). If so, the applicant must develop and submit the necessary revisions for review and approval by the FAA Oversight Office. (2) Ensure that any revised EWIS ICA remain compatible with any fuel tank system ICA previously developed to comply with SFAR 88 and any redundant requirements between them are minimized.

STC applicants. When an STC applicant proposes changes to existing EWIS ICA, ACO and Transport Standards Staff engineers need to coordinate proposed changes with the appropriate AEG office. STC applicant obtains existing EWIS ICA data so a determination can be made on whether revisions are necessary. You should make this clear to the applicant as soon as the final rule is issued to assist them in complying with the requirements by the compliance date.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-8

Mod 3, Lesson 1

Part 26 & 25 Appendix H Rules

26.11(c): Why Amended STCs?


Under 21.101, may determine its not appropriate to require applicants to comply with new airworthiness standards However, it is appropriate for applicants to comply with same requirements as existing certificate holders
Otherwise, safety improvements resulting from TC holder compliance with part 26 could be undone by later modifications
EAPAS IVT, Course 24910, Mod 3 Federal Aviation Administration

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Applicable Part 25 Appendix H Requirements: H25.5 Electrical Wiring Interconnection System (EWIS) Instructions for Continued Airworthiness

Part 25 H25.5(a): EWIS ICA


Prepare EWIS ICA defined by 25.1701, including maintenance and inspection requirements for EWIS developed via EZAP

EAPAS IVT, Course 24910, Mod 3

Federal Aviation Administration

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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-9

Mod 3, Lesson 1

Part 26 & 25 Appendix H Rules

25 H25.5(a)(1): EWIS ICA Must Identify


Each zone of airplane Each zone with EWIS Each EWIS zone with combustible materials Each EWIS zone close to both primary and back-up flight controls and lines Tasks, intervals, and procedures to reduce combustibles Instructions for protections & caution information
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Paragraph is below and in Appendix E of this Guide. H25.5(a)(1): (a) The applicant must prepare Instructions for Continued Airworthiness applicable to EWIS as defined by 25.1701 that are approved by the FAA and include the following: (1) Maintenance and inspection requirements for the EWIS developed with the use of an enhanced zonal analysis procedure (EZAP) that includes: (i) Identification of each zone of the airplane. (ii) Identification of each zone that contains EWIS. (iii) Identification of each zone containing EWIS that also contains combustible materials. (iv) Identification of each zone in which EWIS is in close proximity to both primary and back-up hydraulic, mechanical, or electrical flight controls and lines. (v) Identification of (A) tasks, and the intervals for performing those tasks, that will reduce the likelihood of ignition sources and accumulation of combustible material, and (B) procedures, and the intervals for performing those procedures, that will effectively clean the EWIS components of combustible material if there is not an effective task to reduce the likelihood of combustible material accumulation. (vi) Instructions for protections and caution information that will minimize contamination and accidental damage to EWIS, as applicable, during performance of maintenance, alteration, or repairs.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-10

Mod 3, Lesson 1

Part 26 & 25 Appendix H Rules

Part 25 H25.5(b): EWIS ICA


EWIS ICA must be:
In document appropriate for information Easily recognizable as EWIS ICA

Document must
Contain required EWIS ICA or Specifically reference other portions of the ICA that contain this information
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Paragraph is below and in Appendix E of this Guide. H25.5(b): The EWIS Instructions for Continued Airworthiness developed in accordance with the requirements of H25.5(a)(1) must be in the form of a document appropriate for the information to be provided, and they must be easily recognizable as EWIS Instructions for Continued Airworthiness. This document must either contain the required EWIS ICA or specifically reference other portions of the ICA that contain this information.

Part 25 H25.5(b): EWIS ICA, cont.


Purpose of requirement is to be able to easily identify EZAP-related maintenance tasks, given that these tasks may be integrated with non-EWIS-related tasks

EAPAS IVT, Course 24910, Mod 3

Federal Aviation Administration

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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-11

Mod 3, Lesson 1

Part 26 & 25 Appendix H Rules

EAPAS IVT, Course 24910, Mod 3

Federal Aviation Administration

18

Example of a page from an MRB report.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-12

Mod 3, Lesson 1

Summary of Lesson 1

SUMMARY OF LESSON 1
On your keypads, choose the correct answer for this question.

Which one does not have to comply with section 26.11?


a. A 330 b. Cessna Citation c. CRJ-100 d. MD11
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Mod 3, Les 1

Part 26 reqs.:
Develop & doc. EWIS ICA Ensure EWIS ICA compatible with SFAR 88 ICA

Mod 3, Les 2
Develop & doc. EWIS ICA

Mod 3, Les 3
FAA approval & operator integration of EWIS ICA

Mod 4
Roles & responsibilities of FAA and DAH to comply with part 26 requirements
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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-13

Mod 3, Lesson 2

Introduction

LESSON 2: PRODUCING AN EWIS ICA


Module 3: EAPAS DAH Requirements of Part 26

Lesson 2: Producing an EWIS ICA

EAPAS IVT, Course 24910, Mod 3

Federal Aviation Administration

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INTRODUCTION
Lesson 2 Objectives

Lesson 2 Objectives
You will be able to:
Explain the EZAP process for developing EWIS ICA Review EWIS ICA with SFAR 88 ICA to identify that redundancy & compatibility issues are satisfactorily addressed Identify the components of EWIS ICA Document
EAPAS IVT, Course 24910, Mod 3 Federal Aviation Administration

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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-14

Mod 3, Lesson 2

Introduction

Introduction to Lesson 2

Introduction to Lesson 2
Two sections
How EWIS ICA is developed via EZAP How EWIS ICA document for operators is produced

AC 120-XX, Program To Enhance Transport Category Airplane EWIS Maintenance, use EZAP flowchart
EAPAS IVT, Course 24910, Mod 3 Federal Aviation Administration

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You do not perform an EZAP, the DAH does. However, you will be reviewing and making decisions on whether the DAH data and reports are compliant with the ICA requirements.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-15

Mod 3, Lesson 2

EZAP Basics

EZAP BASICS
What is an EZAP?

What is an EZAP?
A process to develop EWIS ICA
Identifies physical and environmental conditions in each airplane zone and their effects on electrical wiring Assesses possibilities for smoke and fire

Helps to ensure proper attention given to EWIS during maintenance, and to define inspection tasks and intervals
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An EZAP is typically done airplane zone by airplane zone.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-16

Mod 3, Lesson 2

EZAP Basics

Why Do You Need an EZAP?

Why Do You Need an EZAP?


EZAP used to develop ICA to prevent ignition sources by
Minimizing accumulation of combustibles on and around EWIS Detecting EWIS degradation issues

Fewer EWIS failures due to cleaning and inspection lead to safer operation
EAPAS IVT, Course 24910, Mod 3 Federal Aviation Administration

25

Contaminants in Wheel Well

26

EZAP-derived EWIS ICA will: Minimize the accumulation of combustible materials, Make it easier to detect wire degradation, and as a result Lead to fewer failures and safer operation.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-17

Mod 3, Lesson 2

EZAP Basics

How is an EZAP Done?

How is an EZAP Done?


Divide plane into zones Identify zones with EWIS components For EWIS zones, list
Characteristics & components of all systems Full range of power levels Presence or possibilities of ignition sources or accumulation of combustibles
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EWIS Definition 25.1701


An EWIS is [per 25.1701(a)]:
Any wire, wiring device, or combination of these, including termination devices, installed in any area of the airplane for the purpose of transmitting electrical energy between two or more intended termination points . . .

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Federal Aviation Administration

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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-18

Mod 3, Lesson 2

EZAP Basics

EWIS Is . . .

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Federal Aviation Administration

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EWIS is not

[25.1701(c)]

Electrical equipment or avionics qualified to acceptable environmental conditions and testing procedures Portable electrical devices not part of airplanes type design Fiber optics
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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-19

Mod 3, Lesson 2

Performing an EZAP Using AC 12-XX Flowchart

PERFORMING AN EZAP USING AC 120-XX FLOWCHART


Introduction of the Flowchart
The analysis is performed on a zone-by-zone basis. The flowchart presents a series of yes or no questions that get answered for each zone.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-20

Mod 3, Lesson 2

Performing an EZAP Using AC 12-XX Flowchart

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-21

Mod 3, Lesson 2

Performing an EZAP Using AC 12-XX Flowchart

Focus on this
PROGRAMS WITH ZONAL INSPECTION PROGRAM PROGRAMS WITHOUT ZONAL INSPECTION PROGRAM

Using worksheets, assess zone attributes to determine appropriate level of inspection (examples provided in Appendix B of this AC)

Figure 2 Step 8 Wiring Inspection Level and Interval Selection

side of the chart.

Is zonal GVI alone effective for all wiring in the zone? YES List zone description and boundaries for zonal GVI

Is GVI of all wiring in the zone at same interval effective for all wiring in the zone?

YES

List zone description and boundaries for GVI of all wiring in the zone

NO Define specific wiring in the zone for which stand-alone GVI is justified

NO

Define specific wiring in the zone for which GVI at more frequent interval is justified

Zonal GVI must be augmented with stand-alone GVI and/or DET inspection Define specific wiring in the zone for which DET is justified

Some wiring requires GVI at more frequent interval and/or DET inspection Define specific wiring in the zone for which DET is justified

Using rating tables, assess likelihood of damage to wiring in the zone to determine an appropriate interval for each inspection task identified (example provided in Appendix B of this AC)

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-22

Mod 3, Lesson 2

Performing an EZAP Using AC 12-XX Flowchart

Step 1: Identify Aircraft Zones

AC 120-XX Flowchart, EZAP, Step 1


Identify aircraft zones, including boundaries

EZAP uses zones defined by DAH for original maintenance program Zones: actual physical boundaries (e.g., wing spars, cabin floor) and include access provisions for each zone
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Step 2: List Details of Zone

AC 120-XX Flowchart, EZAP, Step 2


List details of zone, for example: Access Installed equipment Lightning / HIRF protection features Wire bundle installation Possible combustible materials

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Federal Aviation Administration

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With respect to power levels, the DAH needs to know whether the wire bundle consists primarily of main generator feeder cables, low voltage instrumentation wiring, or standard bus wiring. This information will be used in determining potential effects of failure of wires within the zone.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-23

Mod 3, Lesson 2

Performing an EZAP Using AC 12-XX Flowchart

Step 3: Does Zone Contain Wiring?

AC 120-XX Flowchart, EZAP, Step 3


Does zone contain wiring?
YES NO

If answer no, zone is eliminated from EZAP If answer yes, go to Step 4

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Federal Aviation Administration

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Step 4: Are There Likely To Be Combustible Materials in the Zone?

Definitions: Combustible
Ability of any solid, liquid, or gaseous material to cause a fire to be sustained after removal of the ignition source Term used in place of inflammable/ flammable NOT material that requires a continuous source of heat to burn
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Appendix A has definitions of terms used throughout this course.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-24

Mod 3, Lesson 2

Performing an EZAP Using AC 12-XX Flowchart

Definitions: Wiring Contamination


As per AC 120-XX
Presence of a foreign material likely to cause degradation of wiring, OR Presence of a foreign material that is combustible, or capable of sustaining a fire after removal of ignition source

EAPAS IVT, Course 24910, Mod 3

Federal Aviation Administration

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AC 120-XX Flowchart, EZAP, Step 4


Are there, or are there likely to be, combustible materials in the zone?

NO

YES

If answer yes, go to Step 5 If answer no, go to Step 7


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Consider commonly-used liquids such as oils, hydraulic fluids, corrosion prevention compounds, and deicing fluids. Forced air ventilation tends to blow dust and lint through the air, causing it to lodge on wiring surfaces. Wet or oily surfaces attract more dust and lint, which impacts assessing possibility of a buildup of combustibles in the zone.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-25

Mod 3, Lesson 2

Performing an EZAP Using AC 12-XX Flowchart

Step 7: Is Wiring Close To Both Primary And Backup Hydraulic, Mechanical, or Electrical Flight Controls?

AC 120-XX Flowchart, EZAP, Step 7


Is wiring close (2 in/50 mm) to both primary and backup hydraulic, mechanical, or electrical flight controls?
YES

NO

If answer no, zone is eliminated from EZAP If answer yes, go to Step 8


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If there are no combustibles in the zone, DAH must ask question for Step 7. Step 7 addresses the concern that segregation between primary and back-up flight controls may not have been consistently achieved in the design of airplanes. Even in the absence of combustible material, a localized wire arcing could prevent continued safe flight and landing if hydraulic pipes, mechanical cables, or wiring for fly-by-wire controls are routed in close proximity to a wiring harness. In consideration of the redundancy in flight control systems, this question should be answered yes if both the primary AND back-up system might be affected by wire arcing. The question should also be answered yes in zones where a fire might be sustained by combustible materials.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-26

Mod 3, Lesson 2

Performing an EZAP Using AC 12-XX Flowchart

Step 5: Is There An Effective Task To Significantly Reduce The Likelihood Of Accumulation Of Combustible Materials?

AC 120-XX Flowchart, EZAP, Step 5


Is there an effective task to significantly reduce the likelihood of accumulation of combustible materials?

NO

YES

If answer no, go to Step 8 If answer yes, go to Step 6


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Step 5 evaluates whether accumulation on or adjacent to wiring can be significantly reduced. Task effectiveness criteria should include considering the potential for damaging the wiring for either accessing or cleaning the wiring. Though restoration tasks such as cleaning are the most likely applicable tasks, the possibility of identifying other tasks is not eliminated. DAH will always answer this question no in the case of fuel vapors, as there is never an effective task to rid the zone of fuel vapors.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

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Mod 3, Lesson 2

Performing an EZAP Using AC 12-XX Flowchart

Step 6: Define Task And Assign An Interval For Performing It

AC 120-XX Flowchart, EZAP, Step 6

Define the task and assign an interval for performing it.

CONTINUE THE ANALYSIS

Cleaning tasks should not be so aggressive that they damage wiring; however . . . They should be applied to a level that significantly reduces likelihood of combustion
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Step 8: Wiring Inspection Tasks Determination

AC 120-XX Flowchart, EZAP, Step 8

Select wiring inspection level and interval. See Figure 2.


INSPECTION TASK(S)

Steps 5, 6, and 7 ultimately lead to 8.

EAPAS IVT, Course 24910, Mod 3

Federal Aviation Administration

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On Figure 1, Step 8 says to go to Figure 2 to make the determination about the wiring inspection task and its interval. Once the wiring inspection task and its interval have been determined, we move on to task consolidation, as depicted in Step 9.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-28

Mod 3, Lesson 2

Performing an EZAP Using AC 12-XX Flowchart

Step 9: Task Consolidation


Step 9 examines the potential for consolidation between the tasks derived from the EZAP and inspections that already exist in the maintenance program.

Definitions: Zonal Inspection


Collective term comprising selected general visual inspections (GVI) and visual checks applied to each zone of the airplane, defined by access and area, to check system & powerplant installations and structure for security and general condition Essentially a GVI to detect obvious unsatisfactory conditions & discrepancies
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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-29

Mod 3, Lesson 2

Performing an EZAP Using AC 12-XX Flowchart

Definitions: General Visual Inspection


Visual examination of interior or exterior area, installation, or assembly to detect obvious damage, failure, or irregularity
Level of inspection
Usually made from within touching distance May require a mirror to enhance visual access Made under normally available lighting May require removal or opening of access panels or doors, or require ladders
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Definitions: GVI, cont.


Area to be inspected should be clean enough to minimize possibility that collected dirt or grease might hide unsatisfactory conditions that would otherwise be obvious Cleaning process itself should not compromise the integrity of EWIS Identify degradation from wear, moisture, contamination, aging, etc.
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For cleaning considered necessary, operator should use airplane manufacturers procedures or other equivalent methods and practices acceptable to the FAA.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-30

Mod 3, Lesson 2

Performing an EZAP Using AC 12-XX Flowchart

Definitions: Detailed Inspection (DET)


Intensive examination of specific item, installation, or assembly to detect damage, failure, or irregularity
Available lighting normally supplemented with a direct source of good lighting at an intensity deemed appropriate

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Definitions: DET, cont.


Inspection aids (mirrors, magnifying lenses, or other means) may be necessary Surface cleaning and elaborate access procedures may be required May include tactile assessment in which component or assembly checked for tightness and security (to ensure
continued integrity of installations such as bonding jumpers and terminal connectors)
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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-31

Mod 3, Lesson 2

Performing an EZAP Using AC 12-XX Flowchart

AC 120-XX Flowchart, EZAP, Step 9


GVI consolidated in zonal inspection

Consider consolidation with existing inspection tasks in systems and powerplant and/or zonal programs *
GVI Stand-alone Assign task to EWIS ICA GVI Maintenance program systems DET and powerplant section Recommend inclusion in ATA 20

Assign task to EWIS ICA Maintenance program zonal section Aircraft with ZIPs

* Section 26.11(b) requires consolidation of EWIS ICA with fuel tank ICA where possible
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Application of the EZAP may identify some GVIs that are adequately covered by existing zonal GVIs in the zone. No change or addition to the existing zonal GVI is required, thus reducing the number of new GVIs that must be introduced into a program that already includes a zonal inspection program (ZIP). Consolidation of GVI tasks should consider access requirements and intervals. EWIS ICA must be compatible with any SFAR 88 ICA. 26.11(b) requires any fuel tank system ICA developed to comply with SFAR 88 be compatible with EWIS ICA, including minimizing any redundant requirements between the two. Compatibility check ensures EWIS ICA dont invalidate previously developed SFAR 88 ICA, and ensures inspection tasks between the two arent redundant. Typically, fuel tank systems contain elements of electrical wiring interconnection systems. Certain EWIS elements within the fuel tank system contribute to prevention of ignition sources and therefore would require a more in-depth inspection, possibly at a more frequent interval, than what may result from only applying EZAP. In some cases, the EZAP may have been carried out independently of considerations for fuel tank system safety.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-32

Mod 3, Lesson 2

Performing an EZAP Using AC 12-XX Flowchart

Two examples to help illustrate what we mean by this requirement. 1. Consider fuel quantity indication system (FQIS) wires that are relying on specific shielding to prevent transient voltages in the fuel tank may have been identified under SFAR 88 as requiring a DET every 3,600 flight hours, while the EZAP analysis may have identified a stand-alone GVI of the same wires and shielding every 7,200 flight hours. 2. Consider an EWIS ICA that requires a DET every 72 months. The SFAR 88 ICA for same wire bundle requires a GVI every 36 months.

The result of Step 9 is a report (or multiple reports) that documents both sides of flowchart Step 9. Usually the result will be in an MRB report, but it doesnt have to be.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-33

Mod 3, Lesson 2

Performing an EZAP Using AC 12-XX Flowchart

Introduction of the Worksheets

AC 120-XX Flowchart, Figure 2

47
Figure 2 documents how the actual wiring inspection tasks and intervals are developed.

The flowchart illustrates the EZAP process. Worksheets 1 5 are used to perform the EZAP analysis.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-34

Mod 3, Lesson 2

Performing an EZAP Using AC 12-XX Flowchart

Worksheet 1 Details of Zone

48

Worksheet 1 documents the zone number, zone title, and zone description. This accounts for Steps 1 and 2 of the flowchart. DAH checks the boxes for all of the major components of the zone, such as electrical wiring and flight control. The large box is used for comments.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

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Mod 3, Lesson 2

Performing an EZAP Using AC 12-XX Flowchart

Worksheet 2 Assessment of Zone Attributes

49

Figure 1 flowchart has been replicated on the left of Worksheet 2. This worksheet records the decisions for Steps 3 through 7.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

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Mod 3, Lesson 2

Performing an EZAP Using AC 12-XX Flowchart

Worksheet 3A Inspection Level Determination

50

Worksheet 3A is Step 8 of Figures 1 and 2 of the flowchart. It is used to select the appropriate level of inspection of the wiring in the zone based on an assessment of zone size, density, and potential effects of fire in the zone. The minimum outcome of this analysis will always be a zonal GVI of any zone where the presence of combustible materials is possible and/or wiring is located in close proximity to both primary and backup hydraulic or mechanical flight controls. The inspection level determination table allows the analyst to determine if a zonal GVI alone is adequate for all wiring in the zone or if the zonal GVI must be augmented with a stand-alone GVI or a detailed inspection of some portion of the wiring. If the zonal GVI is adequate for all wiring in the zone, the analyst must identify the inspection area as the zone itself. If the zonal GVI is not adequate for all wiring in the zone, in addition to identifying the zonal GVI, the analyst must also identify the specific items/areas in the zone where a stand-alone GVI and/or a detailed inspection is necessary.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-37

Mod 3, Lesson 2

Performing an EZAP Using AC 12-XX Flowchart

Worksheet 3A, Zone & Density


Density / Zone Size Assessment Low Density Medium High Zone Size Small 1 2 2 Medium 2 2 3 Large 3 3 3

Circle appropriate result & insert below RESULT

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Zone Size
Based on comparing all the zones in a given airplane model and assessing them in relation to each other For purposes of EZAP analysis, zones sizes identified as small, medium or large Smaller the zone and less congested it is, the more likely that wiring degradation will be identified by GVI
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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-38

Mod 3, Lesson 2

Performing an EZAP Using AC 12-XX Flowchart

Zone Density
Density of installed equipment within zone For purposes of EZAP analysis, density identified as low, medium, or high Consider number of components, closeness to one another, complexity of components Density of zone helps to determine level, type, and frequency of inspection required
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Worksheet 3A, Zone & Density, cont.


Density / Zone Size Assessment Low Density Medium High Zone Size Small 1 2 2 Medium 2 2 3 Large 3 3 3

Circle appropriate result & insert below RESULT

3
54

EAPAS IVT, Course 24910, Mod 3

Federal Aviation Administration

To begin, select zone size and zone density. The resulting number is used in the inspection level table.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-39

Mod 3, Lesson 2

Performing an EZAP Using AC 12-XX Flowchart

Worksheet 3A, Potential Effect of Fire


Inspection Level Determination Based on Potential Effect of Fire in the Zone

Size / Density Factor Low Potential Effects of Fire in the Zone

1
Zonal GVI

2
Zonal GVI

3
Zonal GVI

Medium

Zonal GVI

Zonal GVI + Stand-alone GVI of some wiring Zonal GVI + Stand-alone GVI and/or DET of some wiring

Zonal GVI + Stand-alone GVI of some wiring Zonal GVI + Stand-alone GVI and/or DET of some wiring

High

Zonal GVI + Stand-alone GVI of some wiring

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Potential Effect Of Fire


Assessment should include potential for loss of multiple functions and resulting effect on continued safe operation of airplane Base determination on knowledge of airplane systems in the zone and how loss or degradation of these systems could affect safe operation
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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-40

Mod 3, Lesson 2

Performing an EZAP Using AC 12-XX Flowchart

Potential Effects Rating System


Does zone have mitigating design features to reduce adverse effect of fire? If not, consider potential effects of the fire high Credit can be given to zones that contain a fire detection and/or suppression system, or a zone that is designated as a fire zone For wiring in close proximity to both primary and back-up flight controls, GVI alone may not be adequate
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Worksheet 3A, Potential Effect of Fire, cont.


Inspection Level Determination Based on Potential Effect of Fire in the Zone

Size / Density Factor Low Potential Effects of Fire in the Zone

1
Zonal GVI

2
Zonal GVI

3
Zonal GVI

Medium

Zonal GVI

Zonal GVI + Stand-alone GVI of some wiring Zonal GVI + Stand-alone GVI and/or DET of some wiring

Zonal GVI + Stand-alone GVI of some wiring Zonal GVI + Stand-alone GVI and/or DET of some wiring

High

Zonal GVI + Stand-alone GVI of some wiring

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Chart provides the appropriate inspection level for the EWIS in that zone.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-41

Mod 3, Lesson 2

Performing an EZAP Using AC 12-XX Flowchart

Worksheet 3A, EWIS Inspection Details


1. Is a Zonal GVI YES effective for the NO entire zone?

2. List zone description and boundaries for Zonal GVI 3. Define specific items/ areas in the zone for which a Stand-alone GVI is justified 4. Define specific items/ areas in the zone for which a DET is justified

Zonal GVI must be augmented with a Stand-alone GVI and/or a DET inspection If answer to Box 1 is YES, answer Box 2 only. If answer to Box 1 is NO, answer Boxes 2, 3, & 4.

59

The box on the bottom right-hand side of Worksheet 3A is for documenting the EWIS inspection details. DAH lists existing zonal GVIs that can be used, and provides details of EWIS that need to be the subject of a stand-alone GVI or a DET.

The purpose of Step 8 of Figure 1 is to select the wiring inspection level and interval. Worksheet 3A, determines the inspection level. Worksheet 4 aids in determining the inspection interval. Even if a zonal GVI is effective, DAH still needs to complete Worksheet 4.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-42

Mod 3, Lesson 2

Performing an EZAP Using AC 12-XX Flowchart

Worksheet 4 Inspection Interval

Worksheet 4, Inspection Interval


Used to determine how frequently the inspection will occur Hostility of environment and likelihood of accidental damage are used as basis for establishing inspection interval

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Worksheet 4, Hostility of Environment


Hostility of Environment 1 Passive / 2 Moderate / 3 Severe Enter Number Here Temperature Vibration Chemicals (toilet fluids, de-icing fluid, etc.) Humidity Contamination Other Enter the Highest Number Here
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Ratings assigned on Worksheet 4 are based on engineering judgment and maintenance experience/history. Example: temperature in the passenger cabin, (ambient temperature) is rated 1, while temperature rating for an engine zone (outside pressure vessel and near hot engine) could be a 2 or 3.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-43

Mod 3, Lesson 2

Performing an EZAP Using AC 12-XX Flowchart

Worksheet 4, Hostility of Environment, cont.


Hostility of Environment 1 Passive / 2 Moderate / 3 Severe Enter Number Here Temperature Vibration Chemicals (toilet fluids, de-icing fluid, etc.) Humidity Contamination Other Enter the Highest Number Here
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1 2 1 3 2 1

3
62

Each criteria is given a rating of 1, 2, or 3, with the highest number written in the bottom box. Number used with the likelihood of accidental damage number to determine the task interval.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-44

Mod 3, Lesson 2

Performing an EZAP Using AC 12-XX Flowchart

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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-45

Mod 3, Lesson 2

Performing an EZAP Using AC 12-XX Flowchart

Worksheet 4, Likelihood of Accidental Damage


Likelihood of Accidental Damage 1 Passive / 2 Moderate / 3 Severe Enter Number Here Ground handling equipment Foreign object debris (FOD) Weather effects (hail, rain, etc.) Frequency of maintenance activities Fluid spillage Passenger traffic Other Enter the Highest Number Here
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1 3 1 2 2 1 1

3
64

As with the hostility of the environment, each characteristic is rated 1 3. The highest number is written in the bottom box. This number will be used with the hostility of environment number to determine the task interval.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-46

Mod 3, Lesson 2

Performing an EZAP Using AC 12-XX Flowchart

65
The hostility of environment and accidental damage numbers are used to determine the task interval.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-47

Mod 3, Lesson 2

Performing an EZAP Using AC 12-XX Flowchart

Determining Task Intervals


Use interval determination table as a guide; not meant to be absolute When doing analysis, do not choose answers just so new EWIS task interval fits existing task interval that adjustment will come at the end OK to select highest interval possible, as long as all engineering & maintenance factors have been considered
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The intervals will more than likely be chosen to line up with existing maintenance intervals. That way, were not requiring EWIS maintenance tasks out of sequence, which could Cause damage just for the sake of inspecting a wire, or Put undo burden on the operator by requiring them to take an airplane out of service just to perform an EWIS task.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-48

Mod 3, Lesson 2

Performing an EZAP Using AC 12-XX Flowchart

Worksheet 4, Interval Determination


Interval Determination

Likelihood of Accidental Damage 1


4C 6C

2
2C 4C
7,200 14,400 FH 30 60 M

3
1C 2C
3,600 7,200 FH 15 30 M

14,400 21,600 FH 60 90 M

Hostility of Environment

2C 6C

1C 4C
3,600 14,400 FH 15 60 M

A 1C
450 3,600 FH 1 15 M

7,200 21,600 FH 30 90 M

1C 6C

1C 4C
3,600 14,400 FH 15 60 M

A 1C
450 3,600 FH 1 15 M

3,600 21,600 FH 15 90 M

RESULT
Upon completion, enter all task and interval selections onto Worksheet 5, Task Summary

67

Slide includes some intervals for illustrative purposes. The intervals will vary by airplane model. Within the interval determination box, find the intersection of environmental hostility and accidental damage. This yields a range of intervals from which to choose. Base the interval on the reasons for assigning specific rating values for hostility of environment and likelihood of accidental damage. Also use knowledge of the types of EWIS components to be inspected.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-49

Mod 3, Lesson 2

Performing an EZAP Using AC 12-XX Flowchart

Determining Task Intervals, cont.


Higher the likelihood of accidental damage from multiple sources, the more frequent the maintenance task If all factors except one rated 1, then maintenance interval could be longer Base inspection interval on type of environment EWIS is located in
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DAH should consider the assigned ratings and use sound maintenance engineering judgment to assign the maintenance task interval.

Worksheet 4, Interval Determination


Interval Determination

Likelihood of Accidental Damage 1


4C 6C

2
2C 4C
7,200 14,400 FH 30 60 M

3
1C 2C
3,600 7,200 FH 15 30 M

14,400 21,600 FH 60 90 M

Hostility of Environment

2C 6C

1C 4C
3,600 14,400 FH 15 60 M

A 1C
450 3,600 FH 1 15 M

7,200 21,600 FH 30 90 M

1C 6C

1C 4C
3,600 14,400 FH 15 60 M

A 1C
450 3,600 FH 1 15 M

3,600 21,600 FH 15 90 M

RESULT
Upon completion, enter all task and interval selections onto Worksheet 5, Task Summary

69

The decision on task interval is entered into the final box on Worksheet 4.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-50

Mod 3, Lesson 2

Performing an EZAP Using AC 12-XX Flowchart

Worksheet 5 Task Summary

Worksheet 5
At this point in EZAP, required EWIS ICA and their intervals identified Final activity record all task and interval selections for all zones onto Worksheet 5

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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-51

Mod 3, Lesson 2

Producing EWIS ICA Document

PRODUCING THE EWIS ICA DOCUMENT


Regulatory Requirements

Producing EWIS ICA Document


After EZAP, next step is for applicant to produce the EWIS ICA document
26.11(b) requires compliance with part 25, appendix H 25.5(b) Appendix H 25.5(b) requires EWIS ICA be
In a form appropriate for info to be provided Easily recognizable as EWIS ICA
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The applicant produces the EWIS ICA document. Rule not prescriptive in how to identify EWIS ICA. However DAH or STC applicant determines how to identify EWIS ICA, method must be clearly communicated within ICA documentation (such as providing a legend).

Key Points about the EWIS ICA Document

EWIS ICA Document / Source Document


Contains EWIS ICA or references other portions of ICA that contain the EWIS ICA Up to applicant whether to submit a document that contains actual ICA, or provide a reference document that tells where ICA are located within other documents; may be in multiple documents
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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-52

Mod 3, Lesson 2

Producing EWIS ICA Document

Scenario about Task Consolidation

Task Consolidation Scenario


STC applicant proposing to replace FQIS probes and wiring in the left outboard fuel tank Modification utilizes same wire type and routing as whats in the tank today Applicant proposes an SFAR 88/EWIS ICA that calls for a GVI every 9,600 flight hours Existing maintenance program for existing FQIS probes and wiring calls for a DET every 12,000 hours On this model, outboard tank is scheduled to be accessed every 12,000 hours
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Task Consolidation Question


What is best for resolving conflict between the proposed inspection type and its interval and the existing type and interval?
a. Work with applicant to consider justifying longer compliance time based on additional considerations. b. Dont worry about it; operator will escalate interval, so go with applicants proposal for expediency. c. GVI every 12,000 hours. d. Propose GVI every 4,800 hours, as better to perform 2 GVIs more frequently than 1 DET every 9,600.
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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-53

Mod 3, Lesson 2

Sample EWIS Analysis of an Engine Zone

SAMPLE EWIS ANALYSIS OF AN ENGINE ZONE


Background Information about the Engine

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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-54

Mod 3, Lesson 2

Sample EWIS Analysis of an Engine Zone

77

As we go through this example, look at the slides in Participant Guide if youre having a hard time reading them on the screen.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

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Mod 3, Lesson 2

Sample EWIS Analysis of an Engine Zone

EZAP Steps

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Mod 3, Lesson 2

Sample EWIS Analysis of an Engine Zone

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Mod 3, Lesson 2

Sample EWIS Analysis of an Engine Zone

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Mod 3, Lesson 2

Sample EWIS Analysis of an Engine Zone

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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-59

Mod 3, Lesson 2

Sample EWIS Analysis of an Engine Zone

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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-60

Mod 3, Lesson 2

Summary of Lesson 2

SUMMARY OF LESSON 2

Summary of Lesson 2
Purpose of EZAP
Ensures proper attention given to EWIS during maintenance Defines inspection tasks and intervals for EWIS ICA

DAH develops an EWIS ICA by performing an EZAP (AC 120-XX) EWIS ICA consolidated with SFAR 88 ICA
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The major component of an EWIS ICA Document is that it contains EWIS ICA or that it references portions of other ICA that contain EWIS ICA. The Document must be in a form appropriate for the information to be provided to the operators, and it must be easily recognizable as an EWIS ICA.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-61

Mod 3, Lesson 3

Introduction

LESSON 3: APPROVAL AND INTEGRATION OF EWIS ICA


Module 3: EAPAS DAH Requirements of Part 26

Lesson 3: Approval and Integration of EWIS ICA

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INTRODUCTION
Lesson 3 Objectives

Lesson 3 Objectives
You will be able to:
Identify the need for EWIS ICA approval Describe how EWIS ICA approval is accomplished Describe how EWIS ICA are incorporated into operators maintenance or inspection programs

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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-62

Mod 3, Lesson 3

Introduction

Focus of Lesson 3

Focus of Lesson 3
EWIS ICA must be approved by the FAA Oversight Office (different from other ICA covered by 25.1529 that require that the ICA be accepted) accepted Two sections of Lesson 3
FAA approval of EWIS ICA Incorporation of EWIS ICA into operators maintenance or inspection programs
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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-63

Mod 3, Lesson 3

EWIS ICA FAA Approval

EWIS ICA FAA APPROVAL


Why Is EWIS ICA Approval Necessary?

Why Is EWIS ICA Approval Needed?


25.1729, 26.11(b), and 26.11(c) require EWIS ICA be approved by FAA
1. Approval supports EAPAS objective of increasing awareness of safety impact of EWIS 2. Development of EWIS maintenance & inspection requirements using an EZAP often requires qualitative engineering and maintenance assumptions; approval helps ensure standardized application of these assumptions
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Approval changes the minimum safety and maintenance standards, and the manner in which the FAA approaches and views the effect that improperly maintained EWIS can have on safe operation of transport category airplanes.

Why Is EWIS ICA Approval Needed?, cont.


3. FAA approval ensures operators can use data and documents to comply with their operational requirements 4. Data delivered to operators and maintenance providers will be standardized

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A primary objective of DAH rule is to ensure that operators have at least one source of FAA-approved data and documents to use to comply with the operational requirements.
EAPAS: Part 26 DAH Public Version 1.1, Aug 2007 Participant Guide page 3-64

Mod 3, Lesson 3

EWIS ICA FAA Approval

Why Is EWIS ICA Approval Needed?, cont. Historically, STC applicants for electrical modifications have not paid proper attention to identifying and developing ICA
Without review and approval, FAA wont be able to ensure that ICA developed by DAH are adequate and compatible with EWIS ICA developed by the airplanes manufacturer or previous modifiers
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Benefits of EWIS ICA Approval


Approval helps ensure:
Previous certification findings not invalidated and that any EWIS added or modified will be properly maintained Consistency & standardization of EWIS ICA independent of ACO or applicant location

Requirement for EWIS ICA approval consistent with roles & responsibilities in ICA Order 8110.54
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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-65

Mod 3, Lesson 3

EWIS ICA FAA Approval

Form of EWIS ICA Data


Specific data form is not prescribed by the EWIS ICA requirements Form the EWIS ICA data takes is at the discretion of the applicant
Stand alone documents, Wholly contained in same document, or Combination of the two
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The FAA Oversight Office is going to approve the EWIS ICA developed as a result of using the EZAP discussed earlier in this module.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-66

Mod 3, Lesson 3

EWIS ICA FAA Approval

Airplane Manufacturer/Oversight Office Table


This table lists the Oversight Offices and airplane manufacturers associated with them. Since an STC Holder is also a DAH, every ACO is an Oversight Office for those particular DAHs. From EAPAS NPRM Airplane Manufacturer Aerospatiale Airbus BAE Boeing Bombardier CASA deHavilland Dornier Embraer Fokker Lockheed McDonnell-Douglas SAAB FAA Oversight Office Transport Airplane Directorate, International Branch, ANM-116 Transport Airplane Directorate, International Branch, ANM-116 Transport Airplane Directorate, International Branch, ANM-116 Seattle Aircraft Certification Office New York Aircraft Certification Office Transport Airplane Directorate, International Branch, ANM-116 New York Aircraft Certification Office Transport Airplane Directorate, International Branch, ANM-116 Transport Airplane Directorate, International Branch, ANM-116 Transport Airplane Directorate, International Branch, ANM-116 Atlanta Aircraft Certification Office Los Angeles Aircraft Certification Office Transport Airplane Directorate, International Branch, ANM-116

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-67

Mod 3, Lesson 3

EWIS ICA FAA Approval

The Process for Approving EWIS ICA

Process for Approving EWIS ICA


Need clear identification of what comprises EWIS ICA data Most manufacturers will probably use Maintenance Review Board (MRB) process (see AEG rep. & AC 121-22A) STC applicants will develop EWIS ICA outside of MRB process
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For an understanding of the MRB process, talk with your AEG representative and refer to AC 121-22A.

Process for Approving EWIS ICA, cont.


ACOs will need to be consistently involved in MRB process ACO engineers need to review EZAP analysis and to participate in industry steering committee meetings to ensure final EWIS ICA submitted by DAH is approvable

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Applicants will have to submit the EWIS ICA to the ACOs for approval. Most EWIS ICA developed by using an EZAP will be located in the MRB report. The means of compliance proposed by the DAHs may differ from that of AC 120-XX. This is addressed in Module 4 of this IVT.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-68

Mod 3, Lesson 3

EWIS ICA FAA Approval

Typical Process For Developing And Approving EWIS ICA Developed by a TC Holder or an STC Applicant For Compliance To 26.11(c) EWIS ICA Requirements
The lists on the next couple of pages are meant to represent the general types of activities that should occur when EWIS ICA are developed and approved. The lists may not contain all of the necessary actions or be listed in the exact sequential order. The processes listed are consistent with the Maintenance Review Board procedures outlined in AC 121-22A.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-69

Mod 3, Lesson 3

EWIS ICA FAA Approval

Typical Process For Developing & Approving EWIS ICA Developed by a DAH for Compliance to the Part 26 EWIS ICA Requirements
Typical Process for EWIS ICA Development & Approval
Preliminary EZAP reviewed at the ISC MRB meeting (FAA Oversight Office participates) DAH updates EZAP as necessary based on ISC MRB meeting results

DAH prepares preliminary EZAP

DAH incorporates EWIS ICA into MRBR & submits it to AEG Chairperson for approval

After MRBR approval, DAH submits ICA source document to FAA Oversight Office for approval

FAA Oversight Office approves EWIS ICA source document [part 25, App H H25.5(b)]
94

ISC

Industry Steering Committee

MRB Maintenance Review Board MRBR Maintenance Review Board Report 1. 2. 3. 4. 5. 6. 7. 8. 9. DAH conducts preliminary EZAP analysis DAH presents EZAP analysis results at the Industry Steering Committee (ISC) meeting ACO personnel working with AEG and ISC members review and identify modifications to the EZAP analysis results as necessary EZAP derived EWIS maintenance and inspection requirements are included in the MRB report DAH prepares instructions for continued airworthiness which include EWIS ICA MRB Chairman (AEG) approves the MRB report DAH receives approved MRB report DAH produces source document [required by H25.5(b)] identifying the location of the EWIS ICA DAH submits source document and referenced ICA documents to ACO for approval

10. ACO reviews and approves the source document, which indicates their approval of the EWIS M&IR referenced or contained in that document

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-70

Mod 3, Lesson 3

EWIS ICA FAA Approval

Typical Process For Developing & Approving EWIS ICA Developed By An STC Applicant For Compliance To 26.11(c) EWIS ICA Requirements
Typical Process for STC EWIS ICA Development & Approval STC applicant conducts an EZAP to generate EWIS ICA for proposed modification ACO works with AEG to determine any impact to existing EWIS ICA for airplane undergoing modification

STC applicant presents EZAP results to FAA Oversight Office (ACO)

STC applicant produces EWIS ICA source document

STC applicant submits ICA source document to ACO for approval

ACO approves EWIS ICA source document [part 25, App H H25.5(b)]
95

ISC

Industry Steering Committee

MRB Maintenance Review Board MRBR Maintenance Review Board Report 1. 2. 3. 4. STC applicant conducts EZAP analysis STC applicant presents EZAP analysis results to ACO ACO personnel work with AEG to determine any impact to existing airplane ICA STC applicant produces source document [required by H25.5(b)] identifying the location of the EWIS ICA that were developed using an EZAP (or the source document would contain the EWIS ICA its the applicants choice) STC applicants submits the source document to the ACO for approval ACO reviews and approves the source document, which indicates their approval of the EWIS ICA referenced or contained in that document, and other ICA documentation

5. 6.

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Public Version 1.1, Aug 2007

Participant Guide page 3-71

Mod 3, Lesson 3

EWIS ICA FAA Approval

How FAA Oversight Office Indicates Approval

How Oversight Office Indicates Approval


Uses same manner as for any other compliance documentation Also send copy of approval to
ANM-110 (Massoud Sadeghi, Stephen Slotte), AFS-308 (Fred Sobeck), and MRB Chairperson for affected model (contact AEG for current MRB Chairperson)
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The reason for sending the copies is that these individuals are either on the Standardization Team or involved in the development of the EWIS ICA through the industry steering committee meetings. They need to be aware of the progress of the DAHs in complying with the part 26 requirements.

Name
Massoud Sadeghi Stephen Slotte Fred Sobeck MRB Chairperson

Routing Number
ANM-110 ANM-110 AFS-308 AEG: varies depending on model

Email
Massoud.Sadeghi@faa.gov Steve.Slotte@faa.gov Frederick.Sobeck@faa.gov

Phone
425-227-2117 425-227-2315 202-267-7355

Fax
425-227-1320 425-227-1320 202-267-5115

Even once the ICA are delivered, the FAA Oversight Office is still involved because certain changes to the ICA will have to come back thru the Oversight Office for approval.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-72

Mod 3, Lesson 3

Integration of EWIS and FTS ICA

INTEGRATION OF EWIS AND FTS ICA INTO PART 121 AND 129 AIR CARRIERS MAINTENACE PROGRAMS AND INTEGRATION OF FTS ICA INTO PART 91 AND 125 OWNER/OPERATORS INSPECTION PROGRAMS
Introduction

Integration of EWIS/FTS ICS


Operators required to incorporate EWIS/FTS ICA into maintenance or inspection program
121 & 129 air carriers required to have FAA-approved maintenance program (EWIS and FTS ICA) 91 & 125 air operators only required to have inspection program for airplane (only FTS ICA)
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EAPAS rule contains requirements for the operators to incorporate Fuel Tank System ICA that were developed under 25.1529 and Appendix H. The EAPAS/FTS NPRM has details of this specific requirement.

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Participant Guide page 3-73

Mod 3, Lesson 3

Integration of EWIS and FTS ICA

Operator Changes to EWIS ICA

Operator Changes to EWIS ICA


Operational rules 121.1111 & 129.111 Require EWIS maintenance program be based on EWIS ICA developed in accordance with Appendix H and approved by FAA Oversight Office Changes to EWIS maintenance program must be submitted by operator to FAA Principle Inspector (PI) for review & approval
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FAA PIs have guidance on what deviations to FAA-approved data and documents need to be coordinated with the FAA Oversight Office.

Operator Changes to EWIS ICA, cont.


Operators allowed to escalate or de-escalate EWIS ICA task intervals as authorized in their ops. specs.; FAA Oversight Office approval not necessary PIs not authorized to allow deletion or change of an EWIS ICA task without first obtaining approval from the FAA Oversight Office
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For the EWIS ICA developed using EZAP, PI will review and approve changes to operators maintenance program by applying the same criteria as they would in accepting other maintenance program changes.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-74

Mod 3, Lesson 3

Integration of EWIS and FTS ICA

Operator Changes to EWIS ICA, cont.


FAA Principle Investigator
May approve escalations and de-escalations of EWIS ICA Must coordinate approval from the FAA Oversight Office prior to deletion or other changes of an EWIS ICA task
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EAPAS: Part 26 DAH

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Participant Guide page 3-75

Mod 3, Lesson 3

Summary of Lesson 3

SUMMARY OF LESSON 3
This lesson discussed why and how EWIS ICA are approved by the FAA Oversight Office. We also discussed the integration of the EWIS ICA into the operators maintenance or inspection programs.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-76

Module 3

Module 3 Summary

MODULE 3 SUMMARY

Summary of Module 3
New part 26 requirements for EAPAS DAH Goal of EAPAS to enhance safety by addressing electrical wiring system deterioration and wire contamination Within EAPAS, requirement for DAH to develop EWIS ICA and make them available to operators
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Summary of Module 3, cont.


Major focus: process DAHs use to develop EWIS maintenance and inspection ICA by using an EZAP Also, discussed part 26 requirement to ensure compatibility and minimize redundancy between EWIS ICA and SFAR 88 maintenance actions
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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 3-77

Module 3

Module 3 Summary

Mod 3, Les 1 Part 26 reqs.:


Develop & doc. EWIS ICA Ensure EWIS ICA compatible with SFAR 88 ICA

Mod 3, Les 2
Develop & doc. EWIS ICA

Mod 3, Les 3
FAA approval & operator integration of EWIS ICA

Mod 4
Roles & responsibilities of FAA and DAH to comply with part 26 requirements
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Fax instructors any questions that youd like them to consider.

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PARTICIPANT GUIDE
Version 1.1 Note: The information contained in this Participant Guide is presented by the instructors through captioned video and audio. A transcript of the captioning is also available with each with each video segment.

MODULE 4: ROLES AND RESPONSIBILITIES

INTRODUCTION TO MODULE 4 INTRODUCTION TO MODULE 4 ....................................................1 Overview ....................................................................................2 October 2005 IVT and DAH Documents.....................................4 Why New DAH Approach Developed .........................................5 Culture Shift................................................................................6

LESSON 1: AC 28.XX AND ORDER 8110.26-X ROLES AND RESPONSIBILITIES INTRODUCTION .............................................................................7 Lesson Purpose and Objective...................................................7 Overview of Standardization and Compliance Teams and DAHs ...................................................................................8 TEAM ROLES AND RESPONSIBILITIES ....................................10 Standardization Team ..............................................................10 Compliance Team ....................................................................18 DAH Responsibilities ................................................................27 COMPLIANCE AND ENFORCEMENT PROGRAM......................30 General Enforcement Information ............................................30 SUMMARY OF LESSON 1............................................................31

EAPAS: Part 26 DAH

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Mod 4: Roles & Responsibilities

LESSON 2: KEY ELEMENTS OF AN EWIS ICA COMPLIANCE PLAN INTRODUCTION ...........................................................................33 Lesson Purpose and Objective ................................................33 REQUIRED ELEMENTS OF A COMPLIANCE PLAN..................34 Regulatory Overview................................................................34 26.11(e)(1): Milestone Schedule .............................................35 26.11(e)(2): Means of Compliance and Required Submittals..36 26.11(e)(3): Proposal for Submitting Draft of all Compliance Items Required by Paragraph (e)(2).....................38 26.11(e)(4): Proposal for Distribution Process and Schedule for Making Data and Documents Available ..............39 GOOD PRACTICE TO INCLUDE IN A COMPLIANCE PLAN......42 Elements from AC 26.XX and Order 8110.26-X.......................42 LESSON 2 CONCLUSION............................................................44 Final Point about the Compliance Plan ....................................44 Lesson 2 Summary ..................................................................45

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Mod 4: Roles & Responsibilities

LESSON 3: CRITICAL COMPLIANCE PROCESS ELEMENTS INTRODUCTION ...........................................................................48 Lesson Overview ......................................................................48 Lesson Objectives ....................................................................49 Introduction to Flowchart from DAH Order 8110.26-X ..............49 COMPLIANCE PROCESSES OF DAH ORDER 8110.26-X .........58 Paragraphs 5-2.a and b, Activities Prior to Final Rule ..............58 Paragraph 5-3, Familiarization of DAH .....................................59 Paragraphs 5-4 through 5-6, Compliance Plan Development and Approval ......................................................61 Paragraphs 5-6 through End of Page 1, Compliance Plan Implementation .........................................................................68 Paragraph 5-7.a, Review and Approval of Draft Data and Documents ........................................................................71 Paragraph 5-8.a, Review and Approval of Final Data and Documents ........................................................................75 Paragraph 6-2.e and f, Operator Implementation of Data and Documents ........................................................................80 LESSON 3 SUMMARY..................................................................82

SUMMARY FOR MODULE 4 SUMMARY ....................................................................................84

EAPAS: Part 26 DAH

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Mod 4: Roles & Responsibilities

Introduction to Module 4

MODULE 4: ROLES AND RESPONSIBILITIES INTRODUCTION TO MODULE 4


EAPAS/FTS: Training for Part 26 DAH Requirements
Module 4: Roles and Responsibilities
Federal Aviation Administration

Course Number: 24910 Course Manager: Massoud Sadeghi Version Date: May, 2007 Version Number: Version 1.0

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-1

Mod 4: Roles & Responsibilities

Introduction to Module 4

Overview

Overview of Module 4
FAA requirements drive compliance with design approval holder (DAH) rules and development of a compliance plan Compliance plan schedules support complimentary requirements for DAHs & operators; change in how FAA/DAH work AC 26.XX and Order 8110.26-X support this change
EAPAS IVT, Course 24910, Mod 4 Federal Aviation Administration

Major Goal
Achieve on-time compliance with objectives & requirements of EAPAS Safety Initiatives Implementation strategy will
Involve a structured, proactive project management approach Ensure early awareness of risks to acceptable compliance and Allow FAA to facilitate resolution of issues to ensure on-time compliance
EAPAS IVT, Course 24910, Mod 4 Federal Aviation Administration

The implementation strategy does identify enforcement actions to help obtain compliance. However, enforcement would be used only as a last resort, if collaborative, proactive approach with DAHs fails to facilitate timely compliance.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-2

Mod 4: Roles & Responsibilities

Introduction to Module 4

Purpose of Module
Provide you with information on
Your role and responsibilities, and How you can facilitate the processes to implement the EAPAS DAH rules

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Module 4 Composed of 3 Lessons


1. Overview of Standardization Team, Compliance Teams, and DAH roles and responsibilities 2. Key elements of EWIS ICA compliance plan DAH provides to operators 3. Processes for facilitating DAH compliance, supporting compliance standardization, and identifying when compliance is at risk
EAPAS IVT, Course 24910, Mod 4 Federal Aviation Administration

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-3

Mod 4: Roles & Responsibilities

Introduction to Module 4

October 2005 IVT and DAH Documents

October 2005 Aging Airplane IVT


Overview of Aging Airplane program, DAH requirements, and overall program plan
Original implementation schedule for rules changed since IVT, plan has not DAHs required to make available data and documents to support operator compliance with new or existing ops rules
EAPAS IVT, Course 24910, Mod 4 Federal Aviation Administration

There are ACs, Orders, and, the NPRMs that contain information regarding rulemaking and processes to follow for compliance and implementation. The DAH Order will be finalized and issued concurrently with the EAPAS final rule. While references to Orders or guidance information may be to draft material, we do not anticipate any substantial change in the finalized versions of these references.

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Mod 4: Roles & Responsibilities

Introduction to Module 4

Why New DAH Approach Developed

Why New DAH Approach?


Operators expressed concerns about timely availability of data to support compliance with operational rules
Voluntary support problems
Thrust reversers Structural repair manuals Class D to C cargo conversions Reinforced flight deck door program
EAPAS IVT, Course 24910, Mod 4 Federal Aviation Administration

The FAA believes that DAH support of operators in complying with operational rules has occasionally been lacking. The FAAs historic approach of adopting rules with compliance times only for operators may cause economic impact to operators, with no consequences for design approval holders.

Result of FAA Review


FAA determined that DAH requirements will be adopted as necessary to support future operational rules
FAA Policy Statement: Safety A Shared Responsibility New Direction for Addressing Airworthiness Issues for Transport Airplanes (Federal Register/ Vol 79, No. 132/Tuesday, July 12, 2005/ Rules and Regulations)
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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-5

Mod 4: Roles & Responsibilities

Introduction to Module 4

Culture Shift

Culture Shift
Complementary DAH and operational rules a policy and culture shift
Requires shared responsibility between DAHs and operators Requires culture shift in relationship between the FAA and DAHs

DAH rules, AC 26-XX, & Order 8110.26-X help achieve the safety benefits
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FAA teams need to be up and running before the final rule is out to ensure these teams have the necessary information to facilitate the DAH activity. FAA teams need to be knowledgeable of rules and associated guidance, as well as roles and responsibilities in promoting acceptable on-time compliance.

Which is NOT a reason for using DAH rules to support certain rulemaking initiatives, including EAPAS?
a. Achieve safety benefits in a timely manner. b. Ensure operators have information needed to comply with the operational rules. c. Provide the FAA with mechanisms to facilitate compliance. d. Ensure consistency and standardization in how initiatives are implemented.
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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-6

Mod 4, Lesson 1

Introduction

LESSON 1: AC 26.XX AND ORDER 8110.26-X ROLES AND RESPONSIBILITIES

Module 4: Roles & Responsibilities

Lesson 1: AC 26.XX and Order 8110.26-X Roles and Responsibilities


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INTRODUCTION
Lesson Purpose and Objective

Lesson Purpose
AC 26.XX and Order 8110.26-X define roles & responsibilities of FAA Standardization Team & Compliance Teams, and DAHs for EAPAS Main difference from current certification process, is that FAAs mandate for continued airworthiness of fleet is driving the schedule, not the DAH These initiatives require DAHs support to help operators implement safety actions
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There is more information in the AC and Order.

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Mod 4, Lesson 1

Introduction

Lesson 1 Objective
Upon completion of this lesson, you will be able to describe, as defined in AC 26.XX, Order 8110.26-X, and Order 2150.3A
Key roles and responsibilities of the Standardization and Compliance Teams Responsibilities of the DAH General process for enforcement
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Overview of Standardization and Compliance Teams and DAHs

Standardization Team
Interface with all Compliance Teams and other civil aviation authorities Serve as resource on technical requirements of rules and compliance methodology to help ensure standardized application of rules Assist Compliance Teams and other authorities, and keep management informed of issues and compliance status
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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

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Mod 4, Lesson 1

Introduction

Compliance Teams
(FAA Oversight Office)
Familiarize DAHs with rules & guidance for developing compliance plan Monitor DAHs progress Review and approve data & documents Provide status updates and coordinate issues with Standardization Team
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The Compliance Team is part of the FAA Oversight Office referenced in the DAH rules.

Design Approval Holder


Required by regulation to create, submit to the FAA for approval, and implement a compliance plan When all draft and final data and documents are approved, then DAH makes data & documents available to affected operators
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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-9

Mod 4, Lesson 1

Team Roles and Responsibilities

TEAM ROLES AND RESPONSIBILITIES


Standardization Team

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Standardization Team
(formed for each safety initiative)
Composed of representatives from (per Order 8110.26-X: 4-3b)
Transport Standards Staff (including
international & standardization branch offices)

AFS policy division

Supported by legal counsel


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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-10

Mod 4, Lesson 1

Team Roles and Responsibilities

Standardization Team for EAPAS


Massoud Sadeghi, Sadeghi
ANM-117 *

Meghan Gordon, Gordon


ANM-113

Stephen Slotte, Slotte


ANM-111 *

Shahram Dareshmandi, Dareshmandi


ANM-116

Fred Sobeck, Sobeck


AFS-308 *

* Technical focals and authors of EAPAS


airworthiness & ops rules & guidance materials
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Communication
The Standardization Team will be in frequent communication with the Compliance Teams
Helpful for areas not addressed in policy Standardization Team will identify key information for Compliance Teams to provide to support standardization

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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-11

Mod 4, Lesson 1

Team Roles and Responsibilities

Communication & Teleconferences


Set up regular discussions with Compliance Team Leads/Oversight Office focals, other civil aviation authorities
Technical guidance Status information on compliance milestones Compliance risk concerns Issues needing special attention Recommendations for issue resolutions
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Key for Success

Proactive versus reactive coordination


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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-12

Mod 4, Lesson 1

Team Roles and Responsibilities

Key for Success, cont.


Standardization Team provides program management oversight
Compliance Teams provide project management oversight

Coordination between FAA Teams expected to be structured & frequent

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Standardization Team: Roles


Provide technical guidance to Compliance Teams Ensure technical standardization, standardized issue resolution, and standardized enforcement activities Perform program management tasks: monitor compliance status, resolve issues, and ensure communication with management (ANM-100 & AFS-300)
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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-13

Mod 4, Lesson 1

Team Roles and Responsibilities

Standardization Team Role:

Technical Guidance
Serve as resource regarding technical requirements of rules and compliance methodology Help to determine if DAHs applying rule correctly

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Standardization Team Role:

Standardization
Ensure technical standardization, standardized issue resolution, and standardized enforcement activities
Standardized familiarization briefing for Compliance Teams to use with DAHs Review alternate methods of compliance Review proposals by DAHs outside U.S.
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Standardization Team will review the proposed means to confirm compliance to ensure that it is both appropriate to the type design and consistently applied. This role is conducted with input from the Compliance Teams on the acceptability of the DAH-proposed compliance methodology.
EAPAS: Part 26 DAH Public Version 1.1, Aug 2007 Participant Guide page 4-14

Mod 4, Lesson 1

Team Roles and Responsibilities

Standardization Team Role:

Program Management Tasks


Monitor compliance status & issue resolution, and ensure communication with management (ANM-100, AFS-300)
Make recommendations to management in coordination with Compliance Teams for resolution of issues Coordinate DAH issues with Compliance Teams Encourage timely & effective communication
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FAA Order 8110.26-X outlines the responsibilities of the Compliance Teams to coordinate DAH issues with the Standardization Team and the FAA Oversight Office management. The frequency and content of communication to ANM-100/AFS-300 management must be prompt to avoid unnecessary delays. Significant deviations to the approved compliance plan or lack of communication or responsiveness from the DAH will be raised to ANM-100/AFS-300 management.

If necessary, the Flight Standards Service will alert affected operators of a compliance risk. This will enable the operators to pursue alternate means of compliance with the requirements of the DAH regulations in support of the operators compliance with the operational rules. If a DAH were to surrender their type certificate, the FAA could not share the technical type design data. However, interested parties may contact the DAH to obtain permission to use the type design data.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-15

Mod 4, Lesson 1

Team Roles and Responsibilities

Standardization Team
Summary of Roles
1. Technical guidance for Compliance Teams 2. Technical standardization, standardized issue resolution & enforcement activities 3. Monitor compliance status, resolve issues, & ensure communication with management (ANM-100 & AFS-300)
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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-16

Mod 4, Lesson 1

Team Roles and Responsibilities

Question #1 on Standardization Team


The Standardization Team helps the Compliance Teams determine if an alternate method of compliance meets the intent of the part 26 rules. a. True b. False

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Question #2 on Standardization Team


The Standardization Team will conduct familiarization briefings with the DAHs. a. True b. False

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EAPAS: Part 26 DAH

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Mod 4, Lesson 1

Team Roles and Responsibilities

Compliance Team

June 1, 2006

Federal Aviation Administration

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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

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Mod 4, Lesson 1

Team Roles and Responsibilities

Compliance Team Composition


Representatives from FAA Oversight Office [ACO or TAD responsible for relevant TC or STC, & representatives from affected Aircraft Evaluation Group (AEG) offices] EAPAS representatives from Oversight Offices AEG, Systems & Equipment Branch, and Propulsion Branch as needed to coordinate EWIS & fuel tank safety ICA
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Compliance Team members are selected depending on the model airplane and the DAH. It is up to each ACO manager to determine an appropriate team based on resources and the complexity of the project. This team will work directly with the DAHs to: Familiarize them with the safety initiative rule requirements and associated guidance, Review and approve the DAH compliance plan, Monitor the implementation of the plan, and Make the final determination of DAH compliance with requirements.

The Compliance Teams have two main roles: Performing project management tasks by overseeing DAH activities. Determining compliance.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-19

Mod 4, Lesson 1

Team Roles and Responsibilities

Compliance Team Role:

Project Management
Oversee DAH activities
Have familiarization meetings with DAHs Monitor development and achievement of compliance plan Work closely with DAHs to resolve issues in a timely manner

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Compliance Team Role:

Project Management, cont.


Familiarization meetings with DAHs
Highlight EAPAS requirements Emphasize expectations (e.g., timely compliance & cooperative relationship) Emphasize technical expectations Inform DAH that FAA retains initial findings of compliance to part 26 Discuss potential enforcement action
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Familiarization meetings are needed for existing TC holders as well as pending TC, ATC and STC applicants, since these affected DAHs will need to comply with all of the related part 26 requirements. Future applicants with the part 26 technical requirements as part of their certification basis will show compliance with those requirements as part of their certification program. They will not be required to submit compliance plans or draft data and documents.
EAPAS: Part 26 DAH Public Version 1.1, Aug 2007 Participant Guide page 4-20

Mod 4, Lesson 1

Team Roles and Responsibilities

Compliance Team Role:

Project Management, cont.


Monitor development & achievement of compliance plan
Establish communication plan with DAH
Means to promptly identify technical & process issues Process for issue resolution Expectations for level of coordination
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Although early drafts of data and documents are not required submittals, they are strongly recommended for successful projects).

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

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Mod 4, Lesson 1

Team Roles and Responsibilities

Compliance Team Role:

Project Management, cont.


Monitor development & achievement of compliance plan, cont. Monitor status of milestones Identify issues for Standardization Team Document all communication related to potential compliance issues: summary of
actions taken, recommendations for resolution

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Documentation may be in the form of a letter, in particular, the approval of the compliance plan or the identification of deficiencies in the plan or the implementation of an approved plan. Emails, records of meeting, or telecons with the DAH, are essential information to document for any potential enforcement actions the FAA may take because of DAH non-compliance. Compliance status information must include a summary of the actions taken by the Standardization and Compliance Teams to facilitate compliance and, if compliance appears to be still at risk, the Teams recommendations for resolution. It is important to accurately know and document the DAHs progress towards compliance.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-22

Mod 4, Lesson 1

Team Roles and Responsibilities

Compliance Team Role:

Project Management, cont.


Work closely with DAHs to resolve issues in a timely manner
Raise issue to Standardization Team if resolution with DAH isnt timely
Recommend a course of action Initiate enforcement actions

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Compliance Team Role:

Determine Compliance
Review and approval of DAH compliance data and documents
Similar to review and approval of compliance plan

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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-23

Mod 4, Lesson 1

Team Roles and Responsibilities

Compliance Team Role:

Determine Compliance, cont.


Handling significant deficiencies in draft or final data and documents
Promptly identify and document deficiencies Recommend resolutions Provide Standardization Team with assessment for consequent impact on operator and operators compliance with operational rules
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Compliance Team Role:

Determine Compliance, cont.


Maintain schedules and response times per rules & Order 8110.26-X for
Review of compliance plans Identification of deficiencies in plan and its accomplishment Acceptability of draft and final data and documents
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Response times ensure prompt FAA responses to DAHs, and support DAHs achieving timely compliance.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-24

Mod 4, Lesson 1

Team Roles and Responsibilities

Compliance Team
Summary of Roles

1. Oversee DAH compliance activities (project management) 2. Determine compliance with DAH rules

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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-25

Mod 4, Lesson 1

Team Roles and Responsibilities

Question #1 on Compliance Teams


In conducting the project oversight of DAHs, a Compliance Team will NOT
a. Have familiarization meetings with DAH. b. Monitor implementation of DAH compliance plan. c. Have Standardization Team resolve technical issues with the DAH. d. Initiate enforcement actions if necessary.
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Question #2 on Compliance Teams


EAPAS DAH rule Compliance Teams will include representatives from the FAA Oversight Offices AEG, Systems and Equipment Branches, and Propulsion Branch (if needed). a. True b. False

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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-26

Mod 4, Lesson 1

Team Roles and Responsibilities

DAH Responsibilities

June 1, 2006

Federal Aviation Administration

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DAH Responsibilities
DAH has legal obligation to:
1. Comply with part 26 requirements
If doesnt comply, Compliance Teams identify and document by notifying DAH and Standardization Team, and submit recommendations for FAA action

2. Submit compliance plan within 90 days after effective date of the rule [26.11(e)]
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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-27

Mod 4, Lesson 1

Team Roles and Responsibilities

DAH Responsibilities, cont.


DAH has legal obligation to, (cont.):
3. Implement FAA-approved compliance plan
Work closely with operators

4. Submit draft compliance data & documents 60 days before final data and documents are required [26.11(e)] 5. Submit final data and documents within 24 months after effective date of rule [26.11(d)]
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DAH Responsibilities, cont.


DAH has legal obligation to (cont.):
6. Make documents and data available to support operator compliance
Inform affected operators of availability of approved data and documents To comply with DAH requirements of EAPAS, DAH may provide revision pages for existing maintenance manuals

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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-28

Mod 4, Lesson 1

Team Roles and Responsibilities

Question #1 on DAHs
DAHs do NOT have a legal responsibility to:
a. Submit compliance plan for approval. b. Implement compliance plan. c. Make data & documents available to operators. d. Include operators in ICA development activity.

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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-29

Mod 4, Lesson 1

Lesson 1 Summary

COMPLIANCE AND ENFORCEMENT PROGRAM


General Enforcement Information

Compliance & Enforcement Program

Primary objective: objective obtain compliance through cooperative efforts

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Compliance & Enforcement Program, cont.


Enforcement: legal tool when cooperative Enforcement efforts unsuccessful novel role for ACOs Order 2150.3A provides general direction All DAH rules written to be enforceable DAH Order 8110.26-X provides direction 8110.26for ensuring we can take enforcement action for these rules
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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-30

Mod 4, Lesson 1

Lesson 1 Summary

LESSON 1 SUMMARY

Lesson 1 Summary
DAH rules
Are intended to ensure data & documents are available in a timely manner to support operator compliance with operational rules Drive the schedule for compliance actions, which is different from certification projects where DAHs drive the schedule

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Lesson 1 Summary, cont.


Using a team approach for overseeing DAH compliance activities
Standardization Team provides technical guidance, ensures standardization, and provides program management Compliance Teams oversee DAH activities (project management) and determine compliance with DAH rules
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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-31

Mod 4, Lesson 1

Lesson 1 Summary

Lesson 1 Summary, cont.


Teams must work together and with DAHs (proactively monitor activities) to ensure DAH compliance will be achieved on time to support operator compliance with ops rules DAHs have legal obligation to comply with part 26 rules If efforts with DAHs are not successful and DAH does not comply with DAH rules, FAA may need to pursue enforcement action
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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-32

Mod 4, Lesson 2

Introduction

LESSON 2: KEY ELEMENTS OF AN EWIS ICA COMPLIANCE PLAN


Module 4: Roles & Responsibilities

Lesson 2: Key Elements of an EWIS ICA Compliance Plan

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INTRODUCTION
Lesson Purpose and Objective

Lesson Objective
Upon completion of this lesson, you will be able to describe and recognize key elements of a DAHs EWIS ICA compliance plan

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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-33

Mod 4, Lesson 2

Required Elements of Compliance Plan

REQUIRED ELEMENTS OF A COMPLIANCE PLAN


Regulatory Overview

Compliance Plan Elements, 26.11(e)


1. Proposed project schedule 2. Proposed means of compliance and identification of required compliance submittals 3. Proposal for submitting drafts of all compliance items 4. Proposal for how approved ICA made available to operators
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26.11(e) is shown below this slide, and its in Appendix E of this Guide.

26.11(e): Each person identified in paragraphs (d)(1), (d)(2), and (d)(4) of this section must submit to the FAA Oversight Office for approval a compliance plan by [insert date 90 days after effective date of final rule]. The compliance plan must include the following information: (1) A proposed project schedule, identifying all major milestones, for meeting the compliance dates specified in paragraph (d) of this section. (2) A proposed means of compliance with this section, identifying all required submissions, including all compliance items as mandated in part 25, Appendix H paragraphs H25.5(a)(1) and (b) of this subchapter in effect on [effective date of this final rule], and all data to be developed to substantiate compliance. (3) A proposal for submitting a draft of all compliance items required by paragraph (e)(2) of this section for review by the FAA Oversight Office not less than 60 days before the compliance time specified in paragraph (d) of this section. (4) A proposal for how the approved Instructions for Continued Airworthiness will be made available to affected persons.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-34

Mod 4, Lesson 2

Required Elements of Compliance Plan

26.11(e)(1): Milestone Schedule

Milestone Schedule, 26.11(e)(1)


Basis for monitoring plan implementation and potential for on-time compliance
(sufficient compliance plan status meetings) Good practice: milestones include operator reviews of planned data to ensure data and documents acceptable for operator compliance

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For EWIS ICA development, DAHs may use the MSG-3 process, which includes operators. However, other processes that may not inherently include operators may be acceptable for compliance. For these situations, DAHs should indicate coordination with operators as part of their milestones.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-35

Mod 4, Lesson 2

Required Elements of Compliance Plan

26.11(e)(2): Means of Compliance and Required Submittals

Means of Compliance & Required Submittals, 26.11(e)(2)


ACs 25.17XX & 120-XX define acceptable means of compliance If proposed means of compliance differ from ACs, the DAH should provide rationale

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Means of Compliance & Required Submittals, 26.11(e)(2), cont.


MSG-3 v2005.1 is same as in AC 120-XX MSG-3 v2003, doesnt ask if wiring close to both primary and backup hydraulic, mechanical, or electrical flight controls
DAH must address this difference

For both MSG-3, need to perform EZAP on representative airplane configuration


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Some DAHs have developed EWIS ICA using EZAP. Two different processes: MSG-3 v2003, and MSG-3 v2005.1. DAHs may not have fully considered using a representative airplane configuration. The Standardization Team needs to be consulted in these cases.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-36

Mod 4, Lesson 2

Required Elements of Compliance Plan

DAH may propose to use alternative compliance methods to those in the guidance material. The Compliance Teams must coordinate with the Standardization Team on the acceptability. This coordination must include the teams recommendations on the acceptability of the DAH compliance methodology.

26.11(e)(2): Proposed Means of Compliance

A proposed means of compliance with this section, identifying all required submissions, including all compliance items as mandated in part 25, Appendix H paragraphs H25.5(a)(1) and (b) of this subchapter in effect on [effective date of this final rule], and all data to be developed to substantiate compliance.
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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-37

Mod 4, Lesson 2

Required Elements of Compliance Plan

26.11(e)(3): Proposal for Submitting Draft of all Compliance Items Required by Paragraph (e)(2)

Proposal for Submitting Drafts, 26.11(e)(3)


DAH submits draft compliance documents not less than 60 days before final compliance date
As available, review results of EZAP with DAH If Compliance Team participated in development of EZAP-derived EWIS ICA and is satisfied with results, the review should be minimal
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If the DAH has not previously addressed or conducted an EZAP analysis with FAA involvement, then the Compliance Team needs to get involved with review of the analysis as early as possible, therefore sooner than 60 days. The purpose of these early reviews is to ensure the data and documents will be appropriate for compliance.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-38

Mod 4, Lesson 2

Required Elements of Compliance Plan

26.11(e)(4): Proposal for Distribution Process and Schedule for Making Data and Documents Available
The review and approval by the FAA of the final EWIS ICA need to be made expeditiously so that the DAH can get the information to the operators quickly. This gives the operators as much time as possible to incorporate changes into their maintenance or inspection programs.

Compliance Timeline for TC Holders


DAH submits Rule draft data/docs Effective to FAA Date DAH submits compliance plan to FAA DAH submits EWIS ICA to FAA EWIS ICA available for operators 12 months Operational Compliance Deadline

// 24 months
3 months 60 days 24 months from effective date of rule

3 months FAA approves EWIS ICA

39 months from effective date of rule

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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-39

Mod 4, Lesson 2

Required Elements of Compliance Plan

Compliance Timeline for Pending TC/ATC/STC Applicants


Pending TC/ATC applicant submits Rule draft data/docs Effective to FAA Date 60 days Applicant Pending STC applicant submits draft data/docs to FAA 60 days

Operators incorporate new/ revised EWIS ICA

submits compliance plan to FAA

//
3 months

Applicant submits EWIS ICA to FAA

EWIS ICA available for operators

24 months FAA approves EWIS ICA Pending STC applicants: 30 months from effective date of rule or date certification is issued, whichever occurs later
Federal Aviation Administration

24 months from effective Pending date of rule, or date TC/ATC certificate is issued, applicants whichever occurs later
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Future applicants for ATCs and STCs who filed their applications on or after the effective date of the rule and for which compliance with 25.1729 was not required or elected, would comply with the part 26 requirements as part of their certification program. They would not be required to submit a specific compliance plan or draft data and documents, as would be required for existing or pending DAHs.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-40

Mod 4, Lesson 2

Required Elements of Compliance Plan

Distribution Process of Final Data and Documents, 26.11(e)(4)


Operator not required to use approved DAH data and documents DAH must make docs available as soon as possible (DAH may require compensation) The plan for how and when applicable approved data and documents will be made available to operators must be outlined in the compliance plan
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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-41

Mod 4, Lesson 2

Good Practice Compliance Plan Elements

WHAT IS GOOD PRACTICE TO INCLUDE IN A COMPLIANCE PLAN?


Elements from AC 26-XX and Order 8110.26-X

Additional Compliance Plan Elements


Proposed communication and coordination plan Proposed delegation plan Explanation if means of compliance differs from ACs

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Communication & Coordination Plan


Plan identifies
DAH contacts for Compliance Team Frequency and mechanism for status updates and other information

Compliance Team
Ensure DAH knows FAA contact

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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-42

Mod 4, Lesson 2

Good Practice Compliance Plan Elements

Proposed Delegation Plan


If DAH delegates, DAH ensures designee has ability to comply, knowledgeable of regs & guidance Compliance Team determines if delegation plan & designees acceptable per FAA delegation policy for EAPAS FAA will not delegate review and approval of compliance plan
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If the Compliance Team agrees with the delegation plan, the designee has the responsibility for finding compliance, or recommending approval, with all the requirements of the DAH regulations, as appropriate. FAA policy does address designees and airworthiness representative (ODA).

Means of Compliance Differences


If proposed means of compliance differs from FAA guidance material, DAH should explain how and why the proposal is acceptable
Facilitates timely FAA review and approval of DAH compliance plan, saving both DAH and FAA resources

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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-43

Mod 4, Lesson 2

Lesson 2 Conclusion

LESSON 2 CONCLUSION
Final Point about the Compliance Plan

Lack of expected content or an unacceptable plan does NOT stop compliance clock!
DAH expected to comply by final date in rule If no acceptable compliance plan submitted, FAA may pursue enforcement action
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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-44

Mod 4, Lesson 2

Lesson 2 Conclusion

Lesson 2 Summary

Lesson 2 Summary
Elements of compliance plan required by 26.11(e)(1)(2)(3)(4):
1. Proposed project schedule 2. Proposed means of compliance and required compliance submittals
ACs 25.17XX & 120-XX acceptable means MSG-3 processes need to address using a representative airplane configuration
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Lesson 2 Summary, cont.


Elements of compliance plan required by 26.11(e)(1)(2)(3)(4):
3. Proposal for submitting drafts of all compliance items 4. Proposal for how approved ICA will be made available to the operators

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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-45

Mod 4, Lesson 2

Lesson 2 Conclusion

Lesson 2 Summary, cont.


Additional elements to help DAH and Compliance Teams manage project more effectively and efficiently
Proposed communication and coordination plan Proposed delegation plan Explanation if proposed means of compliance differs from the ACs
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Which element is NOT a required element of an EWIS compliance plan?


a. Proposed means of compliance b. Proposed communication plan c. Proposed milestone schedule d. Proposed distribution process and schedule
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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-46

Mod 4, Lesson 2

Lesson 2 Conclusion

If the DAH-proposed method of compliance is different from published material, what is NOT a Compliance Team action?
a. Request DAH identify differences from published guidance b. Evaluate acceptability of method c. Coordinate with Standardization Team d. Require DAH to use AC methodology
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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-47

Mod 4, Lesson 3

Introduction

LESSON 3: CRITICAL COMPLIANCE PROCESS ELEMENTS


Module 4: Roles & Responsibilities

Lesson 3: Critical Compliance Process Elements

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INTRODUCTION
Lesson Overview

Lesson 3 Overview
Covering processes essential to
Facilitating DAH compliance and compliance standardization, and Identifying when compliance at risk

Lesson highlights critical elements

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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-48

Mod 4, Lesson 3

Introduction

Lesson Objectives

Lesson 3 Objectives
You will be able to:
Describe critical process elements used in:
Approval of the compliance plan, Resolution of deficiencies, Monitoring DAHs plan implementation, and Review/approval of final data & documents

Identify required review, approval, and response times needed to support various compliance activities
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Introduction to Flowchart from DAH Order 8110.26-X


Flowchart from DAH Order 8110.26-X (summary version in AC 26-XX) will be used to present the critical compliance plan processes. The flowchart in the final DAH Order will have minor revisions/clarifications, but the main process information will not change.

The flowchart is on the next two pages of this Guide.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-49

Mod 4, Lesson 3

Introduction

Flowchart from DAH Order 8110.26-X


(Summary Version in AC 26-XX)

1 2 3 4

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-50

Mod 4, Lesson 3

Introduction

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-51

Mod 4, Lesson 3

Introduction

Flowchart, DAH Order 8110.26-X

F AA S tan dard izat ion Tea m - p ara grap h 5- 2.a. Fa m ilia rize all C om plianc e T ea m s w ith re gulat ions , guida nc e , and ex pe cta tion s fo r c om plianc e p lan , a naly ses , da ta , a nd doc u m e nts .

F A A C om plianc e T ea m - paragraph 5-2 . b. Organ ize t eam , d evelo p p lan , defin e roles & resp ons ib ilities , part icipa te in trainin g a nd p rep ara tion act iv itie s .

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For the most part, the processes focus on Compliance Team activities with the DAH and indicate coordination with the Standardization Team as necessary. However, the Standardization Team will be carrying out their roles and responsibilities as well.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-52

Mod 4, Lesson 3

Introduction

Flowchart, DAH Order 8110.26-X, cont.


Fin al rule app rov ed (p rior to FR pub licat ion ) S tart

F AA S tan dard iz at ion Tea m - p ara grap h 5- 2.a. Fa m ilia riz e all C om plianc e T ea m s w ith re gulat ions , guida nc e , and expe cta tion s fo r c om plianc e p lan , a naly ses , da ta , a nd docu me nts .

1 2 3

F A A C om plianc e T ea m - paragraph 5-2 . b. Organ iz e t eam , d evelo p p lan , defin e roles & resp onsib ilities , part ic ipa te in trainin g a nd p rep ara tion ac t iv itie s .

F A A C o mplia nc e T eam - pa rag raph 5 -3 F am iliariz e a ssig ned D A H w ith reg ulat ions , guid ance , an d expe cta tion s fo r c om plianc e p lan , a naly ses , da ta , a nd docu me nts .

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The first two boxes (numbers 1 and 2 on the right) deal with activities to be done by the Standardization and Compliance Teams prior to the final DAH rule. The third box addresses the Compliance Team activity to familiarize the DAH with the rules, procedures, and expectations.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-53

Mod 4, Lesson 3

Introduction

Flowchart, DAH Order 8110.26-X, cont.


F A A C o mplia nce & S ta nda rdiz a tion T eam s - pa rag raph 5 -4 C om plia nc e Te am ov ers e es D A H d ev e lopm ent an d s ubm itta l of c om plia nc e plan . C o ord inat es w ith S tan dard iz at ion T ea m . S tand ard iz at ion T ea m ens u res s t anda rdiz atio n . D A H sub mit s c omp lianc e pla n .
D AH re vise s p lan, see para. 5-5.d

4 5
* C oord inat e w ith S t and ardiz atio n T eam .

FA A C om plian c e and S tan dardiz at ion Te ams p ara grap h 5 -5 T he Tea ms re v iew the propos ed D A H c om plian ce p lan .

Yes

A n y d efic ie nc ie s ? * No F A A C o m p lianc e T eam p ara gra ph 5-5 .c an d 5- 6

D AH revises pla n, if app rop riate para. 5-6

C om plian c e t eam a ppro v es co mplia nc e pla n an d m on itors D A H c o m plia nc e pla n im plem en tatio n . C o ordin ate s w it h S t and ardiz atio n T eam .

Yes

A ny def ic ienc ies ? * No D A H s ub mit s draft da ta and doc um e nts .

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The remaining boxes and decision points on the first page of the flowchart concern: Overseeing DAH development of the compliance plan, Approving the compliance plan, and Monitoring DAH compliance plan implementation.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-54

Mod 4, Lesson 3

Introduction

Flowchart, DAH Order 8110.26-X, cont.


7
F A A C omplianc e T eam paragraph 5-7.a . R ev iew s dra ft D A H d ata and do cum ent s , coordinates w ith S tandardization T eam . I f acceptable, notif ies D A H of decis ion.

R eso lve in tim e?


No

FAA C omp liance Team pa ragraph 5-7.a. N otifies D AH of de cisio n .


Y es

No

A c cept able ?

Yes

FAA E nfo rcem en t A ct ion R ef ere nce Ord er 215 0 .3

D A H subm its final dat a and documents .

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The top third of the second page of the flowchart centers on the draft data and documents.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-55

Mod 4, Lesson 3

Introduction

Flowchart, DAH Order 8110.26-X, cont.


8
FA A C om plian ce Team paragraph 5- 8.a .
Y es No

R ev iew s D A H final dat a and docu me nts and ap pro ves if a cce ptab le . C o ordin ate s w ith S t andardization T eam .

R esolve in time?

No

FA A a pprove d ?
Yes

D A H m ak es data and docum ents available to operato rs .

Op era tors propo se chan ges to maintenance or operation al program s

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The middle third deals with the final data and documents and approval of this material.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-56

Mod 4, Lesson 3

Introduction

Flowchart, DAH Order 8110.26-X, cont.


9
FA A Principal I nspector paragraph 6-2.e.
Yes

R eview operators proposed programs and approve if ac ceptable . C oordinat es w ith C om pliance Team if necessary .

R esolve in time?

F A A A pproved ?

Yes

A FS polic y div isions


No

No

C oordinat e c orrectiv e action .

O perator im plem ent s program change paragraph 6- 2.f.

FA A E nforcement A ct ion R eference Order 2150 .3 E nd

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And the final section of the flowchart shows the transition of data and documents to the operators and working with the FAA Principal Inspector.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-57

Mod 4, Lesson 3

Compliance Processes of Order 8110.26-X

COMPLIANCE PROCESSES OF DAH ORDER 8110.26-X


Paragraph 5-2.a and b, Preparatory Activities

Preparatory Activities
FAA Standardization Team paragraph 5-2.a.
Familiarize all Compliance Teams with regulations, guidance, and expectations for compliance plan, analyses, data, and documents

FAA Compliance Team paragraph 5-2.b.


Organize team develop plan, define roles & responsibilities, participate in training and preparation activities

Set up structured communication process & discuss expectations for how Teams work together
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The slide shows paragraphs 5-2.a and 5-2.b. They represent the activities of the Standardization and Compliance Team prior to the issuance of the final rule. This preparation involves close coordination even before the EAPAS final rule is issued.

The Standardization Team will: Discuss what key information it needs from the Compliance Teams so it can conduct the standardization activities, and Provide the Compliance Teams with standardized briefing materials to conduct familiarization briefings with the affected DAHs.

The Teams will also develop plans to carry out their roles and responsibilities. This will include participating in necessary training activities and reviewing all of the available documents on the EAPAS rulemaking initiative.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-58

Mod 4, Lesson 3

Compliance Processes of Order 8110.26-X

Paragraph 5-3, Familiarization of DAH

Familiarization of DAH
FAA Compliance Team paragraph 5-3
Familiarize assigned DAH with regulations, guidance, & expectations for compliance plan, analyses, data, & documents.

Letter to DAH
States final rule issued Identifies EAPAS contact in Oversight Office Provides regulatory references & guidance Provides training information, if appropriate Requests DAH schedule familiarization meeting with FAA
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Compliance Teams will send a letter to each affected DAH as soon as the final rule has been issued. That letter should be sent within 2 weeks after the issuance of the final rule.

Due to ex parte concerns, you may not hold the familiarization meeting before the final rule is issued. However, you may coordinate with the DAH to let them know that you will be in contact as soon as the final rule is issued to schedule a familiarization meeting.

A sample form letter will be developed by the Standardization Team and provided to all Compliance Teams. The letter will be provided once the Standardization and Compliance Teams begin preparing for the final rule issuance.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-59

Mod 4, Lesson 3

Compliance Processes of Order 8110.26-X

Familiarization of DAH, cont.


Familiarization meeting
Ensure DAH understands the rules Familiarize DAH with guidance material Establish a communication plan
Status updates Issue identification Issue resolution
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The FAA would like to have the familiarization meetings occur within a month after the issuance of the final rule to support the DAHs development of a compliance plan, which is to be submitted 90 days after the effective date of the rule.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-60

Mod 4, Lesson 3

Compliance Processes of Order 8110.26-X

Paragraphs 5-4 - 5-6, Compliance Plan Development & Approval

Compliance Plan Development & Approval


F A A C o m plia nc e & S ta nda rdiza tion T eam s - pa rag raph 5 -4 C om plia nce Te am ov erse es D A H d ev e lopm ent an d s ubm itta l of com plia nce plan . C o ord inat es w ith S tan dard iz at ion T ea m . S tand ard izat ion T ea m ensu res st anda rdiz atio n . D A H sub m it s c om p lianc e pla n .
D AH re vise s p lan, see para. 5-5.d

4 5
* C oord inat e w ith S t and ardiz atio n T eam .

FA A C om plian ce and S tan dardizat ion Te am s p ara grap h 5 -5 T he Tea ms re v iew the propos ed D A H c om plian c e p lan .

Yes

A n y d eficie nc ie s ? * No F A A C o m p lianc e T eam p ara gra ph 5-5 .c an d 5- 6

D AH revises pla n, if app rop riate para. 5-6

C om plian ce t eam a ppro v es co m plia nc e pla n an d m on itors D A H c o m plia nce pla n im plem en tatio n . C o ordin ate s w it h S t and ardiz atio n T eam .

Yes

A ny def icienc ies ? * No D A H s ub mit s draft da ta and doc ume nts .

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Paragraphs 5-4 through 5-6 focus on compliance plan development and approval activities.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-61

Mod 4, Lesson 3

Compliance Processes of Order 8110.26-X

DAH Compliance Plan Development


FAA Compliance & Standardization Team para. 5-4
Compliance Team oversees DAH development and submittal of compliance plan. Coordinates with Standardization Team. Standardization Team ensures standardization.

DAHs have 90 days from effective date of EAPAS rule to submit compliance plan for FAA approval Compliance Teams work closely with DAH and coordinate with Standardization Team, especially for compliance methods that differ from existing guidance materials
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The Compliance Team must be proactive in carrying out its oversight responsibilities and facilitating compliance.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-62

Mod 4, Lesson 3

Compliance Processes of Order 8110.26-X

DAH Compliance Plan Development, cont.


D AH re vise s p lan, see para. 5-5.d

FA A C om plian ce and S tan dardizat ion Teams p ara grap h 5 -5 T he Tea ms review the propos ed D A H com plian ce p lan .

5
* C oord inat e w ith S t and ardiz atio n T eam .

Yes

A n y d eficie ncie s? * No F A A C omp liance T eam p ara gra ph 5-5 .c an d 5- 6

D AH revises pla n, if app rop riate para. 5-6

C om plian ce t eam a ppro ves co mplia nce pla n an d m on itors D A H co mplia nce pla n im plem en tatio n . C oordin ate s w it h S t and ardiz atio n T eam .

Yes

A ny def icienc ies ? * No D A H s ub mit s draft da ta and doc ume nts .

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There is a process for recognizing and dealing with deficiencies in the compliance plan. The Compliance Team will follow the steps and milestones in the DAH Order for reviewing the plan and responding to DAH, and coordinating with the Standardization Team.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-63

Mod 4, Lesson 3

Compliance Processes of Order 8110.26-X

Communication Summary
Appendix N of Participant Guide:
Communication Schedule: Minimum Requirements For Documented Communication With DAH 1st table: Review/Approval of Compliance Plan (Ref. Order 8110.26-X chap. 5, section 5)
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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-64

Mod 4, Lesson 3

Compliance Processes of Order 8110.26-X

Review/Approval of Compliance Plan

Appendix N, Review/ Approval of Compliance Plan

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1. Preliminary review within 1 week of receipt (identify major deficiencies in the plan and contact DAH). 2. Complete review within 4 weeks of receipt (contact DAH immediately to identify deficiencies). 3. Send letter stating approval or non-approval of plan within 6 weeks of receipt. 4. If a plan is not acceptable, the DAH must submit a revised plan as soon as possible. The Compliance Team will review the revised areas of the plan and, if acceptable, will send a letter approving the plan to the DAH within 3 weeks of receipt of the revised plan.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-65

Mod 4, Lesson 3

Compliance Processes of Order 8110.26-X

DAH Compliance Plan Development


No regulatory requirements to force timely resolution of issues Compliance Teams must work with DAHs to resolve deficiencies and request FAA Oversight Office management support if quick resolution with DAH isnt possible If disagreement over plan or means of compliance, Compliance Teams raise issue to Standardization Team & Oversight Office management if quick resolution not likely
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The earlier management is aware of the potential for non-compliance, the greater the opportunity for management to take action to resolve the issues and facilitate timely compliance. In the final DAH Order, we will revise the flowchart to indicate an enforcement option if the DAHs compliance plan is not submitted by the required date.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-66

Mod 4, Lesson 3

Compliance Processes of Order 8110.26-X

Which is NOT a preparatory activity for the EAPAS DAH rule implementation?
a. Development of structured communication process between the Standardization Team and Compliance Teams b. Team members attend EAPAS rule training c. Team members review EAPAS rulemaking and guidance materials d. Compliance Teams conduct familiarization meetings with DAHs
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The Compliance Teams must work closely with DAHs during compliance plan development activities to ensure an acceptable plan will be submitted by the compliance plan due date specified in the EAPAS rule
a. True b. False
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EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Participant Guide page 4-67

Mod 4, Lesson 3

Compliance Processes of Order 8110.26-X

Paragraphs 5-6 - End of Page 1, Compliance Plan Implementation

Compliance Plan Implementation


D AH revises pla n, if app rop riate para. 5-6

No F A A C o mp liance T eam p ara gra ph 5-5 .c an d 5- 6

C om plian ce t eam a ppro v es co m plia nc e pla n an d m on itors D A H c o m plia nce pla n im plem en tatio n . C o ordin ate s w it h S t and ardiz atio n T eam .

Yes

A ny def icienc ies ? * No D A H s ub mit s draft da ta and doc ume nts .

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Once the DAHs compliance plan is approved, then the Compliance Team will actively monitor the DAHs implementation of that plan. It is expected the Compliance Team will schedule regular status reviews with the DAH to discuss the progress toward these DAH milestones. If there is no plan, or the plan is lacking, the Compliance Team must institute frequent discussions with the DAH to determine if compliance is on-track. Also, the FAA may pursue enforcement action, but the Compliance Team should continue to work with the DAH to monitor progress toward compliance. If it appears that compliance is not on track, it is important to notify the DAH of the concern as soon as possible, and within a week. These notifications should be documented.

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Mod 4, Lesson 3

Compliance Processes of Order 8110.26-X

Communication Summary
Appendix N of Participant Guide:
Communication Schedule 2nd table: Monitor Implementation of Compliance Plan (Ref. Order 8110.26-X chap. 5, section 6)

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Monitor Implementation of Compliance Plan

Appendix N, Monitor Implementation of Compliance Plan

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Mod 4, Lesson 3

Compliance Processes of Order 8110.26-X

DAH Compliance Plan Implementation


Document discussions of deficiencies or potential non-compliance Standardization Team has templates for certain types of letters that may be appropriate to send DAHs
See Appendixes G - M

Need close coordination between Teams


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Paragraph 5-7.a, Review and Approval of Draft Data and Documents

Review Draft Data/Documents


FAA Compliance Team paragraph 5-7.a
Reviews draft DAH data and documents, coordinates with Standardization Team. If acceptable, notifies DAH of decision.

26.11(e) requires DAH to submit draft data and documents at least 60 days prior to compliance date Review and communication process similar to that for compliance plan
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A formal letter is not necessary for communicating outcomes of the FAA review of draft data and documents.

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Mod 4, Lesson 3

Compliance Processes of Order 8110.26-X

Communication Summary
Appendix N of Participant Guide:
Communication Schedule 3rd table: Draft Data and Documents Submittal and Review (Ref. Order 8110.26-X chap. 5, section 7)

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Draft Data and Documents Submittal and Review

Appendix N, Draft Data and Documents Submittal and Review

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Mod 4, Lesson 3

Compliance Processes of Order 8110.26-X

Note that if draft data and/or documents are unacceptable, Compliance Team must continue to work with DAH to help ensure that deficiencies are corrected prior to the submittal of the final compliance data and documents.

Review Draft Data/Documents, cont.


Prompt Compliance Team reviews and notifications give DAH time to make needed changes prior to submitting final data and documents If issues not likely to be resolved in time, FAA may choose to initiate enforcement action per Order 2150.3A
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Review Draft Data/Documents, cont.


For project to be successful, need coordination with Standardization Team and Oversight Office management When enforcement action recommended, Standardization Team will coordinate with ANM-100 and AFS-300
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Mod 4, Lesson 3

Compliance Processes of Order 8110.26-X

Paragraph 5-8.a, Review and Approval of Final Data and Documents


Review & Approve Final Data/Documents
FAA Compliance Team paragraph 5-8.a
Reviews DAH final data and documents and approves if acceptable. Coordinates with Standardization Team.

Purpose of review to:


Determine compliance with part 26, and Verify format & content of data/ documents acceptable for operator compliance

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Mod 4, Lesson 3

Compliance Processes of Order 8110.26-X

Review & Approval of Final Data/Docs., cont. 8


Y es No

FA A C om pliance Team paragraph 5- 8.a. R ev iew s D A H final dat a and documents and approves if acceptable . C oordinates w ith S t andardization T eam .

R esolve in time?

No

FA A approved ?
Yes

D A H m ak es data and docum ents available to operators .

Operators propose changes to maintenance or operational program s

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Compliance Team actions associated with the review and approval of the final data and documents are similar to those for compliance plan and draft data and documents.

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Mod 4, Lesson 3

Compliance Processes of Order 8110.26-X

Communication Summary
Appendix N of Participant Guide:
Communication Schedule 4th table: Final Data and Documents Submittal, Review, and Approval (Ref. Order 8110.26-X, chap. 5, section 8)

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Mod 4, Lesson 3

Compliance Processes of Order 8110.26-X

Final Data and Documents Submittal, Review, and Approval

Appendix N, Final Data & Documents Submittal, Review, and Approval

118
The approval letter to DAH will be copied to Massoud Sadeghi and Stephen Slotte (ANM-117/111) and Fred Sobeck (AFS-308), and chair of the MRB so the TAD and AFS policy divisions are aware of the approval. The appropriate AEG will then alert their affected PIs of the approval. Routing Number ANM-110 ANM-110 AFS-308 AEG: varies depending on model

Name Massoud Sadeghi Stephen Slotte Fred Sobeck MRB Chairperson

Email Massoud.Sadeghi@faa.gov Steve.Slotte@faa.gov Frederick.Sobeck@faa.gov

Phone 425-227-2117 425-227-2315 202-267-7355

Fax 425-227-1320 425-227-1320 202-267-5115

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Mod 4, Lesson 3

Compliance Processes of Order 8110.26-X

The actions in this final table must be expedited to the greatest extent possible, as any delays will impact the operators ability to comply on time. Raise any issues that are not resolved quickly to management. Enforcement action may be taken as a result of deficient documents as appropriate.

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Mod 4, Lesson 3

Compliance Processes of Order 8110.26-X

If the DAH is not meeting the compliance milestones outlined in their compliance plan, the Compliance Team should
a. Work with DAHs to resolve deficiencies b. Request FAA Oversight Office management support if quick resolution is not likely c. Alert Standardization Team to deficiencies and status of resolution d. All of the above
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If the final data and documents are not acceptable, the Compliance Team must send a letter to the DAH within
a. 1 week of receipt b. 4 weeks of receipt c. 5 weeks of receipt d. 6 weeks of receipt

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Mod 4, Lesson 3

Compliance Processes of Order 8110.26-X

Paragraph 6-2.e and f, Operator Implementation of Data and Documents


Operator Use of Data/Documents
FAA Principal Inspector paragraph 6-2.e
Review operators proposed programs and approve if acceptable. Coordinates with Compliance Team if necessary.

Once data/documents are approved, DAH must make available information to support operator compliance
Done in accordance with schedule in FAA-approved compliance plan Compliance Teams should ensure DAHs complete this activity
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Operators may propose program changes that differ from the data and documents approved by the FAA, such as different inspection intervals than the those developed by the DAH. In these cases, it would be important for the Principle Investigator to work with the Compliance Team to ensure the proposal is acceptable. The need for this type of coordination is outlined in policy under development by AFS-300 for the PIs (this policy was developed in conjunction with AIR).

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Mod 4, Lesson 3

Compliance Processes of Order 8110.26-X

Operator Use of Data/Documents, cont.


9
FA A Principal I nspector paragraph 6-2.e.
Yes

R eview operators propo sed programs and approve if ac ceptable . C oordinat es w ith C om pliance Team if necessary .

R esolve in time?

F A A A pproved ?

Yes

A FS polic y div isions


No

No

C oordinat e c orrectiv e a ction .

O perator im plem ent s program change paragraph 6- 2.f.

FA A E nforcement A ct ion R eference Order 2150 .3 E nd

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These boxes show the AFS/PI activity to work with operators to ensure they have complied with the related operational rules by their compliance date. If not, AFS will take appropriate enforcement action.

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Mod 4, Lesson 3

Lesson 3 Summary

LESSON 3 SUMMARY

Lesson 3 Summary
Flowchart processes include
Approval of compliance plan Resolution of deficiencies Monitoring compliance plan implementation by the DAH Review and approval of data and documents
No

Final rule approved (prior to FR publication )

Start

FAA Standardization Team - paragraph 5- 2.a. Familiarize all C omplianc e Teams with regulations , guidance , and expectations for c om plianc e plan , analy ses , data , and documents .

FAA C omplianc e Team - paragraph 5-2.b. Organize team , develop plan , define roles & responsibilities , participate in training and preparation act ivities .

FAA Compliance Team - paragraph 5-3 Fam iliariz e assigned DAH with regulations , guidance , and expectations for c om plianc e plan , analy ses , data , and documents .

FAA Compliance & Standardization Teams - paragraph 5-4 Compliance Team ov ersees DAH development and s ubmittal of compliance plan . Coordinates w ith Standardization Team . Standardization Team ensures standardiz ation . DAH submits c ompliance plan.
DAH revises plan, see para. 5-5.d

FAA Compliance and Standardization Teams paragraph 5 -5 The Teams review the propos ed DAH compliance plan .

Yes

Any deficiencies? * No FAA Compliance Team paragraph 5-5 .c and 5-6

* C oordinate with Standardiz ation Team .

DAH revises plan, if appropriate para. 5-6

C ompliance team approves compliance plan and monitors DAH compliance plan im plementation . Coordinates w ith St andardiz ation Team .

Yes

Any deficienc ies ?* No DAH submits draft data and documents .


Continued C o n tin ue d fro m p re v io u s on next p ag e page

F A A C omp lianc e T eam par agra ph 5 - 7 .a . R ev ie w s dra ft D A H d ata and do c um ent s , c o ord inate s w ith S ta ndar diz a tion T eam . I f a c c ep tab le , notif ies D A H o f d ec is ion.

R e s o lve in ti m e ?
No

F AA C o m p lia n c e Te a m p a ra g ra p h 5 -7.a. N o tifie s D A H o f d e cisio n .


Y es

No

A c c ept able ?

Ye s

FAA E nfo rc em en t A c t ion R ef ere nc e O rd er 215 0 .3


Y es

D A H s u bm its final dat a a nd d oc u m e nts .

FA A C om plian c e Tea m pa ragraph 5- 8.a . R ev iew s D A H fina l dat a a nd doc u m e nts and ap pro v es if a c c e ptab le . C o ordin ate s w ith S t and ard iz atio n T ea m .

R e so lv e in tim e?

No

FA A a ppr ove d ?
Ye s

D A H m ak es data an d d oc um en ts av aila ble to oper ato rs .

O p era tors propo s e c han ges to m a inte nan c e o r o per ation al p rog ram s

FA A Princ ip al I nspe c to r para gra ph 6-2 .e.


Yes

R ev ie w op era tors propo sed pro gra ms and ap pro v e if ac c ep tab le . C o ord inat es w ith C om plian c e Tea m if n ece s s ary .

R e so l ve in tim e?

F A A A pp rove d ?

Ye s

A FS polic y d iv is ion s
No

No

C oordinat e c orrec tiv e a ctio n .

O pera tor im plem ent s program c ha nge p ara grap h 6- 2.f.

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R e fere nc e O rder 2 150 .3

E nd

123

Lesson 3 Summary, cont.


Flowchart processes rely on
Close and frequent communication between Standardization Team and Compliance Teams and between Compliance Teams and DAH Accurate understanding of DAH compliance status Prompt issue identification and resolution Documentation of discussions related to issues potentially affecting compliance

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Mod 4, Lesson 3

Lesson 3 Summary

Lesson 3 Summary, cont.


Necessary FAA review, approval and response times needed to support DAH compliance activities (summary chart in Appendix N of Participant Guide)
Response times needed to support timely DAH compliance so operators have timely, acceptable, data and documents to support their compliance with the operational rules

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Module 4

Summary for Module 4

SUMMARY FOR MODULE 4

Module 4 Summary
DAH rule - timely implementation of ops rules of EAPAS safety initiative Standardization & Compliance Teams support implementation of EAPAS DAH rule Order 8110.26-X & AC 26-XX processes to facilitate DAH compliance to part 26 rules
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Module 4 Summary, cont.


Implementation strategy will
Involve a structured, proactive project management approach Ensure early awareness of risks to acceptable compliance and Allow FAA to facilitate resolution of issues to ensure on-time compliance
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Module 4

Summary for Module 4

Module 4 Summary, cont.


Compliance Teams will need to
Work closely with Standardization Team and DAHs throughout process Coordinate handling of compliance plan or implementation deficiencies with Standardization Team Document communication with DAHs regarding potential compliance issues
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Module 4 Summary, cont.


Most critical factors for success
Regular communication among FAA teams and DAH Proactive behavior
Standardization Team train Compliance Teams & support their work with DAHs Compliance Teams work closely with DAHs and keep Standardization Team updated

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Module 4

Summary for Module 4

EAPAS Standardization Team


Massoud Sadeghi, Sadeghi ANM-117 Stephen Slotte, Slotte ANM-111 Fred Sobeck, Sobeck AFS-308

Meghan Gordon, Gordon ANM-113 Shahram Dareshmandi, Dareshmandi ANM-116

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When in doubt, contact the Standardization Team promptly!

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PARTICIPANT GUIDE
Version 1.1 Note: The information contained in this Participant Guide is presented by the instructors through captioned video and audio. A transcript of the captioning is also available with each with each video segment.

MODULE 5: EAPAS IVT SUMMARY

EAPAS IVT SUMMARY ..........................................................................1 EAPAS IVT Concluding Comments....................................................1

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Module 5, Summary

EAPAS IVT Summary

MODULE 5: EAPAS IVT SUMMARY


EAPAS/FTS: Training for Part 26 DAH Requirements
Module 5: EAPAS IVT Summary
Federal Aviation Administration

Course Number: 24910 Course Manager: Massoud Sadeghi Version Date: May, 2007 Version Number: 1.0

EAPAS IVT SUMMARY


EAPAS IVT Concluding Comments

From IVT, Remember


Traditional ways of designing, installing, and maintaining EWIS no longer work Electrical wires and associated components need to be treated as a system
2

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Module 5, Summary

EAPAS IVT Summary

Change due to

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Influence of accidents, investigations, and follow-on recommendations from the collaboration of the FAA, industry, and others.

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Module 5, Summary

EAPAS IVT Summary

It All Resulted In
1. Development of enhancements in EWIS design, certification, installation, maintenance requirements, and new technologies 2. FAA EAPAS rulemaking package: enhanced and new requirements and guidance material for design and operational rules
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EAPAS

EAPAS rulemaking package contains: Revisions of existing EWIS-related requirements, Additions of enhanced EWIS requirements, Adoption of new continued airworthiness requirements for EWIS, New design approval holder requirements, and Requirements for operators to include new EWIS maintenance instructions into their maintenance or inspection programs.

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Module 5, Summary

EAPAS IVT Summary

For New 14 CFR Part 26


Who has to comply? 26.11(a)
Transport category, turbine-powered airplanes with a TC that meet certain passenger and payload criteria

And what do they have to do? 26.11(b)


Develop ICA for representative airplanes EWIS [Appendix H 25.5(a)(1) & (b)] & submit to FAA Oversight Office for approval
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AC 120-XX Flowchart for Developing EWIS ICA Using an EZAP


Ensure EWIS ICA compatible with SFAR 88 ICA & minimizes redundancies DAH required to produce source doc. containing EWIS ICA or references DAH-develops EWIS ICA data & docs. that you review
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Module 5, Summary

EAPAS IVT Summary

FAA Oversight Office Approval Role


1.Approval of EWIS ICA
Supports EAPAS program objectives of increasing awareness of the safety impact EWIS can have by changing
Minimum safety & maintenance standards, How FAA approaches and views effect that improperly maintained EWIS can have on safe operation of transport airplanes
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FAA Oversight Office Approval Role


2. FAA approval
Ensures that DAH data are appropriate for the operators and support operators ability to comply with operational requirements

P EA

AS

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Module 5, Summary

EAPAS IVT Summary

Major Difference Between Past and New Practices


FAAs mandate for continued airworthiness of the fleet is driving the schedule, not the DAHs timeline
Requires DAHs support to help operators in their implementation of safety actions

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Roles and Responsibilities


Key players:
Standardization Team Compliance Teams DAH

Need for cooperative working among all groups

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Module 5, Summary

EAPAS IVT Summary

Roles and Responsibilities


Standardization Team for EAPAS:
Massoud Sadeghi,
ANM-117 *

Meghan Gordon, Gordon


ANM-113

Stephen Slotte, Slotte


ANM-111 * AFS-308 *

Shahram Dareshmandi, Dareshmandi


ANM-116

Fred Sobeck, Sobeck

Technical focals and authors of EAPAS airworthiness & ops rules & guidance materials
Federal Aviation Administration

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Contact Information for the Technical Focals of the EAPAS Standardization Team Name
Massoud Sadeghi Stephen Slotte Fred Sobeck MRB Chairperson

Routing Number
ANM-110 ANM-110 AFS-308 AEG: varies depending on model

Email
Massoud.Sadeghi@faa.gov Steve.Slotte@faa.gov Frederick.Sobeck@faa.gov

Phone
425-227-2117 425-227-2315 202-267-7355

Fax
425-227-1320 425-227-1320 202-267-5115

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Module 5, Summary

EAPAS IVT Summary

Roles and Responsibilities


Compliance Teams:
Work with DAHs Monitor and support DAHs development of EWIS ICA and other documents Coordinate issue resolution and team actions with Standardization Team

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Keys for Success for Standardization & Compliance Teams


Proactive vs. reactive coordination
Standardization Team provides program management oversight Compliance Teams provide project management oversight

Coordination between FAA Teams expected to be structured & frequent


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Module 5, Summary

EAPAS IVT Summary

Roles and Responsibilities


DAH:
Creates & follows compliance plan Provides data & documents for review & approval by Compliance team Makes appropriate data, in a form readily useable by operators, available to support operators compliance with the operational rules
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To Facilitate Timely Compliance


Part 26 DAH Rules rely on
Program management mechanisms (compliance plan), and Processes (flowchart from DAH Order 8110.26-X)

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Module 5, Summary

EAPAS IVT Summary

Culture Shift: EAPAS Safety Initiative


Existing fleet will meet part 26 regs. New applicants will comply with part 25 The critical element is recognizing the importance of wiring systems in the safe operation of airplanes
In order to support this recognition, the FAA needs to be more proactive Requires a culture shift in three areas
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Requires Culture Shift in 3 Areas


1. Treat wiring as a system
New wiring system certification and continuing airworthiness requirements

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EAPAS IVT Summary

Requires Culture Shift in 3 Areas


2. Mandating DAH support of the initiative
New processes, roles, and responsibilities with specific deadlines Proactive involvement of ACO engineers will help ensure success Relies heavily on regular communication between affected parties
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Requires Culture Shift in 3 Areas


3. Integration of FAA lines of business: joint AFS/AIR activity; and integration of work with DAHs and operators
With implementation of part 26, AEG and ACO working together from beginning of projects Relies heavily on regular communication between affected parties
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Module 5, Summary

EAPAS IVT Summary

20
There will be follow-on training for part 25 rule changes. Flight Standards Division will provide additional training for implementation of the operational rules.

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Module 5, Summary

EAPAS IVT Summary

Fred, Massoud, and Stephen Thank the Following for Their Great Support & Help in Developing This Training!
Doug Anderson Ali Bahrami Angelique Berry Kay Christiansen Steve Edgar Nedra Loveridge
EAPAS IVT, Course 24910, Mod 5

Diane Pagel Dionne Palermo Dan Poblete Brett Portwood Margie Sanders Mike Zielinski
Federal Aviation Administration

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EAPAS: Part 26 DAH

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VERSION 1.1

Note: The information contained in this Participant Guide is presented by the instructors through captioned video and audio. A transcript of the captioning is also available with each with each video segment.

EAPAS APPENDIX

A: B: C: D E: F: G: H: I: J: K: L: M: N: O:

Definitions and Acronyms ........................................................1 Additional ATSRAC Background Information...........................8 List of Final EWIS 14 CFR Regulations .................................15 EWIS Advisory Circulars........................................................19 14 CFR Part 26.11 Rule and Part 25 Appendix H..................20 Worksheets from AC 120-XX to Record Responses to the Flowchart ..................................................24 No Plan Submitted Template .................................................30 Unacceptable Plan Template.................................................31 Unacceptable Implementation Template (Approved Plan).....................................................................32 Unacceptable Implementation Template (No Approved Plan) ...............................................................33 Unacceptable Draft Template ................................................34 No Drafts Submitted Template...............................................35 Sample Letters of Investigation..............................................36 Communication Schedule: Minimum Requirements For Documented Communication With DAH .........................38 EWIS Part 26 Sample Compliance Plan ................................41

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Appendix-i

EAPAS

Appendix A: Definitions and Acronyms

Appendix A Definitions and Acronyms


AASR. Aging Airplane Safety Rule. Aircraft Evaluation Group (AEG). Flight Standards Service representatives who know the operational and maintenance aspects of the certification project and are responsible for determining the operational acceptability and continuing airworthiness requirements of newly certified or modified aircraft, engines, and propellers intended to be operated under the provisions of the CFR. This function includes providing the cognizant ACO support in the review and approval of the initial and subsequent changes to the type design. Arc tracking. A phenomenon in which a conductive carbon path forms across an insulating surface. This carbon provides a short circuit path through which current can flow. Arc tracking is normally a result of electrical arcing. Also referred to as "carbon arc tracking," "wet arc tracking," or "dry arc tracking." Aircraft Zones. Generally identified by actual physical boundaries, such as wing spars, major bulkheads, cabin floor, control surface boundaries, skin, and include access provisions for each zone. ALS. Airworthiness Limitation Section. Civil Aviation Authority (CAA). The aviation organization or organizations authority given jurisdiction by an ICAO State of Design with which the U.S. has an agreement for the certification and continued airworthiness of those airplanes having U.S. type certificate. Combustible. refers to the ability of any solid, liquid, or gaseous material to cause a fire to be sustained after removal of the ignition source. The term is used in place of inflammable/flammable. It should not be interpreted as identifying material that will burn when subjected to a continuous source of heat as occurs when a fire develops. Compliance Plan Elements. See 14 CFR 26.11(e). Additional items that are good practice to have are in AC 26-XX and Order 8110.26-X.

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Appendix-1

EAPAS

Appendix A: Definitions and Acronyms

Compliance Teams. Composed of representatives from the FAA Oversight Office; that is, the ACO or TAD office with responsibility for the relevant TC or STC and representatives from affected Aircraft Evaluation Group offices. Main focus is with DAHs: familiarizing them with the new rules and guidance materials, monitoring their progress, reviewing and approving data and documents, and providing status updates and coordination of issues with the Standardization Team. Part of the FAA Oversight Office. Contamination. For the purposes of this AC, wiring contamination refers to either of the following: Presence of a foreign material likely to cause degradation of wiring. Presence of a foreign material that is combustible, or capable of sustaining a fire after removal of ignition source. Continued Airworthiness. Certified aircraft, engines, propellers, and appliances are safe to operate for the intended purpose; they are maintained safely throughout their service life; the product meets its type design and is in a condition for safe operation. Design Approval Holder (DAH). The holder of any design approval, including TC, amended TC, STC, amended STC, parts manufacturer approval, TSO authorization, letter of TSO design approval, and field approvals. DAH can be an airplane manufacturer or an operator if they hold design approvals. Required to create, submit to FAA for approval, and implement a compliance plan. Also must submit draft and final data and documents for FAA approval. Makes data and documents available to affected operators. Detailed Inspection (DET). An intensive examination of a specific item, installation, or assembly to detect damage, failure, or irregularity. Available lighting is normally supplemented with a direct source of good lighting at an intensity deemed appropriate. Inspection aids such as mirrors, magnifying lenses, or other means may be necessary. Surface cleaning and elaborate access procedures may be required. May include tactile assessment in which a component or assembly is checked for tightness/security. This is of particular significance when identifying applicable and effective tasks to ensure the continued integrity of installations such as bonding jumpers, terminal connectors, etc.

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Appendix-2

EAPAS

Appendix A: Definitions and Acronyms

Effective Task/Task Interval. An inspection or maintenance task, performed at defined intervals, that will ensure that the desired outcome of the task is achieved. To be effective the task must reduce the risk of wire failure, to ensure safe operation. For example, a cleaning task to remove contaminants that have accumulated on a wire bundle would be considered effective if it cleaned the bundle sufficiently to minimize the potential of contaminantinduced failure of the bundle, and allow an inspection for wire defects to be performed. The methods and intervals for performing an effective task are developed using a combination of standard industry practices, expert opinion, and engineering judgment from operators, manufacturers, and regulatory authorities. The document ATA MSG-3 Operator/Manufacturer Scheduled Maintenance Development, discusses the various criteria for the effectiveness of a task based on safety and operational and economic considerations. Refer to Table 2-3-7.1 Criteria for Task Selection of that document for further information. Electrical wiring interconnection system (EWIS). Any wire, wiring device, or combination of these, including termination devices, installed in any area of the airplane for the purpose of transmitting electrical energy between two or more intended termination points. See 25.1701 for full definition. Wiring and its associated components are now being treated as a system. Enhanced Airworthiness Program for Airplane Systems (EAPAS). Goal is to enhance safety by addressing electrical wiring system deterioration and wire contamination. Designed to enhance current airplane systems airworthiness programs at operator facilities, repair stations, and manufacturing plants, including improving design, installation, certification, maintenance, and training requirements for aircraft electrical wiring. See Module 2, Lesson 1 of EAPAS IVT for details on how EAPAS history. TWA 800 accident in 1996 was the impetus, and subsequent recommendations by the Aging Transport Systems Rulemaking Committee (ATSRAC). There are 73 new, revised, renumbered certification and operational requirements, and 12 new Advisory Circulars in the EAPAS/FTS rulemaking package. New approach is analytical, multilayered, and proactive.

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Appendix-3

EAPAS

Appendix A: Definitions and Acronyms

Enhanced zonal analysis procedure (EZAP). An analytical procedures that identifies the physical and environmental conditions contained in each zone of an airplane, analyzes the effects of the conditions on electrical wiring and components, and assesses the possibilities for smoke and fire. See AC 120-XX. Used to develop EWIS ICA. From the EZAP, maintenance tasks can be developed to prevent ignition sources and minimize the possibilities for combustion by minimizing accumulation of combustible materials. FAA Oversight Office. The aircraft certification office or office of the Transport Airplane Directorate with oversight responsibility for the relevant TC or STC, as determined by the Administrator. Flight Standards Service Offices. Offices located in FAA headquarters responsible for developing guidance and policy applicable to transport category airplanes for AEG personnel and AFS field personnel (airworthiness and operations Aviation Safety Inspectors) in the conduct of their responsibilities. Fuel Tank Safety (FTS). Rulemaking, including SFAR 88, resulted from TWA 800 accident and resulting NTSB recommendations. Addresses fuel tank wiring concerns and flammability issues. SFAR 88 includes maintenance actions and design changes.

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EAPAS

Appendix A: Definitions and Acronyms

General Visual Inspection (GVI). A visual examination of an interior or exterior area, installation, or assembly to detect obvious damage, failure, or irregularity. This level of inspection is made from within touching distance unless otherwise specified. A mirror may be necessary to enhance visual access to all exposed surfaces in the inspection area. This level of inspection is made under normally available lighting conditions such as daylight, hangar lighting, flashlight, or droplight and may require removal or opening of access panels or doors. Stands, ladders, or platforms may be required to gain proximity to the area being checked. When performing a GVI, there is usually no need to remove equipment or displace wire unless the access instructions specifically call for it. The area to be inspected should be clean enough to minimize the possibility that collected dirt or grease might hide unsatisfactory conditions that would otherwise be obvious. For any cleaning considered necessary, you should use the airplane manufacturers procedures or other equivalent methods, techniques, and practices acceptable to the FAA. The cleaning process itself should not compromise the integrity of EWIS. In general, the person performing a GVI is expected to identify degradation from wear, vibration, moisture, contamination, excessive heat, aging, etc.

Instructions for Continued Airworthiness (ICA). The information developed in accordance with applicable airworthiness requirements that includes the applicable methods, inspections, processes, procedures, and airworthiness limitations to keep the product airworthy throughout its operational life. Ref. 14 CFR 26.11(e). Maintenance Instructions. Information that includes recommended periods for cleaning, inspection, adjustment, testing, lubrication, degree of inspection, applicable wear tolerances, and recommended work necessary for each part of the airplane and its engine auxiliary power units, propellers, accessories, instruments, and equipment to provide for continued airworthiness of the airplane. Recommended overhaul periods and necessary cross-references to the Airworthiness Limitations section of the maintenance manual are also included. (See Appendix A of AC 26-XX for additional information.) MRB. Maintenance Review Board.

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Appendix A: Definitions and Acronyms

Maintenance Review Board Report. This report is intended for use by air carriers and contains the initial minimum scheduled maintenance and inspection requirements for a particular transport category aircraft and onwing engine program. Air carriers use the MRB report, and its associated requirements, to develop maintenance programs. See AC 121-22A, Maintenance Review Board Procedures, for additional information. Operator. Person who uses, or is authorized to use, aircraft for air navigation, including piloting the aircraft. PI. Principle Inspector (this may include any or all of the affected Airworthiness or Operations). Products. Products are certified aircraft, aircraft engines, or propellers. Stand-Alone GVI. A general visual inspection, which is not performed as part of a zonal inspection. Even in cases where the interval coincides with the zonal inspection, the stand-alone GVI remains an independent step on the work card. Standardization Team. Composed of representatives from the Transport Standards Staff, including the international and standardization branch offices and representatives from the AFS policy division. Interfaces with all Compliance Teams, other civil aviation authorities, and affected DAHs implementing new EWIS ICA rules. Serves as a resource for technical requirements of the rules and compliance methodology to help ensure rules and guidance materials are applied in a standardized way. Communicates with and assists Compliance Teams and other civil aviation authorities, and keeps management informed of issues and compliance status. TAD. Transport Airplane Directorate. TSO. Technical Standard Order.

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Appendix A: Definitions and Acronyms

Zone Density. Refers to the density of installed equipment, including wiring and other EWIS components, within a zone. It is assessed in relation to the size of the zone and for the purposes of the EZAP analysis is identified as low, medium, or high. Zonal Inspection. A collective term comprising selected general visual inspections and visual checks that are applied to each zone of the airplane, defined by access and area, to check system and powerplant installations and structure for security and general condition. A zonal inspection is essentially a GVI of an area or zone to detect obvious unsatisfactory conditions and discrepancies. Unlike a stand-alone GVI, it is not directed to any specified component or assembly. Zone Size. Based on comparing all the zones in a given airplane model and assessing them in relation to each other. For purposes of the EZAP analysis, zone sizes are identified as small, medium, or large.

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Appendix-7

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Appendix B: Additional ATSRAC Information

Appendix B Additional ATSRAC Background Information


ATSRAC Recommendations, Phase I
ATSRAC Recommendations, Phase I
Inspect Sampling of the Fleet Design & Operational Enhancements Design & Operational Enhancements EZAP Standard Format and Content for SWPM New Criteria for EWIS Training 7

Review Fleet Service History

Improve Maintenance Criteria

Review and Update Standard Wiring Practices Manual Review Air Carrier & Repair Station Inspection & Repair Training Programs
EAPAS IVT, Course 24910, Mod 2, Les 1

Federal Aviation Administration

In Phase I, ATSRAC formed five different Harmonization Working Groups (HWG).. Harmonization was the term selected because the work was conducted with the participation and support of the JAA/EASA and TCCA, and all agreed that recommendations would be fully embraced by the FAA, JAA/EASA, and TCCA. Each rectangle on the left of the slide represents an HWG. The rectangles on the right of the slide show the main deliverable that came out of the Working Groups efforts. The first HWG was tasked to inspect electrical wiring on sample airplanes representative of the aging fleet. This HWG completed its task and developed recommendations for enhancements in the design and operation of airplane wiring. The second group also identified enhancements for design and operation of airplane wiring, however instead of inspecting representative airplanes, they reviewed the fleet service history. The third HWG was tasked to identify issues in the maintenance of airplane electrical wiring. This effort resulted in the enhanced zonal analysis procedure (EZAP). The fourth Working Group worked on the Standard Wiring Practices Manual (SWPM). This resulted in standardizing the format and content of SWPM. The review of training for personnel working on and around the airplane electrical wiring by the fifth HWG lead to new criteria for electrical wiring interconnection systems training.

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Appendix B: Additional ATSRAC Information

Large transport airplane inspections.


As part of Phase I, the group that inspected a representative sample of the fleet looked at large transport airplanes. Later, as part of Phase II, similar inspections were performed on small transport airplanes. The non-intrusive inspections of electrical wiring on 81 large airplanes, all over 20 years old, included looking at the DC-8,9,10, Boeing 727,37,47, Lockheed L1011, and Airbus A300. Findings were defined as significant if the condition found was a potential hazard requiring redesign, or if the condition was found frequently at a specific location. Minor discrepancies not requiring fleet action were also noted. Of the 81 large airplanes inspected, on average 40 wire discrepancies were found on each plane. These discrepancies ranged from nicks, to charred wire, to improper clamping, to improper installation of the bundle. Significant findings were generally repeat occurrences of a given problem at a given location. For instance, if the same wire bundle was chaffed in the same location in several of the airplanes inspected, the event was judged significant. The inspection found an average of 2 significant items per plane inspected. There were no immediate safety concerns identified during the inspections and no new ADs were generated due to the inspections. However, 23 ADs were generated as a result of a review of existing ADs and service bulletins. Any service bulletins that were determined would rise to alert status were made ADs.

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Appendix B: Additional ATSRAC Information

Small transport airplane inspections.


The HWG also looked at 39 small transport airplanes. Models inspected included ones from Bombardier, Cessna, and Raytheon. The same definitions of findings were used as with the large airplanes, although there were some differences, too. Because the small transport planes were looked at after the large ones, some lessons learned from previous inspections were used. Also more stringent finding criteria were used. And finally, the FAA provided training for inspectors of the small aircraft, but not for large. So of the 39 small transport airplanes inspected, there was an average of 58 findings per plane, 1.9 of which were significant. Most of the findings were related to lint buildup on wire bundles, minor chafes, liquid contamination, loose clamps, etc. As with the large airplanes, significant findings were generally repeat occurrences of a given problem at a given location. Inspections didnt find any immediate safety concerns, and no further ADs were issued after subsequent studies of existing ADs and service bulletins.

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Appendix B: Additional ATSRAC Information

The Phase I Harmonization Working Groups completed their tasks and the reports were approved by ATSRAC and submitted to the FAA in January 2001. FAA tasked ATSRAC to begin development, in Phase II, of the necessary rulemaking recommendations to completely and properly address the issues identified in Phase I.

ATSRAC Recommendations, Phase II


ATSRAC Recommendations, Phase II
Enhance Electrical Wiring Design Requirements Enhance Standard Electrical Wiring Practices Manual Enhance Electrical Wiring Training Enhance Electrical Wiring Maint. (EZAP, clean-as-u-go) Assess Applicability of 6-9 to Small Transport Airplanes
EAPAS IVT, Course 24910, Mod 2, Les 1

Proposed Rulemaking + Advisory Circular Proposed Rulemaking + Advisory Circular

Advisory Circular

Proposed Rulemaking + Advisory Circular Means of Compliance under consideration

Federal Aviation Administration

17

In Phase II, ATSRAC formed another five Harmonization Working Groups to develop enhancements based on the recommendations developed in Phase I and to make recommendations to the FAA for rulemaking. The first HWG focused on developing enhancements to the wiring design regulations and developing associated advisory circulars. Another HWG focused on developing enhancements to the Standards Wiring Practice Manual that led to rulemaking and an advisory circular. Two more advisory circulars came out of the next two Working Groups. One group focused on enhanced training criteria in an advisory circular, and the other focused on developing enhanced maintenance procedures for airplane electrical wiring. Then, based on an NTSB recommendation, a final HWG was formed in Phase II to assess the applicability of all of the developed enhancements to the electrical wiring on small transport airplanes. Phase II Status: These tasks were completed and the reports were approved by ATSRAC in January 2003.

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Appendix B: Additional ATSRAC Information

ATSRAC Recommendations, Phase III


ATSRAC Recommendations, Phase III
To Promote Efficient Rulemaking, Provide Technical & Economic Data, Assist Disposition NPRM Comments
New Recommendations

Assist in Developing Strategies to Implement and Transfer New Technologies for EWIS

New Recommendations

Identify and Develop Criteria for Upgrading/ Developing Enhanced Wiring on Small Transport Airplanes

New Recommendations

EAPAS IVT, Course 24910, Mod 2, Les 1

Federal Aviation Administration

18

And for the final phase, Phase III, after developing and recommending rulemaking enhancements to the FAA, the FAA tasked ATSRAC with the three major tasks shown on the slide. First to promote efficient rulemaking, provide technical & economic data, assist disposition NPRM comments, Second to assist in developing strategies to implement and transfer new technologies for EWIS; And third, to identify and develop criteria for upgrading and/or developing enhanced wiring on small transport airplanes. Phase III Status: These tasks were completed in January 2005.

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Appendix B: Additional ATSRAC Information

Technology Development
The following information is on the major EAPAS-related research and developments. Some of the research and development is on-going, while other efforts have been completed and are enhancing mitigation of the aging issues in aircraft wiring today.

General Information on Technology Development


In addition to the revised and new regulations, the FAA, jointly with industry and DoD, has actively been involved in developing new prognostic and diagnostic tools and techniques to effectively and efficiently mitigate aging issues in the electrical wiring on aircraft. The following are the major electrical wiring R&D projects in which the FAA is involved: Development of new technologies for wire testing/inspection (NDI). Development of wire separation/segregation requirements. Development of wire performance requirements. Study of effects of related and unrelated maintenance on wiring. Development of arc fault circuit breakers.

Arc Fault Circuit Breakers


Single phase development is completed for arc fault circuit breakers (AFCB), and arc fault circuit breaker devices are now available commercially. A Supplemental Type Certificate has been issued for a Delta 737 aircraft. The SAE Arc Fault Specification has been completed, AS5692, and there is major industry acceptance of this technology. A solid state 28vdc and 3-phase prototype completed. Flight testing began in summer 2006. Arc fault devices have flown over 200,000 hours without a nuisance tripping incident.

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Appendix B: Additional ATSRAC Information

Major AFCB Accomplishments, cont.


White ring turns to red

Normal overload indication


EAPAS IVT, Course 24910, Mod 2, Les 1 Federal Aviation Administration

Arc fault indication


45

The circuit breaker on the left shows the normal overload indication of a white ring, which is the fault detected by the conventional fault detection part of the arc fault detection. On the right, the arc fault is visually indicated by the red ring.

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Appendix C: Final EWIS Regulations

Appendix C List of Final EWIS 14 CFR Regulations


Part 1Definitions And Abbreviations 1.2 Abbreviations and symbols

Part 21Certification Procedures For Products And Parts 21.4 Continued airworthiness and safety improvements for transport category airplanes. Designation of applicable regulations Type design. Instructions for continued airworthiness and manufacturer's maintenance manuals having airworthiness limitations sections. Designation of applicable regulations.

Subpart BType Certification 21.17 21.31 21.50

Subpart DChanges to Type Certificates 21.101

PART 25Airworthiness Standards: Transport Category Airplanes Subpart D Design and Construction 25.611 25.855 Accessibility provisions. Cargo or baggage compartments.

Subpart E Powerplant 25.869 Fire protection: systems. 25.899 Electrical bonding and protection against static electricity. 25.1203 Fire detector system. Subpart F Equipment 25.1301 25.1309 25.1310 25.1353 25.1357 25.1360 25.1362 25.1365 Function and installation. Equipment, systems, and installations. Power source capacity and distribution. Electrical equipment and installations. Circuit protective devices. Precautions against injury. Electrical supplies for emergency conditions. Electrical appliances, motors, and transformers.

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Appendix C: Final EWIS Regulations

Subpart HElectrical Wiring Interconnection Systems (EWIS) 25.1701 25.1703 25.1705 25.1707 25.1709 25.1711 25.1713 25.1715 25.1717 25.1719 25.1721 25.1723 25.1725 25.1727 25.1729 25.1731 25.1733 Definition. Function and installation: EWIS. Systems and Functions: EWIS. System separation: EWIS. System safety: EWIS. Component identification: EWIS. Fire protection: EWIS. Electrical bonding and protection against static electricity: EWIS. Circuit protective devices: EWIS. Accessibility provisions: EWIS. Protection of EWIS. Flammable fluid fire protection: EWIS. Powerplants: EWIS. Flammable fluid shutoff means: EWIS. Instructions for Continued Airworthiness: EWIS. Powerplant and APU fire detector system: EWIS. Fire detector systems, general: EWIS.

Appendix H to Part 25Instructions for Continued Airworthiness H25.1 H25.4 H25.5 General. Airworthiness Limitations section. Electrical Wiring Interconnection System (EWIS) Instructions for Continued Airworthiness.

Part 26Continued Airworthiness And Safety Improvements For Transport Category Airplanes Subpart AGeneral 26.1 26.3 26.5 26.11 Purpose and scope Definitions Applicability Table Electrical wiring interconnection systems (EWIS) maintenance program

Subpart BEnhanced Airworthiness Program for Aging Systems

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Appendix C: Final EWIS Regulations

Part 91General Operating And Flight Rules 91.1 91.1501 91.1503 91.1505 91.1507 91.1505 91.410 Applicability. Purpose and definition. [Reserved] [Reserved] Fuel tank system inspection program. Repairs assessment for pressurized fuselages. [Reserved] Subpart LContinued Airworthiness and Safety Improvements

Part 121Operating Requirements: Domestic, Flag, And Supplemental Operations 121.1 Applicability Subpart AAContinued Airworthiness And Safety Improvements 121.1101 Purpose and definition. 121.1111 Electrical wiring interconnection systems (EWIS) maintenance program. 121.1113 Fuel tank system maintenance program. 121.368 [Reserved] 121.1107 Repairs assessment for pressurized fuselages. 121.370 [Reserved] 121.370a [Reserved] Part 125Certification And Operations: Airplanes Having A Seating Capacity Of 20 Or More Passengers Or A Maximum Payload Capacity Of 6,000 Pounds Or More; And Rules Governing Persons On Board Such Aircraft 125.1 125.501 125.503 125.505 125.507 125.505 125.248 Applicability. Purpose and definition. [Reserved] [Reserved] Fuel tank system inspection program. Repairs assessment for pressurized fuselages. [Reserved] Subpart MContinued Airworthiness and Safety Improvements

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Appendix C: Final EWIS Regulations

Part 129Operations: Foreign Air Carriers And Foreign Operators Of U.S.Registered Aircraft Engaged In Common Carriage Subpart AGeneral 129.1 129.101 129.103 129.105 129.107 129.109 129.111 Applicability and definitions. Subpart BContinued Airworthiness and Safety Improvements Purpose and definition. [Reserved] [Redesignated from 129.33] [Redesignated from 129.32] [Redesignated from 129.16] Electrical wiring interconnection systems (EWIS) maintenance program. 129.113 Fuel tank system maintenance program.

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Appendix D: EWIS Advisory Circulars

Appendix D EWIS Advisory Circulars


AC 25.869-1 AC 25.899-1 AC 25.1353-1 AC 25.1357-1X AC 25.1360-1X AC 25.1362-1X AC 25.1365-1X AC 26-XX Part 26 AC 25-YY AC 120-XX AC 120-YY AC 25.17XX Fire Protection Systems Electrical bonding and Protection Against Static Electricity Electrical Equipment and Installations Circuit Protective Devices Protection Against Injury Electrical Supplies for Emergency Conditions Electrical Appliances, Motors, and Transformers Continued Airworthiness and Safety Improvements Development of Standard Wiring Practices Documentation Program to Enhance Transport Category Airplane Electrical Wiring Interconnection System Maintenance Aircraft Electrical Wiring Interconnection Systems Training Program Certification of Electrical Wiring Interconnection Systems on Transport Category Airplanes

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Appendix E: 26.11 and 25 H5

Appendix E 14 CFR Part 26.11 Rule and Part 25 Appendix H


Subpart BEnhanced Airworthiness Program for Aging Systems 26.11 Electrical wiring interconnection systems (EWIS) maintenance program (a) Except as provided in paragraph (f) of this section, this section applies to transport category, turbine-powered airplanes with a type certificate issued after January 1, 1958, that, as a result of the original certification, or later increase in capacity, have (1) A maximum type-certificated passenger capacity of 30 or more or (2) A maximum payload capacity of 7,500 pounds or more. (b) Holders of, and applicants for, type certificates, as identified in paragraph (d) of this section must develop Instructions for Continued Airworthiness (ICA) for the representative airplanes EWIS in accordance with part 25, Appendix H paragraphs H25.5(a)(1) and (b) of this subchapter in effect on [effective date of this final rule] for each affected type design, and submit those ICA for review and approval by the FAA Oversight Office. For purposes of this section, the representative airplane is the configuration of each model series airplane that incorporates all variations of EWIS used in production on that series airplane, and all TC-holder-designed modifications mandated by airworthiness directive as of the effective date of this rule. Each person specified in paragraph (d) of this section must also review any fuel tank system ICA developed by that person to comply with SFAR 88 to ensure compatibility with the EWIS ICA, including minimizing redundant requirements. (c) Applicants for amendments to type certificates and supplemental type certificates, as identified in paragraph (d) of this section, must: (1) Evaluate whether the design change for which approval is sought necessitates a revision to the ICA required by paragraph (b) of this section to comply with the requirements of Appendix H, paragraphs H25.5(a)(1) and (b). If so, the applicant must develop and submit the necessary revisions for review and approval by the FAA Oversight Office. (2) Ensure that any revised EWIS ICA remain compatible with any fuel tank system ICA previously developed to comply with SFAR 88 and any redundant requirements between them are minimized.

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Appendix E: 26.11 and 25 H5

(d) The following persons must comply with the requirements of paragraph (b) or (c) of this section, as applicable, before the dates specified. (1) Holders of type certificates (TC): [insert date 24 months after effective date] (2) Applicants for TCs, and amendments to TCs (including service bulletins describing design changes), if the date of application was before [effective date of final rule] and the certificate was issued on or after [effective date of final rule]: [insert date 24 months after effective date], or the date the certificate is issued, whichever occurs later. (3) Unless compliance with 25.1729 of this subchapter is required or elected, applicants for amendments to TCs, if the application was filed after [effective date of final rule]: [insert date 24 months after effective date], or the date of approval of the application, whichever occurs later. (4) Applicants for supplemental type certificates (STC), including changes to existing STCs, if the date of application was before [effective date of final rule] and the certificate was issued on or after [effective date of final rule]: [insert date 30 months after effective date], or the date of approval of the application, whichever occurs later. (5) Unless compliance with 25.1729 of this subchapter is required or elected, applicants for STCs, including changes to existing STCs, if the application was filed after [effective date of final rule], [insert date 30 months after effective date], or the date of approval of the application, whichever occurs later. (e) Each person identified in paragraphs (d)(1), (d)(2), and (d)(4) of this section must submit to the FAA Oversight Office for approval a compliance plan by [insert date 90 days after effective date of final rule]. The compliance plan must include the following information: (1) A proposed project schedule, identifying all major milestones, for meeting the compliance dates specified in paragraph (d) of this section. (2) A proposed means of compliance with this section, identifying all required submissions, including all compliance items as mandated in part 25, Appendix H paragraphs H25.5(a)(1) and (b) of this subchapter in effect on [effective date of this final rule], and all data to be developed to substantiate compliance. (3) A proposal for submitting a draft of all compliance items required by paragraph (e)(2) of this section for review by the FAA Oversight Office not less than 60 days before the compliance time specified in paragraph (d) of this section.
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Appendix E: 26.11 and 25 H5

(4) A proposal for how the approved Instructions for Continued Airworthiness will be made available to affected persons. (f) Each affected person must implement the compliance plan, or later approved revisions, as approved in compliance with paragraph (e) of this section. (g) This section does not apply to the following airplane models: (1) Convair CV-240, 340, 440, 580, if modified to include turbine engines. (2) Lockheed L-188 (3) Vickers Armstrong Viscount (4) Douglas DC-3, if modified to include turbine engines (5) Bombardier CL-44 (6) Mitsubishi YS-11 (7) British Aerospace BAC 1-11 (8) Concorde (9) deHavilland D.H. 106 Comet 4C (10) VFW-Vereinigte Flugtechnische Werk VFW-614 (11) Illyushin Aviation IL 96T (12) Bristol Aircraft Britannia 305 (13) Handley Page Herald Type 300 (14) Avions Marcel Dassault - Breguet Aviation Mercure 100C (15) Airbus Caravelle

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Appendix E: 26.11 and 25 H5

H25.5

Electrical Wiring Interconnection System (EWIS) Instructions for Continued Airworthiness.

(a) The applicant must prepare Instructions for Continued Airworthiness applicable to EWIS as defined by 25.1701 that are approved by the FAA and include the following: (1) Maintenance and inspection requirements for the EWIS developed with the use of an enhanced zonal analysis procedure that includes: (i) Identification of each zone of the airplane. (ii) Identification of each zone that contains EWIS. (iii) Identification of each zone containing EWIS that also contains combustible materials. (iv) Identification of each zone in which EWIS is in close proximity to both primary and back-up hydraulic, mechanical, or electrical flight controls and lines. (v) Identification of (A) tasks, and the intervals for performing those tasks, that will reduce the likelihood of ignition sources and accumulation of combustible material, and (B) procedures, and the intervals for performing those procedures, that will effectively clean the EWIS components of combustible material if there is not an effective task to reduce the likelihood of combustible material accumulation. (vi) Instructions for protections and caution information that will minimize contamination and accidental damage to EWIS, as applicable, during performance of maintenance, alteration, or repairs. (2) Acceptable EWIS maintenance practices in a standard format. (3) Wire separation requirements as determined under 25.1707. (4) Information explaining the EWIS identification method and requirements for identifying any changes to EWIS under 25.1711. (5) Electrical load data and instructions for updating that data. (b) The EWIS Instructions for Continued Airworthiness developed in accordance with the requirements of H25.5(a)(1) must be in the form of a document appropriate for the information to be provided, and they must be easily recognizable as EWIS Instructions for Continued Airworthiness. This document must either contain the required EWIS ICA or specifically reference other portions of the ICA that contain this information.

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Appendix F: Worksheets from AC 120-XX

APPENDIX F Worksheets From AC 120-XX To Record Responses To The Flowchart

Worksheets begin on the next page.

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Appendix F: Worksheets from AC 120-XX

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EAPAS

Appendix F: Worksheets from AC 120-XX

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EAPAS

Appendix F: Worksheets from AC 120-XX

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Appendix F: Worksheets from AC 120-XX

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Appendix F: Worksheets from AC 120-XX

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Appendix G: No Plan Submitted Template

Appendix G No Plan Submitted Template


In accordance with 14 CFR 26.XX, [Company] was required to submit a compliance plan, describing its proposed means of compliance with 26.YY, no later than m/d/yr. To date [Company] has not submitted the required plan. Unless [Company] submits an acceptable compliance plan, we believe it is unlikely that [Company] will be able to show compliance with 26.YY by m/d/yr, as required. Such a failure would make it difficult for operators of [Companys products] to comply with the related operational rules and may lead to enforcement action against [Company] in accordance 14 CFR part 13. Advisory Circulars 26-XX and 26-YY describe acceptable means of compliance with these regulations. If you have any questions regarding these regulations or acceptable means of compliance with them, please contact [POC] as soon as possible. We look forward to continuing to work with [Company] to assist you in complying with these important regulations. [Alternatively, if we know or suspect that Company has no intention of complying, we can issue an LOI at this stage, based on the failure to comply with the requirement to submit the plan. The sooner they recognize were serious, the more likely theyll try to recover.]

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Appendix H: Unacceptable Plan Template

Appendix H Unacceptable Plan Template


As required by 14 CFR 26.XX, on m/d/yr [Company] submitted its compliance plan, describing its proposed means of compliance with 26.YY. As discussed on m/d/yr, we have reviewed the plan and identified the following deficiencies: 1. [Explain deficiency] 2. [Explain deficiency] 3. [Explain deficiency] Unless these deficiencies are corrected, we believe it is unlikely that [Company] will be able to show compliance with 26.YY by m/d/yr, as required. Such a failure would make it difficult for operators of [Companys products] to comply with the related operational rules and may lead to enforcement action against [Company] in accordance 14 CFR part 13. To remedy these deficiencies, we consider that the following revisions to the plan are necessary: 1. [Explain revision] 2. [Explain revision] 3. [Explain revision] If you have any questions regarding the identified deficiencies or our suggested revisions, please contact [POC] as soon as possible. We look forward to continuing to work with [Company] to assist you in complying with these important regulations.

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Appendix I: Unacceptable Implementation Template (Approved Plan)

Appendix I Unacceptable Implementation Template (Approved Plan)


On m/d/yr, this office approved [Companys] compliance plan, describing its proposed means of compliance with 26.YY. As discussed on m/d/yr, we have identified the following deficiencies in [Companys] implementation of the approved plan. 1. [Explain deficiency] 2. [Explain deficiency] 3. [Explain deficiency] Unless these deficiencies are corrected, we believe it is unlikely that [Company] will be able to show compliance with 26.YY by m/d/yr, as required. Such a failure would make it difficult for operators of [Companys products] to comply with the related operational rules and may lead to enforcement action against [Company] in accordance 14 CFR part 13. To remedy these deficiencies, we consider that the following actions are necessary: 1. [Explain revision] 2. [Explain revision] 3. [Explain revision] If you have any questions regarding the identified deficiencies or our suggested actions, please contact [POC] as soon as possible. We look forward to continuing to work with [Company] to assist you in complying with these important regulations.

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Appendix J: Unacceptable Implementation Template (No Approved Plan)

Appendix J Unacceptable Implementation Template (No Approved Plan)


By letter dated m/d/yr, this office informed [Company] that its proposed compliance plan, describing its proposed means of compliance with 26.YY, was unacceptable. In that letter we identified deficiencies and revisions necessary to make it acceptable; however, to date [Company] still has not submitted an acceptable plan. Further, as discussed on m/d/yr, we have identified the following deficiencies in [Companys] ongoing efforts to comply with 26.YY. 1. [Explain deficiency] 2. [Explain deficiency] 3. [Explain deficiency] Unless these deficiencies are corrected, we believe it is unlikely that [Company] will be able to show compliance with 26.YY by m/d/yr, as required. Such a failure would make it difficult for operators of [Companys products] to comply with the related operational rules and may lead to enforcement action against [Company] in accordance 14 CFR part 13. To remedy these deficiencies, we consider that the following actions are necessary: 1. [Explain actions] 2. [Explain actions] 3. [Explain actions] If you have any questions regarding the identified deficiencies or our suggested actions, please contact [POC] as soon as possible. We look forward to continuing to work with [Company] to assist you in complying with these important regulations.

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Appendix K: Unacceptable Draft Template

Appendix K Unacceptable Draft Template


On m/d/yr, [Company] submitted its draft data and documents, developed to show compliance with 26.YY. As discussed on m/d/yr, we have identified the following deficiencies in [Companys] draft data and documents. 1. [Explain deficiency] 2. [Explain deficiency] 3. [Explain deficiency] Unless these deficiencies are corrected, [Company] will not be able to show compliance with 26.YY by m/d/yr, as required. Such a failure would make it difficult for operators of [Companys products] to comply with the related operational rules and may lead to enforcement action against [Company] in accordance 14 CFR part 13. To remedy these deficiencies, we consider that the following revisions are necessary: 1. [Explain revision] 2. [Explain revision] 3. [Explain revision] If you have any questions regarding the identified deficiencies or our suggested revisions, please contact [POC] as soon as possible. We look forward to continuing to work with [Company] to assist you in complying with these important regulations.

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Appendix L: No Drafts Submitted Template

Appendix L No Drafts Submitted Template


In accordance with 14 CFR 26.XX, [Company] was required to submit draft data and documents showing compliance with 26.YY, no later than m/d/yr. To date [Company] has not submitted the required drafts. Unless [Company] submits acceptable drafts, we believe it is unlikely that [Company] will be able to show compliance with 26.YY by m/d/yr, as required. Such a failure would make it difficult for operators of [Companys products] to comply with the related operational rules and may lead to enforcement action against [Company] in accordance 14 CFR part 13. Advisory Circulars 26-XX and 26-YY describe acceptable means of compliance with these regulations. If you have any questions regarding these regulations or acceptable means of compliance with them, please contact [POC] as soon as possible. We look forward to continuing to work with [Company] to assist you in complying with these important regulations. [Alternatively, if we know or suspect that Company has no intention of complying, we can issue an LOI at this stage, based on the failure to comply with the requirement to submit the drafts. The sooner they recognize were serious, the more likely theyll try to recover.]

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Appendix M: Sample Letters of Investigation

Appendix M Sample Letters of Investigation


No data and documents submitted [Company], as the holder of [supplemental] type certificate number XXX, was required to submit data and documents to this office to show compliance with 14 CFR 26.XX, by m/d/yr. To date, we have not received those data and documents. This letter is to inform you that this matter is under investigation by the Federal Aviation Administration. We would appreciate receiving any evidence or statements you might care to make regarding this matter within 10 days of receipt of this letter. Any discussion or written statements furnished by you will be given consideration in our investigation. If we do not hear from you within the specified time, our report will be processed without the benefit of your statement. Unacceptable data and documents submitted [Company], as the holder of [supplemental] type certificate number XXX, was required to submit data and documents to this office to show compliance with 14 CFR 26.XX, by m/d/yr. While [Company] submitted draft data and documents on m/d/yr purporting to show compliance, on m/d/yr, this office advised [Company] of deficiencies in those data and documents. To date, we have not received data and documents [adequately] addressing those deficiencies. [Note: adequately can be deleted if no additional submissions have been received.] This letter is to inform you that this matter is under investigation by the Federal Aviation Administration. We would appreciate receiving any evidence or statements you might care to make regarding this matter within 10 days of receipt of this letter. Any discussion or written statements furnished by you will be given consideration in our investigation. If we do not hear from you within the specified time, our report will be processed without the benefit of your statement.

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Appendix M: Sample Letters of Investigation

No compliance plan submitted [To be used if we conclude more than just template letter is needed] [Company], as the holder of [supplemental] type certificate number XXX, was required to submit a compliance plan to this office describing its proposed means of compliance with 14 CFR 26.XX, by m/d/yr. To date, we have not received this plan. This letter is to inform you that this matter is under investigation by the Federal Aviation Administration. We would appreciate receiving any evidence or statements you might care to make regarding this matter within 10 days of receipt of this letter. Any discussion or written statements furnished by you will be given consideration in our investigation. If we do not hear from you within the specified time, our report will be processed without the benefit of your statement. No draft data and documents submitted [To be used if we conclude more than just template letter is needed] [Company], as the holder of [supplemental] type certificate number XXX, was required to submit draft data and documents to this office, showing compliance with 14 CFR 26.XX, by m/d/yr. To date, we have not received these drafts. This letter is to inform you that this matter is under investigation by the Federal Aviation Administration. We would appreciate receiving any evidence or statements you might care to make regarding this matter within 10 days of receipt of this letter. Any discussion or written statements furnished by you will be given consideration in our investigation. If we do not hear from you within the specified time, our report will be processed without the benefit of your statement.

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Appendix N: Communication Schedule

Appendix N Communication Schedule: Minimum Requirements For Documented Communication With DAH
REVIEW/APPROVAL OF COMPLIANCE PLAN (ORDER 5-5) Item 1 Schedule Within 1 week from receipt of plan. Compliance Team Action Conduct preliminary review of DAH submitted compliance plan to determine any major deficiencies. Complete review of DAH submitted compliance plan. Comment If deficiencies found immediately contact DAH. Documented form of Communication Email, telecom or meeting

Within 4 weeks from receipt of plan. Within 6 weeks from receipt of plan.

If deficiencies found immediately contact DAH.

See Item #3

Formally inform DAH of approval or disapproval (includes proposed resolution) of plan.

If disapproval of plan continue to work with DAH. If impasse inform management.

Letter stating approval or disapproval (templates available). Informally document efforts to resolve deficiencies with the DAH. Letter stating approval or disapproval (templates available). Informally document efforts to resolve deficiencies with the DAH.

Within 3 weeks from receipt of revised plan.

Complete review of revised plan and formally inform DAH of approval or disapproval.

If disapproval of plan continue to work with DAH. If impasse inform management.

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Appendix N: Communication Schedule

MONITOR IMPLEMENTATION OF COMPLIANCE PLAN (ORDER 5-6) Item 5 Schedule Within 1 week from identification of deficiencies. Compliance Team Action Inform the DAH of deficiencies and monitor DAH efforts to resolve deficiencies. Comment This action occurs irrespective of the DAH having an approved compliance plan or not. Documented form of Communication If significant deficiencies are identified that put timely compliance at risk, inform DAH by letter. If deficiencies are identified and an acceptable recovery plan is developed that does not put compliance at risk, informally document efforts with the DAH.

DRAFT DATA AND DOCUMENTS SUBMITTAL AND REVIEW (ORDER 5-7) Item 6 Schedule Within 1 week from receipt of draft data and documents. Within 5 weeks from receipt of draft data and documents. Compliance Team Action Conduct preliminary review of DAH submittal to determine any major deficiencies. Complete review of draft data and documents and coordinate with Standardization Team as required. Notify the DAH of acceptability or nonacceptability of draft data and documents. Comment If deficiencies found immediately contact DAH. Documented form of Communication Email, telecom or meeting

If draft data and documents are unacceptable, continue to work with DAH. If impasse inform management.

Email, telecom or meeting

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Appendix N: Communication Schedule

FINAL DATA AND DOCUMENTS SUBMITTAL, REVIEW, AND APPROVAL (ORDER 5-8) Item 8 Schedule Within 1 week from receipt of final data/ documents. Within 4 weeks from receipt of final data /documents. Compliance Team Action Conduct preliminary review of final data/ documents to determine any major deficiencies. Complete review of final data and documents and coordinate with Standardization Team as required. If significant deficiencies are identified in the final data coordinate action with Standardization team and inform DAH If final data and documents are acceptable, inform the DAH of FAA approval and notify affected operators and PIs/Flight Standard District Offices (FSDO) of the availability of the approved data/ documents that can show compliance with the operational rules. If revised final data/ documents are acceptable inform the DAH of FAA approval and notify affected operators and PIs/Flight Standard District Offices (FSDO) of the availability of the approved data that can show compliance with the operational rules. This action needs to be expedited if possible to maximize time for operator compliance with operational rules. Comment If deficiencies found immediately contact DAH. This action needs to be expedited if possible to maximize time for operator compliance with operational rules. Documented form of Communication Email, telecom or meeting

See Item #10

10

Within 5 weeks from receipt of final data/ documents.

Letter stating disapproval (template available).

11

Within 6 weeks from receipt of the final data/ documents.

Letter stating approval (template available).

12

Within 3 weeks from resubmittal of final data/ documents to correct deficiencies

This action needs to be expedited if possible to maximize time for operator compliance with operational rules.

Letter stating approval (template available).

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Appendix O: EWIS Part 26 Sample Compliance Plan

Appendix O EWIS Part 26 Sample Compliance Plan


This begins on the next page.

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An example for EAPAS DAH requirements training. This is provided for training purposes only and is not meant to be used as advisory or policy guidance. Although we are using a fictitious airplane manufacturer for illustrative purposes, this example compliance plan can also be applied to STC applicants who are required to submit a compliance plan. Revised 4/25/2007

Electrical Wiring Interconnection System (EWIS)

14 CFR Part 26 Compliance Plan


Document No. 26.11-CP-01

DAH: Excellent Airplane Company Airplane Model: E123


Rev 0 October 27, 2007

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Table of Contents
Subjects I. II. III. IV. DAH: Excellent Airplane Manufacturer Description: Airplane Model E123 Relevant Part 26 Requirements Means of Compliance a. Deviations for FAA Relations and Policies b. Proposed Alternate Means of Compliance V. Model E123 Part 26 Compliance Team a. Team Focal VI. Delegation Plan VII. Required Documents VIII. Compliance Schedule IX. Communication Processes X. Operators Involvement/Inputs XI. Understanding/Agreements Page 44 44 45 47 47 47 49 49 50 51 52 52 53 53

List of Figures
Figure 1 - E123-P Airplane Configuration for Enhanced Zonal Analysis Figure 2 Compliance Schedule for E123 Airplane Model 45 47

List of Tables
Table 1 Part 26 Means of Compliance for E123 Airplane Models 52

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I.

Design Approval Holder: Excellent Airplane Company

The Excellent Airplane Company (EAC) is a specialized well-established airplane manufacturer which has been designing and manufacturing only one airplane model E123 to the best design and manufacturing standards since 1977. The EAC is using the stateof-the-art and highly advanced wiring fabrication processes with the advanced tooling, testing, and inspection techniques. Our airplane electrical wiring interconnection systems (EWIS)are designed and built in house with teams of very knowledgeable and capable engineers and technicians with vast and diverse skills of many years.

II.

Description: Airplane Model E123 (or STC STC777-HACO)

The E123 is designed and built in two configurations; E123-P passenger version with a total capacity of 325 passenger in a single class seating and 285 in a three class configuration, and E123-C, a cargo version. We are currently working on design of our third version which will offer an option of cargo and passenger combination for our airplanes (E123-PC). Figure 1., below, depicts the passenger version of our E123-P airplane model. We used this version as the representative configuration for performing Enhanced Zonal Analysis (EZAP) because this version includes the most complex wiring configuration of this model due to the features included/offered for the passengers comfort such as galleys and in-flight entertainment systems. In other words, the model of airplane we used as the basis for the performing the EZAP incorporates all variations of EWIS used in production and all of our design modifications that have been mandated by airworthiness directive as of {effective date of the final EAPAS rule}. Variations in the EWIS ICA due to configurations differences between the passenger and cargo version of the E123, are clearly noted in the final EWIS ICA documentation required by Part 25, Appendix H, paragraph H25.5(b). The Excellent Airplane Model E123 is owned and operated by two operators: The Safe Airlines Incorporated (SAI) operates 500 of Model E123-P and On-time Jet Cargo (OJC) operates 400 of E123-C cargo version. The Excellent Aircraft Company is in process of installing a new in-flight entertainment (IFE) system on E-123-P under Supplemental Type Certificate (STC) No. STC777HACO. The application for installation of the new IFE was made to the FAA at the Honolulu Aircraft Certification Office on January 1, 2006 and it is expected to be completed one day after the effective date of the EAPAS/FTS rule. The EAC will develop ICA for the new IFE EWIS as part the ICA required for the E123-P model. (NOTE to students: Since the STC was applied for before the effective date of the final rule and will be issued after the effective date, EAC is required per 26.11(e) to submit a compliance plan.)

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Zone 1 Zone 2 Zone 3 Zone 5

Zones:
Zone 4

Zone 6

---------- Size Popul. Severity Zone 1: H H H Zone 2: M H L Zone 3: L L H Zone 4: H L H Zone 5: H L Zone 6: L L L

1: EE Bay (wiring, combustible material) 2: FWRD Cargo, dedicated to Eel. Equipment (wiring, no combustible material) 3: Front Wing Cargo (wiring, combustible material) 4: Left Wing Fuel Tank (wiring, flammable) 5: Left Wing Faring (no wiring) 6: Aft Cargo (wiring, no combustible material, Prim. & Bkup Mech. Control within 2 of wiring)

Figure 1 - E123-P Airplane Configuration for Enhanced Zonal Analysis

III.

Relevant Requirements

Part 26 Requirements 26.11 Electrical wiring interconnection systems (EWIS) maintenance program (a) Except as provided in paragraph (g) of this section, this section applies to transport category, turbine-powered airplanes with a type certificate issued after January 1, 1958, that, as a result of the original certification, or later increase in capacity, have (1) A maximum type-certificated passenger capacity of 30 or more or (2) A maximum payload capacity of 7,500 pounds or more. (b) Holders of, and applicants for, type certificates, as identified in paragraph (d) of this section must develop Instructions for Continued Airworthiness (ICA) for the representative airplanes EWIS in accordance with part 25, Appendix H paragraphs H25.5(a)(1) and (b) of this subchapter in effect on [effective date of this final rule] for each affected type design, and submit those ICA for review and approval by the FAA Oversight Office. For purposes of this section, the representative airplane is the configuration of each model series airplane that incorporates all variations of EWIS used in production on that series airplane, and all TC-holder-designed modifications mandated by airworthiness directive as of the effective date of this rule. Each person specified in paragraph (d) of this section must also review any fuel tank system ICA developed by that person to comply with SFAR 88 to ensure compatibility with the EWIS ICA, including minimizing redundant requirements.

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(c) Applicants for amendments to type certificates and supplemental type certificates, as identified in paragraph (d) of this section, must: (1) Evaluate whether the design change for which approval is sought necessitates a revision to the ICA required by paragraph (b) of this section to comply with the requirements of Appendix H, paragraphs H25.5(a)(1) and (b). If so, the applicant must develop and submit the necessary revisions for review and approval by the FAA Oversight Office. (2) Ensure that any revised EWIS ICA remain compatible with any fuel tank system ICA previously developed to comply with SFAR 88 and any redundant requirements between them are minimized. (d) The following persons must comply with the requirements of paragraph (b) or (c) of this section, as applicable, before the dates specified. (1) Holders of type certificates (TC): [insert date 24 months after effective date] (2) Applicants for TCs, and amendments to TCs (including service bulletins describing design changes), if the date of application was before [effective date of final rule] and the certificate was issued on or after [effective date of final rule]: [insert date 24 months after effective date], or the date the certificate is issued, whichever occurs later. (3) Unless compliance with 25.1729 of this subchapter is required or elected, applicants for amendments to TCs, if the application was filed after [effective date of final rule]: [insert date 24 months after effective date], or the date of approval of the application, whichever occurs later. (4) Applicants for supplemental type certificates (STC), including changes to existing STCs, if the date of application was before [effective date of final rule] and the certificate was issued on or after [effective date of final rule]: [insert date 30 months after effective date], or the date of approval of the application, whichever occurs later. (5) Unless compliance with 25.1729 of this subchapter is required or elected, applicants for STCs, including changes to existing STCs, if the application was filed after [effective date of final rule], [insert date 30 months after effective date], or the date of approval of the application, whichever occurs later. (e) Each person identified in paragraphs (d)(1), (d)(2), and (d)(4) of this section must submit to the FAA Oversight Office for approval a compliance plan by [insert date 90 days after effective date of final rule]. The compliance plan must include the following information: (1) A proposed project schedule, identifying all major milestones, for meeting the compliance dates specified in paragraph (d) of this section. (2) A proposed means of compliance with this section, identifying all required submissions, including all compliance items as mandated in part 25, Appendix H paragraphs H25.5(a)(1) and (b) of this subchapter in effect on [effective date of this final rule], and all data to be developed to substantiate compliance. 3) A proposal for submitting a draft of all compliance items required by paragraph (e)(2) of this section for review by the FAA Oversight Office not less than 60 days before the compliance time specified in paragraph (d) of this section. (4) A proposal for how the approved ICA will be made available to affected persons. (f) Each affected person must implement the compliance plan, or later approved revisions, as approved in compliance with paragraph (e) of this section.

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IV.

Means of Compliance

The proposed compliance means chosen by EAC to comply with the requirements of Part 26 are provided in Table 1. Table 1 Part 26 Means of Compliance for E123 Airplane Models
Part 26.11 Sections (a) (b) H25.5(a)(1) Requirements Applicability Means / Alternative Products: Data/Document Remarks The rule applies to Models E123P and E123C Using guidance of AC 120-XX and MSG-3 process conducted via MRB ICA MSG-3 version 2005.1 was used to conduct the original EZAP analysis. A follow-on analysis will be performed in order to fully address the guidance as provided by AC 120-XX. NOTE: Since ECA says that the EWIS ICA were developed using MSG-3 V2005.1, they should add a statement about how they intend to ensure compliance with H25.5(a)(1). For example, they may state that they have performed a gap analysis to state that they will account for any difference between MSG-3 V2005.1 and the requirements of H25.5(a)(1) NOTE: Since section 26.11(b) talks about the representative airplane configuration, EAC should add information that states what configuration EAC used when conducting MSG-3 V2005.1 and if that will be the same configuration used for the gap analysis.] [NOTE: A statement about how EAC intends to comply with the requirement to ensure compatibility between fuel tank system ICA developed to comply with SFAR 88 and EWIS ICA should be included in the compliance matrix.] [NOTE: A statement about the form of the EWIS ICA source document required by H25.5(b) should be included in the compliance matrix.] All required compliance documentation will be submitted to FAA for Approval.

Development of EWIS ICA

H25.5(b)

Documentation

MRB Report & Source Letter

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(c)(1) & (2) Amendments to TC and STC N/A N/A This section is not applicable to EAC. At this time EAC does not own any STCs and has no plans for amending our Model E123 Type Certificate. If EAC applies for an ATC in the future, a compliance plan will be submitted at that time. EWIS ICA for Model E123 will be submitted by [24 months after effective date of final rule.] for review and approval by the [FAA Oversight Office] This section is not applicable to EAC. This section is not applicable to EAC. This section is not applicable to EAC. This section is not applicable to EAC. A compliance plan (this document) will be submitted to [FAA Oversight Office] by [90 days after effective date of final rule] The plan contains 1) A proposed project schedule (see paragraph XX of this document) 2) A proposed means of compliance with the requirements of section 26.11 (this compliance matrix) 3) A proposal for submitting a draft of all compliance items required by 26.11(e)(2) to the [FAA Oversight Office] by [24 months after the effective date of the final rule 60 days] (see paragraph XY of this document) 4) A proposal for how we intend to make available the EWIS ICAs to our affected operators. (See paragraph VII of this document). (f) Implementation of Compliance Plan Compliance plan implemented in accordance with 26.11(f) and AC 26-XX. Implementation of compliance plan includes submittal of draft and final data/documents and making the approved ICA available to operators. The EAC intends to follow the process and schedule outlined in this plan as agreed and approved by the [FAA Oversight Office].

(d)(1)

Effectively

N/A

N/A

(d)(2) (d)(3) (d)(4) (d)(5) (e)(1), (2), (3), (4)

Effectivity Effectivity Effectivity Effectivity Compliance Plan Submittal

N/A N/A N/A N/A Compliance Plan developed in accordance with 26.11(e) and AC 26-XX.

N/A N/A N/A N/A Compliance Plan

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V. Excellent Airplane Company Compliance Team for Model E123


Listed below are the EAC personnel assigned to develop EWIS ICA for ECA Models 123P and 123C. Name Organization Position Role/Responsibility
Focal for communication with [FAA Oversight Office]. e.g., Correspondence, meeting coordinator, ensuring ECA compliance with applicable Part 26 requirements

Serty Fyed

Regulatory and Government Affairs ECA-001

Regulatory Liaison

Lead Guy

Engineering Commercial Airplanes ECA-101 Engineering Commercial Airplanes ECA-101 Engineering Commercial Airplanes ECA-101 Maintenance Commercial Airplanes ECA-201

Engineering Lead

Technical focal for development of EWIS ICA

Wing Mann

EWIS Design Engineer

Technical focal for design of Models ECA 123P and 123C

Iye C. Sparks

EWIS Maintenance Engineer

Technical focal for EWIS engineering support to maintenance department Maintenance Planning department focal for development of Models ECA 123P and 123C maintenance programs (including EWIS maintenance). Maintenance department focal for ECA/Customer Relations for

Susan Rusty Wrench

EWIS Maintenance Program Coordinator

Keepem Happy

Maintenance Commercial Airplanes ECA-201

Maintenance Program Customer Liaison

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VI. Delegation Plan EAC is working to expand the delegated authority/authorized areas of the following DERs in accordance with FAA Orders XXXX and YYYY. We plan to have these DERs participate in MSG-3 meetings and review the Maintenance Review Board Report (MRBR) and Source Document (required by Part 25, Appendix H, H25.5(b)) to recommend approval. Once the FAA has satisfactory experience with our DERs and the new delegated functions/authorized areas, we plan to request that the FAA grant full approval authority to these designees. We will submit a more detailed delegation plan in the near future. Our Regulatory Liaison, Mr. Serty Fyed, will contact [FAA Oversight Office] within 10 business days after submittal of this plan to request a preliminary meeting regarding our delegation plan.

Name Jeffery Jet

Organization Engineering Commercial Airplanes ECA-101

Delegation EWIS Design DER

Ann Analyst

Engineering Commercial Airplanes ECA-101

EWIS Analysis DER

Inna Staller

Engineering Commercial Airplanes ECA-101

EWIS Installation DER

Aire Worthy

Maintenance Commercial Airplanes ECA-201

EWIS Maintenance DER

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VII.

Required Documents

The EAC will provide the following data/documents to the [FAA Oversight Office] for review and approval . The following table provides the name and reference number of the documents containing the regulatory required data.
Document Reference Overview Submittal Date to [FAA Oversight Office] 90 days after effective date of the final rule

14 CFR Part 26 Compliance Plan

26.11-CP-01

Contains details of how EAC intends to show compliance with the applicable Part 26 DAH requirements This is a reference document that details what EAC maintenance documents contain the actual EWIS ICA. It will also contain a summary of all EWIS ICA. All documents referenced by the EWIS ICA Source Document will be made available to [FAA Oversight Office] as requested. These various documents, as referenced in the EWIS ICA Source Document, EWIS-ICA01, contain the EWIS ICA and will be made available upon request. This document provides details of the how ECA intends to make the EWIS ICA available to our owners/operators. This document contains the details of our DER delegation proposal.

EWIS ICA Source Document

EWIS-ICA-01

24 months after the effective date of the final rule 60 days

ECA Maintenance Documents

Varies

24 months after the effective date of the final rule 60 days

EWIS ICA Distribution Method

EWIS-DIST-01

90 days after effective date of the final rule

EWIS ICA DER Delegation Plan

EWIS-DER-01

90 days + 10 days after the effective date of the final rule

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VIII. Compliance Schedule In addition to the guidance provided in AC 26-XX [Note: the DAHs dont have to follow the Order], EAC will follow the timeline provided in Figure 2, below, to develop the data and documents identified in Paragraph VII of this document.

EAC Submit EAC/FAA Compliance Plan Meeting/coordination to the FAA as often as necessary EAPAS/FTS Effective Date

EAC submit ICA for FAA approval

Operators incorporate ICA

Et + 4m

Ed + 27m

Ed

Ed + 3m
FAA Formally notify EAC of any deficiencies

Ed + 24m

Ed + 39m
1. FAA approves ICA 2. EAC makes ICA available for operators

Figure 2 Compliance Schedule for E123 Airplane Model

IX.

Communication Processes

As defined in AC 26-XX, EAC will have a very close communication with the FAA Compliance Team to ensure all the necessary data developed are of high quality and submitted to FAA in timely manner. Through frequent meetings and correspondence the EAC will work continuously with the [FAA Oversight Office]to ensure all issues are resolved in timely manner and no surprises nor any noncompliance issue will need to be dealt with close to the compliance due dates. Therefore, EAC proposes monthly status meetings with [FAA Oversight Office]. The point of contact for scheduling these meetings is Mr. Serty Fyed, who can be reached at 555-555-5555, or via e-mail at serty.fyed@eac.com.

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X.

Operators Involvement/Inputs

As part of the MSG-3 process, EAC plans to involve E123P and E123C owners and operators during the development of the EWIS ICA. Although not required by regulation, EAC involves operators in the development of the EWIS ICA to ensure that they will be readily usable by our owners and operators once the EWIS ICA are approved by [FAA Oversight Office]. This will help fulfill, as required by part 26, the responsibility of the operators of Models E123-P and E123-C (SAI and OJC) to incorporate the FAA-approved EWIS IAC into their maintenance programs by the required date (39 months after the effective date of the EAPAS/FTS rule).

XI.

Understanding/Agreements

It is EACs intent that all data and documents identified in this plan will be developed with a high level of quality and will be acceptable to the FAA. In addition it is our intent to make all submittals in a timely manner in order to meet our regulatory requirements (refer to paragraph VIII of this document). We understand that a noncompliance issue does not stop the compliance clock. Any noncompliance issue must be acceptably resolved with the FAA as soon as possible to ensure on time compliance. We understand the FAA will perform prompt reviews of our submittals and alert us as soon as possible regarding any potential issues or concerns that could affect compliance (within the required time period; no later than 15 months after the effective date of the EAPAS/FTS rule). We also understand that as defined by the regulation, FAA may pursue an enforcement action for any unresolved issues.

EAPAS: Part 26 DAH

Public Version 1.1, Aug 2007

Appendix-53