Recommendation R20010251

Recommendation issued to: Civil Aviation Safety Authority

Recommendation details
Output No: R20010251
Date issued: 20 December 2001
Safety action status:
Background: Why this Recommendation was developed

Output text

The Australian Transport Safety Bureau recommends that the Australian Civil Aviation Safety Authority ensure that all Boeing 717-200 aircraft on the Australian Register are fitted with a flight recorder system that complies with the requirements of all applicable Australian Civil Aviation Orders.

Initial response
Date issued: 28 February 2002
Response from: Civil Aviation Safety Authority
Response text:

CASA accepts the above Recommendations and will take the following action:

1. CASA wishes to advise the ATSB that all Boeing 717-200 aircraft presently on the Australian Civil Register are operated by the one airline. CASA intends to forward a Civil Aviation Regulation (CAR) 38 Direction to the airline directing it to rectify the deficiency in the flight data recorder (FDR) run/stop logic in its B717 aircraft.

2. Issue an Airworthiness Bulletin that;

(i) recommends all Certificate of Registration holders that operate aircraft that require a FDR to be installed to:

i. Check the aircraft to ensure compliance with CAO 20.18;
ii. Advise CASA through the Service Difficulty Reporting process of any aircraft that do not comply; iii. If the aircraft does not comply, contact the aircraft manufacturer or a CAR 35 person to have the aircraft modified to meet the requirements of CAO 20.18; and

(ii) explains to those persons issuing a Certificate of Airworthiness for an aircraft, the requirements for first of airframe/(Flight Data Acquisition Unit (FDAU)/FD combination.

3. Update the CASA Certificate of Airworthiness and Special Flight Permits Manual to ensure that appropriate action is taken in relation to FDRs as part of the initial Certificate of Airworthiness issue.

CASA undertakes to provide the ATSB with copies of the CAR 38 Direction, the Airworthiness Bulletin and details of the Certificate of Airworthiness and Special Flight Permits Manual amendments.

Further correspondence
Date issued: 19 September 2006
Response from: Civil Aviation Safety Authority
Response text:

In December 2001, ATSB issued Recommendations 20010251 and 20010252 (see report 200100477) in relation to the Boeing 717 and flight data recorders.

CASA has reviewed its earlier responses to the recommendations and is considering a revised approach. Accordingly CASA has initiated a small project to review COA20.18 and the current requirements relating to flight data recorders. The review will be primarily carried out by [NAME] of the Manufacturing, Certification and New Technologies Office and [NAME] from the Air Transport Operations Group.

Given the ATSB's involvement in this matter, CASA would like to invite a representative of the Bureau to participate in a review of CAO 20.18, para 6.3 in relation to Recommendations R20010251 and R20010252.

ATSB response:

ATSB correspondence to the CASA CAO 20.18 Review Panel, 3 November 2005.

The ATSB considers that CAO 20.18 Paragraph 6.3 is consistent with the Flight Data Recorder, FDR, start/stop logic requirements specified by The International Civil Aviation Organisation, ICAO, and European Joint Airworthiness Authorities requirements, JAR-OPS. The requirements of CAO 20.18 paragraph 6.3 is also consistent with the FDR start/stop logic operation of Boeing manufactured aircraft.

It would appear reasonable to accept that the design of new aircraft will comply with both the European JAR-OPS requirements and the United States Federal Aviation Regulations, FAR's.

Further correspondence
Date issued: 17 January 2008
Response from: Civil Aviation Safety Authority
Response status: Closed - Not Accepted
Response text:

The original response indicated that CASA would forward a direction to the relevant airline requesting rectification. CASA has since reviewed the original decision communicated to you in May 2005 and has decided that it would be preferable to recognise the Federal Aviation Administration standard for the B717 flight data recorder to ensure compliance with applicable Civil Aviation Orders as outlined in Recommendation R20010251.

ATSB response:

We would like to clarify the intent of CASA's response in relation to ATSB recommendation R20010251.

Is it the intent of CASA to grant an instrument specifically to allow the continued operation of the B717 flight data recorder (FDR) system as currently installed?

Is it also the intent of CASA that all other aircraft types on, and entering, the Australian register that have an FDR or cockpit voice recorder (CVR) system fitted, will be required to have that system installed and operated in accordance with the requirements of CAO 20.18

ATSB Comment

The ATSB notes the decision made by CASA. The ATSB does not agree with the decision as there are other methods of meeting the requirements that have not been fully explored and considers that CAO 20.18 paragraph 6.3 does not require amendment. At the time of closing this recommendation the ATSB has not received a reply to the letter of 24 January 2008 or advice from CASA regarding items 2 and 3 of the CASA response received 28 February 2002, therefore the ATSB reclassifies the recommendation as Closed - Not Accepted.

Last update 01 April 2011