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Recommendation issued to: Civil Aviation Safety Authority

Recommendation details
Output No: R20020149
Date issued: 10 July 2002
Safety action status:
Background:

A prime determinant in aviation safety is the provision of reliable, accurate, and timely information to flight crew. This provides the basis for them to make the best decisions, thereby maximising safety.

One area of aircraft operation where the quality of information is sometimes less than ideal is fuel management. Between 1991 and 2000, there were a total of 139 fuel-related accidents reported to the ATSB. Forty-nine lives were lost as a result, with an estimated cost to the Australian community to be somewhere between $63 million and $127 million. Fuel exhaustion and fuel starvation accidents continue to be a problem in the Australian aviation industry, accounting for over 6% of all accidents between 1991 and 2000. While fuel starvation accident rates have remained relatively stable over the past 20 years, fuel exhaustion accident rates have shown a decrease of 29.6%.

Another area where better information is desirable is engine operation and maintenance. Enhanced engine instrumentation, which provides more accurate presentation of engine operating information has the potential to improve safety in the event of 'one-engine-out' operations. Additionally, such instrumentation may result in increased engine efficiency and reliability, and also reduce maintenance costs.

The introduction of Global Positioning Systems has brought substantial benefits. Other high technology devices are available that have applicability in other aspects of aircraft operation. These include monitoring devices that provide accurate, timely, and reliable information on aircraft engine and fuel systems that may allow crews to operate at a higher level of safety and efficiency.

The Civil Aviation Safety Authority (CASA) is currently reviewing the civil aviation regulations in an attempt to make them simple, unambiguous and generally harmonised with those of other leading aviation nations. As part of this process, a number of additional fuel management requirements have been proposed. However, those requirements make no reference to hardware improvements that are now available in the form of system monitoring devices that provide timely, reliable, and accurate information on many facets of aircraft operation, including fuel and engine system operation. Such systems have the potential to enhance aviation safety, particularly with respect to the operation of general aviation type aircraft whose systems have remained substantially unaltered for many years and make very little use of the technology currently available.

The proposed Civil Aviation Safety Regulation (CASR) Part 121B requires cockpit voice recorders in fixed wing twin-turbine powered aircraft with MTOW less than 5700 kg. There is no reference in the document to monitoring or recording devices in other small aircraft that may be engaged in air transport operations.

While current Digital Flight Data Recording systems may be expensive options for retrofit to the current fleet of general aviation aircraft, there have been many technological developments in cost effective monitoring and recording devices for aircraft systems in recent years. These include devices that could be retro-fitted to aircraft currently in service.

Fuel management and engine monitoring systems can provide additional, accurate, and more reliable information to flight crew and maintenance personnel regarding the operation of various aircraft systems, both in real time, and by way of recorded data. They offer the potential, therefore, to enhance safety in aircraft operation and maintenance.

An additional benefit of such devices is the potential they offer as a source of information for incident and accident investigation.

The level of sophistication of monitoring and recording devices varies, as does the cost. However, with the increasing availability of such equipment, it is timely for an assessment to be made as to whether such equipment should be required for some types of aircraft operation, particularly where fare-paying passengers are involved.

See also ATSB Discussion Paper 'Australian Aviation Accidents Involving Fuel Exhaustion and Starvation'.

Output text

Safety Recommendation

The Australian Transport Safety Bureau recommends that the Civil Aviation Safety Authority examine whether the potential safety benefits from devices such as those that monitor and record aircraft fuel and engine system operation are sufficient to warrant them being required in general aviation aircraft used in air transport operations.

Initial response
Date issued: 16 April 2003
Response from: Civil Aviation Safety Authority
Response text:

I am writing in relation to the Bureau's letter of 5 December 2002 to which was attached a letter from Perkins Engineering Pty Ltd. The Bureau invited the Authority to reconsider its response, dated 21 November 2002, to Air Safety Recommendation R20020149, which also included reference to products of Perkins Engineering. Please accept my apologies for the delay in my reply.

R20020149, issued on 9 July 2002, states:

The Australian Transport Safety Bureau recommends that the Civil Aviation Safety Authority examine whether the potential safety benefits from devices such as those that monitor and record aircraft fuel and engine system operation are sufficient to warrant them being required in general aviation aircraft used in air transport operations.

The Authority has carefully considered the comments of the Bureau and of Perkins Engineering.

The Authority acknowledges that it erred in its interpretation of the intent of the Recommendation and accepts the Bureau's view that the prime objective was to enhance real-time information about fuel and engine operation that would be available to flight crew.

In addition, the Authority acknowledges that the cost obtained for a single unit of the Data Acquisition Alarm Monitor, manufactured by Perkins Engineering, may not have been representative of the true cost of installing this equipment in a large number of aeroplanes. There may be consequent economies of scale.
GPO Box 2005 Canberra City ACT 2601 Telephone: (02) 6217 1619 Facsimile: (02) 6217 1444

Notwithstanding this, the Authority is not inclined to vary its position on the fitment of the mandatory devices for the following reasons:

• It would be an Australian unique requirement not required by any other major aviation nation nor required of aircraft manufacturers;

• We are unable to estimate the number of lives saved or injuries avoided through the use of these devices even using worldwide data. Whilst it is possible to determine the number of accidents, deaths and injuries caused in the past by fuel related accidents and engine failures, it is not possible to determine how many of those would have been avoided if fuel and engine monitoring systems had been installed;

• In addition, the true cost of the mandatory installation of aviation equipment will inevitably vary from one aircraft type to another, often depending on the number of such aircraft in Australia and any consequent economies of scale. The true cost also includes the economic impact of reduction or loss of air services which could occur as a result of escalating costs of uniquely Australian requirements. The purchase price of an item of aviation equipment and its installation is only one element of the true cost that needs to be estimated;

• Operators/owners are already able to fit these devices if they consider it worthwhile. The cheaper the cost of fitment the more likely operators/owners are to pursue the enhancement. For CASA to mandate the requirement, a substantial supporting case needs to be developed and implies either CASA knows something operators/owners don't or is substituting CASA's judgement for theirs.

In its letter of 21 November 2002, the Authority advised that it did not consider the potential safety benefits of fitting devices that monitor and record aircraft fuel and engine system operation are sufficient to warrant the costs involved in their fitment'. Whilst Perkins Engineering has advised the Bureau that their systems would not be as expensive as set out in the Authority's letter, this has not significantly affected the judgement we had formed.

On reflection the Authority's position might be better recorded as: "CASA does not consider the potential safety benefits of fitting devices that monitor and record aircraft fuel and engine system operation are sufficient to warrant their fitment being made mandatory." This construct does not imply any concerns with operators/owners voluntarily fitting this equipment.

Thank you for bringing this matter to the attention of the Authority.

ATSB Note: On 30 April 2008, the ATSB re-classified the response as Closed - Not Accepted.

Further correspondence
Response from: Civil Aviation Safety Authority
Response status: Closed - Not Accepted
Response text:
Further correspondence
Date issued: 21 November 2002
Response from: Civil Aviation Safety Authority
Response status: Open
Response text:

Thank you for providing a copy of Air Safety Recommendation R20020149 which related to engine/fuel monitoring and recording. Please accept my apologies for the delay in replying.

Recommendation R20020149

The Australian Transport Safety Bureau recommends that the Civil Aviation Safety Authority examine whether the potential safety benefits from devices such as those that monitor and record aircraft fuel and engine system operation are sufficient to warrant them being required in general aviation aircraft used in air transport operations.

The authority has examined this matter, and for the reasons set out below, does not consider that the potential safety benefits of fitting devices that monitor and record aircraft fuel and engine system operation are sufficient to warrant the costs involved in their fitment. In addition CASA's view is that the decision to mandate the installation of this equipment should be based upon a larger international analysis supporting its fitment.

The ATSB has advised that the cost of these records can be modest, say $5,000 compared to approximately $100,000 for sophisticated recorders.

One such low cost recorder investigated by CASA was the Data Acquisition Alarm Monitor (DAAM), manufactured by Perkins Technologies of Mentone Victoria. Perkins Technologies advised that the cost of their recorder and sensor ranges from $10,000 for a single engine piston aircraft to $20,000 for a twin engine piston aircraft. The DAAM can accommodate up to eight individual sensors.

Perkins Technologies also advises that, for a turbine aircraft, an alarm only system would cost about $25,000. An alarm and trend monitoring system would cost about $35,000.

This cost does not include installation costs associated with the recorder and sensors. Perkins Technologies estimate that installation would add an additional $10,000.

The development of a Supplemental Type Certificate (STC) for one of these low cost recorders would take approximately 6-9 months for conformity, testing and approvals. It is estimated that this development would cost in the order of $5,000 to $10,000 for each aircraft type. These times and costs are indicative of modifications of this complexity.

These modifications are usually unique to each aircraft. As CASA has shown from its research, they are expensive to develop, and expensive to install and maintain.

Moreover, the benefits of low cost recorders are also limited because they:

* Are not designed for aircraft use and therefore may emit undesirable radiation that can interfere with the aircraft electronics;
* Are not crashworthy and may not survive a substantial crash and subsequent fire; and
* Have limited capacity in terms of data channels which can be recorded, in that the data that may be important to an investigation cannot be recorded.

Thank you for bringing this matter to the attention of the Authority.

ATSB response:

The following letter was sent to the Civil Aviation Safety Authority on 5 December 2002:

Thank you for your letter dated 21 November 2002 in response to ATSB recommendation R20010149 which is posted on the ATSB web site. As you are aware, ATSB recommendations are generally not prescriptive and the ATSB does not advocate a particular make/model of equipment or suggest how they should be priced.

On 22 November 2002 the ATSB received correspondence from the manufacturer referenced in the CASA response, indicating his concern about some of the matters raised by CASA.

He asserts that a single piston engine design could be purchased for around $9,000 including sensors, subject to some market forces and may even reduce considerably if sold in quantity. The twin-engine variant would cost in the vicinity of $15,000 and a turbine variant should be under $20,000 (again subject to market forces).

He further asserts that installation has proved to be inexpensive with the example of a Bell 47 installation taking 6 hours to complete.

The question of an STC is still being considered by the manufacturer, but at present, installation of units is being accomplished using an approved CAR35 company producing detailed Engineering Orders to accomplish fitment in accordance with CASA requirements.

Addressing CASA's final three points of concern:

* Are not designed for aircraft use and therefore may emit undesirable radiation that can interfere with the aircraft electronics.

In his letter to the ATSB, the manufacturer stated that his design engineers have considered radio (RF) interference as part of the original concept (use in high performance racing cars) and have designed accordingly. They have had no problems with interference in any of the installations in ground or airborne platforms to date.

* Are not crashworthy and may not survive a substantial crash and subsequent fire.

As pointed out in the recommendation, the retrieval of data after a crash might be an added benefit, but was not the ATSB prime objective in making this recommendation. Enhancement of real-time fuel and engine system operation information available to the crew to better manage safety of flight and thereby operate their aircraft at higher levels of safety was the driver. Additional benefits may also be improved reliability and reduced maintenance costs and finally as a possible investigative tool.


* Have limited capacity in terms of data channels which can be recorded, in that the data that may be important to an investigation cannot be recorded.

Again for the reasons stated above this was not the ATSB prime objective in making this recommendation and therefore should not be the focus in the CASA decision making process. The issue of channel availability can be addressed on an individual installation basis by consultation with the manufacturer. We are told that these individual needs can be addressed and systems designed to suit.

In light of this information, the ATSB would invite CASA to reconsider its response on this matter.

 
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Last update 03 April 2012