Via twitter friend Steve M. (@PUBspotter) comes this fascinating article by John Goglia from AIN Online entitled “Torqued: FAA must get it’s act together on ADs.”
In a nutshell: the FAA is issuing Airworthiness Directives without thoroughly reviewing them for accuracy, necessity, or mechanical feasibility. The AD process is apparently plagued by technical inaccuracy and selective enforcement. The article specifically questions action taken against mechanics regarding AD 2004-13-06, applicable to the Airbus 318/319/320/321.
The AD involves removal of a pump and an accumulator, and inspection of ‘the area around the rivets’ for cracking. The problems begin with the process outlined to access the area to be inspected. Quote:
So here is the first accuracy issue with the AD: it requires–via the Airbus Service Bulletin that’s incorporated by reference–that the pump be removed first and then the accumulator. Once the inspection is completed, it requires the pump to be re-installed followed by the accumulator. It doesn’t take a mechanic to figure out that there’s something wrong with these directions: when removal of parts is done sequentially, their re-installation is also done sequentially but in the reverse order. So if the pump were removed first, for example, it would normally be re-installed last. In this case, if the steps were followed as required by the AD, they could be accomplished but it would take significantly longer than removing the accumulator first and then the pump, and then reinstalling the pump and then the accumulator. According to the FAA, sequential steps in an AD must be followed sequentially even if the outcome, as in this case, is absurd.
But, regardless of the order in which these components are to be removed, the FAAcontended that the detailed visual inspection of the “area around the rivets” for cracks required by the AD could not have been accomplished without removal of those components. Without going into whether an inspection of the area under those components could be done without their removal, the issue here is that there are no rivets (as the term is defined by Airbus in its manuals, which are the manuals that apply to this AD) under these components. If there are no rivets, then mechanics can’t inspect for cracks around them–with or without the components removed.
So there’s the second accuracy issue: while there are no rivets under these components, there are fasteners–Hi-Lok pin fasteners to be specific–and it could be that Airbus in its Service Bulletin meant for the mechanics to inspect for cracks in the area around the fasteners. Maybe that’s what the FAA meant when it issued the AD. Maybe not. Maybe the rivets are somewhere else on the keel beam. Maybe they’re under different components. But are mechanics supposed to guess? Are mechanics’ licenses subject to revocation if they fail to conclude that Airbus meant “fastener” when what was written was “rivet” even when Airbus’s own manual differentiates between fasteners and rivets? According to Airbus’s manual, all rivets are fasteners but not all fasteners are rivets.
Scary stuff. It sounds as though the FAA is issuing inaccurate ADs that require impossible or illogical workflow, then punishing mechanics for working around the AD. It’s armchair flying at it’s worst: I’d like the guy who maintains my airplane to be free to do it correctly, and not constrained by inaccurate and unreasonable paperwork. As Mr. Goglia writes:
If the FAA doesn’t scrutinize ADs for large aircraft that carry millions of people around the world, just how much scrutiny do you think it’s giving ADs applicable to GA aircraft?
Aviation needs administrative oversight. There must be rules, and there must be safety requirements. Unfortunately, we appear to have a system that’s all paperwork and no real oversight, and it seems unlikely that it will improve anytime soon.