We have met the enemy and he is us. (Pogo)  








SEPTEMBER 15, 1999

A compromise is the art of dividing a cake in such a way that everyone believes he has the biggest piece.- Ludwig Erhard


Madame Chair, Mr. Traficant, Members of the Subcommittee:

I am Tom McSweeny, the Associate Administrator for Regulation and Certification of the Federal Aviation Administration ("FAA"). I am pleased to be here today to discuss with you aircraft electrical system safety. The FAA's Regulation and Certification division is the line of business of the FAA responsible for the oversight of aircraft systems, both structural and non-structural. This afternoon, I would like to discuss with you the FAA's aging aircraft program, and in particular, our focus on non-structural components, including aircraft wiring. Joining me this morning is Beth Erickson, the Director of our Aircraft Certification Service.

Following the Trans World Airlines Flight 800 tragedy, President Clinton established the White House Commission on Aviation Safety and Security, chaired by Vice President Gore ("Commission" or "Gore Commission") in August 1996. The Gore Commission delivered its final report to the President on February 12, 1997, which contained numerous recommendations to improve the safety and security of our National Airspace System ("NAS"). Among the many recommendations, the Gore Commission specifically identified the need for the FAA to expand its Aging Aircraft program to include non-structural systems.

The FAA has been aware of the need to scrutinize aging aircraft structural systems, and placed additional emphasis on aging structures, since a 1988 incident involving a Boeing 737 in Hawaii. In that incident, the aircraft suffered severe structural failure of the forward fuselage sections due to corrosion and disbonding which was not visible through normal maintenance inspections.

The FAA expanded its structural integrity inspection program by forming the Aging Aircraft Program. The FAA developed an approach to deal with aging structural issues by first focusing on older aircraft used in commercial service and with a focus on gathering and using data for decision-making. This included a comprehensive review of service information and conducting detailed inspections and research. The data and information were then used to develop a comprehensive system of focused actions. These actions ranged from issuing airworthiness directives ("AD's"), developing enhanced maintenance protections, conducting training for FAA personnel and aviation industry personnel, and conducting research programs. Since the introduction of this program, there has not been another aging structures related accident. We believe that by all measures, the program and its comprehensive approach have been successful.

As correctly noted by the Gore Commission report, the FAA aging aircraft program related only to the structural components of aircraft. At that time, there were no service data that indicated a need to give the non-structural systems of the airplanes the same enhanced scrutiny we gave to the structures. Because of a concern that maintenance and inspection procedures may not be sufficient to prevent safety related problems caused by the deterioration or damage of non-structural components, the Gore Commission recommended that the FAA work with airlines and manufacturers to expand the aging aircraft program to include non-structural components, through steps including: full and complete tear-downs of selected aircraft scheduled to go out of service; the establishment of a lead-the-fleet research program; an expansion of the cooperative aging aircraft program between the FAA, the Department of Defense and the National Aeronautics and Space Administration ("NASA"); and, encouraging the development of modern technical means to ensure and predict the continued airworthiness of aging non-structural components and systems.

Pursuant to the Gore Commission's recommendations, the FAA established an Aging Non-Structural Systems Plan. This plan went beyond the Gore Commissions recommendations to focus on wiring by including all systems on an aircraft, including electrical and hydraulic systems. The FAA formed the Aging Non-Structural Systems Study team. Led by the FAA's Transport Airplane Directorate ("TAD"), the team was comprised of FAA employees and industry personnel. The team developed several initiatives to re-examine the FAA's approach to aging systems and to ascertain the scope of any problems. Three on-site visits to maintenance facilities were accomplished.

As with the aging structures program, the FAA began with data collection, including the examination of the state of the fleet with a sampling of older aircraft. Three DC-10's, a DC-9 and a Boeing 727 were evaluated. These aircraft were selected because they represent the core of the domestic airline fleet considered aging: the DC-10's were all over 24 years old and had in excess of 24,000 cycles (cycles represent the number of landings that an aircraft experiences over the course of its life), the DC-9 was 29 years old and had approximately 70,000 cycles, and the 727 was 19 years old and had approximately 21,000 cycles. Evaluations of these aircraft were primarily based on visual inspections with a special emphasis on wiring, lightning protection, hydraulics and flight control systems. At the time of the FAA's team inspections, these aircraft were undergoing heavy maintenance visits. A "heavy maintenance visit" requires that an airplane be out of service for approximately two to five weeks. This level of inspection and maintenance is typically performed every three to five years. During such maintenance, most of the airplane's major systems are available for viewing because skin panels, outer body fairings, seats, galleys, and floor panels are removed. In addition to these on-site evaluations, the team conducted a number of meetings with a group of the FAA's Principal Maintenance Inspectors who are tasked with oversight of the major carriers, to assess their concerns with respect to aging aircraft.

The on-site inspections revealed some deterioration of wiring components. However, none of these situations presented immediate safety concerns. Contamination of wire bundles in some areas was evident. The team also found that maintenance practices and guidance to mechanics needed improvement. The team also believed that a systematic process to identify and address potential catastrophic failures caused by electrical faults of wiring systems was needed.

From the observations and recommendations in this initial study, the FAA developed a comprehensive plan for the non-structural components of aging aircraft. An Aging Transport Systems Oversight Committee ("Committee") was established in September 1998. Membership on the Committee is drawn from across the FAA professional workforce, including representatives from the Flight Standards Service and Aircraft Certification Service divisions. This Committee has the primary responsibility to manage the overall aging transport non-structural systems plan. The Committee is pro-active and is working with an industry advisory committee to initiate research projects, participate in industry fleet reviews, sponsor periodic technical exchanges with the Department of Defense and NASA, identify training needs for FAA and industry personnel in wiring practices, and develop with industry a better reporting system which will allow more visibility to incidents and maintenance actions which have an aging system root cause or component.

To facilitate broad governmental and industry participation, both domestically and internationally, in October 1998, Administrator Garvey established the Aging Transport Systems Rulemaking Advisory Committee ("ATSRAC"). ATSRAC was created to provide a mechanism for public input into the FAA's activities with respect to the overall plan for aging systems on aircraft. The ATSRAC serves the public interest by providing a forum for interaction among the FAA, the Department of Defense, NASA, airlines, labor organizations representing pilots and mechanics, manufacturers and their representatives. The level of expertise and balanced viewpoint will enable the committee to identify necessary actions for both long-term improvements and, at the earliest possible moment, the potential for problems and accelerate development of appropriate corrective action.

In establishing the ATSRAC, the Administrator charged the committee with several tasks. Among them: (1) to review service histories, service bulletins and service letters for the aging transport fleet which pertain to aging systems for possible mandatory action and provide recommendations to the FAA; (2) to conduct evaluations of in-service transport airplane models; (3) to provide recommendations to the FAA for improvements to airplane maintenance to better address aging airplane systems, including the study of inspection criteria for systems; and (4) to propose revisions to the Federal Aviation Regulations ("FAR's") and associated guidance material as may be appropriate to institutionalize the lessons learned from the aging systems program.

It is important to note that in many respects, the FAA and indeed, the entire aviation industry, are only now beginning to have a greater appreciation and understanding about the need to examine non-structural aspects of our aircraft. The so-called "aging aircraft fleet" will soon include those aircraft that were introduced in the early 1980's. Aircraft such as the Boeing 757, 767, and the Airbus A300, have been in service for 15 years. These aircraft designs include substantially more electronic equipment and wiring. More importantly, the introductions of new aircraft, such as the Boeing 777, are increasingly relying on more electronics for flight.

The FAA is moving aggressively to address concerns with respect to the effects of aging on aircraft non-structural systems. Like our aging structures program, the FAA is working to ensure that our non-structural program is data driven. We are just beginning to collect the data necessary to assist us in our efforts. It is important to recognize that we must prioritize our actions to identify the interventions that will yield the highest level of safety benefit.

Through our fleet sampling inspections, the comprehensive review of service data and research and development projects, the FAA is continually working to develop a systemic and data-driven strategy. It is important to note that we are not waiting to complete our review of the aircraft fleet or service data. We are taking corrective actions as we progress. For example, the FAA has already issued over 20 airworthiness directives addressing wiring within fuel tanks and fuel pumps, in the wake of the TWA Flight 800 incident. In addition, the FAA has issued several airworthiness directives on the MD-11 aircraft regarding the wire harnesses within the aircraft structure.

We are confident that this approach to non-structural aircraft systems is already proving beneficial and making improvements for the continued safe operation of the civilian aircraft fleet. We are confident that our record of success with respect to structural systems is being replicated with non-structural systems. As we move forward with our non-structural aging systems program, we will continue to learn and make decisions to enhance the safe operations of our civilian aircraft fleet.

This concludes my prepared testimony. I would be pleased to answer any questions that you and the Members of the Subcommittee may have. 

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