The FAA is proposing a civil penalty of $13.57 million against the Boeing Company for failing to meet a deadline to submit required service instructions.

Back in 2008, the FAA published Fuel Tank Flammability Rule, which required manufacturers to develop design changes and service instructions for installing systems to further reduce fuel tank flammability. Boeing committed to meeting the statutory December 2010 deadline.

Instead the manufactured delivered the requires information to the FAA and operators, 301 days late for 747 model aircraft and 406 days late on the 757 model. In total 383 US registered Boeing planes are affected by the delays

Press release:
http://www.faa.gov/news/press_releases/news_story.cfm?newsId=13776

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Is it just me or is the FAA just a little too far-reaching into the aviation industry?

Quoting PHX787 (Reply 1): Is it just me or is the FAA just a little too far-reaching into the aviation industry?

Well, they are the Federal Aviation Administration, after all.

  

Quoting jetmatt777 (Reply 2): Well, they are the Federal Aviation Administration, after all.

LOL true but it still seems like they're doing more than they need to..


but on the flip side of the coin, we haven't had much in the way of fatal accidents in the last few years

Quoting PHX787 (Reply 3): LOL true but it still seems like they're doing more than they need to..

We have a federal budget deficit. $$

Quoting PHX787 (Reply 1): Is it just me or is the FAA just a little too far-reaching into the aviation industry?

Not only is this a right the FAA has, it's the FAA's mandate. While the agency is tasked with the promotion of aviation, punitive measures need to be taken in some cases.

As we've seen recently with DL, UA, AA, and several times with WN, the agency is making it a priority to promote good maintenance practices and punish risky decisions. The finding against DL was a little flimsy, I'll admit...but this finding against Boeing is more than justified. They were instructed to issue a bulletin and they dragged their feet. Since there was already one major accident attributed to this (TWA800), this was NOT something to delay. I'm a big fan of Boeing products, but neglecting this issue was not the best move on their part.

Quoting PHX787 (Reply 3): but on the flip side of the coin, we haven't had much in the way of fatal accidents in the last few years

Most of that is due to FOQA and better training and maintenance practices. FAA's threats to levy fines do add a certain level of motivation, too.

Quoting Goldenshield (Reply 4): We have a federal budget deficit. $$

I'll assume this was sarcasm. $13m in the grand scheme of things doesn't make a damn bit of difference to a deficit.

Quoting PHX787 (Reply 1): Is it just me or is the FAA just a little too far-reaching into the aviation industry?

What, there's something wrong with the FAA holding Boeing accountable for failing to meet a deadline they committed to on a safety-related item?

If you're going to have regulations, they need to be enforced. Otherwise, what's the point of having them?

-Mir

[Edited 2012-07-13 16:04:11]

Quoting atcsundevil (Reply 6): I'll assume this was sarcasm. $13m in the grand scheme of things doesn't make a damn bit of difference to a deficit.

In an industry where removing 100lbs of weight from an aircraft is a big deal, you'd think we'd be used to such penny-pinching.. Sure, 13.6m in the "grand scheme" doesn't seem like much, but it all adds up eventually.

Quoting PHX787 (Reply 1): Is it just me or is the FAA just a little too far-reaching into the aviation industry?

Seems they are not far-reaching enough as companies do not live up to requirements. Would love to know how they figure out the fines.

Quoting atcsundevil (Reply 5): this finding against Boeing is more than justified. They were instructed to issue a bulletin and they dragged their feet.

Is there any evidence they dragged their feet? SB's are complicated beasts, especially for situations like this. It's possible Boeing just underestimated what it would take. SB's need to be certified too; it's not that unusual to have to sit on a draft SB for months trying to line up an aircraft to certify the thing on (this is a much worse problem with out-of-production models).

Tom

Quoting ghifty (Reply 8): In an industry where removing 100lbs of weight from an aircraft is a big deal, you'd think we'd be used to such penny-pinching.. Sure, 13.6m in the "grand scheme" doesn't seem like much, but it all adds up eventually.

If you read what I was responding to -- this wasn't what I was referring to. I was referring to the federal deficit and the assertion that this was somehow an attempt to "close the gap." I'm well aware of what implications a $13m fine can mean to an airline or a manufacturer.

Quoting tdscanuck (Reply 10): Is there any evidence they dragged their feet? SB's are complicated beasts, especially for situations like this. It's possible Boeing just underestimated what it would take. SB's need to be certified too; it's not that unusual to have to sit on a draft SB for months trying to line up an aircraft to certify the thing on (this is a much worse problem with out-of-production models).

Yep exactly Tom. I don't know about the 747 but the 757 was delayed as Boeing and the FAA fought over what Boeing considered prepriority data. So the FAA was involved the entire time this was in discustion...yet they fine Boeing.

This is good news.

There has been far too close a relationship between the regulator, operator and OEMs. You only need to go back the last two decades and read the reports on the rudder issues, cargo doors, engine pylons and no doubt more I've missed, to see a very laid back and reactionary culture existing between the FAA, the OEMs and the airlines (all in the name of saving a buck).

How many lives has this cosy threesome cost?

And just to add salt into the wounds:

The US National Transportation Safety Board says an engine fire on an American Airlines Boeing 767-300ER in February would not have occurred had the Federal Aviation Administration issued an airworthiness directive after a similar problem in 2006.

http://www.flightglobal.com/news/art...cf6-directive-in-2006-ntsb-374366/

View Large View Medium Photo © Gustavo Bertran - Iberian Spotters

View Large View Medium Photo © Michael Carter

Quoting imiakhtar (Reply 13): There has been far too close a relationship between the regulator, operator and OEMs.

Have you ever actually worked with an aviation regulator? "Close" is not exactly the right word to describe the relationship. "FAA: We're not happy unless you're not happy" is closer to the mark.

Quoting imiakhtar (Reply 13): You only need to go back the last two decades and read the reports on the rudder issues, cargo doors, engine pylons and no doubt more I've missed, to see a very laid back and reactionary culture existing between the FAA, the OEMs and the airlines (all in the name of saving a buck).

Not a single one of those events was done intentionally; as soon as they knew what was wrong the problem was fixed. You can argue that maybe the problem should have been detected sooner but the problems didn't happen because of any coziness (or believed cost savings at the expense of safety). They happened because someone made an incorrect judgement, not a malicious one.

Crashes cost *far* more than you save by shorting safety; all the airlines and OEM's know that.

Quoting imiakhtar (Reply 13): How many lives has this cosy threesome cost?

Air travel is the safest form of transportation devised by man; it would be far more appropriate to measure how many lives they've saved.

Quoting imiakhtar (Reply 13): And just to add salt into the wounds: The US National Transportation Safety Board says an engine fire on an American Airlines Boeing 767-300ER in February would not have occurred had the Federal Aviation Administration issued an airworthiness directive after a similar problem in 2006.

If airplanes never took off we'd have a perfect safety record.

The NSTB's job is to determine what caused an incident and what you would need to do to stop that incident from happening again. It is *not* their job to determine if their recommendation is feasible or viable. That is the FAA's job. The NTBS recommends stuff that's unfeasble and/or unviable all the time; that's OK, that's their job. The FAA looks at the NTSB recommendations and implements those that are feasible and viable and rejects those that aren't; that's OK too...that's *their* job.

Tom.

Quoting atcsundevil (Reply 6): I'll assume this was sarcasm. $13m in the grand scheme of things doesn't make a damn bit of difference to a deficit.

I was being sarcastic, yet at the same time, making a point. Congress wants to strip the DOT, and especially the FAA of non-vital funds. While you're right, $13M will barely put a dent in a company's budget, if congress gets its way, then say goodbye to a huge chunk of the federal deposit to aviation general fund, which pays for a lot of FAA programs, and construction. Thus, the FAA will have to start being self supporting, which means more fines being levied to a lot more places, more often.

Quoting tdscanuck (Reply 14): Air travel is the safest form of transportation devised by man; it would be far more appropriate to measure how many lives they've saved.

As most statistics it depends on how you measure. Aviation is very safe when measured per passenger km. Measure by vehicle km, trips or hour and the result changes. All are valid measurements but vehicle km may be more proper measurement of individual risk.

Quoting cmf (Reply 16): As most statistics it depends on how you measure. Aviation is very safe when measured per passenger km. Measure by vehicle km, trips or hour and the result changes.

Aviation is also very safe when measured by vehicle km. The breakeven between aircraft and cars is about 500 miles (above that, aircraft are safer). It's mostly an effect of aircraft risk being primarily cycle based and vehicle risk being primarily distanced based. The aircraft risk doesn't grow much with travel distance.

Tom.

Quoting cmf (Reply 16): Quoting tdscanuck (Reply 14): Air travel is the safest form of transportation devised by man; it would be far more appropriate to measure how many lives they've saved. As most statistics it depends on how you measure. Aviation is very safe when measured per passenger km. Measure by vehicle km, trips or hour and the result changes. All are valid measurements but vehicle km may be more proper measurement of individual risk.

I don't really get you reasoning. A 747 crashing once a month would seem to obviously be a much greater impact on airline safety that a Cessna 402 crashing every month. If a person is travelling somewhere, he's going to be travelling about the same km, no matter how he does it, so safety comparisons would seem to mean more figured by passenger km.

In this case, it doesn't depend on how you measure it. With 24,000 or so vehicle deaths in the US last year and almost no commercial avition deaths you can figure it any way you want, and it's still as lopsided as it can be. The ratios for the rest of the world would be different since few countries have folks who drive as much as Americans, but I'd be surprised if aviation didn't still come out as safest by a longshot no matter how you measured it.

Quoting tdscanuck (Reply 14): Not a single one of those events was done intentionally; as soon as they knew what was wrong the problem was fixed.

Are you serious?

In many of those instances, the OEMs were aware of the underlying design flaws and yet the FAA was only too happy for airlines to carry on flying another 6 months or whatever before mandatory compliance.

Lets take United 811 as an example. Two years prior, a PanAm 747 failed to pressurise climbing out of LHR due to a failure of the cargo door latching mechanism. Once the flaw was discovered, the FAA gave airlines 18 months to implement the fix. Maybe the cost of compliance was too "great" for the airlines and they along with Boeing leaned on the FAA - I don't know. Result? Nine people dead.

Quoting tdscanuck (Reply 14): Air travel is the safest form of transportation devised by man; it would be far more appropriate to measure how many lives they've saved.

Complacency kills. It's disappointing to hear that coming from an engineer.

Quoting LAXintl (Thread starter): The FAA is proposing a civil penalty of $13.57 million

Exactly where do the funds for fines wind up? Do they stay with the FAA or is it divide up somehow?

Quoting beau222 (Reply 20): Exactly where do the funds for fines wind up? Do they stay with the FAA or is it divide up somehow?

Fines normally go into the general fund.

Quoting imiakhtar (Reply 19): In many of those instances, the OEMs were aware of the underlying design flaws and yet the FAA was only too happy for airlines to carry on flying another 6 months or whatever before mandatory compliance.

Airplanes don't suddenly become less safe when a safety problem is discovered. Almost all ADs and Service Bulletins that are safety related have compliance times. Without compliance times the fleets would be grounded on an almost weekly basis. That 6 month window was decided based on engineering analysis just like the fix was. It was not about happy or not.

Opinions don't create service bulletins, engineering does after quite a bit of research analysis and design. A service bulletin and design change like mentioned is complex involving dozens of different engineering disciplines. We all wish it could be done faster but sometimes investigations and engineering work draws out over a year.

Quoting PHX787 (Reply 1):

No. The FAAs job is to find things and force them to be fixed. If we didn't have the FAA we wouldn't nearly have the safety we have now, IMO. Boeing, Delta, Southwest, American etc. can NOT stand getting fined by the FAA. Most of the time the money itsn't much, its the terrible PR that gets them.

Quoting Mir (Reply 7):

very very true.

Quoting tdscanuck (Reply 14): Have you ever actually worked with an aviation regulator? "Close" is not exactly the right word to describe the relationship. "FAA: We're not happy unless you're not happy" is closer to the mark.

lol true that. FAA is the boss 100%. Not much meeting half way.

Quoting Goldenshield (Reply 15): Thus, the FAA will have to start being self supporting, which means more fines being levied to a lot more places, more often.

yep. This had good sides and bad sides. (good sides would be it will greatly reduce the chance of any kind of buddy-buddying but the bad side is it may force the FAA to fine things that normally wouldn't/shouldn't be fined.)

Quoting Roseflyer (Reply 22): Without compliance times the fleets would be grounded on an almost weekly basis

10x if it was for every single AD. I would bet money that if you come to Atlanta and go to TechOps you can find something every hour of the day that has to do with an AD. It can be a light bulb to a cargo door. The parts/people/space would simple kill Aviation.

Quoting tdscanuck (Reply 14): Have you ever actually worked with an aviation regulator? "Close" is not exactly the right word to describe the relationship. "FAA: We're not happy unless you're not happy" is closer to the mark

For someone who apparently works in the industry that's a horrendous thing to say. What a cavalier and dangerous attitude to airworthiness.

Quoting tdscanuck (Reply 14): They happened because someone made an incorrect judgement, not a malicious one

You're bleating for evidence that Boeing 'dragged their feet' (a term which seems to downplay the seriousness of Boeing's problem), yet you're making sweeping statements about 'incorrect judgements'?

Quoting tdscanuck (Reply 10): SB's are complicated beasts, especially for situations like this.

If Boeing don't like FAA-endorsed processes they can feel free not to build commercial aircraft.

Of course, had Boeing designed the 747 FQIS in an intrinsically safe way in the first place then they wouldn't have to adopt this SB.

Quoting 777236ER (Reply 24): For someone who apparently works in the industry that's a horrendous thing to say. What a cavalier and dangerous attitude to airworthiness.

I work with another similarly-regulated industry on a daily basis, and I'd say that his statement is largely accurate, especially under the current administration. Too many regulators with too large egos. Sometimes, the industry tries to do the right thing and it bites them in the butt. Sometimes - but not always - the adversarial relationship is justified.

Quoting tdscanuck (Reply 17): Aviation is also very safe when measured by vehicle km. The breakeven between aircraft and cars is about 500 miles (above that, aircraft are safer). It's mostly an effect of aircraft risk being primarily cycle based and vehicle risk being primarily distanced based. The aircraft risk doesn't grow much with travel distance.

As you say the risk in aviation is based on cycles. Combine that with that the average trip is much longer than the average trip of any other form of transportation and you have stacked everything to favor aviation. Use passenger km and you have stacked the deck even more.

I am surprised the break even is 500 miles. I expected much much less. What percentage of car trips are 500 miles? I don't have statistics but would expect less than a hundredth of a percent. Think the median car trip about 3 miles?

Quoting nomadd22 (Reply 18): I don't really get you reasoning. A 747 crashing once a month would seem to obviously be a much greater impact on airline safety that a Cessna 402 crashing every month. If a person is travelling somewhere, he's going to be travelling about the same km, no matter how he does it, so safety comparisons would seem to mean more figured by passenger km.

People use different forms of transportation depending on how far they are traveling so no it isn't about the same km no matter how. By that logic the more appropriate measurement is by trip. Incidentally what insurance companies tend to use.

Quoting nomadd22 (Reply 18): In this case, it doesn't depend on how you measure it. With 24,000 or so vehicle deaths in the US last year and almost no commercial avition deaths you can figure it any way you want, and it's still as lopsided as it can be. The ratios for the rest of the world would be different since few countries have folks who drive as much as Americans, but I'd be surprised if aviation didn't still come out as safest by a longshot no matter how you measured it.

You're missing how vastly different the number of trips are. It doesn't take much of a city to have more car trips than there are flights in the country in the same period.

When using statistics it is extremely important to understand the circumstances where it is used. Measured by trip air is about 3 times as dangerous as a car ride. Surprisingly it is the same by foot which by other measures is very dangerous.. You're about 30 times more likely to get killed when getting on a plane than on a bus.

Measure in time air and trains are about equal and buses much safer. Mesured by distance air knocks everything else out but it doesn't mean air is safest. It means that you need to understand the situation where you use the statistcs.

The only consistent is that motorcycles are very dangerous no matter how you measure.

Quoting beau222 (Reply 20): Exactly where do the funds for fines wind up?

Isn't there a lot of much more important issues? For example, is it the right amount to make the parties comply in the future?

Quoting Roseflyer (Reply 22): Airplanes don't suddenly become less safe when a safety problem is discovered.

No, but it is when we find out they are not as safe as we thought.

Quoting imiakhtar (Reply 19): Are you serious?

Yes.

Quoting imiakhtar (Reply 19): In many of those instances, the OEMs were aware of the underlying design flaws and yet the FAA was only too happy for airlines to carry on flying another 6 months or whatever before mandatory compliance.

You're talking about compliance intervals...as others have said, there is no other realistic option. If every AD was an emergency issue with instant compliance there would be no commercial air travel. That defeats the entire purpose of the industry.

Quoting imiakhtar (Reply 19): Lets take United 811 as an example. Two years prior, a PanAm 747 failed to pressurise climbing out of LHR due to a failure of the cargo door latching mechanism. Once the flaw was discovered, the FAA gave airlines 18 months to implement the fix

Exactly. They did the safety calculation based on the time to implement and the relative safety gain and figured out what they believed was a safe interval. It turned out they were wrong (this always happens when you're working with statistics). Are you really suggesting they should have grounded the fleet for that one?

Quoting imiakhtar (Reply 19): Maybe the cost of compliance was too "great" for the airlines and they along with Boeing leaned on the FAA - I don't know. Result? Nine people dead.

All airlines complied; the balance is how do you do it without cancelling thousands of flights and grounding the fleets for weeks. Part of the issue is that, even if incorporating the SB only takes a day, you don't have enough manpower to do all aircraft in parallel and you don't have enough parts available all at once. If you don't do compliance intervals you ground airplanes for weeks, minimum. Typically months. The FAA's mandate is to provide a safe, viable air transport systems, which they do. It's not to have zero deaths at the expense of everything else.

The airlines and OEM's have no ability to lean on the regulators; it's like arguing with a border guard, you don't have any leverage. They just say "no" and that's it.

Quoting imiakhtar (Reply 19): Complacency kills. It's disappointing to hear that coming from an engineer

It's not about complacency; when a safety issue is identified it's dealt with as fast as the system can handle it. It's disappointing to hear someone denigrate the phenomenal safety records of tens of thousands of engineers who make air travel possible, especially when the aircraft engineers have done it about three orders of magnitude better than any other mode of transportation.

Quoting 777236ER (Reply 24): Quoting tdscanuck (Reply 14): Have you ever actually worked with an aviation regulator? "Close" is not exactly the right word to describe the relationship. "FAA: We're not happy unless you're not happy" is closer to the mark For someone who apparently works in the industry that's a horrendous thing to say.

How so? I was accused (via my employer) of colluding with the FAA and airlines to put passenger lives at risk for financial gain. My point was that the relationship with the regulator is highly adversarial and they keep the airlines and OEM's honest; I wasn't criticizing what the FAA does, I was pointing out that the view of the FAA/OEM/airline relationship as "close" or "cozy" is simply inaccurate.

Quoting 777236ER (Reply 24): What a cavalier and dangerous attitude to airworthiness.

You lost me. I'm all in favour of fixing airworthiness as fast and as well as possible.

Quoting 777236ER (Reply 24): Quoting tdscanuck (Reply 14): They happened because someone made an incorrect judgement, not a malicious one You're bleating for evidence that Boeing 'dragged their feet' (a term which seems to downplay the seriousness of Boeing's problem), yet you're making sweeping statements about 'incorrect judgements'?

Someone accused Boeing of negligently delaying the introduction of a safety-critical SB. Asking for evidence that that's true, as opposed to the far more likely scenario that it simply took longer to develop the SB than expected, is hardly "bleating."

Similarly, someone accused multiple OEM's of *intentionally* allowing safety problems to go unresolved for financial gain; my point was that, in those cases where additional deaths may have occured, it was due to incorrect judgement, not intentional negligence.

Quoting 777236ER (Reply 24): Quoting tdscanuck (Reply 10): SB's are complicated beasts, especially for situations like this. If Boeing don't like FAA-endorsed processes they can feel free not to build commercial aircraft.

Nobody's saying that Boeing shouldn't have complied. All I took issue with was the (currently) baseless accusation that Boeing dragged their feet, as opposed to just took longer than they thought they would.

Quoting 777236ER (Reply 24): Of course, had Boeing designed the 747 FQIS in an intrinsically safe way in the first place then they wouldn't have to adopt this SB.

The 747 FQIS was intrinsically safe (all Boeing FQIS's are).

If you breach the wiring of an intrinsically safe system and connect higher voltage into it, the system is no longer intrinsically safe. That's a property of *all* intrinsically safe systems that's been known about a hundreds of year. No OEM can prevent bad maintenance practices from breaching security features.

Tom.

Quoting 777236ER (Reply 24): If Boeing don't like FAA-endorsed processes they can feel free not to build commercial aircraft.

Even if they did, they would still have to support their fleets. I fully agree that the design process and service bulletin process is painfully slow. There is so much coordination and planning involved that being on time is a challenge.

Boeing has airlines beating on them to get the fix correct so that they only have to do it once while the FAA is pushing for it faster. Faster often results in errors.

Quoting tdscanuck (Reply 27): If you breach the wiring of an intrinsically safe system and connect higher voltage into it, the system is no longer intrinsically safe. That's a property of *all* intrinsically safe systems that's been known about a hundreds of year. No OEM can prevent bad maintenance practices from breaching security features.

Which is what happened with the cargo door failure as well. The AD change was to make it even harder to breach the safeguards that ensured the door was properly locked prior to flight that workers had managed to compromise over time.

If you don't do the engineering work before you make a change... you can make the problem worse. Remember, the safety threshold for critical systems cant exceed one failure in a billion opportunities. Any changes you make have to reduce that opportunity and also make sure you don't adversely affect it anywhere else. Airplanes are highly complex interconnected systems. This is not a simple task. Boeing and Airbus both made hundreds of changes to remove all possible, unlikely ignition sources from the fuel tanks this was done in around 1999. All the likely ones were designed out from the start. The FAA rolled out a rule in 2006 to add nitrogen inerting systems into older airplanes. These NGS systems are complicated as well. You also have to make sure that the nitrogen generating system that you just connected to a fuel tank doesn't make the safety situation worse. Airplanes like the A380 still don't have any inerting systems though the 787 and new 737s do.

Its way more complicated than some of the comments above imply

Quoting tdscanuck (Reply 27): You're talking about compliance intervals...as others have said, there is no other realistic option. If every AD was an emergency issue with instant compliance there would be no commercial air travel. That defeats the entire purpose of the industry.

Quoting tdscanuck (Reply 27): Exactly. They did the safety calculation based on the time to implement and the relative safety gain and figured out what they believed was a safe interval. It turned out they were wrong (this always happens when you're working with statistics). Are you really suggesting they should have grounded the fleet for that one?

Quoting tdscanuck (Reply 27): All airlines complied; the balance is how do you do it without cancelling thousands of flights and grounding the fleets for weeks. Part of the issue is that, even if incorporating the SB only takes a day, you don't have enough manpower to do all aircraft in parallel and you don't have enough parts available all at once. If you don't do compliance intervals you ground airplanes for weeks, minimum. Typically months. The FAA's mandate is to provide a safe, viable air transport systems, which they do. It's not to have zero deaths at the expense of everything else. The airlines and OEM's have no ability to lean on the regulators; it's like arguing with a border guard, you don't have any leverage. They just say "no" and that's it.

You hit the nail on the head when you said it was about finding a balance. Prescribing a 30 day compliance period for every issue would be unworkable.

However, taking the cargo door as an example again, given past troubles with the DC-10 and the catastrophic failures encountered, following the Panam 747 failure, red lights should have been flashing at the FAA. For a regulator to then come up with an 18 month compliance period is downright negligent.

If this had been a one off, it could have been forgiven. But then we see parallels with rudder issues and 747 engine pylons.

December 1991 - China Airlines # 3 engine separation - crashed
October 1992 - El Al # 3 engine separation - crashed
March 1993 - Evergreen # 2 separation - landed


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Photo © Kris Kjelstrup


More than 12 months after the initial accident, aircraft were still flying in an unsafe condition. But then the OEMs and Airlines are covered by insurance and don't lose a penny. Passengers and crew on the otherhand.......

Quoting imiakhtar (Reply 30): For a regulator to then come up with an 18 month compliance period is downright negligent.

So 18 months is wrong . . .

Quoting imiakhtar (Reply 30): More than 12 months after the initial accident, aircraft were still flying in an unsafe condition.

. . . and so is 12 months. What's the right answer? And why do you know better than FAA?

Quoting imiakhtar (Reply 30): More than 12 months after the initial accident, aircraft were still flying in an unsafe condition. But then the OEMs and Airlines are covered by insurance and don't lose a penny. Passengers and crew on the otherhand.......

I have never seen a mandatory safety change that required new hardware implemented in under 12 months. I think you underestimate the work involved.

I have worked such a problem before and it takes a lot of coordination and work to get new hardware on a plane. If you would like me to explain all the steps I can.

Quoting cmf (Reply 26): I am surprised the break even is 500 miles. I expected much much less. What percentage of car trips are 500 miles?

In hindsight, that does sound high. The number was in my head because my former employer (non-aviation) had *huge* driving exposure so they directed everyone to fly if the trip was more than x miles...I thought it was 500 but, on reflection, it had to have been shorter. I remember it being something like 5-6 hours driving, so it was probably 250 miles. But that was more than a decade ago; air travel has gotten safer (statistically) since then so the breakeven distance is probably lower than that now.

Quoting imiakhtar (Reply 30): More than 12 months after the initial accident, aircraft were still flying in an unsafe condition.

You're lucky to have a fully complete investigation 12 months after a major accident, and the final investigation report is typically the *start* of the AD process. Then you have to do the NPRM, the comment period, actually devise the engineering fix, write the SB, validate the SB, certify it, then ship several thousand parts kits.

It's also important to note that the other flying aircraft are exactly the same before and after the accident; the fact that the accident occurs doesn't make the other airplanes any less safe than they already were. I guarantee that every airplane you fly on today has such conditions on it right now (every type gets AD's at a pretty regular rate, which means they're flying around right now with the issues that future AD's will address); are you going to not fly?

Quoting imiakhtar (Reply 30): But then the OEMs and Airlines are covered by insurance and don't lose a penny.

They both lose huge; they may have insurance for direct liability costs (I suspect the OEM's are actually self-insured on that anyway) but they have no financial protection from lost business, litigation costs, the *huge* cost of developing, certifying, delivering, and supporting the fix, etc. It is, by far, cheaper to get it right the first time.

*Even if* it was all about the money (and it's not) it would still make good business sense to fix the issues as soon as you can.

Tom.

Quoting tdscanuck (Reply 27): My point was that the relationship with the regulator is highly adversarial and they keep the airlines and OEM's honest; I wasn't criticizing what the FAA does, I was pointing out that the view of the FAA/OEM/airline relationship as "close" or "cozy" is simply inaccurate.

Unlike with A.netters who solve all issues within hours, the cause of a problem, lab duplication, design (both for new a/c and for retrofit which may include more models than the failure), certification, SB preparation and certification, take months.. Then when approved, parts and tools need to be built and shipped, fleet down times coordinated. Major S/B's are not duct tape patches. I recall a 707 S/B that the new cast forged strap had a 18 month lead time and the maximum lot size was 6. I took us 2 years to retrofit the affected fleet.

Now Boeing and the FAA personnel know each other, respect each other, work with each other, however the FAA is always in charge even when they are in error. They are anal in their tasks, the only way to get them to laugh is to out anal them in preparation. (I did pre audits before FAA visits..)

But back to the subject, we read the news bulletin, and leap to judgement.. I seem to recall that Boeing found some issues with the system and requested extensions to ensure it was done correctly. These were denied. Then I saw that the design the FAA wanted to use was designed by an FAA engineer. That puts both the FAA and Boeing in an odd relationship, especially if there were design problems.

Quoting tdscanuck (Reply 33): Then you have to do the NPRM, the comment period, actually devise the engineering fix, write the SB, validate the SB, certify it, then ship several thousand parts kits.

The need for rulemaking is somewhat peculiar to FAA, though. To cite a similar - but not completely analogous - industry, the vast majority of recalls ordered by (or negotiated with) NHTSA by automobile manufacturers do not involve changes to the Federal Motor Vehicle Safety Standards and, accordingly, do not require rulemaking and can occur more quickly.

Quoting kanban (Reply 34): But back to the subject, we read the news bulletin, and leap to judgement.. I seem to recall that Boeing found some issues with the system and requested extensions to ensure it was done correctly. These were denied. Then I saw that the design the FAA wanted to use was designed by an FAA engineer. That puts both the FAA and Boeing in an odd relationship, especially if there were design problems.

Yep and a CAL 757 was the pilot project for the 757. That airplane flew around for months after the pilot project while the final SB was being worked on. After several months the SB was finally released.

Miles as a passenger or driver in a ground vehicle in the US is right around 3 trillion a year with 32,000 killed last year, or about 1 death per 100 million miles. About how many passenger air miles within the borders would there be?

Quoting tdscanuck (Reply 27): How so? I was accused (via my employer) of colluding with the FAA and airlines to put passenger lives at risk for financial gain. My point was that the relationship with the regulator is highly adversarial and they keep the airlines and OEM's honest; I wasn't criticizing what the FAA does, I was pointing out that the view of the FAA/OEM/airline relationship as "close" or "cozy" is simply inaccurate.

"Highly adversarial" is your subjective statement, and is bizarre when you're trying to claim you are trying to ensure airworthiness. You're defending practices that challenge airworthiness regulations - written in blood - in a way which is wholly commercial.

Quoting tdscanuck (Reply 27): I'm all in favour of fixing airworthiness as fast and as well as possible.

It doesn't look like it when you're defending Boeing for their (in your view) incompetence when it comes to safety.

Quoting tdscanuck (Reply 27): All I took issue with was the (currently) baseless accusation that Boeing dragged their feet, as opposed to just took longer than they thought they would.

So Boeing's incompetence should be excused?

Quoting tdscanuck (Reply 27): The 747 FQIS was intrinsically safe (all Boeing FQIS's are). If you breach the wiring of an intrinsically safe system and connect higher voltage into it, the system is no longer intrinsically safe. That's a property of *all* intrinsically safe systems that's been known about a hundreds of year. No OEM can prevent bad maintenance practices from breaching security features.

An intrinsically safe FQIS wouldn't have allowed high energy into the fuel tanks. Are you now accusing TWA of poor maintenance, instead of the poor design of the 747 FQIS?

Let's be clear: Boeing's designs were unsafe. It took TWA800 for the FAA to act, and now 16 years later Boeing are still refusing to embody mandatory SBs in the time allocated by the FAA. Boeing's unsafe designs caused this problem, and they are either refusing to comply, or are so incompetent that they can't comply in time.

Quoting 777236ER (Reply 38): "Highly adversarial" is your subjective statement, and is bizarre when you're trying to claim you are trying to ensure airworthiness.

Bizarre how? What would you prefer, a cozy lovey-dovey setup? Which would advance safety how?

I suspect you're taking "adversarial" the wrong way.

Quoting 777236ER (Reply 38): So Boeing's incompetence should be excused?

Don't be putting words in people's mouths. Tom took argument with the position that Boeing was malicious, not incompetent. (and "incompetent" is almost surely too strong as well, but I've no facts to argue that -- and I suspect neither do you.)

Quoting 777236ER (Reply 38): An intrinsically safe FQIS wouldn't have allowed high energy into the fuel tanks.

There is no such thing as an 'intrinsically safe" FQIS by this definition, and about the only implementation that I can envision that comes anywhere close to this would also be one that is intrinsically unreliable, which in turn is also intrinsically unsafe. You are thinking way too simplistically, and it's becoming clear to me at least that you have some sort of axe to grind regardless of engineering or physical reality.

The FAA has been trying to justify its own exsistance for decades now. That is why a few times every year headlines are made by the FAA about some huge fine they imposed on the airlines or airframe and engine OEMs. It is almost always buried somewhere on page 25 in the newspapers later the FAA settled the fine dispute for only 10%-25% or the original fine.

Where were they during the almost one year Boeing was late with these SBs if the SB was so time critical? Why didn't they take a more pro-active approach and ask Boeing earlier why the SBs were not out in time? Was Boeing working on the engineering developement for the fuel tank flamability equipment, and testing of it? It would make no sense for Boeing, or any other OEM, to just put out a SB that didn't work just to please the FAA. These things take time, and sometimes it takes years.

So the real question that no one has asked is was the original time line the FAA gave to develope the fel tank flamability equipment realistic?

BTW, the AA B-767-200ER fire at LAX had nothing to do with this type of testing and engineering, the engine exploded and punchered the wing fuel tanks.

The FAA routinely ignors the recommendations of aircraft modification, crew training, etc. from the NTSB, and that does cost lives. Instead they consintrate on paperwork and not real life practical solutions.

Boeing is the only airliner manufacturer in the US and the FAA only has regulatory authority over them. They cannot regulate Airbus, BBD, Embraer, or anyone else.

This is one reason why I have always considered the FAA nothing more than a Boy Scout type organization, one that requires adult supervision.

I have worked with the FAA many, many times, and you never know what direction they are coming from. What one FAA Inspector says is often said to be illegal by another Inspector. They have no consistancy within the FAA.

Quoting 777236ER (Reply 38): An intrinsically safe FQIS wouldn't have allowed high energy into the fuel tanks. Are you now accusing TWA of poor maintenance, instead of the poor design of the 747 FQIS? Let's be clear: Boeing's designs were unsafe. It took TWA800 for the FAA to act, and now 16 years later Boeing are still refusing to embody mandatory SBs in the time allocated by the FAA. Boeing's unsafe designs caused this problem, and they are either refusing to comply, or are so incompetent that they can't comply in time.

Let's be clear, before TWA800, it was considered adequately remote that ignition sources requiring separate bonding and grounding in the fuel tank would result in catastrophic events. The design was considered safe, but then upon reviewing an event, the FAA acting on NTSB recommendations decided that additional fuel tank ignition prevention was necessary.

The designs weren't specifically unsafe or not. It was believed that it was remote enough to not be needed to be accounted for in certification which is typically 1*10^-9. TWA 800 proved that the original analysis for fuel tank ignition sources was inadequate. The FAA issued Special Federal Air Regulation 88 and required Nitrogen Generation Systems.

The change in regulations forced Boeing to redesign the fuel tank system. Adding Nitrogen Generation Systems and bonding and grounding requirements within the tanks is a difficult task. It's a very complicated retrofit system, which has taken years to develop a suitable design. I wouldn't use words like incompetence to describe designing a fully retrofitable system into an airplane that never had the provisions for it. I use words such as complicated, restricting, difficult, challenging, etc.

Again there is no Safe vs Unsafe emotional argument in aircraft design. It's all based on functional hazard assessments and system safety analysis. The criticality analysis indicates the the impact of a failure, and the probability necessary to meet the certification requirements. It's all based on analysis and probabilities. At times very rare events will happen, and the analysis is reviewed accordingly and often revised with new understanding.

Quoting 777236ER (Reply 38): You're defending practices that challenge airworthiness regulations - written in blood - in a way which is wholly commercial.

Which specific practice do you think I'm defending? I do defend compliance intervals; your counter-position appears to be that all AD's should be "mandatory compliance before further flight". In a highly philosophical way that is "safer" but only by shutting down all commercial air travel.

Aviation safety, like all safety systems, is a balance. You can't myopically grab onto one side of the balance and throw all the rest away.

Quoting 777236ER (Reply 38): It doesn't look like it when you're defending Boeing for their (in your view) incompetence when it comes to safety.

I said nothing about incompetence; you have variously claimed that Boeing was negligent, malicious, and/or incompetent. All I asked for is some evidence that any of the three are true; evidence which has so far not been provided.

Quoting 777236ER (Reply 38): Quoting tdscanuck (Reply 27): All I took issue with was the (currently) baseless accusation that Boeing dragged their feet, as opposed to just took longer than they thought they would. So Boeing's incompetence should be excused?

1) It's not necessarily incompetence; I've asked for evidence that it is and received nothing.
2) If it is incompentence, I'm not excusing it.

Quoting 777236ER (Reply 38): An intrinsically safe FQIS wouldn't have allowed high energy into the fuel tanks.

Correct. But if you remove the intrinsically safe barriers an intrinsically safe system is no longer intrinsically safe; that's not the fault of the intrinsically safe system.

Quoting 777236ER (Reply 38): Are you now accusing TWA of poor maintenance, instead of the poor design of the 747 FQIS?

Well, me, the NTSB, and the FAA. It's not exactly "poor maintenance", which is rather inaccurately pejorative of TWA, but "unrealized incorrect maintenance". The airline's didn't realize what their maintenance practices were doing to the safety features of the system. One of the big changes out of SFAR88 was to identify critical design, configuration, and control limitations (CDCCL's) in all the manuals so that maintenance crews know when actions they're taking may impact critical design featuers.

Quoting 777236ER (Reply 38): Let's be clear: Boeing's designs were unsafe.

No, they weren't. TWA's FQIS wasn't per design due to their maintenance practices. As designed, the system was intrinsically safe. If it had been maintained per the OEM instructions (Standard Wiring Practices Manual) it would have stayed that way. It wasn't maintained that way, the intrinsically safe barriers were un-intentionally breached, and the rest is history.

Quoting 777236ER (Reply 38): It took TWA800 for the FAA to act, and now 16 years later Boeing are still refusing to embody mandatory SBs in the time allocated by the FAA

Where is Boeing *refusing* to do anything? They didn't make the deadline; where is there any evidence that that happened because Boeing didn't want to?

Quoting 777236ER (Reply 38): Boeing's unsafe designs caused this problem, and they are either refusing to comply, or are so incompetent that they can't comply in time.

Boeing's "unsafe design" is exactly the same design that's been used on every aircraft since about the DC-3. So it's an industry design, not a Boeing design, to start with. The *design* isn't unsafe; it has some unsafe failure modes if it's not maintained, which is quite a bit different. Also, the *only* FQIS system in the business that's immune to the specific TWA failure is...tah dah...a Boeing design.

In addition, you've bucketed Boeing's response into two buckets: refuse to comply or incompetence...what is your basis for discarding the third (and in my view more likely) bucket: that they made discoveries during development that took more time than they originally forecast?

Quoting Roseflyer (Reply 41): The designs weren't specifically unsafe or not.

Actually, the 747 FQIS was specifically intrinsically safe when maintained as designed. All FQIS systems, as far as I know, are the same in that regard. SFAR88 was all about how the fuel system (not just FQIS) responds to failure modes.

Tom.

Quoting PITingres (Reply 39): Tom took argument with the position that Boeing was malicious, not incompetent

Quoting tdscanuck (Reply 42): I said nothing about incompetence; you have variously claimed that Boeing was negligent, malicious, and/or incompetent

Either Boeing are ignoring the FAA, or they can't comply with a simple safety-related SB. What's the third alternative?

Quoting PITingres (Reply 39): There is no such thing as an 'intrinsically safe" FQIS

Yes, there is.

Quoting Roseflyer (Reply 41): It was believed that it was remote enough to not be needed to be accounted for in certification which is typically 1*10^-9.

No, it wasn't. Boeing never carried out a quantitative safety analysis on the 747-100 FQIS. In fact, when they did provide the NTSB with a quantitative analysis the results were incredible. Not only did the submitted data include inconsistencies between tabular and graphical data, but Boeing included ridiculously short exposure intervals. So again, either Boeing were deliberately trying to mislead the authorities, or they incompetently carried our a post-accident safety analysis for submission to the NTSB. When they fail in basic safety assessments with such a spotlight on them, how much confidence does it give to more routine day to day analyses?

Quoting tdscanuck (Reply 42): I do defend compliance intervals; your counter-position appears to be that all AD's should be "mandatory compliance before further flight"

No, Boeing should comply with the FAA's mandates

Quoting tdscanuck (Reply 42): It's not exactly "poor maintenance", which is rather inaccurately pejorative of TWA, but "unrealized incorrect maintenance". The airline's didn't realize what their maintenance practices were doing to the safety features of the system.

Let's look at the report, shall we?

The condition of the wiring system in the accident airplane was not atypical for an
airplane of its age, and the airplane was maintained in accordance with prevailing
accepted industry practices.

Your insinuation that TWA weren't maintaining the aircraft correctly was wrong, and quite offensive.

Quoting tdscanuck (Reply 42): Quoting 777236ER (Reply 38): Let's be clear: Boeing's designs were unsafe. No, they weren't.

The NTSB, FAA and the relatives of 230 people disagree with you. What was incredible about this crash is it's a true single-failure system problem. A genuine design flaw that caused a catastrophic failure. And Boeing can't comply with flammability regulations 16 years later.

Quoting tdscanuck (Reply 42): Actually, the 747 FQIS was specifically intrinsically safe when maintained as designed.

Clearly it wasn't. There was no FQIS wiring segregation, no analyses of ignition sources, no protection against high energies entering the tanks.

Let's just remind ourselves of the NTSB's conclusion:

"Contributing factors to the accident were the design and certification concept that
fuel tank explosions could be prevented solely by precluding all ignition sources and the
design and certification of the Boeing 747 with heat sources located beneath the CWT
with no means to reduce the heat transferred into the CWT or to render the fuel vapor in
the tank nonflammable"

Had Boeing designed the 747 FQIS correctly in the first place there wouldn't be an FRS SB to implement today. Yet Boeing can't even develop that SB correctly 16 years after TWA800.

Quoting KC135TopBoom (Reply 40): Where were they during the almost one year Boeing was late with these SBs if the SB was so time critical? Why didn't they take a more pro-active approach and ask Boeing earlier why the SBs were not out in time?

Do you have anything to backup your insinuation that they weren't pro-active and didn't ask Boeing?

Quoting KC135TopBoom (Reply 40): So the real question that no one has asked is was the original time line the FAA gave to develope the fel tank flamability equipment realistic?

Airbus managed to do it in time. I think both of them are equally capable.

Quoting Roseflyer (Reply 41): The change in regulations forced Boeing to redesign the fuel tank system. Adding Nitrogen Generation Systems and bonding and grounding requirements within the tanks is a difficult task. It's a very complicated retrofit system, which has taken years to develop a suitable design. I wouldn't use words like incompetence to describe designing a fully retrofitable system into an airplane that never had the provisions for it. I use words such as complicated, restricting, difficult, challenging, etc.

I agree with all of this. But I think there is another very important question: What can we do to speed up the process? At least to me it seems unacceptable that a change deemed important for safety is taking the better part of an air-frames commercial life to identify and implement.

Quoting 777236ER (Reply 43): Either Boeing are ignoring the FAA, or they can't comply with a simple safety-related SB. What's the third alternative?

Simple safety-related Service Bulletin? SFAR88, is one of the most complex changes to aircraft design & maintenance that is being retrofitted that has ever been mandated. In my opinion SFAR88 has been the biggest change to maintenance programs since going from MSG-2 to MSG-3 analysis.

While I agree that delays are a problem, I also understand that this is a complex issue and can see why it got delayed and words like negligence and incompetence aren't the reason why I see it as so delayed.

Quoting cmf (Reply 44): I agree with all of this. But I think there is another very important question: What can we do to speed up the process?

That's a discussion that I absolutely think is worth having. I think all parties are involved in the lengthy process. An also important is why could Airbus do it and not Boeing?

Quoting imiakhtar (Reply 30): However, taking the cargo door as an example again, given past troubles with the DC-10 and the catastrophic failures encountered, following the Panam 747 failure, red lights should have been flashing at the FAA. For a regulator to then come up with an 18 month compliance period is downright negligent. If this had been a one off, it could have been forgiven. But then we see parallels with rudder issues and 747 engine pylons

So really, what your saying is that the complete 737 fleet should have been grounded (for years) until the rudder issues were really sorted out?
And, in your expert opinion, when exactly should the Trent-power 777 fleet have been grounded, considering the fact that it took the better part of two years before they figured out the problem (let alone fix it on all airplanes) that caused the BA LHR mishap.
Not to mention grounding the A300 fleet after the AA accident. Oh wait, that also took a couple of years to establish that it wasn't really just the airplanes fault.

And then to realize, that of all modern airliner accidents and deaths, less than 15 percent has a maintenance or design issue as main root cause. I'd say we have a pretty safe industry in terms of OEM and MRO (design, manufacturing and maintenance). 100% safety will never be reached.

PW100

Quoting 777236ER (Reply 43): Either Boeing are ignoringthe FAA, or they can't comply with a simple safety-related SB. What's the third alternative?

That it's not a simple safety-related SB and it's more complicated than you think. There's a very simple question behind this...have you read SFAR88?

Quoting 777236ER (Reply 43): Quoting PITingres (Reply 39): There is no such thing as an 'intrinsically safe" FQIS Yes, there is.

Do tell. If there is, you should be selling it to the OEM's.

Quoting 777236ER (Reply 43): Quoting tdscanuck (Reply 42): I do defend compliance intervals; your counter-position appears to be that all AD's should be "mandatory compliance before further flight" No, Boeing should comply with the FAA's mandates

They're trying; they didn't make it and got fined, which is perfectly within the FAA's power. But "just comply" is overly simplistic; what do you do when compliance in the planned timeframe isn't possible?

Quoting 777236ER (Reply 43): Let's look at the report, shall we? The condition of the wiring system in the accident airplane was not atypical for an airplane of its age, and the airplane was maintained in accordance with prevailing accepted industry practices.

Exactly; the accepted industry wiring practices weren't adequate. That one point, alone, was the primary basis behind SFAR88. And it wasn't against Boeing in pariticular, it was against ALL manurfacturers for ALL aircraft.

Quoting 777236ER (Reply 43): Your insinuation that TWA weren't maintaining the aircraft correctly was wrong, and quite offensive.

It's not an insinuation; it's a fact straight from the NTSB investigation that I'm repeating here. When the NTSB went to look at similar aircraft of similar age that had been maintained, as far as anyone knew, to standard industry practices, they found compromised bundles, FOD, broken insulation, etc. That's why they altered the entire basis of design, certification, and maintenance of the fuel system; the airlines couldn't maintain the design integrity over the life of the airplane.

Quoting 777236ER (Reply 43): Quoting tdscanuck (Reply 42): Quoting 777236ER (Reply 38): Let's be clear: Boeing's designs were unsafe. No, they weren't. The NTSB, FAA and the relatives of 230 people disagree with you.

They disagreed with the certification basis and design of ALL FQIS systems on all aircraft. There was *nothing* unique about the 747 FQIS, or Boeing, in that regard. To claim that TWA800 was a result of a Boeing design flaw is, at best, hugely and intentionally misleading.

Quoting 777236ER (Reply 43): What was incredible about this crash is it's a true single-failure system problem.

No, it's not. There were at least three independant failures; compromised FQIS wiring, compromised wiring on another high voltage system, and a path between the two (either direct wire-to-wire contact or intervening conductive FOD).

Quoting 777236ER (Reply 43): A genuine design flaw that caused a catastrophic failure. And Boeing can't comply with flammability regulations 16 years later.

If you think it's a design flaw, let's hear it. The FAA and NTSB couldnt' find one, so I'm intrigued.

Quoting 777236ER (Reply 43): Quoting tdscanuck (Reply 42): Actually, the 747 FQIS was specifically intrinsically safe when maintained as designed. Clearly it wasn't.

Yes, it was. If the wiring hadn't been compromised the FQIS would have been safe. Maintenance practices breached the wiring, allowing excess voltage into the FQIS wiring. That is *not* how the system was designed.

Quoting 777236ER (Reply 43): There was no FQIS wiring segregation, no analyses of ignition sources, no protection against high energies entering the tanks.

There was analysis of ignition sources; there was no FQIS wiring segregation (which is not unique to Boeing or the 747). There was protection against high energy entering the tanks. The fault in TWA got into the FQIS system downstream of the protection (a common failure mode for all intrinsically safe systems).

Quoting 777236ER (Reply 43): "Contributing factors to the accident were the design and certification concept that fuel tank explosions could be prevented solely by precluding all ignition sources

Exactly; the investigation showed that the design features to prevent all ignition sources weren't being maintained over the life of the airplane.

Quoting 777236ER (Reply 43): and the design and certification of the Boeing 747 with heat sources located beneath the CWT with no means to reduce the heat transferred into the CWT or to render the fuel vapor in the tank nonflammable"

This is, again, nothing unique to Boeing or to the 747.

Quoting 777236ER (Reply 43): Had Boeing designed the 747 FQIS correctly in the first place there wouldn't be an FRS SB to implement today.

You're mixing a bunch of issues here; the FRS SB has nothing to do with the FQIS SB or SFAR88 (FRS and SFAR 88 are two different sets of regulations).

Tom.

Quoting cmf (Reply 44): Quoting KC135TopBoom (Reply 40): Where were they during the almost one year Boeing was late with these SBs if the SB was so time critical? Why didn't they take a more pro-active approach and ask Boeing earlier why the SBs were not out in time? Do you have anything to backup your insinuation that they weren't pro-active and didn't ask Boeing? Quoting KC135TopBoom (Reply 40): So the real question that no one has asked is was the original time line the FAA gave to develop the fuel tank flammability equipment realistic? Airbus managed to do it in time. I think both of them are equally capable. Quoting Roseflyer (Reply 41): The change in regulations forced Boeing to redesign the fuel tank system. Adding Nitrogen Generation Systems and bonding and grounding requirements within the tanks is a difficult task. It's a very complicated retrofit system, which has taken years to develop a suitable design. I wouldn't use words like incompetence to describe designing a fully retrofitable system into an airplane that never had the provisions for it. I use words such as complicated, restricting, difficult, challenging, etc. I agree with all of this. But I think there is another very important question: What can we do to speed up the process? At least to me it seems unacceptable that a change deemed important for safety is taking the better part of an air-frames commercial life to identify and implement.

EASA has not mandated NGS on Airbus aircraft yet. Though that may change. Airbus and EASA said that because the A380 has its ECS systems in the wing root and no center tank fuel (yet) that NGS wasn't needed.

Lets be clear, both Boeing and Airbus redesigned the wiring systems to provide more separation between FQIS wiring and high energy sources. This was done in the 90's on service bulletins.

It wasn't until 2006 that final rule making on NGS systems was released by the FAA and the new clock started ticking.

Quoting tdscanuck (Reply 47): what do you do when compliance in the planned timeframe isn't possible?

I can only think of extension or grounding. Neither is a good option.

Unless there is something to suggest that the airplanes are increasingly becoming less safe over time I would suggest extension. Unless the reason it hasn't been done in time is because the companies involved have dragged their feet. NOTE: I am not suggesting that is the reason Boeing did not have it ready in time.