Commenter 1 |
Comment: Cost to conduct each prefight detailed visual inspection is $20. Should read preflight |
CASA Response: Agreed PAD changed to preflight as this is a typographical error. |
Commenter 2 |
Comment: Item 1. Refer to the latest issue of the Fokker All Operator Message AOF100.230#05. Item 2. Refer to SBF100-32-175 to formally cover the accomplishment instructions for the Detailed Visual Inspection. Item 3. Strongly supported a compliance period of at least 12 months, and preferably 18 months as it is not possible if the reduced timeframe is imposed. Item 4. Recommendation to specify the required inspection in the AD in such a way that the operators do have the flexibility to have the inspections at out-stations accomplished by flight crew members specifically trained and authorised for that purpose. |
CASA Response: Item 1. Agree to refer to latest Fokker All Operator Message AOF100.230#05. This version of the AOM specifies at a minimum the inspection is carried out every flight day. Item 2. A detailed inspection is necessary whilst these units are in service as they have the potential to crack quickly, and such inspections are achievable at main bases. Those flights that are to a remote location do present an issue for compliance with this requirement. However, regulation 39.004 allows an alternative to be presented to CASA for the preflight DVI but it must be of equivalent safety. Item 3. Agree to changed compliance time to 1 February 2024 for removal from service of the affected main landing gear pistons. 1 February 2024 aligns with the expected removal from service by EASA of the affected pistons. This would be just over 18 months since the investigation report was provided to CASA by EASA. CASA acknowledges industry feedback that requiring piston removal from service within six months after the effective date of the AD, will not be logistically manageable. The number of spare units readily available at the moment is simply insufficient to replace the pistons that are presently still installed on the aircraft. Item 4. CASA considers there are issues with pilots conducting the inspection, as pilots are not specifically trained in this level of detail in a walk around inspection. This level of inspection requires thoroughly cleaning the lower aft side of the Main Landing Gear Piston, in preparation prior to conducting the detailed inspection. It also requires using a strong flashlight and magnifying glass to perform the detailed visual inspection. In order for pilots to conduct the inspection would require a change to the expositions of Part 42 (refer Chapter 15 of MOS 42) and Part 145 (refer 145.A.37(f)) to cater for this level of inspection (refer 15.2.1 List item 6 of MOS 42). |
Commenter 3 |
Comment: Item 1. As the high risk time period for hydrogen embrittlement cracking has passed (see report of Dr Romeyn), the likelihood is extremely low to the point that the existing inspection process or heightened one should be sufficient and that there is no obvious basis for requiring replacement of all the components after 2,000 calendar hours have elapsed (or 5,000 calendar hours if a more conservative position is preferred). Item 2. The pre-flight inspection is also unnecessary, and a detailed daily visual inspection is more appropriate. |
