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Safety Recommendation Details

Safety Recommendation A-15-001
Details
Synopsis: The NTSB has long been concerned about rapid recovery of recorded information to guide investigations, help determine accident causes, and develop recommendations to prevent recurrences. To focus attention on this issue, the NTSB convened its Emerging Flight Data and Locator Technology Forum on October 7, 2014, in Washington, D.C. Forum discussions among government, industry, and investigative experts helped identify the following safety issues: • Need for improved technologies to locate aircraft wreckage and flight recorders following an accident in a remote location or over water • Need for timely recovery of critical flight data following an accident in a remote location or over water This letter presents recommendations to address these safety issues and discusses open recommendations regarding cockpit image recorders and the need to protect flight recorder systems against intentional or inadvertent deactivation.
Recommendation: TO THE FEDERAL AVIATION ADMINISTRATION: Require that all aircraft used in extended overwater operations and operating under Title 14 Code of Federal Regulations (1) Part 121 or (2) Part 135 that are required to have a cockpit voice recorder and a flight data recorder, be equipped with a tamper-resistant method to broadcast to a ground station sufficient information to establish the location where an aircraft terminates flight as the result of an accident within 6 nautical miles of the point of impact.
Original recommendation transmittal letter: PDF
Overall Status: Open - Acceptable Response
Mode: Aviation
Location: Washington, DC
Is Reiterated: No
Is Hazmat: No
Is NPRM: No
Accident #: DCA14SS009
Accident Reports:
Report #: None
Accident Date: 10/7/2014
Issue Date: 1/22/2015
Date Closed:
Addressee(s) and Addressee Status: FAA (Open - Acceptable Response)
Keyword(s):

Safety Recommendation History
From: NTSB
To: FAA
Date: 12/13/2018
Response: We note that you are continuing to work with the International Civil Aviation Organization (ICAO), RTCA, and the European Organisation for Civil Aviation Equipment (EUROCAE) to develop criteria for tracking aircraft in distress. We recognize that the FAA serves as co-chair on the RTCA Special Committee (SC) 229/EUROCAE Working Group-98, which addresses ICAO’s Global Aviation Distress and Safety System (GADSS) concept of using the emergency locator transmitter to transmit event-triggered data. Further, we understand that you also advise the US representative on the ICAO Flight Recorder Specific Working Group (FLIRECSWG) of the Flight Operations Panel, and that you are working with ICAO to develop standards and recommended practices (SARPs), as well as other supporting documentation. Pending completion of the ICAO SARPs and your mandating the recommended equipment, Safety Recommendation A 15-1 remains classified OPEN--ACCEPTABLE RESPONSE.

From: FAA
To: NTSB
Date: 9/21/2018
Response: -From Daniel K. Elwell, Acting Administrator: The Federal Aviation Administration (FAA) continues to work with the International Civil Aviation Organization (ICAO) regarding the tracking of aircraft in distress. As noted in our previous letter to the Board, this work includes serving as RTCA SC-229/WG-98 co-chair to working group I, which is addressing ICAO·s Global Aeronautical Distress and Safety System (GADSS) concept of operation using the emergency locator transmitter to transmit event-triggered data. The FAA also serves as advisor to the U.S. representative on the ICAO Flight Data Recorder Operations Panel Working Group. The FAA is working with ICAO to develop both Standards and Recommended Practices as well as supporting documentation. We anticipate that this work will be completed by December 2019. Once this work is completed, the FAA will assess the feasibility of mandating requirements.

From: NTSB
To: FAA
Date: 1/6/2017
Response: We note that you are continuing to work with the International Civil Aviation Organization (ICAO), RTCA, and the European Organisation for Civil Aviation Equipment (EUROCAE) to develop criteria for tracking aircraft in distress. We recognize that the FAA serves as co-chair on the RTCA Special Committee (SC) 229/EUROCAE Working Group-98, which addresses ICAO’s Global Aviation Distress and Safety System concept of using the emergency locator transmitter to transmit event-triggered data. Further, we understand that the FAA also advises the US representative on the ICAO Flight Recorder Specific Working Group (FLIRECSWG) of the Flight Operations Panel. We note that you will not consider any related FAA rulemaking until after ICAO standards and recommended practices (SARPs) and associated guidance are established. You indicated that the draft ICAO SARPs specify that, when an airplane is in distress, it shall autonomously transmit information from which a position can be determined at least once every minute. We understand that, although the 1-minute transmission interval cannot guarantee an accident’s location within the recommended 6-nautical-mile range given the cruising speed of most transport-category aircraft, the airplane’s position can be located in that range with this transmission interval. Therefore, we agree that a 1-minute transmission interval is an acceptable alternative specification. In your letter, you asked that we clarify the term “tamper-resistant” as used in Safety Recommendation A-15-1. You interpret the term to mean that the system cannot be turned off by the flight crew by, for example, switching a circuit breaker, and you are concerned that tamper resistance in a system design may create a more unsafe condition than it alleviates in the event of a fire. You have raised similar concerns with Safety Recommendations A-15-5 and -6, which address adequate protections against disabling flight recorder systems and were issued at the same time as Safety Recommendation A-15-1. In our November 19, 2015, letter to you regarding Safety Recommendations A-15-5 and -6, we described a teleconference we held with your staff on July 22, 2015, to discuss these issues. During this meeting, we pointed out examples of currently certificated transport-category airplanes in service, such as the Boeing 777, that we believed had tamper-resistant power supplies for the recorders that would satisfy Safety Recommendations A 15 5 and 6. The recorders’ circuit breakers are located in the electronics bay of these airplanes, not in the cockpit, and the main power bus circuit breaker, which supplies electricity to the recorders, is in the cockpit. Therefore, in the event of an electrical fire, the crew can remove electrical power from wiring that may be causing the fire, but they cannot readily disable power to the recorders, alone. Using the circuit breaker to remove power from a main power bus would disable many systems, and we believe it unlikely that a crew would do so unless there was a clear threat of an in-flight fire. During our teleconference, we acknowledged that the circuit breaker location for the recorders in the Boeing 777 was a design convenience rather than a response to our recommendation; however, we reemphasized that the Boeing 777 is an example of a design that satisfies the recommendation and complies with current design standards regarding electrical fire safety. Pending completion of the ICAO SARPs and your mandating the recommended equipment, Safety Recommendation A-15-1 remains classified OPEN--ACCEPTABLE RESPONSE.

From: FAA
To: NTSB
Date: 9/13/2016
Response: -From Michael P. Huerta, Administrator: The Federal Aviation Administration (FAA) agrees in principle with this recommendation. As such, we are continuing to work with the International Civil Aviation Organization (ICAO), RTCA, and the European Organization for Civil Aviation Equipment to develop criteria for tracking aircraft in distress. The FAA serves as RTCA SC-229/WG-98 co-chair to working group 1 that addresses ICAO's Global Aviation Distress and Safety System (GADSS) concept of operation using the emergency locator transmitter to transmit event-triggered data. The FAA also serves as an advisor to the U.S. representative (who is from the Board) on the ICAO Flight Recorder (FLIREC) Operations Panel Working Group. However, because international harmonization is paramount, the FAA will consider rulemaking only after ICAO Standards and Recommended Practices (SARPs) and associated guidance are firmly established. The draft ICAO SARPs indicate all airplanes of a maximum certificated take-off mass of over 27,000 kg for which the individual certificate of airworthiness is first issued on or after January 1, 2021, shall autonomously transmit information from which a position can be determined by the operator at least once every minute, when in distress. The requested one-minute transmission interval correlates to the ICAO requirements for distress tracking in its GADSS concept of operations. Location of an accident site within 6 NM cannot be guaranteed. However, the one-minute transmission interval was selected because, given the cruising speed of the majority of transport category aircraft, location of an aircraft within 6 NM is likely. The FAA requests that the Board clarify its use of the term "tamper-resistant". The FAA interprets "tamper-resistant" to mean the system is not capable of being turned off by the flight crew (e.g., switching a circuit breaker). Manufacturers design aircraft with the philosophy of having the flight crew intervene if an electrical problem is detected on board. Tamper resistance in a system design may create more of an unsafe condition than it alleviates if the flight crew is not able to pull a circuit breaker or take other action to address malfunctioning systems. Circuit breakers and similar circuit protection devices are extremely important in preventing propagation of fire in the event of ce1tain system malfunctions. I will keep the Board informed of the FAA's progress on this recommendation and provide an update by May 31, 2017.

From: NTSB
To: FAA
Date: 11/19/2015
Response: We are aware that some misunderstandings have arisen over Safety Recommendation A 15 3; specifically, the belief that this recommendation calls for three recorders. We wish to clarify that there are several possible solutions that would satisfy the NTSB’s recommended action that the FAA require mandatory flight data parameters to be recoverable other than by underwater retrieval. Among these options is a requirement for a single combination recorder and a single deployable recorder. Another option that would satisfy Safety Recommendation A-15-3 is a triggered flight data transmission combined with the existing requirements for recorders. The International Civil Aviation Organization (ICAO) Air Navigation Commission recently proposed revisions to the carriage requirements of flight recorders that are currently being reviewed by States that are signatories to ICAO. Although these actions are not yet complete and you are participating in ICAO’s activities, we believe that the FAA should be more proactive, particularly in the United States, to encourage these efforts, such as by forming a US industry group to consider technologies that would address our recommendations, and by encouraging voluntary implementation of an alternative method of data recovery for those aircraft capable of such technology. Pending your completion of the recommended actions, Safety Recommendations A 15 1, -3, and -4 are classified OPEN—ACCEPTABLE RESPONSE.

From: FAA
To: NTSB
Date: 4/22/2015
Response: -From Michael P. Huerta, Administrator: These recommendations have created a lot of discussions and activities within the avionics community and multiple policy offices within the Federal Aviation Administration (FAA). The International Civil Aviation Organization has tasked the Flight Recorder Working Group with the issue of tracking aircraft in remote locations and over water. The FAA is a member of this working group. Once the working group has reviewed the concerns raised at the Emerging Flight Data and Locator Technology Forum, it will determine the best feasible course of action. We will provide an updated response by June 2016.