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Safety Recommendation Details

Safety Recommendation A-15-002
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 an airframe low frequency underwater locating device that will function for at least 90 days and that can be detected by equipment available on military, search and rescue, and salvage assets commonly used to search for and recover wreckage.
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: In previous letters to you about this recommendation, we noted that the ICAO standard regarding LF-ULDs specified only a 30-day operating requirement, and we pointed out that a 90 day operating requirement was needed in any standard that you implement to satisfy this recommendation. We note that, in May 2016, you published a revision to Technical Standard Order (TSO) C200, “Airframe Low Frequency Underwater Locating Device (Acoustic) (Self Powered),” providing the basis for manufacturers to design and produce airframe-mounted LF ULDs. The revised TSO uses Society of Automotive Engineers Aerospace Standard AS6254 revision A, which requires a 90-day battery. Issuance of TSO C200a partially satisfies Safety Recommendation A-15-2, but we note that, after ICAO finalizes its work pertaining to the GADSS, you plan to address requirements for airframe-mounted LF-ULDs as part of a larger rulemaking effort to align US and European rules and ICAO annex requirements. We remain concerned that, because of your desire to harmonize with ICAO, your planned mandate for airframe-mounted LF-ULDs may only include the 30-day requirement in the ICAO standard. Pending a mandate that the specified aircraft be equipped with LF-ULDs that will function for at least 90 days, Safety Recommendation A-15-2 remains classified OPEN--ACCEPTABLE RESPONSE.

From: FAA
To: NTSB
Date: 9/21/2018
Response: -From Daniel K. Elwell, Acting Administrator: In May 2016, the FAA published revised Technical Standard Order (TSO)-C200a, Airframe Low Frequency Underwater Locating Device (Acoustic) (Self Powered). The revised TSO provides the basis for manufacturers to design and produce airframe-mounted low frequency locating devices by directing users to meet Society of Automotive Engineers Aerospace Standard AS6254 revision A, which requires a 90-day battery. This exceeds the 30-day requirement instituted by ICAO. After ICAO finalizes its work pertaining to the GADSS, the FAA plans to address requirements for Airframe Mounted Underwater Locating Devices as part of a larger rulemaking effort to align U.S. rules with European rules and ICAO annex requirements.

From: NTSB
To: FAA
Date: 1/6/2017
Response: In our previous letter to you about this recommendation, we noted that ICAO planned a standard requiring LF-ULDs, but the standard specified only a 30-day operating requirement. We said that a 90-day operating requirement is needed in any standard that you implement to satisfy this recommendation. We note that Technical Standard Order (TSO)-C200, “Airframe Low Frequency Underwater Locating Devices (Acoustic)(Self Powered),” references SAE Aerospace Standard (AS) 6254, “Minimum Performance Standard for Low Frequency Underwater Locating Devices (Acoustic)(Self Powered),” and that you plan to soon finish a revision of TSO-C200 that will reference an update to SAE AS 6254, which requires a minimum 90-day operating requirement. Additionally, we note that you are considering rulemaking requiring LF-ULDs to be installed on newly manufactured aircraft used in oceanic operations, and that you are committed to harmonizing requirements with ICAO. We are encouraged that the revision of TSO-C200 will include a 90 day operating requirement and that you plan to mandate LF-ULD installation, but we are concerned that, because of your desire to harmonize with ICAO, your planned mandate may only include the 30-day requirement in the ICAO standard. We ask that you clarify your planned action regarding the operating requirement in any LF-ULD mandate. Pending an acceptable clarification as to how you will harmonize the length requirement with ICAO standards, issuance of the revised TSO with a 90-day life for the LF-ULD, and a mandate for LF ULD installation, Safety Recommendation A-15-2 remains classified OPEN—ACCEPTABLE RESPONSE.

From: FAA
To: NTSB
Date: 9/13/2016
Response: -From Michael P. Huerta, Administrator: On June 26, 2012, the FAA published Technical Standard Order (TSO)-C200 Airframe Low Frequency Underwater Locating Devices (Acoustic)(Self-Powered). This TSO references SAE Aerospace Standard (AS) 6254, Minimum Performance Standard for Low Frequency Underwater Locating Devices (Acoustic)(Self-Powered). The next revision of this TSO will reference SAE AS 6254A which requires a minimum 90-day operating requirement. TSO-C200A is expected to be published in calendar year 2016. The FAA is considering rulemaking to require installation of low frequency underwater locating devices (LF ULDs) on newly manufactured aircraft used in oceanic operations. The FAA notes the ICAO mandate requires LF ULD installation on all airplanes, operating long-range nights over water with a maximum certificated take-off mass of over 27,000 kg. by no later than January I, 20 18. The FAA is committed to harmonizing with ICAO and other regulatory authorities to the maximum extent possible. 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 note that ICAO’s standard states that, no later than January 1, 2018, airplanes weighing over 27,000 kg flying over water must install a 30-day LF-ULD; our recommendation is for the device to last 90 days. We believe that you should issue a regulation specifying a 90 day LF-ULD rather than the 30-day LF-ULD required by the ICAO standard. Pending issuance of a regulation adopting the ICAO standard modified to require a 90-day LF-ULD instead of one lasting 30 days, Safety Recommendation A 15-2 is 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.