Government of Bermuda DCA

Fuel Tank System Safety

Module 6

Len Arnot-Perrett
AVISA

1
fuel tank system safety

Overview for managers of

airworthiness & maintenance

2
 Welcome to the course

Course objectives
¾ Familiarise candidates with the elements of
Fuel Tank System Safety Issues
¾ Enable candidates to understand the historical
background and elements requiring
consideration in relation to fuel system safety
¾ Equip candidates to understand and use the
language of fuel system safety issues
¾ Allow candidates to understand and interpret
fuel system safety issues from regulatory and
manufacturer’s maintenance publications
¾ Satisfy Parts M & 145 Amendments on fuel
system safety
Note: this course covers level 1 requirements 3
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Fuel tank system safety – the beginning?

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 Fuel tank system safety – the beginning?

TWA Flight 800 crashed at 20.30 on July 17 1996

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 Fuel tanks system safety – the end?

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 Fuel tank system safety –
introduction for managers of
airworthiness & maintenance

Neither the beginning nor the end!

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 Fuel tank system safety – introduction for
managers of airworthiness &
maintenance

The investigations surrounding the accident

led to many basic design and certification
assumptions about installed fuel tank
system safety to be substantially revised.

What have design and certification

assumptions got to do with in-service
continuing airworthiness management
and maintenance of aircraft?

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 Fuel tank system safety – introduction
for managers of airworthiness &
maintenance

All of the continuing airworthiness processes

could be affected!

“covers all of the processes ensuring that at

any time in their operating life, all aircraft
comply with the airworthiness requirements in
force and are in a condition fit for safe
operation.”

Regulation 2042/2003 – Article 2 - Definitions

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 Fuel tank system safety – introduction for
managers of airworthiness &
maintenance

• AD • Records
• Flight Manual • Maintenance
• Modifications Programme
• Repairs • Maintenance
• MMEL Standards
• Life Limits • Reliability Programme
• Airworthiness • Certification
Limitations Maintenance
Requirements
• C of A
• Weight & Balance
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• Occurrence Reporting
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 Fuel tank system safety – introduction
for managers of airworthiness &
maintenance

• As you can see, these processes are

those associated with the operation,
continuing airworthiness and maintenance
of aircraft.

In the global fleet of aircraft – all of the

processes have been affected

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 Fuel tank system safety – introduction for
managers of airworthiness &
maintenance

We all accept that aviation fuel is dangerous

when handling the fuel: but it has mostly
been safe inside aircraft installations….

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 Fuel tank system safety – introduction
for managers of airworthiness &
maintenance

Or has it been safe?

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 Fuel tank system safety – introduction for
managers of airworthiness &
maintenance
Or has it been safe?

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 Fuel tank system safety – introduction
for managers of airworthiness &
maintenance

Or has it been safe?

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 Fuel tank system safety –
introduction for managers of
airworthiness & maintenance

Or has it been safe?

A global review of in-service fuel tank

safety data demonstrated that fuel tank
safety does not meet contemporary
standards for system safety targets

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 Fuel tank system safety –
introduction for managers of
airworthiness & maintenance

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 Fuel tank system safety – introduction
for managers of airworthiness &
maintenance

In the period 1960 – 1996 – 17 fatality

events due to fuel tank system events!

Let us consider a sample – relevant to

today.....

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 Fuel tank system safety – introduction for
managers of airworthiness & maintenance

• 8 December 1963 – Pan Am B707

• 9 May 1976 – Iranian Air Force B747
• 22 August 1985 – BA Air Tours B737
• 11 May 1990 – Philippine Air Lines B737
• 17 July 1996 – TWA 800 B747
• 3 March 2001 – Thai Airways B737
• 5 September 2001 – BA B777
• 20 August 2007 – China Air B737
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 Fuel tank system safety – introduction
for managers of airworthiness &
maintenance

Is this a Boeing problem?

Not exclusively!

Boeing had flown approximately 70% of

large commercial airplane flights in 2000

It is a matter of exposure then.

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 Fuel tank system safety – introduction for
managers of airworthiness &
maintenance
1990 - B-737-300 1996 - B-747, TWA 2001 - B-737-400
Manila, Philippines 800, JFK Bangkok Thailand
Almost new airplane 25 year old airplane 10 year old airplane
Air Conditioning Packs Air Conditioning Packs Air Conditioning Packs
running during Ground running during Ground running during Ground
Operations Operations Operations
Empty CWT explosion Empty CWT explosion Empty CWT explosion
during pushback from during climb minutes after
gate refueling
CWT pumps operating CWT pumps operating
at time of explosion at time of explosion
8 fatalities 230 fatalities 1 fatality
Jet-A fuel, approx. 95 Jet-A fuel, approx. Jet-A1 fuel, approx.
degree F ambient 120 degree F tank 97 degree F ambient
temp.(35’C) temp.(49’C) temp.(36’C)
NO IGNITION SOURCE NO IGNITION SOURCE NO IGNITION SOURCE
IDENTIFIED IDENTIFIED IDENTIFIED 21
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 Fuel tank system safety – introduction for
managers of airworthiness &
maintenance
10

9
-8
ARAC ~10E
8

7
Cumulative Accidents

5
Bangkok

4 New York

-9
10E
3
Manila Extremely improbable -
not anticipated to occur in the life of
2 the fleet

0
1990 1995 2000 2005 2010 2015 2020
Year
Systemic Change Needed 22
22
 CS25.1309 AMC 1309

Figure 1 - Relationship between Probability and

Severity of failure Condition

JAR 25 EXTREMELY
PROBABILITY PROBABLE IMPROBABLE
IMPROBABLE

100 10-3 10-5 10-7 10-9

CLASSIFICATION
OF FAILURE MINOR MAJOR HAZARDOUS CATASTROPHIC
CONDITIONS

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 Fuel tank system safety – introduction
for managers of airworthiness &
maintenance

Investigations revealed that the CWT were

heated to a greater extent than previously
believed - 140°f peak recorded on one
aircraft type

High temperature leads to high flammability

High flammability means that ignition source

energy required to initiate event is much 24
lower than previously calculated
 Fuel tank system safety – introduction
for managers of airworthiness &
maintenance
“Prevent fuel system
accidents through ignition
Ignition
source elimination and
flammability reduction”

Oxygen Fuel Vapor

Flammability Reduction Heated tanks

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 Fuel tank system safety – introduction
for managers of airworthiness &
maintenance
Fuel Tank Flammability Exposure Worldwide Fleet Average
Main Tanks 2-4%
Tail Tanks 2-5%

Body Tanks
• Pressurized <5%
• Un-pressurized >20%

Heated Center Wing Tank 15-30%

Un-heated Center Wing Tanks 2-6%

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 Fuel Tank Safety – Module 2
Flammability Envelope
vs. Ignition Energy, Flash Point and O2 Level
50 LFL
Flammable Zone

40 UFL
Altitude 1000's ft.

30 Heated CWT
Profile

20 Unheated Wing
Tank Profile

10 Pointer

0
-50 0 50 100 150 200
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Temperature Deg F 27
 Fuel tank system safety – introduction
for managers of airworthiness &
maintenance
Reinvestigation of design certification
standards also led to need to review all
tank installations – including un-heated
tanks

• Special Federal Aviation Rulemaking –

SFAR 88
– FAA AC 25.981.1(b)
– FAA AC 25.981.2
• JAA INT/POL/25/12 28

JAA TGL 47
 Fuel tank system safety – introduction
for managers of airworthiness &
maintenance

SFAR 88
Initiated in 2001 – assessment stage

Existing fleet in Europe and North America

All basic airplane design configurations and

supplemental Designs affecting the fuel
system
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 Fuel tank system safety –
introduction for managers of
airworthiness & maintenance

CDCCL and Fuel System Airworthiness

Limitation Items to be identified to comply
with SFAR 88

Implementation aimed for 2004

Differences between EASA & FAA on

Flammability Reduction Systems delay
implementation 30
 Fuel tank system safety –
introduction for managers of
airworthiness & maintenance

Full reinvestigation of design – fuel tank

systems – require DAH to identify Fuel
Tank Airworthiness Limitation Items
including

• Critical Design Configuration Control

Limitations
• Airworthiness Limitation – inspections
• Airworthiness Limitation – modifications 31

• Airworthiness Limitation - procedures

 Fuel tank system safety – introduction
for managers of airworthiness &
maintenance

SFAR 88 (AC 25.981.1c) & JAA TGL 47 and

INT/POL/25/12
Critical Design Configuration Control Limitation
(CDCCL):
A fuel system feature the design integrity of which
must be maintained to ensure that an unsafe
condition does not develop. Features in an
aircraft system or component. May exist in fuel
system but may also be features in systems or
assemblies that interact or cross-couple with
fuel systems 32
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 Fuel tank system safety – introduction
for managers of airworthiness &
maintenance

SFAR 88 (AC25.981.1c) & JAA TGL 47 and

INT/POL/25/12
Examples of CDCCL:-
¾Bonding feature attaching to component and
tank
¾Separation of fuel gauge wiring from other high
– power wiring
¾Fuel pump configuration
¾Wire support for high power wiring near to tank
We will later look at some characteristic CDCCL
from TC Holders 33
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 Fuel tank system safety –
introduction for managers of
airworthiness & maintenance

SFAR 88 (AC25.981.1c) & TGL 47 and

INT/POL/25/12

Fuel Tank System Airworthiness Limitation

Items (ALI)
Fuel System Mandatory Instructions – can
include
¾ Design changes
¾ Maintenance
¾ Inspections
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¾ Procedures 34
 Fuel tank system safety –
introduction for managers of
airworthiness & maintenance

SFAR 88 (AC25.981.1c) & TGL 47 and

INT/POL/25/12

Fuel Tank System Airworthiness Limitation Items

(ALI)
Those items necessary to ensure that
Unsafe conditions do not arise in the fuel
system throughout the service life of the
airplane
ALI to be mandated by AD and included in the
Airworthiness Limitations Section of ICAW 35
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 Fuel tank system safety – introduction
for managers of airworthiness &
maintenance
SFAR 88 (AC25.981.1c) & JAA TGL 47 and
INT/POL/25/12
For the identification and management of CDCCL

¾Related tasks highlighted by TCH in AMM/CMM

¾Airworthiness management procedures put in place
¾ Ensure features are protected during repair/changes
¾ Ensure maintenance organisation is aware
¾ Implement training programmes

Remember, the feature itself may not be directly related

to the fuel system and also may be at component level
e.g. fuel pump! 36 36
 Fuel tank system safety – introduction
for managers of airworthiness &
maintenance
Identification and management of CDCCL – at a
component level

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 Fuel tank system safety – introduction
for managers of airworthiness &
maintenance

SFAR 88 (AC25.981.1c) & JAA TGL 47 and

INT/POL/25/12
For the identification and management of CDCCL

If fuel pump configuration is to be

identified as a CDCCL, how will the
operator control the CDCCL?
¾Pool parts
¾Component suppliers
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 Fuel tank system safety – introduction
for managers of airworthiness &
maintenance

SFAR 88 (AC25.981.1c) & JAA TGL 47 and

INT/POL/25/12 – continued – 24
For the identification and management of CDCCL
Fuel Pump CDCCL management:-
This will be a challenge for the operators
¾EASA Part 145 Form 1, FAA 8130-3
¾Contracts will need to specify CDCCL
managed and complied with during MRO
activity – box 13(?)
¾CAME procedure in place
¾Maintenance procedure for MRO
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Fuel tank system safety – introduction for
managers of airworthiness &
maintenance
CRD-22-2005

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 Fuel tank system safety –
introduction for managers of
airworthiness & maintenance

An ALI could be a modification/change:-

EASA AD 2006-0191
A330-200, A340 – 200/300 aircraft

Air Conditioning – prevention against fuel

explosion risks – installation of heat
shields in belly faring

HO2 41
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 Fuel tank system safety –
introduction for managers of
airworthiness & maintenance

Boeing Airplane MPD already published with

ALI/CDCCL
e.g. B767 MPD
AWL No. 28-AWL-01: Task – ALI – detailed inspection
of wire bundles over CWT – 12y/36000H
AWL No. 28-AWL-02: CDCCL – External Wires over
CWT – maintain existing wire bundle routing and
clamping

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for managers of airworthiness &
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Boeing Airplane MPD already published with

ALI/CDCCL
e.g. B767 MPD
AWL No. 28-AWL-03: CDCCL – Lightning protection –
Engine fuel feed line - verify electrical fay surface
bond from bulkhead fitting to structure – 0.5 milliohms
or less
AWL No. 28-AWL-04: CDCCL – Lightning protection –
Hydraulic line fuel tank penetration – bond checks on
heat exchanger and lines – to structure and in-line
connectors

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 Fuel tank system safety – introduction
for managers of airworthiness &
maintenance
Operator required to maintain integrity of
CDCCL throughout operation and
maintenance of airplane.
This could be a challenge…

• Airworthiness management processes –

including modification, repair & ARC
• Maintenance procedures
• Component maintenance
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 Fuel tank system safety – introduction
for managers of airworthiness &
maintenance

FAA Aviation Rulemaking Advisory

Committee – ARAC studies heating effects
on fuel Tanks 1998.

External heat sources to be avoided – for

the future!

Flammability suppression guidance

developed 46
 Fuel tank system safety – introduction
for managers of airworthiness &
maintenance

Industry Fuel Tank System Safety

programme commenced in 1998

Sample surveys of aircraft in-service fleets

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 Fuel tank system safety – introduction
for managers of airworthiness &
maintenance

Industry Fuel System Safety Programme

Survey was not conclusive but there were
findings

¾Bonding provisions missing

¾Swarf and contamination in tanks
¾Damaged components
¾Evidence of overheated pumps
¾Wiring problems
¾Vent systems incorrectly assembled
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 Fuel tank system safety – introduction
for managers of airworthiness &
maintenance

Bonding straps in tanks

¾ Straps missing, broken, loose
¾ Straps frayed/worn as a result of wing movement
¾ Corroded straps and attachment points

Lightning strikes have resulted in the loss of aircraft due to

poor bonding!
Poor/missing bonds are often caused by maintenance
error! You may be only 1 fault away from an unsafe
condition!

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 Fuel tank system safety – introduction for
managers of airworthiness & maintenance

Another Survey finding that was very relevant

to the future was the relatively high level of
maintenance error induced occurrences in fuel
tank system installations

UK study of B747 occurrences showed 16%

maintenance error correlation over a 20 year
period!

Another relevant finding was the comparative

seriousness of the fuel tank system related
occurrences
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 Fuel tank system safety – introduction for
managers of airworthiness &
maintenance
Maintenance error? Serious occurrences?

Most regulatory systems had provisions for

flying control system maintenance to reduce
the likelihood of maintenance error induced
occurrences
¾Required Inspection Items
¾Duplicate Inspections
¾Independent Inspections

Perhaps we need to build similar defences for

fuel system maintenance?
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 Fuel tank system safety – introduction
for managers of airworthiness &
maintenance

Another finding was that Zonal Inspection

Programmes were not proving as effective
as they ought to be
Problems with
• Mechanic licensing schemes
• Training of Inspectors at MRO
• Poor maintenance at component
organisations
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 Fuel tank system safety –
introduction for managers of
airworthiness & maintenance
Mechanic licensing schemes, Training of Inspectors at
MRO
Poor maintenance at component organisations?
Licensing schemes are not able to adequately address all
inspection standards and licensing schemes do not exist
at a component level
e.g. Zonal Inspection standard could be
• General Visual
• Surveillance
What do they mean? How are they applied?
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 Fuel tank system safety – introduction
for managers of airworthiness &
maintenance

MSG3 Definition:
General Visual Inspection:-

¾ A visual examination from arms length that will

detect obvious unsatisfactory conditions/
discrepancies. This type of inspection may require
removal of fillets, fairings, access panels / doors,
etc. Workstands, ladders etc. may be required to
gain proximity.

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 Fuel tank system safety – introduction
for managers of airworthiness &
maintenance

Mechanic licensing schemes, Training of Inspectors at

MRO
Poor maintenance at component organisations?

General Visual Inspection requires the identification of

obvious signs of deterioration: the Part 66/A&P
examinations are not able to test the applicants
knowledge to that extent!

This determination requires visual parameters…….

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 Fuel tank system safety – introduction
for managers of airworthiness &
maintenance
Mechanic licensing schemes, Training of Inspectors at
MRO
Poor maintenance at component organisations?

How are the MRO’s meant to deal with this?

Part 145 requires organisation training for issue of

authorisations – this would include the need to ensure
that relevant inspection standards were covered at an
airplane as well as a component level!
• Continuation training
• Pictures of inspection findings 56
 Fuel tank system safety – introduction
for managers of airworthiness &
maintenance

Mechanic licensing schemes, Training of Inspectors at

MRO
Poor maintenance at component organisations?

Some of the problems uncovered were

probably due to poor installation standards
during modification activities!

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Fuel tank system safety – introduction
for managers of airworthiness &
maintenance

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 Fuel tank system safety –
introduction for managers of
airworthiness & maintenance

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 Fuel tank system safety –
introduction for managers of
airworthiness & maintenance

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Fuel tank system safety – introduction
for managers of airworthiness &
maintenance

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 Fuel tank system safety – introduction for
managers of airworthiness &
maintenance

Wiring problems were being investigated by

the Ageing Transport Systems Rulemaking
Advisory Committee (ATSRAC) study going
on in parallel with SFAR 88

ATSRAC set up by FAA to study ageing

effects in systems – focuses on wiring
systems

Produces rule making Enhanced

Airworthiness Programme for Aircraft
Systems/Fuel Systems
62 – (EAPAS) 62
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 Fuel tank system safety – introduction
for managers of airworthiness &
maintenance

2000 - ARAC 2 set up to look into

requirements for Flammability Reduction
Systems – FRS – to significantly reduce
the development of flammable vapours

Workable and economically viable on-board

system developed by FAA Technical
Centre

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 Fuel tank system safety – introduction
for managers of airworthiness &
maintenance

ARAC
Flammability SFAR SFAR 88
Reduction NPRM Assessment SFAR 88
Study
Implementation
Bangkok
Manila New York

1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004+

NTSB Industry Fuel

NGS
recommendations Systems
Development
Safety ARAC
FAA Task to Industry Program Inerting
based on NTSB Study
Recommendations

Industry and Regulatory consensus: Reducing flammability

would provide major benefit to enhancing fuel tank safety

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for managers of airworthiness &
maintenance

What has happened since 2004?

Things have moved slowly!

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 Fuel tank system safety –
introduction for managers of
airworthiness & maintenance

March 2007 – EASA Agency Decisions 2007/01R,

2007/02R and 2007/03R issued on Fuel system
safety
¾ Part 145 organisations – component and
airplane level
¾ Part M airworthiness Management
organisations
¾ Part 66 Licensing
NPA 2008-19 to change rules still not closed!

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 Fuel tank system safety – introduction
for managers of airworthiness &
maintenance

2007 – Flammability Reduction System

certified by FAA/EASA for Boeing products

Boeing introduce production cut-ins for

current models and proposals for fitment
to existing fleets

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 Fuel tank system safety –
introduction for managers of
airworthiness & maintenance

Why bother with FRS?

FAA estimate that in order to obtain the

order of magnitude change required to
obtain the required level of safety –
Ignition Source Suppression – on its own –
required to be at least 75% effective.

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 Fuel tank system safety –
introduction for managers of
airworthiness & maintenance

• Malaysian Register 727 tank explosion

due to wiring failure in wing – fuel pump
supply wire.
• B777 CWT fuel leak during TO – panel left
off after maintenance
• Airbus FQIS lightning protection failures

Ignition source suppression cannot be

guaranteed to be wholly effective! 69
 Fuel tank system safety – introduction
for managers of airworthiness &
maintenance

October 22 2007 FAA issue final rule ‘’Enhanced

Airworthiness Programme for Airplane
Systems/Fuel Tank Safety (EAPAS/FTS)’’

This rulemaking was part of the ATSRAC

rulemaking relating to airplane wiring systems
and included fuel tank system installations

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for managers of airworthiness &
maintenance

What is EAPAS and what has EAPAS got to

do with Fuel Tank System Safety?

Wiring problems connected with Fuel Tank

Safety were delegated to Ageing
Transport System Rulemaking Advisory
Committee – ATSRAC – who developed
EAPAS.
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for managers of airworthiness &
maintenance

July 21 2008 FAA issue final rule

‘’Reduction of Fuel Tank Flammability in
Transport Category Airplanes’’

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airworthiness & maintenance

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What do the FAA Rules do and will they

affect me?

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airworthiness & maintenance

Any differences between European/US

implementation could affect
¾ Insurance Premiums
¾ Lease arrangements – operator/operator
¾ Lease arrangements – operator/leasing company
¾ Transfer/Export of Airplanes
¾ Airbus/Boeing will be required to meet FAA production
cut-in targets – production aircraft will be standard

In addition - an operator operating an airplane in

accordance with Part 129 would obviously be affected!
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 Fuel tank system safety –
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airworthiness & maintenance

The FAA final rule RIN 2120-A123 simultaneously

introduces a number of FAA rule changes
applicable to US Design Approval Holders
(DAH) and operators of US Register airplanes
¾ Introduces Part 26 for DAH – to harmonise with
EASA(?)
¾ Part 121 - Domestic, Flag and Supplemental Operations
¾ Part 125 – Airplanes seating cap. 20+ pax. Or
payload>6000lbs.
¾ Part 129 – Foreign Air Carriers and Foreign Operators
of US Register Airplanes Engaged in Common Carriage
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 Fuel tank system safety – introduction
for managers of airworthiness &
maintenance
A detailed knowledge of the FAA rulemaking is
not necessary for a non-US register aircraft
operator

We include a brief summary of the rule making

however since there will almost certainly be a
need to understand the basics due to the
continuing movement of aircraft ownership
across international boundaries

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FAA Final Rule summary

¾ Introduction of FAR 26 requirements – fuel
tanks within the fuselage contour – flam>7%, all
other tanks flam>7%
¾ DAH to assess fleet average flammability exposure – to be
complete within 150 days following 19 September 2008
¾ Fleet average flammability exposure target <7%
¾ Flammability Reduction Means (FRM) to be identified if
exposure>7% fuselage contour tanks (AC 25.981-2)
¾ Ignition Mitigation Means (IMM) to mitigate ignition sources in
tanks (AC 25.981-1)
¾ September 20 – 2010 DAH to submit FRM ICAW including
CDCCL
¾ September 20 – 2010 DAH to submit FRM ALI 79
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Fuel tank system safety – introduction for managers
of airworthiness & maintenance

FAA Final Rule summary

¾Introduction of FAR 26 requirements
¾ALI – Airworthiness Limitation Items
¾CDCCL – Critical Design Configuration
Control Limitations

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FAA Final Rule summary

¾ Part 121 – by September 20 2010 – new
production airplanes
¾FRM, to be operational
¾Ignition Mitigation Means (IMM) to be
implemented
¾B747 Series Airbus A 318, A 319,
A320,A321 series
¾B737 Series Airbus A 330, A 340
Series
¾B777 Series
¾B767 Series 81
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 Fuel tank system safety –
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airworthiness & maintenance

FAA Final Rule summary

¾ Part 121 – Retrofit

¾ 50% of US operator’s fleet to have installations

required by Part 26 by 2014
¾ 100% of US operator’s fleet to have installations
required by Part 26 by 2017
¾ Installations to be operational

The flammability targets will effectively result in FRM

for most Airbus and Boeing types in current airline
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 Fuel tank system safety – introduction
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maintenance

FAA Final Rule summary

¾ Part 121 – Maintenance Programmes
¾ Type specific ALI and CDCCL mandated by AD
¾ Maintenance Programmes must be revised to take
into account modifications required by Part 26
¾ Compliance dates for Maintenance Programme
changes may be extended subject to use of ground
air conditioning for B737, 747, 757, 777, 767 and
A300, A310, A318, A319, A320, A321, A330, A340.

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29 May 2008 EASA issue NPA No 2008-16

‘’Fuel Tank Safety – incorporation of the
Critical Design Configuration Control
Limitations (CDCCL) into Acceptable Means
of Compliance for Part-M, Part-145 and Part
66’’
17 July 2008 EASA issue NPA N0 2008-19
‘’Fuel tank flammability reduction’’ – this is
equivalent to FAA FAR 25 and AC 25.981-1
and AC 25.981-2 – this is a design and certification
code for future airplanes and is not retrospective -
FAA FAR 26 is! 84
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The EASA change to CS 25 will not result in

retrospective implementation to existing
fleets and will probably only come into
effect for A350 and B787

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managers of airworthiness & maintenance

EASA rule making will not implement

requirement for retro-fit of flammability
reduction systems whilst FAA rule will.

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managers of airworthiness &
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EASA has issued AD’s for Airbus fleet ALI

and CDCCL
Will result in need for changes in
maintenance and airworthiness
management organisations – Part 145 and
Part M

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maintenance

Changes to airworthiness management and

maintenance procedures
¾ Task card development
¾ Maintenance Procedures including verification tasks –
tank closure
¾ Repairs/changes
¾ Maintenance Programme development
¾ ARC issue
¾ MEL management
¾ Occurrence reporting standards
¾ Training
¾ Quality Audit
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