Airbus Model A330, A340-200, A340-300 Series Airplanes - 2004-NM-83-AD

FAA has proposed adoption of an immediate adopted rule, applicable to A330, A340-200, and A340-300 series airplanes equipped with a piston rod of the main landing gear (MLG) retraction actuators having part number (P/N) 114256309 or 114256321. This airworthiness directive (AD) requires repetitive inspections of the piston rods, and related investigative and corrective actions if necessary. ATA appreciates the opportunity to comment on this proposed rule. Our members generally support the intent of the rulemaking; however, additional review and clarification would be desirable on the attached comment. Specifically: ¿Repetitive inspections ¿ Reevaluate the seven-day repetitive inspections after six months based on finding reports. The repetitive interval for the detailed visual inspection then could be adjusted to seven days or fifty cycles, whichever is later. ¿MLG retraction actuator ¿ The inspection prior to installation on an aircraft needs to be reviewed with regards to zero time piston rods and increased inspection thresholds. ¿Inspection results ¿ FAA should be involved in the inspection results to better gather information so that a substantiated change in the repetitive interval may be made. Your serious consideration of these observations and comments would be greatly appreciated. Sincerely, Robert Peel Director of Quality Air Transport Association