Boeing Model 767-400ER Series Airplanes; and Model 777-200 and -300 Series Airplanes

Comment on Docket No. FAA-2005-21713; Directorate Identifier 2005-NM-085-AD, RIN 2120-AA64 The proposed action relies heavily upon various service bulletins issued by Boeing and Kidde Aerospace. The bulletins cited in the action are regarded as supporting documents without being incorporated by reference into the regulatory action. Unincorporated service bulletins are generally copyrighted documents that may not be copied without the permission of the author. Therefore, they are generally available only to aircraft owners and operators. Under 14 CFR § 21.303 (Known colloquially as PMA) there may exist parts in the fleet that are approved replacement parts for those determined by Boeing and Kidde to be defective. The precise determination cannot be made because of the limited availability of the documents required to determine applicability. We can state positively, however, that some PMA parts appear very similar to those determined to be defective. The similarity is such that we believe further research should be conducted because a situation could exist where defective PMA parts could escape the regulatory umbrella of this action because they carry different part numbers than those original parts now known to be defective. There also exists the possibility that "new and improved" PMA parts approved as replacement parts for the defective OEM parts may already exist in the fleet. Again, this determination can not be made except by persons having access to the service documents. The "Catch 22" here is that those persons generally do not have access to the information required to determine if alternative PMA parts exist. For the above reasons, this commenter, Modification and Replacements Parts Association (MARPA) requests the following: 1. That the proposed action be modified to include sufficient information in the government document to determine precise applicability of the action. This will allow other segments of the industry such as maintenance facilities, parts purveyors and PMA parts producers to determine if parts in process or inventory are affected and for them to take appropriate action to insure that defective parts are not mistakenly returned to service as airworthy. 2. That a statement be included in the action that provides for the possible existence of alternative approved (PMA) parts that are replacements for the defective OEM parts. We suggest that the following language might be sufficient: "The parts designated herein as requiring replacement or modification as well as those designated to be installed shall be interpreted broadly to also include any replacements parts approved under FAR 21.303 for the original equipment parts cited in this action. Nothing in this action prevents or precludes the installation of such alternatively approved parts provided such parts meet current airworthiness standards including those cited in this action." Jack Buster AD Committee