When Notices of Proposed Rule Making (NPRM) are published, air carriers and manufacturers as well as other individuals or organizations have an opportunity to submit comments about the NPRM as it relates to cost, schedule, effectiveness and alternative means of compliance. Under the lead air line process established by ATA (now A4A), member carriers can collaborate and develop a consensus response to the NPRM. In many cases Original Equipment Manufacturers (OEMs) such as Boeing and Airbus support A4A with related facts and information and also submit their own comments about the NPRM.
It would be safe to assume, that when the lead airline process was initiated for the above cited fuel tank safety upgrade, that kit components and delivery schedule were included in the comments to the FAA. Despite the best planning efforts, sometimes supply chain issues pop up and such developments can have a downstream impact on the operators that have to incorporate the upgrade.
The fuel tank upgrade is no simple task and it is good to read that the FAA is willing to work with the air carriers to ensure airplanes are not needlessly grounded. Since the TWA mishap in 1996, the FAA, airlines and manufacturers put an extensive amount of effort into researching the problem and developing operational procedures to prevent the mishap from reoccurring until the fuel system upgrade could be developed, tested and installed.
This case is a testament to both the FAA and the industry working together to address a very difficult problem.
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