oversight

Aviation Safety: Installation of Smoke Detection and Fire Suppression Systems in U.S. Transport Aircraft

Published by the Government Accountability Office on 1997-12-19.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

      United States
GAO   General Accounting  Office
      Washington, D.C. 20548
                                                                    -
                                                                                 ls3bG3

      Resources, Community,   and                                  .- -
      Economic Development    Division


      B-278016


      December 19, 1997


      The Honorable John J. Duncan, Jr.
      Ch2l.bYlm
      The Honorable William 0. Lipmsld
      Ranking Democratic Member
      Subcommittee on Aviation
      Committee on Transportation and Infrastructure
      House of Representatives

      Subjectz    Aviation Safelx Installation of Smoke Detection and Fire
                  Sunpression Svstems in U.S. %ansoort Aircraft

      The Federal Aviation Administration (F’u) is planning to issue new
      regulations to upgrade the fire safety standards for cargo or baggage
      compartments in certain passenger and cargo aircraft. These regulations
      would require that apiroximately 3,700 erristing aircraft be retrofitted to
      include tie suppression and/or smoke detection systems in their cargo or
      baggage compartments and that all new aircraft entering service include such
      systems. At your request, we reviewed the actions under way at FAA and
      within the aviation industry to effect these changes withjn the 3-year time
      frame proposed by FAA. We addressed the following questions:

      -   What is the status of FAA’s and the airline industry’s efforts to equip
          aircraft cargo compartments with new smoke detection and Be
          suppression systems?

      -   What factors may affect the timetable for equipping the entire fleet with
          this new equipment?

      On December 11, 1997, we briefed your staffs on the results of our review
      and agreed to provide you with this report summarizing our iixdirlgs. our
      responses to the spe&c questions you raised are provided in brief below.
      Additional information regarding these questions is contained in the briefing
      slides in enclosure L

                                   GAO/lMXXb9%54R A&raft   Smoke Detection   and Fire Suppression


                                          /5f9hG7
3278016                                                      -
FAA and the aviation industry have taken the initial steps needed to begm
installing smoke detection and fire suppression systems in aircraft cargo and
baggage compartments. FAA has accelerated its rulemaking procedures .for
insta&ng these systems with the goal of publishing the final rule by January 1,
1998. The rule includes a plan to monitor and report, on a quarterly basis, the
status of retrofitting affected aircraft. In addition, FAA has certified smoke
detection and tie suppression systems for DC-9 and 731 aircraft, and our
discussions with affected aircraft manufacturers revealed that most plan to 1
develop, test, and certify systems; issue technical installation instructions; and
offer modScation kits to airlines. Our survey of 15 major, national, and
regional a&lined indicates that most of those surveyed believe that the retrofit
of affected a&raft can be accomplished in 3 years, the compliance period
suggested in FAA’s proposed rule.2

In our discussions with smoke detection and fire suppression suppliers, we
found that current suppliers of smoke detection equipment have developed
more sensitive and reliable equipment to meet FAA’s requirement of smoke
detection within 1 minute and that emexing detection and suppression
technologies may reduce mod.i&ation c 4s and speed installation of the
systems.

We identified factors that could aEect FAA’s proposed 3-year timetable. We
found that detection and suppression suppliers capacity to provide equipment
to meet the retrofit program requirements and the use and availability of
halon are not likely to affect the timetable. However, a lack of
standardization in the application of FAA’s test criteria for certlfyini smoke
detection and fire suppression systems and repair stations’ capacity, if
installation cannot be accomplished during annual scheduled maintenance,
could slow industrywide installation. In addition, we are concerned that (1)
not all airhnes have fully developed plans to retrofit fleeted aircraft (2) any
delays in publication of FAA’s fmal rule could delay industry’s efforts to
retrofit aircraft; and (3) FAA’s proposed compliance reporting may not provide
 sxdkient information for effective congressional oversight.




 ‘See pages 2.2 and 23 in enc. L

2The 3-year compliance period begins when the rule is issued.
 3Halon gas is the most common extinguishing agent for tie suppression
 systems.
 2                        GAOBXD-98-54ll   Aircraft   Smoke Detection   and Fire Suppression
B-278016                                                       -
In commenting on a draft of this report, FAA officials, including the Deputy
Associate Admini&ator for Regulation and Certification, noted that they had
conducted a series of workshops to increase the level of standardization~of
FAA’s certification efforts in smoke detection testing and planned to revise
FAA’s advisory circular on smoke detection test procedures. FAA also said
that if the airlines begin the installation process promptly and schedule the
ins&llations aggressively, the retrofit program could be completed within the
time period proposed. FAA agreed that timely publication of the rule is
essential and reiterated its plans to publish the rule on January 1,1998. FAA
aLso said that the level of reporting specified in the proposed rule would
provide sufficient information to monitor the industry’s progress and that any
further reporting requirements might require a supplemental rule and/or
approval by the office of Management and Budget.

We generally agree with FAA’s comments but remain concerned that FAA’s
proposed reporting procedures may not provide suf6cient advance notice to
the Congress of any serious delays that might develop during the retrofit
Prom-



To determine the status of FAA’s efforts and timetable, we interviewed
officials from FAA, airlines, aircraft manufacturers, and the Environmental
Protection Agency and reviewed FAA’s proposed tie and preliminary
regulatory evaluation and the public comments provided in response to the
proposed rule. We conducted our review from August 1997 to December 1997
in accordance with generzilly accepted government auditing standards.
Enclosure II presents more details of our scope and methodology.

If you have any questions or need additional information, please call me at
(202) 51273650. Major contributors to this report were Marion Chastain,
Christopher Keislmg, Richard Scott, and Robert White.




Gerald L. Dillingham
Associate Director, Transportation
 Issues

Enclosures - 2


3                        GAO/ECED-98-543   Aircraft   Smoke Detection   and Fire Snppression
ENCLOSURE I                                                        ENCLOSURE I




MO      Installation of Smoke Detection and Fire
        Suppression Systems in U.S. Transport Aircraft




              Briefing for Congressional Requesters
                       December II,1997




                            GAO/RCED-98-54R   Aircraft   Smoke Detection   and F’ire Suppression
 4
ENCLOSURE I                                                     ENCLOSURE I




GAo Briefing Outline


        Background
        Research Questions
        Status of FAA’s and Industry’s Efforts
        Factors That Could Affect Timetable
        Conclusions and Potential Concerns
        Appendix




                        GAO/RCED-9%54R   Aircraft   Smoke Detection   and Fire Suppression
5
ENCLOSURE I                                                             ENCLdSUFiE I




a0           Background

 l       Fires in the cargo or baggage compartments
         of transport aircraft in recent years have resulted
         in accidents and loss of life and prompted FAA’s
         issuance of a proposed rule to require that 3,684
         aircraft be modified to include fire suppression
         and/or smoke detection systems.
 l       FAA estimates that the cost of an industrywide
         retrofit effort is about $296 million.
     l   FAA believes that installation can occur during
         annual scheduled maintenance for these aircraft.




                                 GAO/RCED-98-54R   Aircraft   Smoke Detection   and Fire Suppression
ENCLOSURE I                                                      ENCLOSURE I




w         Research Questions


      l   What is the status of FAA’s and the airline
          industry’s efforts to equip aircraft cargo holds
          with new smoke detection and fire suppression
          systems?

      l   What factors may affect the timetable for
          equipping the entire fleet with this new
          equipment?




                          GAO/RCED-9%54R   Aircraft   Smoke Detection   and Fire Suppression
ENCLOSTJREI                                                            ENCLOSURE I




GLQ-I Status of FAA’s Efforts--Rulemaking

 l           Key elements of FAA’s proposed rule
         l    Require retrofit of 2,994 passenger aircraft
              to install smoke detection and fire
              suppression equipment
         l    Require retrofit of 690 cargo aircraft to
              install smoke detection equipment only
         l    3-year compliance period




                                 GAO/RCED-9%54R   Aircraft   Smoke Detection   and Fire Suppression
     8
ENCLOSURE I                                                                                                         ENCLOSURE I




GJW Status of FAA’s Efforts--Rulemaking

                     Public comments on proposed rule*

                 “pressman
                 Require cargo




                                                                                                               Other




              Exclude selected on-demand                                             Extend/shorten
              air charters                                                           compliance period


‘Total of 92 comments received; percentages indicate the relative number of comments advocating the indicated change.




                                                                GAOLRCED-9%54R           Aircraft   Smoke Detection     and Fire Suppression
  9
ENCLOSURE I                                                                  ENCLOSURE I




MO                  Status of FAA’s Efforts--Rulemaking

l           FAA has accelerated issuance of final rule.
        l        Law requires FAA to issue final rules within
                 16 months after end of the comment period.
        l        FAA plans to issue smoke detection and fire
                 suppression rule by l/1/98--in less than 4 months.
    l           FAA plans to monitor operators’ compliance.
            l    Number of systems installed/to be installed
            l    Publicly report compliance progress




                                       GAO/RCED-9%54R   Aircraft   Smoke Detection   and Fire Suppression
        10
ENCLOSURE I                                                             ENCLOSURE I




w           Status of Industry’s Efforts--Alternative
            Approaches for Installation
l   Approaches        Used to Date
    l    Delta developed a system for its 737-200 aircraft
         and obtained FAA certification.
    l    AirTkan purchased certificated systems from
         an independent integrator for its DC-g-30 aircraft.
l       Alternative Approach
    l    Operators may also buy certificated systems
         from aircraft manufacturers that provide
         technical instructions and sell installation kits.




                                GAO/RCED-9%54R   Aircraft   Smoke Detection   and F’ire Suppression
ENCLOSURE I                                                                                                               ENCLOSURE I




m*               Status of Industry’s Efforts--Aircraft
                 Manufacturers’ Plans
   l        Most manufacturers plan to issue
            technical installation instructions and
            certify systems.
        l    Airbus, Boeing, British Aerospace, Dornier,
             Embraer, and Fokker plan to issue service
             bulletins* (about 3,500 aircraft or 95% of
             the affected fleet).
        l    CASA, Lockheed, and Shorts have no plans
             to issue service bulletins (about 180 aircraft).
 *Service bulletins will provide detailed technical information on installation of certified smoke detection and fire suppression systems.




                                                                     GAO/RCED-9%54R            Aircraft    Smoke Detection          and Fire Suppression
   12
ENCLOSURE I                                                                ENCLOSURE I




w               Status of Industry’s Efforts--Operators’
                Plans for Installation
      l       Most of the responding airlines                          believe
              3-year compliance is feasible.
          l    GAO obtained information from 15 airlines.
          l    Only about half indicated they had detailed
               plans for scheduled installation of smoke
               detection and fire suppression systems.
          l    Plans for installation varied in specificity
               in terms of schedule and selection of
               suppliers and integrators.




                                  GAOLRCED-98-54R   Aircraft   Smoke Detection   and Fire Suppression
 13
ENCLOSURE I                                                          ENCLOSURE I




CI+KI Status of Industr$s Efforts--Suppliers’
      Development of New Technologies
l   Current suppliers have developed more sensitive
    and reliable detection equipment to meet FAA’s
    requirement of smoke detection within 1 minute.
    l    Kidde, Autronics, Whittaker, Cerebrus Guinard
l       Emerging detection/suppression  technologies
        may reduce modification costs/speed
        installation.
    l    Securaplane testing wireless detection systems
    l    Microsafe and CeaseFire developing systems




                              GAO/RCED-98-54R   Aircraft   Smoke Detection   and Fire Suppression
    14
ENCLOSURE I                                                                                                           ENCLOSURE I




MO                Factors That Could Affect Timetable:
                  Certification Process

 l    Interpretation of FAA’s test criteria for certifying
      smoke detection and fire suppression systems
      may cause testing and certification delays.

      --Definition of a “small smoldering fire”
      --Definition of “start of fire”
      --Identification of ignition source
      --Status of cargo hold contents (empty, full)
      --Measurement of halon concentration*

‘Halon gas is the most common extinguishing agent for fire suppression systems; its use is regulated by the Environmental Protection Agency.




                                                                  GAO/RCED-98-54R          Aircraft    Smoke Detection       and Fire Suppression
     15
ENCLOSURE I                                                    ENCLOSURE I




MO      Factors That Could Affect Timetable:
        Industry’s Production/Installation Capacity

  l   Detection and suppression suppliers
      assert sufficient capacity to meet
      industry requirements.

  l   Repair stations contacted indicate that
      capacity is not a limiting factor if
      installation can be accomplished during
      scheduled maintenance.




                         GAO/RCED-9%54R   Aircraft   Smoke Detection   and Fire Suppression
 16
ENCLOSURE I                                                           ENCLOSURE I




MO        Factors That Could Affect Timetable:                                 Use
          and Availability of Halon

      l       Use: EPA’s current policy is to manage the
              release of halon rather than ban its use.
          l    No consensus has formed on a viable halon
               replacement or alternative.
      l       Availability: EPA estimates implementation
              of the rule will require 2.5% to 7% of U.S.
              halon stockpile.
          l    Future needs could be met through
               recycling efforts.




                             GAO/RCED-98-54R   Aircraft   Smoke Detection   and Fire Suppression
ENCLOSTJREI                                                       ENCLOSUIZE I




Gho Preliminary Conclusions

      Smoke detection and fire suppression
      systems have been certified for DC-9
      and 737 aircraft.

      Detection and suppression suppliers and
      repair stations contacted report sufficient
      capacity for production and installation.

  l   Availability and use of halon is not a limiting
      factor.




                           GAO/RCED-98-54R   Aircraft   Smoke Detection   and F’ire Suppression
 18
ENCLOSURE I                                                            ENCLOSURE I




GAO Potential Concerns

 l    FAA’s lack of standardization of certification test
      criteria may slow future certification efforts.
 l    Not all airlines have fully developed plans to
      retrofit affected aircraft.
 . Industry’s capacity may be an issue if installation
   cannot occur during scheduled annual maintenance.
 l    Timely publication of final rule is essential.
 l    FAA’s proposed compliance reporting may require
      more information for effective congressional
      oversight.




                              GAO/RCED-98-54R   Aircraft   Smoke Detection   and Fire Suppression
 19
ENCLOSUJXE I                                                                                       ENCLOSURE I




MO            Appendixm Manufacturers of Affected
              Passenger Aircraft

                                                              Boeing   46.1%




                                                                                    Total all Other        8.5%

          MD/Douglas           29.8%                                          Lockheed         3.2%
                                                                          Fokker 5.1%
                                                                   Embraer 7.3%



                                                  2,994 passenger aircraft affected


 Source: FAA Preliminary Regulatory Evaluation.




                                                                  GAO/RCED-98-54R   Aircraft   Detection   and F’ire Suppression
 20
ENCLOSURE I                                                                                     ENCLOSURE I




w              Appendix: Manufacturers of Affected
               Cargo Aircraft

                                                         MD/Douglas




               Other 4.2%




                                                                    Boeing


                                                  690 cargo aircraft affected
 Source: FAA Preliminary Regulatory Evaluation.




                                                      GAOIRCED-98-54R    Aircraft   Smoke Detection   and Fire Suppression
 21
ENCLOSURE I                                                                                                        ENCLOSURE I




GAO Appendix: Impact of Retrofit Program
    on Selected Major Airlines’ Fleets*
                                         Percentage of fleet affected

          American

        Continental

                 Delta
                                              I                         I
                                                                .:
 Federal Express             ‘.
                                              I                         I             I                     I
          Northwest           .-::                      .i.         I                .“.      ;
                                                                                                                      I
                                              I                         I                l-                                 -I
         Southwest
                                  :y..                                              :.
        TransWorid 1

        US Airways

               United

      UnitedParcel                ‘.’                               ;
                                                  I                         ,
                         0                   20                     40               60                    80              100

 *A major airline is one whose annual revenues exceed $1 billion.




                                                                        GAO/RCED-9%54R        Aircraft   Smoke Detection   and Fire Suppression
 22
ENCLOSURE I                                                                                                               ENCLOSURE I




GAQ Appendix: Impact of Retrofit on Selected
    National and Regional Airlines’ Fleets*
                                     Percentage of fleet affected


                Hawaiian



     Midwest Express



   Atlantic Southeast



          PSA Airlines



        UFSlTranstate


                              0
*A national airline generates annual revenues between $100 million and $1 billion, and a regional airline’s annual revenues total less than $100 million.




                                                                    GAO/RCED-98-54R           Aircraft    Smoke Detection        and Fire Suppression
  23
ENCLOSURE I                                                                           ENCLOSURE I




w                Appendixm Smoke Detection and Fire
                 Suppression Suppliers Contacted
         l       Established         Suppliers
                 l       Walter Kidde (Delta--detector and suppression)
                 l       Pacific Scientific (AirTran--suppression)
                 l       Whittaker (FAA-approved Boeing supplier)
                 l       Autronics (FAA-approved Boeing supplier)
             l       Suppliers     of Developmental             Systems
                     l   SecuraPlane--SouthWest          (STC pending)
                     l   MicroSafe--developmental         system
                     l   CeaseFire--developmental          system




                                              GAO/RCED-98-54R    Aircraft   Smoke Detection   and Fire Suppression
    24
ENCLOSURE I                                                              ENCLOSURE I




w            Appendix: Repair Stations


l        Repair Stations capable of installation                       include
     l    Major airlines (American, Continental, Delta,
          FedEx, Northwest, TWA, United)
     l    National airlines (Aloha, Evergreen)
     l    Manufacturers (Boeing, Lockheed)
     l    Independent stations (TRAMCO, TIMCO)
l        Regional airlines also operate repair stations
         that may have the capability for installation.




                                GAO/RCED-98-54X   Aircraft   Smoke Detection   and Fire Suppression
    25
            ENCLOSURE II                                           ENCLOSURE II
                               SCOPE AND METHODOLOGY
                                                                   .- -
       To determine the status of FAA’s and the industry’s efforts and timetable, we
obtained information on the rulemaking and certification processes from FAA and
discussed completed certification efforts with a representative from FAA’s Aircraft
Certification Office in Atlanta, Georgia.. We also discussed the certification efforts with
representatives from the airlines that were involved in the process.

      To determine the aircraft manufacturers’ plans to provide technical guidance, we
met with officials from the Boeing Commercial Airplane Group in Seattle, Washington,
and Douglas Products Division of Boeing in Long Beach, California. We also contacted
U.S. representatives of internationally based aircraft manufacturers.

      To determine the status of airlines’ plans for installation of smoke detection and fire
suppression systems, we obtained information from selected airlines about their retrofit
programs and the extent to which they had planned for installation of the equipment.
Affected aircraft operated by these airlines account for almost three-quarters of FAA’s
estimate of all affected aircraft.

      To identify the major factors that could affect the timetable for installation of the
equipment, we interviewed industry representatives from the National Transportation
Safety Board, the Air Transport Association, and the Regional Airline Association, as well
as other aviation industry associations.

      To determine the capacity of smoke detection and fire suppression system
manufacturers, we visited facilities of current industry suppliers and contacted
representatives from suppliers that were developing new technologies.

        To determine the capacity of the industry to install the retrofit systems, we
discussed installation plans with (1) officials at the selected airlines that intended to
retrofit some or all of their aircraft m-house and (2) representatives Tom two major
independent repair stations certified to perform a comprehensive range of aircraft
maintenance and modifications.

      To determine whether limitations on the use and availability of halon would affect
the retrofit program, we discussed those issues with an official from the Environmental
Protection Agency and officials horn FAA’s William J. Hughes Technical Center.

 (348044)




 26                                  GAO/NED-9%54R    Aircraft   Smoke   Detection   and Fire   Suppression
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