Airworthiness Directives; The Boeing Company Airplanes

SUPPLEMENTARY INFORMATION:

Background

The FAA issued a notice of proposed rulemaking (NPRM) to amend 14 CFR part 39 by adding an AD that would apply to all The Boeing Company Model 787-8, 787-9, and 787-10 airplanes. The NPRM published in the Federal Register on February 6, 2024 (89 FR 8109). The NPRM was prompted by a determination that the flight deck door decompression panel can strike the captain's seat headrest if a flight deck or below the flight deck rapid decompression event occurs when the seat is in a certain position. In the NPRM, the FAA proposed to require, for certain airplanes, replacing the affected captain's seat assembly. The FAA also proposed to prohibit the installation of affected parts. The FAA is issuing this AD to address the possibility that the decompression panel could strike the captain's head or face. The unsafe condition, if not addressed, could result in serious or potentially fatal injury to the captain after a flight deck or below the flight deck rapid decompression event.

Discussion of Final Airworthiness Directive

Comments

The FAA received comments from Air Line Pilots Association, International (ALPA) and United Airlines who supported the NPRM without change.

The FAA received additional comments from six commenters, including American Airlines, Air France, Boeing, British Airways, KLM Royal Dutch Airlines, and an individual. The following presents the relevant comments received on the NPRM and the FAA's response to each comment.

Request To Change Applicability

American Airlines requested that the applicability of the proposed AD be limited to the Boeing airplanes with line numbers in the effectivity of Boeing Special Attention Requirements Bulletin B787-81205-SB250294-00 RB, Issue 001, dated June 14, 2023. The commenter stated that the Boeing Illustrated Parts Data (IPD) does not allow the installation of the captain's seat having Ipeco part number (P/N) 3A380-0007-01-7 on Boeing airplanes with line numbers that are not in the effectivity of Boeing Special Attention Requirements Bulletin B787-81205-SB250294-00 RB, Issue 001, dated June 14, 2023.

The FAA does not agree with the request. As explained in the NPRM, the FAA has determined there is a rotability issue, and the actions required by this AD can be accomplished on Boeing airplanes that are not identified in the effectivity of Boeing Special Attention Requirements Bulletin B787-81205-SB250294-00 RB, Issue 001, dated June 14, 2023. It is physically possible to install a captain's seat having Boeing P/N S632Z301-21 (Ipeco P/N 3A380-0007-01-7) on airplanes initially delivered with the acceptable seat assemblies. The FAA has not changed this AD in response to this request.

Request for Alternative Method of Compliance

Air France, KLM Royal Dutch Airlines, British Airways, and an individual requested the proposed AD be revised to allow using procedures or modifications similar to those in the existing Boeing Flight Crew Operations Manual (FCOM). Air France requested an alternative method of compliance (AMOC) that could consist of marking limits on the flight deck based on existing Boeing FCOM instructions and adding procedures (which the commenter stated Boeing is developing) into the Airplane Flight Manual (AFM). KLM Royal Dutch Airlines requested that, as an alternative to the proposed AD, the FAA consider allowing instructions similar to those in the existing Boeing FCOM, along with revising the procedures in the AFM to include installation of a placard limiting seat recline and providing information to aid accurate seat positioning. British Airways noted that the proposed AD allows installing later-approved part numbers and claimed that the later-approved part will be a seat with a placarding solution as proposed by Boeing that will essentially revert the part number back to a “-7.” British Airways requested that the proposed AD be revised to allow for the Boeing proposal using a placard as a means of compliance. An individual requested an AMOC-type approach that allows operators to enhance procedural compliance with the existing Boeing FCOM using procedures (including FCOM guidance around limiting the recline/aft movement of the seat), flight deck markings, and crew awareness training. The individual also requested a longer-term approach to the decompression panel issue that allow time for Boeing to come up with a permanent engineering solution to the door panel which will avoid the need to artificially limit the captain's seat recline. Air France stated that the seat modification makes it impossible for pilots to achieve effective rest and may force the operator to add a third pilot on the operated routes or change the Boeing 787 fleet network, which can cause significant costs. KLM Royal Dutch Airlines stated that the seat modification limits seat recline to the point that it reduces the ability for pilots to have a controlled rest, which can negatively affect flight safety. KLM Royal Dutch Airlines suggested that its proposal would achieve the same level of safety as the proposed seat hardware modification. British Airways noted that the mechanical limiting device is more restrictive for tilt and recline than the guidance in Boeing's existing FCOM, meaning pilots can't effectively rest in the operating seat, increasing operational risk due to pilot fatigue. British Airways suggested the increased risk due to pilot fatigue outweighs the low risk of a flight deck decompression while the pilot's seat is in the most rearward and tilted position. The individual stated that the risk analysis appears to be exaggerated given the likelihood of a decompression event occurring with a taller pilot without an alternative crew member available to safely continue flight, which the commenter stated is not likely given in-service experience of modern jet aircraft. The individual stated that the seat recline is restricted more than what would be required for 99.9% of the pilot cohort to avoid contact with the decompression panel in the event of an in-flight decompression. The individual suggested that the mechanical limiter doesn't account for the fore/aft position of the seat and assumes an absolute worst-case scenario with a pilot in the 0.01 percentile.

The FAA does not agree with the commenters' requests. The FAA evaluated fleet data and determined through risk analysis that the risk to flight crew is unacceptable and that delaying this action would be inappropriate. Additionally, the FAA notes that the flight deck door decompression panel may strike a taller or shorter pilot during a flight deck decompression event because the captain's seat headrest is in the path of the decompression panel when the seat is in the aft track position with full recline and full seat pan tilt. The commenters' proposals do not include supporting data that demonstrates an acceptable level of safety. However, under the provisions of paragraph (k) of this AD, operators may submit AMOC proposals that include supporting data that demonstrates an acceptable level of safety. Regarding a commenter's request to revise the AD to allow Boeing's proposed placard as a means of compliance, the FAA notes that this AD allows installing later-approved parts that meet the criteria specified in paragraph (h)(2) of this AD. A later-approved part may have a placard solution, but a placard solution alone is not the same as a later-approved part. The FAA has not changed this AD in response to these requests.

Request To Clarify Rapid Decompression Event

Boeing requested that the FAA clarify text regarding the rapid decompression event that could lead to the unsafe condition. Boeing requested that the FAA revise the text “flight deck decompression event” to instead say “flight deck or below the flight deck rapid decompression event” when referring to events that could cause the flight deck door decompression panel to strike the captain's seat headrest. Boeing stated that each event would cause the flight deck door to open in the forward direction, either partially or fully.

The FAA agrees with the request for the reasons provided. The FAA has revised this AD accordingly.

Request To Extend the Compliance Time

British Airways requested that the compliance time be extended. British Airways noted that it relies on subcontractor suppliers to modify the seats, with limited extra seats to use while replacement seats are being provided, and the supplier may not have capacity to ramp up to conversion rate. British Airways added that Boeing does not have stock of the captain's seat having Boeing P/N S632Z301-31 (Ipeco P/N 3A380-0007-01-8) to support a fleet-wide campaign within the 3-year compliance time.

The FAA does not agree with the request. After considering all the available information, the FAA has determined that the compliance time, as proposed, represents an appropriate interval of time in which the required actions can be performed in a timely manner within the affected fleet, while still maintaining an adequate level of safety. In developing an appropriate compliance time, the FAA considered the safety implications, parts availability, and normal maintenance schedules for timely accomplishment of the modifications. The FAA has not changed this AD in response to this request.

Conclusion

The FAA reviewed the relevant data, considered any comments received, and determined that air safety requires adopting this AD as proposed. Accordingly, the FAA is issuing this AD to address the unsafe condition on these products. Except for minor editorial changes, and any other changes described previously, this AD is adopted as proposed in the NPRM. None of the changes will increase the economic burden on any operator.

Material Incorporated by Reference Under 1 CFR Part 51

The FAA reviewed Boeing Special Attention Requirements Bulletin B787-81205-SB250294-00 RB, Issue 001, dated June 14, 2023. This material specifies procedures for replacing the affected captain's seat assembly part number (P/N) S632Z301-21 (Ipeco P/N 3A380-0007-01-7) with captain's seat assembly P/N S632Z301-31 (Ipeco P/N 3A380-0007-01-8).

This material is reasonably available because the interested parties have access to it through their normal course of business or by the means identified in the ADDRESSES section.

Costs of Compliance

The FAA estimates that this AD affects 155 airplanes of U.S. registry. The FAA estimates the following costs to comply with this AD: