Craig Amadeo 

General Manager

Engineering Standards & 

Chief Engineer

Delta Air Lines, Inc.

1775 Aviation Blvd

Atlanta, Ga. 30320

T. +1 404 714 1312

F. +1 404 773 3675

craig.amadeo@delta.com

March 22, 2013

U.S. Department of Transportation

Docket Operations, M-30, West Building Ground Floor, Room W12-140

1200 New Jersey Avenue SE

Washington, DC 20590

Fax: (202) 493-2251

Subject: Docket No. FAA-2013-0090; Directorate Identifier 2012-NM-149-AD– Proposed Rule

Reference: /A/ Notice of Proposed Rule Making (NPRM): Docket No. FAA-2013-0090; Directorate 

Identifier 2-13-NM-149-AD

/B/ Boeing Service Bulletin 747-25-3428, Revision 3, dated 14 June 2012

/C/ Boeing Message: DAL-DAL-13-0578-03B, Subject: 747-25-3428 Compliance Time, 

dated 18 March 2013

SUMMARY:

Ref. /A/ was prompted by reports of worn or incorrectly assembled latches on main deck escape slides installed on 

airplane doors. This NPRM was issued to prevent a latch hook moving from closed to open in an escape slide/raft or 

escape slide not deploying correctly in an emergency or releasing/inflating into the passenger cabin and causing injury 

to passengers and crew.

Compliance with Ref. /A/ requires the inspection and modification of the latch assembly, in accordance with Ref. /B/

within 48 months of the AD effective date.

DELTA’S COMMENTS

Delta requests that the 48 month compliance time for the proposed AD be extended up to 60 months. This will allow for 

the modification to be accomplished at the next scheduled overhaul for Delta’s affected slides. By allowing this 

compliance time extension, it would decrease the financial effect to Delta and other operators by removing the need to 

schedule early removal of the slide/raft and slide packs. At Ref. /B/ creation, a risk assessment was performed to 

determine if modification needed to be expedited. There were too few instances to perform a proper analysis, so Boeing 

determined that it was acceptable to set the compliance time to correspond with the recommended slide overhaul cycle 

at the time of release. The unsafe condition reported in this NPRM and Ref. /B/ has not resulted in injury to passengers 

or crew, thus the modification can be scheduled to coordinate with routine maintenance without an undue risk to 

passengers or crew. Ref. /C/ provides Boeing’s concurrence to the compliance time extension.

Additionally, Delta requests that the proposed AD allow the replacement of affected slides with slides that have 

completed the inspection and modification requirements of Ref. /B/ as an acceptable means of compliance. This will 

allow Delta and other operators to bypass the installation and removal procedures of Ref. /B/ while addressing the 

unsafe condition in the same manner as the proposed AD. Tracking compliance with Ref. /B/ is possible, because the 

slide pack assy. is identified to indicate completion of SB 747-25-3428 Rev. 3.

Alternatively, if replacement is deemed unacceptable, Delta requests that the proposed AD include a statement noting 

that removal and installation of the slide per the SB is not an AD mandated task, but accomplishment by means of an 

approved routine maintenance item would also be acceptable. This would not affect the modification of the slide, 
March 22, 2013

Page 2 of 2

because Ref. /B/ refers to a door-specific AMM section or “an accepted alternative procedure” for these processes. It 

would allow Delta and other operators to track compliance at the slide level and ensure fleet-wide compliance by 

attrition. It will also provide an elegant method to ensure spares are modified.

If you have any further questions or require additional information, please contact Kendra Johnson- Aerospace 

Engineer, Interiors Engineer, at (404)714-1207 or email at kendra.johnson@delta.com.

Thank you,

Peter Lauria

ODA Lead administrator and Acting Chief Engineer

Dept. 574 

for

Craig Amadeo 

General Manager – Engineering Standards & Chief Engineer

Dept. 567