NPRM 2012-NM-004-AD

Presented to Industry MeetingMarch 7, 2012
Status

• AD 2011-04-09/SFAR 111 Issued March 2011• ARC formed and made recommendations Apr• Policy Statement PS-ANM-25-04 issued Decem• NPRM AD 2012-NM-004-AD published Februar

supersede AD 2011-04-09
Status

• COG installations in lavatories require an AMO

04-09

• Non-COG installations, as well as COG install

lavatory do not require an AMOC

• Any COG installation will be judged against p

PS-ANM-25-04 at some point

• Any approvals granted in advance of the final 

be subject to the AD
Rationale for NPRM AD App

• Alternatives Considered• Timing• Nature of the Action• Reconcile Original AD
Alternatives Considered

• Terminate the SFAR

– Rulemaking Process– Indirect imposition of requirements, i.e., implicit but – Ultimately requires further rulemaking

• Part 121/129 Rule Change

– Normally used to raise the level of safety, or addre

previously identified

– This action simply restores level of safety (oxygen 

lavatories)
Timing

• Changes to regulations take time• Even with expedited process would take mult

• Safety/risk assessment was based on limited 

basically not to exceed 4 years

• Any action needs to allow complete retrofit in 

compliance compatible with the safety assess
Nature of the Action

• Reinstallation of oxygen in the lavatories is a 

• Resulting level of safety is what it was prior to • Improvement in security is a necessary action 

safe operation of the airplane

• Net affect is that safety is back to where it was 
Reconcile AD 2011-04-09

• AD 2011-04-09 was always going to require a 

action

• AMOCs to that AD would be required indefinit• ADs are typically resolved with a terminating 

original action is known to be, or learned to b

• This proposal is typical in that respect 
NPRM Key Points

• Distinction between COG and non-COG instal• Applicability• Approval process• AMOCs
COG Distinction

• Several distinctions based on the use of COG • Use of COG necessitates consideration of sec• New application of security measures necess

involvement

• Although ‘immediately obvious’ meets the sec

provisions, we’re not ready to have applicants 

determination on their own

• Approval process differs for non-COG install

• AMOC process differs for non-COG installatio
Discussion of NPRM Provis

• Applicability

– Original applicability of AD 2011-04-09 alone won’t 

airplanes in US commercial service have COG in l

– However, original applicability needs to be retained 

airplanes from entering the fleet ‘unmodified’
Discussion of NPRM Provis

• Approval process is known to be an industry • NPRM permits full exercise of delegated autho

installation

– ODAs with the authority to approve major modifica

even though this is an AD action

– ‘Normal’ STC process can be followed

• In other words, for a non-COG installation it’s 

standard STC installation than an AD approva
Discussion of NPRM Provis

• AMOC provisions are also different

– No formal AMOC required for non-COG installation

approved service instructions are needed

– Still requires approval

• AMOCs (for COG installations) approved by T

– Close coordination with ACOs and AFS– Expect to develop expedited process
Related FAA Actions

• Aircraft Certification Team/Focal Points

– All ACOs have a focal point for this activity– TAD has held periodic telecons with team to upd

standardized process

– Projects will be given priority– No tail number required to apply for an STC– Multiple TAD contacts to assist ACOs with any q– TAD will be involved—similar to flightdeck doors—

consistent standards are applied
Related FAA Actions

• Close coordination between Aircraft Certificat

Standards

• AFS participation in the ACO telecons• InFO drafted to inform both operators and fiel

unique AD provisions