BEFORE THE U.S. DEPARTMENT OF TRANSPORTATION 

The Honorable Chief Administrative Law Judge Ronnie A. Yoder 

rifT'.i 

In the matter of 

BRENDAN AIRWAYS, LLC, 

d/b/aUSA3000 Airlines 

Respondent 

DMS No.: FAA-2009-0032 

FAA Docket No.: CP09EA0007 

FAA Case No.: 2008EA170038 

RESPONSE TO COMPLAINANT'S 

FIRST SET OF INTERROGATORIES, 

REQUEST FOR ADMISSIONS, AND 

REQUEST FOR PRODUCTION OF 

DOCUMENTS 

Comes now the Respondent, Brendan Airways, LLC d^/a US A3000 Airlines [hereinafter 

"USA3000"] and RESPONDS to the Complainant's First Set of Interrogatories, Request for 

Admissions, and Request for Production of Documents. 

Responses to Interrogatories 

1. Identify the names, titles, business or home addresses and telephone numbers of each 

person whom the Respondent intends to call as a witness at the hearing of this matter. 

Response: 

The identity of any witnesses is a matter of trial strategy that has not yet been decided. The 

Respondent reserves the right to amend this answer as trial witnesses are identified. 

2. Provide the substance of the testimony to be offered by each of said witnesses. 

Response: 

The identity of any witnesses is a matter of trial strategy that has not yet been decided. The 

Respondent reserves the right to amend this answer as trial witnesses are identified. 

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3. With respect to each expert witness identified in response to request Nos. 1 and 2 above: 

(a) identify the subject matter on which the expert is expected to testify; 

(b) list the substance of the facts and opinions to which the expert is expected to 

testify; 

(c) provide a summary of the grounds for each opinion; 

(d) if the Respondent intends to introduce into evidence or otherwise rely upon a 

written curriculum vitae or other written document listing the expert's 

professional qualifications, identify and attach copies of all such documents. 

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Response: 

The identity of any expert witnesses is a matter of trial strategy that has not yet been decided. 

The Respondent reserves the right to amend this answer as expert witnesses are identified. 

4. To the extent not encompassed in your response to Nos. 1,2, and 3 above, identify and 

produce statements of all individuals who spoke to, or were interviewed by, the Respondent 

regarding this matter. 

Response: 

We object to this interrogatory to the extent that it might be interpreted to include interviews 

conducted by Counsel, on the grounds that such interviews are protected from discovery as 

Attorney Work Product. 

All Respondent conversations are detailed in a June 11, 2008, letter from Respondent to 

Laurence Johnson, outlining the interviews conducted and describing the information gleaned 

from them. That letter is attached. Two additional documents exist that are also responsive 

(both are also attached): 

• The Respondent interview of Joe Miller resulted in a separate summary of the interview. 

A copy of the June 13, 2008 letter that was produced as a summary of the interview is 

attached. 

• The Respondent asked Chief Pilot Tim Lyons why Captain Walker was in the left seat 

during the flight. A June 3, 2008 email describing the answer is attached. 

5. Identify and produce copies of any and all documents on which the Respondent 

anticipates relying, or will rely, in support of the case it will present at the hearing in this matter, 

including but not limited to documents you intend to introduce into evidence. 

Response: 

Respondent anticipates relying on 

• The ttanscript of the enforcement action Babbitt v. Surratt and Walker (NTSB Docket 

Nos. SE-18562andSE-18563). 

• The Decision of Judge Fowler in the enforcement action Babbitt v. Surratt and Walker 

NTSB Docket Nos. SE-18562 and SE-18563 (Issued orally August 12, 2009 and issued 

in writing on September 2, 2009). 

• The Decision of the NTSB denying the appeal of the enforcement action Babbitt v. 

Surratt and Walker EA-5514 (NTSB March 23, 2010). 

• The Decision of the NTSB denying the petition for reconsideration in the appeal of the 

enforcement acfion Babbitt v. Surratt and Walker EA-5527 (NTSB June 25, 2010). 

• The four documents attached to the Respondent's Discovery Request dated June 21, 

2010, which have previously been provided to the Complainant (with that Discovery 

Request). 

• The documents attached to this Response. 
Respondent objects to the direction to produce copies of the cases and transcripts mentioned 

above, as the transcripts and case decisions are already in the possession of the FAA and the 

cases are also available through standard online research mechanisms. 

The specific identity of additional exhibits is a matter of trial strategy that has not yet been 

decided. The Respondent reserves the right to amend this answer as trial exhibits are identified. 

6. Identify who placed the aircraft's spoiler servo actuators for left wing roll spoilers three 

and five in the maintenance mode prior to the flight and between April 29,2008 and March 17, 

2008. 

Response: 

During the period April 18-April 29, AAR placed the aircraft's spoiler servo actuator for left 

wing spoiler three in the maintenance mode. AAR stated in a May 30, 2008 letter to the FAA 

that the aircraft's spoiler servo actuator for left wing spoiler three was returned to operational 

mode on April 29. This the only time that the aircraft's spoiler servo actuator for left wing 

spoiler three was placed in the maintenance mode between March 17, 2008 and April 29, 2008. 

According to the records we have, the aircraft's spoiler servo actuator for left wing spoiler five 

was not placed in maintenance mode between March 17, 2008 and April 29, 2008. 

7. Explain all reasons why the aircraft's spoiler servo actuators for left wing roll spoilers 

three and five were placed in the maintenance mode prior to the flight and between April 29, 

2008 and March 17, 2008. 

Response: 

To our knowledge, the aircraft's spoiler servo actuator for left wing spoiler three (but not five) 

should have been placed in the maintenance mode only once between March 17, 2008 and April 

29,2008. Between April 18 and April 29, 2008, AAR was working on the left wing's number 

three spoiler control. This was done as part of a non-routine maintenance activity that was 

accomplished pursuant to A3 20 AMM 27-64-43. A successful operational check on April 29 

confirmed that this spoiler was returned to the operational mode. 

8. Identify who and/or what entity is responsible for the aircraft's spoiler servo actuators for 

left wing roll spoilers three and five being placed in maintenance mode prior to the flight and 

explain why you believe that person or entity is responsible. 

Response: 

Aside from the work described in the response to interrogatory 7, we do not know who and/or 

what entity is specifically responsible for the aircraft's spoiler servo actuators for left wing roll 

spoilers three and five being placed in maintenance mode prior to the flight. 
9. Answer whether a failure of one of the aircraft's spoiler servojacks could cause an amber 

LAF DEGRADED message to appear on the aircraft's EC AM. 

Response: 

Yes, that is one of the many scenarios under which an amber LAF DEGRADED message might 

appear on the aircraft's EC AM. 

10. Explain all reasons for your belief that the aircraft can be dispatched when left and right 

wing spoilers three and five are inoperative. 

Response: 

We object to this interrogatory on the grounds that it assumes a "belief that Respondent has not 

professed. Respondent also objects to this interrogatory on the grounds of relevance, because the 

term inoperative is defined as "a system or component malfunction" and the spoilers in this case 

were in maintenance mode, not malfunctioning 

11. If you believe that the aircraft is in a condition for safe operation when the aircraft's left 

and right wing roll spoilers three and five are inoperative please state and explain all reasons for 

your belief 

Response: 

Respondent objects to this interrogatory on the grounds that this interrogatory calls for an 

opinion concerning safety, for which Respondent does not have appropriate engineering data to 

respond. Respondent also objects to this interrogatory on the grounds of relevance, because the 

term inoperative is defined as "a system or component malfunction" and the spoilers in this case 

were in maintenance mode, not malfunctioning Without waiving these objections. Respondent 

states that generally, if spoilers are known to be inoperative, then the aircraft should only be 

dispatched in accordance with the aircraft's MEL. 

12. If you believe that the aircraft conforms to its type certificate and/or type design when the 

spoiler servo actuators for left wing roll spoilers three and five are placed in the 

maintenance mode please state and explain all reasons for your belief 

Response: 

Maintenance mode is provided by the manufacturer as original equipment on the aircraft and is 

therefore described in the type design for the aircraft. 
13. Explain all reasons for your belief that the placement of left wing roll spoilers three and 

five in the maintenance mode was not part of any maintenance performed on the aircraft. 

Response: 

We object to this interrogatory on the grounds that it misstates our contention. We have never 

claimed that that the placement of left wing roll spoilers three and five in the maintenance mode 

was not part of any maintenance performed on the aircraft. We do not know how or when the 

left wing roll spoilers three and five were placed in the maintenance mode. Our contention is 

that the placement of left wing roll spoilers three and five in the maintenance mode was not part 

of any maintenance that was ordered by, or within the control of, USA 3000. 

In a letter to the FAA dated May 30, 2008, AAR (the maintenance contractor) admitted that 

during the course of the visit, on or before April 29, 2008, the servo switches for the #2, #3 and 

#4 LEFT spoilers and the #4 and #5 RIGHT spoilers were placed in the 'Maintenance' mode." 

AAR indicates that on or before April 29, its investigation shows that the servo switch for the #3 

LEFT spoiler was placed in the 'Maintenance' mode" but then was returned to the operational 

mode. AAR indicates that its records and investigation suggest that the servo switch for the #5 

LEFT spoiler was never placed in the 'Maintenance' mode during maintenance performed for 

USA3000. 

AAR's letter indicates that the servos were returned to the operational mode on or before April 

29 and therefore if they were placed in the maintenance mode it had to have happened after the 

April 29 inspection that confirmed they were in the operational mode. 

That May 30 letter explains that while the physical evidence shows that on or before May 17, 

2008, left wing roll spoilers three and five were placed in the maintenance mode, "there is no 

record of such action and we were unable to determine who may have been involved." 

USA3000 requires all maintenance to be performed according to work cards or non-routine 

cards. The USA3000 work cards were completed, and there appears to be no other spoilerrelated irregularities in the work cards or the non-routine cards. None of the work cards and nonroutine cards that were accomplished on or after April 29, 2008 required the left wing roll 

spoilers three and five to be placed in the maintenance mode. 

On May 15,2008, Mr. Miller and Mr. Beal of USA 3000 performed engine tests on the aircraft. 

During the course of those tests, Mr. Miller had occasion to perform a flight control test. He 

received no ECAM warnings about the spoilers and received no indication that the spoilers were 

in maintenance mode. As of this date, all of the maintenance performed on the aircraft before 

the flight, had been accomplished. 

14. Identify what section of the USA 3000 Airlines Minimum Equipment List, if any, states, 

implies, or infers that the aircraft can be dispatched when two pair of symmetrical spoiler 

surfaces three and five are inoperative. 

Response: 

None 
15. Please identify any malfunctions that occurred in the aircraft's ECAM system that 

occurred during the flight but prior to takeoff. 

Response: 

Unknown. 

16. Please describe all ways in which it was determined that the ECAM system 

malfunctioned during the flight but prior to takeoff 

Response: 

We object to this interrogatory in that it either is duplicative of interrogatory 15, or else if it is 

substantively different from interrogatory 15 then it is asking for something that we cannot 

understand (too vague). 

17. If it is your belief that the ECAM failed to report that left and right wing roll spoilers 

three and five were inoperative and/or were locked out at any time prior to takeoff please explain 

all reasons why you hold this belief. 

Response: 

During the matter Babbitt v. Surratt and Babbitt v. Walker, Captain Walker and Captain Surratt 

each testified that at the time of take-off, the only message on the ECAM was "LAF Degraded." 

LAF Degraded indicates that the Load Alleviation Function (LAF) is not operating correctly, and 

is for crew awareness only. 

18. If it is your belief that the pilots aboard the aircraft performed a successful flight control 

check for the flight, with respect to the checks for the spoilers, please explain all reasons why 

you hold this belief 

Response: 

We object to this interrogatory on the grounds of relevance. Without waiving the objection, we 

state that during the matter Babbitt v. Surratt and Babbitt v. Walker, Captain Walker testified that 

he completed a successful flight control check for the flight, and Captain Surratt testified that his 

flight control check was deemed complete after the seemingly-spurious warnings were cleared. 

19. Identify and describe all reasons why during the flight the aircraft's left wing tip 

contacted the runway during the aircraft's first landing attempt. 

Response: 

Object on the grounds that it calls for speculation. Without waiving this objection, the force of 

gravity overcame the counteracting forces of lift with respect to the wing. 
20. Identify and describe what mechanical malfunctions in the aircraft, if any, occurred 

during the flight. 

Response: 

A copy of the aircraft log pages describing the mechanical malfunctions is attached. 

21. Identify and describe what errors were committed by the pilots during the flight, if any, 

that led to the aircraft's left wing tip contacting the runway during the flight. 

Response: 

None identified. 

22. Describe what impact, if any, the inoperative wing roll spoilers had on the pilots ability to 

maneuver the aircraft during the flight. 

Response: 

We object on the grounds that the spoilers were in maintenance mode - they were not 

inoperative. Inoperative means a system or component malfunction, and maintenance mode is 

different from a malfunction. Without waiving this objection we reply that the actual impact the 

wing roll spoilers had on the pilots ability to maneuver the aircraft during the flight is unknown. 

During flight, the aircraft needed to be trimmed and this may have been caused by the wing roll 

spoilers being in maintenance mode but the specific causal effect is unknown. 

23. Answer whether an amber LAF DEGRADED message on the ECAM is supposed to go 

off if spoiler 5 is inoperable. 

Response: 

We object on the grounds that this is argumentative and (as drafted) not relevant. There are 

many reasons why a LAF degraded message might appear. Without waiving this objection. 

Respondent states that spoiler five was part of the load alleviation fianction system. If spoiler 5 

were inoperable, then yes, this is one of the events that might cause an amber LAF DEGRADED 

message to appear on the ECAM. 
24. Please state whether the document attached as Exhibit 1 is an accurate recording of a 

conversation that Joe Miller, Director of Maintenance and Engineering for Brendan Airways 

LLC, d/b/a USA 3000 Airlines, had with an Aviation Safety Inspector employed with the FAA. 

Response: 

Although it appears to be generally accurate as to the inspector's perception, it is not a verbatim 

record of the conversation. 

25. If you disagree with the following statement found in Exhibit 1, or if you don't believe 

this statement was made by Mr. Miller, explain all reasons for your belief: "Cannot have both #3 

and #5 spoilers INOP." 

Response: 

We object to this question on the grounds that it misleadingly misstates the Joe Miller statement 

by taking the statement out of context. In context, the statement was limited to a response to a 

question about dispatching an aircraft known to have inoperative spoilers, pursuant to the 

USA3000 MEL. 

Taking the interrogatory at face value (in which the statement does not have its limiting context), 

we do disagree, because if a problem is discovered during flight, then the pilots are expected to 

refer to the Quick Reference Handbook (QRH) for instructions. If two sets of spoilers are 

discovered to be inoperative during flight, the QRH states that the pilots should confirm that the 

intended landing site has a runway that is at least 1.25 times longer than the minimum runway 

requirement. The QRH provides no other operating instruction for inoperative spoilers. Thus, 

one could have two sets of inoperative spoilers during flight. 

26. Describe the relationship between AAR Aircraft Services and Brendan Airways, LLC, 

d/b/a USA 3000 Airlines, with regards to the aircraft in the time between April 1, 2008 and May 

17,2008. 

Response: 

AAR Aircraft Services was a maintenance vendor for USA 3000 Airlines. 

27. Answer whether or not you paid AAR Aircraft Services for maintenance performed on 

the aircraft between April 1,2008 and May 17, 2008. 

Response: 

We object to this interrogatory on the grounds that it is ambiguous whether it is seeking 

information about maintenance performed during this period, or payment during this period. 

Without waiving the objection, the answer is yes, we paid AAR Aircraft Services for 

maintenance that was performed on the aircraft between April 1, 2008 and May 17,2008. 
28. Answer whether or not International Leasing Finance Corporation (ILFC) paid AAR 

Aircraft Services for any maintenance performed on the aircraft between April 1,2008 and May 

17,2008 and if payment was made identify what type of maintenance the payment was for. 

Response: 

Respondent objects to this interrogatory on the grounds that it seeks information outside of 

Respondent's knowledge that would pose an undue burden on respondent to obtain. Without 

waiving this objection, and following reasonable inquiry. Respondent does not know the answer 

to this question. 

29. Answer whether or not State Transport Company Russia (STCR) paid AAR Aircraft 

Services for any maintenance performed on the aircraft between April 29, 2008 and May 17, 

2008 and if payment was made identify what type of maintenance the payment was for. 

Response: 

Respondent objects to this interrogatory on the grounds that it seeks information outside of 

Respondent's knowledge that would pose an undue burden on respondent to obtain. Without 

waiving this objection, and following reasonable inquiry. Respondent does not know the answer 

to this question. 

Responses to Request for Admissions 

1. During the flight the aircraft's spoiler servo actuators for left wing roll spoilers three and 

five were in the maintenance mode. 

Response: Admitted 

2. When the aircraft's spoiler servo actuators for left wing roll spoilers three and five are in 

the maintenance mode the aircraft is not in a safe condition for flight. 

Response: We object to this request for admissions in that it seeks an opinion about safety that 

would require detailed engineering analysis using engineering data that is not in the possession 

of USA 3000, and that such an analysis would constitute an undue burden. Following reasonable 

inquiry, this is request is Denied for lack of knowledge. 

3. When the aircraft's spoiler servo actuators for left wing roll spoilers three and five are in 

the maintenance mode the aircraft does not conform to its type certificate and/or type design. 

Response: Denied 
4. When the aircraft's spoiler servo actuators for left wing roll spoilers three and five are in 

the maintenance mode the aircraft's left and right wing roll spoilers three and five are 

inoperative. 

Response: Denied 

5. When the aircraft's spoiler servo actuators for left wing roll spoilers three and five are in 

the maintenance mode the symmetrical spoiler surfaces three and five are inoperative. 

Response: Admitted 

6. Pursuant to the USA 3000 Airlines Minimum Equipment List the aircraft cannot be 

dispatched when two pair of symmetrical spoiler surfaces three and five are inoperative. 

Response: Admitted. 

7. Pages 2-27-10 and 2-27-11 of the USA 3000 Airlines Minimum Equipment List provide 

information as to the conditions under which the aircraft can be dispatched when one or more of 

the spoilers is inoperative. 

Response: Admitted 

8. Pages 2-27-10 and 2-27-11 of the USA 3000 Airlines Minimum Equipment List do not 

identify any conditions under which the aircraft can be dispatched when left wing spoilers three 

and five are inoperative. 

Response: Admitted 

9. Pages 2-27-10 and 2-27-11 of the USA 3000 Airiines Minimum Equipment List do not 

identify any conditions under which the aircraft can be dispatched when two pair of symmetrical 

surfaces 3 and 5 are inoperative. 

Response: Admitted 
10. The aircraft is not in a condition for safe operation when left wing and right wing roll 

spoilers No. 3 and No. 5, are inoperative. 

Response: We object to this request for admissions in that it seeks an opinion about safety that 

would require detailed engineering analysis using engineering data that is not in the possession 

of USA 3000. The requirement to perform such detailed engineering analysis using engineering 

data that is not in the possession of USA 3000 would be overly burdensome. Without waiving 

this objection, and following reasonable inquiry, this is request is Denied for lack of knowledge. 

11. During the flight, but prior to takeoff, the ECAM indicated on more than one occasion 

that the following wing roll spoilers were not operational and/or were locked out: left wing roll 

spoiler No. 3; left wing roll spoiler No. 5; right wing roll spoiler No. 3; and right wing roll 

spoiler No. 5. 

Response: We object to this request for admission on the grounds that this is a compound 

statement. Without waiving this objection, paragraph 11 is admitted in part, to the extent that 

such a warning was visible on the ECAM during each rest of the spoiler elevator computers, but 

denied in part, in that the warning was cleared and reasonably deemed by the flight crew to be 

spurious, so it did not indicate a problem. 

12. At all times during the flight the aircraft was on the operations specifications of Brendan 

Airways, LLC d/b/a USA 3000 Airiines. 

Response: Admitted 

13. Brendan Airways, LLC d/b/a USA 3000 Airlines exercised operational control over the 

flight. 

Response: Admitted 

14. At the time of the flight Brendan Airways, LLC d/b/a USA 3000 Airlines was leasing the 

aircraft from International Leasing Finance Corporation (ILFC). 

Response: Admitted 
15. At the time of the flight Brendan Airways, LLC d/b/a USA 3000 Airlines' lease of the 

aircraft was nearing its end and the flight was undertaken as part of the process of the aircraft 

being transferred into the possession of a new lessee. 

Response: We object to this request for admission on the grounds that this is a compound 

statement. Without waiving the objection, the request is admitted. 

16. The new lessee is the air carrier State Transport Company Russia (STCR). 

Response: We object to this request for admission on the grounds that it is vague. Without 

waiving the objection, if the request is referring to the new lessee of the aircraft, then the request 

is Admitted. 

17. The flight was considered a "maintenance acceptance flight". 

Response: Admitted 

18. Prior to the flight, the livery of the new lessee (STCR) was painted on the aircraft. 

Response: Admitted 

19. Pursuant to the terms of the Brendan Airways, LLC d/b/a USA 3000 Airlines lease with 

ILFC the aircraft was required to be repainted before the aircraft left the possession of Brendan 

Airways, LLC d^/a USA 3000 Airiines. 

Response: Admitted 

20. The spoiler servo actuators for left wing roll spoilers three and five were put in the 

maintenance mode during the process of painting the aircraft with livery of the new lessee 

(STCR). 

Response: Following reasonable inquiry. Respondent is unable to Admit or Deny this statement 

because Respondent has no specific knowledge of when the spoiler servo actuators for left wing 

roll spoilers three and five were put in the maintenance mode. Discovery from third parties into 

the factual basis of this statement is ongoing. 
21. The aircraft was painted with the livery of the new lessee, (STCR), by AAR Aircraft 

Services. 

Response: Following reasonable inquiry. Respondent is unable to Admit or Deny this statement 

because Respondent has no specific knowledge of who painted the livery of the new lessee, 

(STCR) on the aircraft. Discovery from third parties into the factual basis of this statement is 

ongoing. 

22. AAR Aircraft Services is a repair station that is the holder of an FAA Air Agency 

Certificate qualifying it to conduct operations under Part 145 of the Federal Aviation 

Regulations. 

Response: Admitted 

23. Prior to the flight, Brendan Airways, LLC d/b/a USA 3000 Airlines hired AAR Aircraft 

Services to perform maintenance on the aircraft so as to allow it to be returned to a condition that 

would permit it to be returned to ILFC. 

Response: Admitted 

24. Pursuant to the manuals of Brendan Airways, LLC d/b/a USA 3000 Airlines painting the 

aircraft could in some cases require that the spoiler servo actuators for spoilers three and five be 

put in the maintenance mode. 

Response: Denied 

25. If the aircraft's ECAM system is working properly it will report that left and right wing 

roll spoilers three and five are inoperative when the spoiler servo actuators for left wing roll 

spoilers three and five are placed in the maintenance mode. 

Response: Denied 

26. At no time subsequent to the flight did an inspection of the ECAM system reveal that 

there was a problem with the system that could have caused it to malfunction just prior to takeoff 

during the flight. 

Response: Admitted 
27. Within two days after the flight the spoiler servo actuators on left wing roll spoilers three 

and five were again put in maintenance mode to see what messages would appear on the ECAM 

and the ECAM reported that left and right wing roll spoilers three and five were inoperable. 

Response: Admitted 

28. During the flight and prior to takeoff the pilots aboard the aircraft failed to complete a 

successful flight control check. 

Response: Denied 

29. During the flight and prior to takeoff the pilots aboard the aircraft failed to complete a 

successful flight control check because it was impossible for the spoilers to have reacted in 

response to inputs from the cockpit. 

Response: Denied 

RESPECTFULLY SUBMITTED this 22nd day of July, 2010. 

WASHINGTON AVIATION GROUP, PC AND THE 

LAW OFFICES OF JASON A. DICKSTEIN 

Jason Dickstein 

Wa^ington Aviation Group, PC and the 

Law Offices of Jason A. Dickstein 

2233 Wisconsin Avenue, NW, Suite 503 

Washington, DC 20007 

Tel: (202) 628-6776 

Attorney for Respondent Brendan Airways, LLC d/b/a USA3000 Airlines 
BEFORE THE U.S. DEPARTMENT OF TRANSPORTATION 

The Honorable Chief Administrative Law Judge Ronnie A. Yoder 

In the matter of 

BRENDAN AIRWAYS, LLC, 

d^/aUSA3000 Airlines 

Respondent 

DMS No.: FAA-2009-0032 

FAA Docket No.: CP09EA0007 

FAA Case No.: 2008EA170038 

RESPONSE TO COMPLAINANT'S 

FIRST SET OF INTERROGATORIES, 

REQUEST FOR ADMISSIONS, AND 

REQUEST FOR PRODUCTION OF 

DOCUMENTS 

The undersigned hereby certifies that she caused the attached 

• RESPONSE TO COMPLAINANT'S FIRST SET OF 

INTERROGATORIES, REQUEST FOR ADMISSIONS, AND REQUEST 

FOR PRODUCTION OF DOCUMENTS 

To be filed at the addresses listed below by overnight FedEx service, on the date indicated 

below. 

Federal Aviation Administration (fOeiGrlMAb ^M ^ °^ ^ COP^ ) ^ ^ 

600 Independence Avenue, SW 

Wilbur Wright Building - Suite 2W1000 

Washington, DC 20591 

Attn: Hearing Docket Clerk, AGC-430 

And to be served on the persons at the addresses listed below by the same method as the filing 

method, on the date indicated below. 

David M. Cohen, Attorney 

Federal Aviation Administration 

Office of the Regional Counsel, EAL-7 

1 Aviation Plaza 

Jamaica, NY 11434 

Tel: (718) 553-3270 

Fax (718) 995-5699 

The Honorable Ronnie A. Yoder 

Chief Administrative Law Judge 

Office of Hearings, M-20 

Room El2-320 

US Department of Transportation 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

Tel: (202) 366-2142 

Fax: (202) 366-7536 

Katt Stanley Date' 

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AIRLINE S 

June 11, 2008 

Laurence Johnson 

Principal Operations Inspector - USA3000 

Philadelphia FSDO-17 

2 Int'l Plaza, Suite 110 

Philidelphia, PA 19113 

Dear Mr. Johnson, 

RE: LOI File Number 2008EA170038 and VDRP Reference ID: 2649 

On May 30,2008, you sent USA3000 Airlines a Letter of Investigation (LOI) concerning 

the maintenance acceptance test flight of Brendan Airways L.L.C, dba USA3000 

Airlines aircraft N265AV, at MIA, on May 17,2008. On June 4,2008, you sent a letter 

to William Hoffinan, USA3000 Airiines Director of Quality Control, accepting a VDRP 

with the condition the acceptance only related to the maintenance aspects of the test 

flight. 

This reply to the LOI refers only to the operation's aspects of the test flight. 

This commentary is based on the Pilot Safety Reports, the report the Director of 

Maintenance & Engineering gave to the FAA on May 19,2008, conversations with 

Joe MiUer, Director of Maintenance & Engineering and Captain Surratt on June 10 

2008, AIRBUS Industries and USA3000 Airlines manuals, and various data 

downloads. USA3000 Airiines is providing to you all of the information, data, and 

documentation with this letter that it has to date. Any additional information that 

comes to light or is discovered will be forwarded to your office as soon as possible. 

On May 17,2008, USA3000 Airlines conducted a MIA-MIA, Part 91 maintenance 

acceptance test flight in preparation for returning MSN 427 to the lessor. International 

Lease Finance Corp. Ehuiog the flight control check during the taxi checklist, the crew 

noted there was an ECAM caution of LAF DEGRADED. It was cleared by resetting the 

Spoiler Elevator Computer (SEC) pushbuttons. According to both Captain Surratt and 

Joe Miller, this caution is not un-common, and quickly cleared. The aircraft had a clean 

upper ECAM page prior to the uneventful takeoff. While airborne, during routine page 

call-ups, the ECAM panel displayed symmetrical, spoiler 3/5 L/R amber indications. 

During the flight a pilot, from the next leasing airline, left the cockpit and returned noting 

335 Bishop Hollow Road, Suite 100 Newtown Square, PA 19073 

Phone: 610.325.1280 Fax 610.325.1285 
two spoilers on the left wing were floating. An USA3000 Airlines inspection's employee 

took some pictures of those spoilers (photos, attachment 1). During the flight, the pilots 

noted the rudder trim going out of limits. Captain Walker diseng^ed the autopilot and 

manually trimmed the aircraft. On ^proach. Captain Walker stated the aircraft felt 

"sloppy." In the flare, the aircraft dropped abruptly, bounced and rolled left. The crew 

initiated a go-around and flew a second approach at Flaps 3 and VREF+2S. On the 

second landing approach, on touchdown, the aircraft tried to roll left ^ai n but was 

controllable to a landing. 

After landing, it was discovered that a portion of left wingtip fence was ground off. 

Repair cost is about $33,000 (photos, attachment 2). 

The initial review of the aircraft after landing (with AAR Services personnel involved) 

found spoilers 3/5 on the left wing to be in 'Maintenance Mode'. Joe Miller, USA3000 

Airlines Director of Maintenance & Engineering, w4io was aboard the flight, formally 

requested an mvestigation by AAR Services at that time (Joe Miller email, attachment 3). 

On May 19,2008, Mr. Miller provided the MIA FAA a written statement (Joe Miller 

Memo, attachment 4). Mr. Miller directed the digital flight data recorder be removed and 

quarantined. The DFDR was sent to Honeywell for download and analysis. 

On May 18,2008, Tim Lyons, USA3000 Airlines Chief Pilot, spoke to both pilots. On 

May 19,2008, Joe Guhin, USA3000 Airlines Director of Safety and Regulatory 

Compliance, called both pilots and directed safety reports be submitted (Surratt Report, 

attachment 5, Walker Report, attachment 6). 

On May 19,2008, Joe Guhin called the National Transportation Safety Boaixl (NTSB) 

Operations center and spoke to the investigator on duty, John Lovell. Mr. Guhin 

provided the essential information of who, what, when, v^ere and the estimated cost 

Mr. Lovell requested photos of tbti damage, vMch were emailed on May 19,2008 

(attachment 2). On May 20,2008, Mr. Lovell, via email, was asked and concurred that 

the NTSB bad no further interest in the event and authorized release of the flight data 

recorder (email, attachment 7). 

On May 19,2008, The FAA requested USA3000 Airlines set aircraft N265AV in the 

same configuration as it was prior to the test flight on May 17,2008, (spoilers 3/5 on the 

left wing in maintenance mode) and take a picture of the ECAM fault panel. The photo 

was emailed to the FAA on May 20,2(X)8 ^hoto and email, attachment 8). 

On May 22,2008, Joe Guhin asked the pilots again to submit detailed summaries. On 

May 23, Jack Eastman, the USA3000Airlines Director of Operations, was called by an 

attorney for the International Brotfaeiiiood of Teamsters, Local 747, that represents the 

pilots in the employ of USA3000 Airlines. Mr. Eastman was advised that the effort to 

obtain additional information was being considered harasanent by the Union. On June 

10,2008, Joe Guhin, USA3000 Airlines Director of Safety and Regulatory Compliance, 

spoke to Joe Miller, USA3000 Airiines Director of Maintenance and Engineering, v/ho 
provided a detailed synopsis of the flight, and his rational on why the aircraft was safe to 

launch, from his viewpoint in the jtmip seat. On 10 June 2008, Joe Guhin spoke to 

Captain Suiratt, who provided a separate and sunilar description and rational on preflight 

indications and for feeling the aircraft was safe to launch. 

Attachment 9 is the Aircraft Log sheet, (Form M-3) for the flight. 

Attachment 10 is the AIMS printouts for Pilots Surratt and Walker showing they were 

scheduled for the flight. 

Attachment 11 is a photo of ECAM flight control display with normal indications. 

Attachment 12 is a training document page of the ECAM F/CTL display, with an 

explanation of the display 

Attachment 13 is an FCOM page with a legend of the color codes on the displays 

Attachment 14 is a print out of a portion of the Post FUght Report (PFR) of the test flight 

showing the time of the ECAM fault displays. Joe Miller, commented that the F/CTL 

SPLR faults will be momentary when the SEC pushbuttons are reset. 

Attachment 14a are Airbus TSM Manual pages related to the LAF DEGRADED fault. 

Attachment 15 is the FCOM page for F/CTL SEC 1 (2) (3) Fault. 

Attachment 16 is the FCOM page for F/CTL SPLR Fault. 

Attachment 17 is the FCOM page for LAF ACCU Fault. 

Attachment 1S are training document pages for spoilers and the ECAM F/CTL display. 

Page one has the statement that when one spoiler smface fails, the symmetric one on the 

other wing is inhibited. 

Attachment 19 are FCOM pages of warning and cautions for Aircraft N265AV. 

Attachment 20 is an FCOM page on "SPEED BRK" memo display logic. 

Attachment 21 are pages from the USA3000 Airlines Minimum Equipment List (MEL), 

Chg 22, concerning spoiler surface malfunctions. (Change 22 is provided. Change 23 is 

the current edition and does not include guidance on N265AV). 

Attachment 22 is the A320 Expanded TAXI CheckUst from the FCOM. Page 2 describes 

the flight control check. 
Attachment 23 is subject flight DFDR tabular data for command stick and flight control 

positions during the flight control test (1718:18 to 1719:38 UTC). The DFDR data did 

not have readouts of the ECAM panel display indications. 

Attachment 24 is a flightaware.com, minute-by-minute, recap of position, speed and 

altitude of the maintenance test flight. 

On May 30,2008, Larry Johnson informed Joe Guhin that Pilot Walker was in the left 

seat and why was PIC Surratt not in the left seat and flying? Afler conferring with Chief 

Pilot Tim Lyons, Joe replied via email that Pilot Walker was Captain qualified (email, 

attachment 25). 

Attachment 26 is a copy of the FAA approved USA3000 Airlines NORMAL 

CHECKLIST 

If you have any questions on this package, please contact me at (610) 325-1289 or at 

jguhin@usa3000.com 

Joseph M. Ouhin 

Director of Safety & Regulatory Compliance 

USA3000 Airlines 

(610) 325-1289 

iguhin(a).USA3000.com 

Attachments: 

1. Photos of left wii\g spoilers floating 

2. Photos of damaged wing fence 

3. Email fix)m Joe Miller to AAR Services 

4. Joe Miller incident Memo to MIA FAA 

5. Safety Report, Pilot Surratt 

6. Safety Report, Pilot Walker 

7. Email from NTSB releasing DFDR 

8. Email & Photo of N265AV ECAM panel with spoiler faults 

9. Log page, N265AV, May 17,2008 

10. AIMS schedule page for Pilots Surratt and Walker 

11. Photo of ECAM flight control page with normal indications 

12. ECAM F/CTL display legend 

13. ECAM color code legend 

14. N265AVPFR,Mayl7,2008 

14a Airbus TSM Manual pages related to the LAF DEGRADED fault 
15. FCOM page for F/CTL SEC 1 (2) (3) Fault 

16. FCOM page for F/CTL SPLR Fault 

17. FCOM page for LAF ACCU Fault 

18. Training doctmient pages for spoilers and the ECAM F/CTL display 

19. FCOM pages of warning and cautions for Aircraft N265AV 

20. FCOM page on "SPEED BRK" memo display logic 

21. USA3000Airlines MEL, Chg 22, spoiler surface malfunctions 

22. A320 TAXI Checklist, fiwm the FCOM 

23. DFDR tabular data for the flight control check 

24. flightaware.com, flight recap 

25. Email on Pilot Walker being in left seat 

26. US A3 000 Airlines Normal Checklist - page 7.01 
Joseph To laurence.johnson@faa.gov 

GuhinAJSA3000/KCDATA . ^ ^ ^. „.^».,„^„^^».r»>=x..^rv.,. , 

cc Joseph Guhin/USA3000/KCDATA@KCDATA, Tim 

06/03/2008 12:31 PM Lyon8/USA3000/KCDATA@KCDATA. Jack 

EastmanAJSA3000/KCOATA@KCDATA 

bcc 

Subject MIA 17 May, Pilots in Seats 

Good Afternoon Larry. 

You told me last week about Pilot Walker being in the left seat and Pilot Surratt in the right seat You 

asked if that was normal for a test flight. 

I discussed the issue with Tim Lyons. He informed me that Pilot Walker is Captain qualified and only on 

FO status due to the manpower requirements of the company. USA3000 is intentionally maintaining his 

left seat currency to allow a instant transition to Captain status when manpower needs require. 

Joe Guhin 

Director of Safety & Regulatory Compliance 

USA 3000 Airlines 

335 Bishop Hollow Road 

Newtown Square, PA 19073 

Phone: 610.325.1289 

Cell: 610.850.4347 

Fax: 610.356.7936 

Jguhin@usa3000airlines.com 

// / 
USA 3000 

I N 

June 13,2008 

Joseph Guhin 

Director of Regulatory Compliance 

USA 3000 Airlines 

Joe, 

SUBJECT: LOI FILE NUMBER 2008EA170038 AN D VDRP ID: 2649 

Further to our conversation of this date and in an attempt to provide additional insight into the events 

surrounding the Maintenance Acceptance Flight of N265AV of 17 May 2008, please find below a reiteration of 

my memory of the event. 

Preflight checks were completed without incident. Auto engine starts were completed without incident. Post 

start checks were completed without incident. Taxi checks were completed without incident. During 

performance of the flight control check, the Lower ECAM Flight Control system page appeared and LAF 

DEGRADED advisory was displayed. I recall no Upper ECAM warnings. 

After a brief discussion on the length of time the aircraft had been out of service and the normal 'gremlins' of 

not being powered for most of the past 45 days we proceeded to reset the SEC computers (during which time 

there were momentary transitory faults, which are indicated by the Post Flight Report (PFR)). After reset the 

LAF DEGRj-\DED advisory message disappeared and then after a few seconds reappeared. The SEC's were 

reset again (which again triggered momentary transitory faults on the PFR) and the advisory disappeared and 

did not return. These resets show as time stamps 1718-1720 Flight Phase (PH) 02. 

During the climb to FL310 a series of tests were to be performed in accordance with the Airbus Single Aisle 

In-Service Aircraft Flight Test profile. During these tests there is a section on flight control authority checks. 

During this process we noted the L.A.F DEGRADED advisory message and spoiler's 3 and 5 left and right 

showing amber on the FLT CTRL system page and the SEC reset was performed again (time stamp 1732 PH 

06). The LAF DEGRADED advisory and spoiler 3/5, L/R amber remained. 

The flight continued with various related (F/CTL SPLR FAULT at 1951/1952 when testing hydraulic pumps 

affectivity and Power Transfer Unit operation) and unrelated faults being triggered due to testing and/or actual 

faults. During the low speed 'un-clean' (flaps not fuUy retracted) tests the crew noted the slip indicator on the 

Primary Flight Display and an unusual rudder trim. The auto-pilot (AP) was selected OFF, rudder trim reset, 

and the AP was selected back ON. After some time had passed the crew again noted the rudder trim, selected 

AP OFF and hand flew the remainder of the flight up to the approach. 

The Quick Reference Handbook was referenced for the limitations of spoilers 3 and 5 (L/R) inoperative 

(which were actually found in a dual hydraulic failure section) and we computed the landing distance penalty for 

this condition. 

TTie final steps in the flight test required a CAT 111 Dual approach, which we were setting up for on the MIA 

8R when the tower requested we change to ML\ 8L, which did not have an ILS. We accepted the runway 

change, already knowing the landing distance penalty, and proceeded to land on \0 A 8L. 

/4^ck^e^-f i . f>'ife //». 

335 Bishop Hollow Road, Suite 100 Newtown Square, PA 19073 

Phone: 610.325.1280 Fax 610.325.1285 
2 - June 16, 2008 

After the attempt to land on MIA 8L was unsuccessfiil, the crew called for GEAR UP and FLAPS 3. There 

was a brief discussion at Mdiich point we determined the aircraft was flying well with FLAPS 3, we would 

proceed on the second approach in that configurarion and out second attempt, which was to 'MIA 8R, was 

successfiil. 

Upon deplaning we noted the damage to the left wing tip. 

Regards, 

inoA 

J^MiUer 

Director of Maintenance & Engineering 

USA 3000 Airlines 

A. Kinnear 

J. Eastman 

W Hoffman 

T. Lyons 

^EUS A 300 0 

I N 
UNi TED STATl-S 01- A.VI1;KICA 

NATION.AL TR.\NSPORTATION SAIIH Y HOARI.) 

Ul-Tli I OF ADMINiSTK.MIVI". 1 AW .11 'DGFS 

RANDY BABBITT, Adminisirator, FAA ) DoAcL Nu. SB-18562 and SE-18563 

) .fiidi'.e h'owlvr 

V. ) 

FRANK \VILI,IA.\1 WAI,KER 

and 

TONY SCOTSURRATr 

) 

) 

) 

) 

Respondents) 

) 

DAVID BEAL'S 

FIRST DECLAIMTION 

(i 1, DAVID BLAL, under penalty of"perjury, tleel.ire as loilows: 

8 1. 1 am a Line Ivnginecr with Brendan Airways, which does business under 

^> the trade name USA ."^OOO. 

10 2. On May 17, 2008, I V\MS present on the maintenance acceptance flight of 

11 the aircraft bearing US registry N265AV (tiic Aircrait), out of .VIIA. 

I 2 .3. Several days after that fligiit, i was asked to lake pictures of the EC.^M of 

I '^ tliat aircraft ba.sed upon certain insli uciions. 

1 ^ 4. 1 took a picture of tlic ECAM will all spoilers operational. 

I ^ 5. 1 then set spoilers 3 and 5 in maintenance mode, and took a picture of the 

16 ECAM under those conditions. 

17 6. I followed appropriate maintenance instruciions and protocols when I .set 

IS the .spoilers in maintenance mode. 

1'' 7. I was not in.structcd to recreate all of the conditions of the May 17 (light. 

20 8. When 1 took the pictures, 1 did not recreate all of the conditions of the 

21 May 17 night. 

DAVID BE.^L'S FIRS'I DLCLARA I ION Wasliinglon Aviation Group, PC and tlic 

Law Oftlees of Jason .A. Dickstein 

2?..'53 Wisconsin Avenue. NW, Suite 503 

\Vajii)i;.i.ji,. o r 7,nno7 -T I: -xnc^z-^^u 
22 9. i"l)e pictures that 1 took were not intended to, and do not, relied the 

2.5 conditions of the aircraft on May 1 7. 

?A 10. I declare under penalty of perjury under the (aws of the United States that 

2.S the foregoing is true and correct. 

26 

27 EXECU TED on the day of .Uily. 2009. 

2:{ 

?.') 

DAVID BEAL 

DAVID IJLAL'S FIRST DLCLARATION Washington Aviation Group, PC and the 

La\v Offices of Jason ;\. Dickstein 

2233 Wisconsin Avenue, XW, Suite .503 

Wai.liiiiiilon, DC ^0007 • TJ: .'02-i',2^^W 
USA 3000 AIRLINES 

CHAPTER 2: MINIMUM EQUIPMENT LIST 

SECTION 27 FLIGHT CONTROLS 

MINIMUM EQUIPMENT LIST 

Revision: 12 

May 1,2005 

SYSTEM & 

SEQUENCE 

NUMBERS 

27 FLIGHT CONTROLS 

64-01 SPOILER 

SURFACES 

1 (N265AV Only) 

LITEM 

C 

C 

C 

2. NUMBER INSTALLED 

10 

10 

10 

3. NUMBER REQUIRED FOR DISPATCH 

8 

8 

8 

4. REMARKS OR EXCEPTIONS 

(M) (0) One pair of symmetrical surfaces 

1or 3 may be inoperative in the retracted 

position provided 

a) SECs associated with operative 

spoilers operate normally, and 

b) AFM perfomiance penalties are 

applied. 

(M) (0) One pair of symmetrical surfaces 5 

may be inoperative in the retracted position 

provided SECs associated with operative 

spoilers normally 

(M) (0) One pair of symmetrical surfaces 2 

or 4 may be inoperative in the retracted 

position provided: 

a) SECs associated position with 

operative spoilers operate 

normally, and 

b) SFCS 2 flap channel operates 

normally, and 

c) AFM performance penalties are 

applied. 

(Continued) 

2-27-10 
USA 3000 AIRLINES 

CHAPTER 2: MINIMUM EQUIPMENT LIST 

SECTION 27 FLIGHT CONTROLS 

MINIMUM EQUIPMENT LIST 

Revision: 12 

May 1,2005 

SYSTEM & 

SEQUENCE 

NUMBERS 

27 FUGHT CONTROLS 

64-01 SPOILE R 

SURFACES 

(CONTD) 

(N265AV Only) 

LITEM 2. NUMBER INSTALLED 

10 

10 

3. NUMBER REQUIRED FOR DISPATCH 

4. REMARKS OR EXCEPTIONS 

(M) (O) Two pair of symmetrical surfaces 1 

and 2 may be inoperative In the retracted 

position provided: 

a) SECs associated with operative 

spoilers operate nonmally, and 

b) SFCS 2 flap channel operates 

normally, and 

c) AFM performance penalties are 

applied. 

(M) (O) Two pair of symmetrical surfaces 3 

and 4 may be inoperative in the retracted 

position provided: 

a) SECs asscjciated with operative 

spoilers operate normally, and 

b) TR 1 and TR 2 operate nonnally, 

c) DC Tie Contractor 1 is verified 

ck}sed before each departure, 

d) SFCS 2 flap channel operates 

normally, and 

e) AFM performance penalties are 

applied. 

NOTE: If spoiler 4 or 5 is inoperative, LAF 

is in degraded mode. Refer to 27-

64-02, 

(Continued) 

2-27-11 
USA 3000 AIRLINES 

CHAPTER 2: MINIMUM EQUIPMENT LIST 

SECTION 27 FLIGHT CONTROLS 

MINIMUM EQUIPMENT LIST 

Revision: 19 

April 18. 2007 

SYSTEM & 

SEQUENCE 

NUMBERS 

27 FLIGHT CONTROLS 

64-01 SPOILER 

SURFACES 

(CONTD) 

(N260AV-N264AV, 

N266AV-N271AV 

Only) 

1. ITEM 

C 

C 

C 

2. NUMBER INSTALLED 1 

10 

10 

10 

3. NUMBER REQUIRED FOR DISPATCH 

8 

8 

8 

4. REMARKS OR EXCEPTIONS 

(M) (O) One pair of symmetrical surfaces 1 

or 3 may be inoperative in the retracted 

position provided: 

a) SECs associated with operative 

spoilers operate normally, and 

b) AFM performance penalties are 

applied. 

(M) (0) One pair of symmetrical surfaces 5 

may be inoperative in the retracted position 

provided SECs associated with operative 

spoilers operate normally. 

(M) (O) One pair of symmetrical surfaces 2 

or 4 may be inoperative in the retracted 

position provided: 

a) SECs associated with operative 

spoilers operate nomially, and 

b) SFCS 2 flap channel operates 

nomnally, and 

c) AFM performance penalties are 

applied. 

(Continued) 

2-27-1 2 
USA 3000 AIRLINES 

CHAPTER 2: MINIMUM EQUIPMENT LIST 

SECTION 27 FLIGHT CONTROLS 

MINIMUM EQUIPMENT LIST 

Revision: 19 

April 18,2007 

SYSTEM & 

SEQUENCE 

NUMBERS 

27 FLIGHT CONTROLS 

64-01 SPOILER 

SURFACES 

(CONTD) 

(N260AV-N264AV 

N266AV-N271AV 

Only) 

64-02 LOAD ALLEVIATION 

FUNCTION (LAF) 

(N265AV) 

LITEM 

C 

C 

D 

2. NUMBER INSTALLED 1 

10 

10 

1 

3. NUMBER REQUIRED FOR DISPATCH 

6 

6 

0 

4. REMARKS OR EXCEPTIONS 1 

(M) (0) Two pair of symmetrical surfaces 1 

and 2 may be inoperative in the retracted 

position provided: 

a) SECs associated with operative 

spoilers operate nonnally, and 

b) SFCS 2 flap channel operates 

nomnally, and 

c) AFM perfonnance penalties are 

applied. 

(M) (0) Two pair of symmetrical surfaces 3 

and 4 may be inoperative in the retracted 

position provided: 

a) SECs associated with operative 

spoilers operate nomnally, and 

b) TR 1 and TR 2 operate nonnally, 

c) DC Tie Contractor 1 is verified 

closed before each departure. 

d) SFCS 2 flap channel operates 

normally, and 

e) AFM performance penalties are 

applied. 

2-27-13 
InFO 

Information for Operators 

U.S. Department InFO 08032 

of Transportation DATE: 5/16/08 

Federal Aviation 

Administration Flight Standards Service 

Washington, DC 

http://www.faa.gov/other visit/aviation industry/airline operators/airline safety/info 

An InFO contains valuable information for operators that should help them meet certain administrative, regulatory, 

or operational requirements with relatively low urgency or impact on safety. 

Subject: Non-Routine Flight Operations (NRFO) 

Purpose: This InFO provides information and guidance for conducting Non-Routine Flight 

Operations (NRFO) for purposes other than the transport of people or materials, and/or after 

performing maintenance, preventive maintenance, rebuilding, or alteration on an airplane. 

NOTE: This InFO does not address authorization for ferry flights with one engine 

inoperative, as set forth in Title 14 of the Code of Federal Regulations (14 CFR) part 91, 

§ 91.611, nor does it address test or experimental flights. 

Background: This InFO has been developed in response to National Transportation Safety 

Board (NTSB) safety recommendations A-97-49, A-97-50, A-97-51 and A-97-52. In addition, it 

supersedes Flight Standards Information Bulletin for Air Transportation (FSAT) 04-02A. 

On December 22, 1996, a Douglas DC-8-63 airplane impacted terrain, killing three flight 

crewmembers and three maintenance/avionics technicians on board. After conducting its 

investigation into this accident, the NTSB identified the flight as a Postmodification Functional 

Evaluation Flight (PFEF). 

Discussion: For further discussion of this accident and further guidance, see: 

http://www.faa.gov/other visit/aviation industry/airlineoperators/airlinesafety/info/allinfos/ 

media/2008/InFO08032Sup.pdf 

Recommended action: Directors of safety and directors of operations (part 121); directors of 

operations (part 135); training managers; and pilots of transport aircraft should be familiar with 

the content of this InFO. They should work together to ensure that the highest level of safety is 

maintained while conducting Non-Routine Flight Operations (NRFOs). 

Approved by: AFS-200 OPR: AFS-220 
Supplement to InFO 08032 

Discussion of Non-Routine Flight Operations (NRFO) 

a. Reasons for NRFOs. 

1. The affected flight was conducted for the purpose of achieving compliance with 14 

CFR part 43, § 43.5, Approval for return to service after maintenance, preventive maintenance, 

rebuilding, or alteration. 

2. For the purposes of this InFO, NRFOs are those flight operations conducted for 

purposes other than the ordinary transport of people or material. For air carriers, this means all 

flights not involving common carriage. 

(a) Examples of NRFOs. 

(1) In-flight functional evaluation of the aircraft and/or its systems, 

(2) Engine inoperative ferry flights. (NOTE: the guidance in this InFO is not 

applicable to Engine inoperative ferry flights.) 

(3) In-flight operational checks of maintenance performed or alteration(s) made, 

(4) Flights conducted for the purpose of crewmember training or qualification, 

(5) All operations conducted under a Special Flight Permit, 

(6) Maintenance troubleshooting flights, and/or 

(7) Sales or customer demonstration flights. 

(b) For air carriers, the list includes all flight operations not conducted as part of the 

air carrier's scheduled or nonscheduled passenger and/or cargo carrying operations. 

b. Clarification of Existing Regulations. There are numerous sections applicable to NRFOs. 

These include: 

1. Section 91.3(a) states that "the pilot in command of an aircraft is directly responsible 

for, and is the final authority as to, the operation of that aircraft." This makes it critical that the 

pilot is the final authority on whether a flight starts, continues, or ends, and is responsible to end 

any such flight at the time the pilot finds safety is compromised. Therefore, the termination of 

an NRFO would be appropriate, even before departure, if the pilot finds that the aircraft is not 

airworthy. 

2. Section 91.7. 
(a) This section sets forth requirements concerning the airworthiness condition of all 

civil aircraft. Section 91.7(a) states that "no person may operate a civil aircraft unless it is in an 

airworthy condition." Section 91.7(b) states that "the pilot in command of a civil aircraft is 

responsible for determining whether that aircraft is in condition for safe flight. The pilot in 

command shall discontinue the flight when unairworthy mechanical, electrical, or structural 

conditions occur." 

(b) A clarification of the term airworthy is necessary because there is no definition of 

airworthy in 14 CFR. The accepted definition for "airworthy" comes from FAA Order 8900.1, 

Flight Standards Information Management System (FSIMS), Volume 7, Chapter 7, Section 1, 

Paragraph 7-223 and from legal interpretation No. 1988-16, dated June 17, 1988, issued by the 

Assistant Chief Counsel, Regulations and Enforcement Division, Office of the Chief Counsel. 

3. Section 91.103 states, in part, that "each pilot in command shall, before beginning a 

flight, become familiar with all available information concerning that flight." Therefore, the PIC 

must be aware of all that was done to the aircraft that might affect its operation. 

4. Section 91.213 sets forth the requirements for operating an aircraft with certain 

instruments and equipment in an inoperable condition. 

Guidance: This guidance material for conducting an NRFO is advisory rather than regulatory. 

The PIC must make the final decision as to the safety of the flight after considering all relevant 

regulations, procedures, and guidance. 

a. Air Carrier NRFOs. The air carrier manual should contain: 

1. Detailed policy and procedures for the authorization, control, and conduct of all nonroutine flight operations, 

2. Addresses of those locations and areas which can be used to conduct the NRFO, and 

3. Detailed information describing the level, amount, and type of required training for 

those flight crewmembers authorized to conduct these types of flights. 

b. Airworthiness. The PIC must be certain that the airplane is airworthy before operating it. 

Regulations prohibit a pilot from operating an airplane that is not airworthy. The PIC must be 

certain that: 

1. An authorized person approved the aircraft for return to service, in accordance with 

the FAA-approved company maintenance manual. 

2. All inspection, maintenance, and alteration tasks were completed before being 

approved for return to service. 

c. Determine the Required Crew Qualifications. 
1. This document divides NRFOs into two groups. 

(a) Group 1 includes those NRFOs in which the flightcrew should consist of a fully 

qualified and current PIC, first officer, and, if appropriate, flight engineer. 

(b) Group 2 includes those NRFOs in which the PIC, and, if applicable, flight 

engineer, are qualified instructors, check airmen, or flight crewmembers that have been trained 

and authorized by the air carrier specifically for conducting NRFOs. 

2. Operations. 

(a) Operations appropriate to Group 1 NRFOs involve the operation of the aircraft in 

accordance with the normal procedures of the flight manual. These include, but are not limited 

to: 

• Normal operation of airplane systems such as the normal retraction and 

extension of the aircraft's landing gear 

• A flight to confirm the proper functioning of the aircraft's communication and 

or navigation radios 

• A flight to confirm the proper functioning of the aircraft's autopilot 

(b) Operations appropriate to Group 2 NRFOs involve procedures described or 

listed, in emergency, abnormal, or alternate procedures. These flights include any flight in which 

any system on the aircraft is de-powered in order to confirm a back-up system is functional, such 

as: 

• Any flight that involves de-powering of any of the aircraft's electric, 

hydraulic, or pneumatic systems 

• Alternate extension of the aircraft's landing gear 

• Alternate extension of the aircraft's flaps 

• A flight that involves approach or actual entry into a stall 

• Actual shut down of an engine 

• De-powering of any flight control power input 

• Operation of the plane's wing flaps following certain procedures 

3. Training. 
(a) The FAA requires that every PIC conducting operations under part 121 is trained 

and qualified to operate the airplane in all normal procedures, and to recover and land the aircraft 

from problems that might occur. 

(b) Even though instructors check airmen, and specifically trained flight 

crewmembers are qualified to simulate emergencies and expect the unexpected, there is a need 

for some additional training for these pilots. Each certificate holder should develop, and have 

accepted by the Administrator, training such that each NRFO will be conducted in accordance 

with procedures consistent with safe flight operations. 

d. Preparation/Pre-Flight. Proper and complete preparation before starting an NRFO might 

well be more extensive than the actual flight. 

1. The PIC should coordinate with maintenance as to why the flight is needed. 

(a) What was inoperative? 

(b) What was repaired? 

(c) What was replaced? 

2. The PIC should determine what precautions to take and plan ahead what course of 

action to take if the airplane does not function in the intended manner. 

3. The crew should thoroughly review all appropriate schematics, systems, and 

limitations consistent with the intended NRFO. 

4. The PIC should pre-plan to immediately land the plane if its condition deteriorates to a 

condition that is no longer airworthy. The NRFO is not a test flight and the crew are not 

qualified test pilots. 

5. The PIC should determine where to conduct the flight. 

6. The PIC should make prior coordination with Air Traffic Control. 

7. The PIC should determine that weather conditions are adequate to safely conduct the 

NRFO. 

e. During the Flight. Following this methodology allows the crew to plan ahead for 

unexpected occurrences during the NRFO. Should the flight encounter such difficulties, the 

previously agreed-upon procedures should be sufficient to permit a safe landing. 
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Miy. 19. 2008 9:i5AM No. 0503 ?, 5 

rfr<--' " ' "• ' ' •^' mtrr 
ly^ / i S300 N W 36th Street 

FAA Repair Station # XE4R646M 

Tel: 305-871-2104 Accounting Fax; 786-265-4360 

Purchasing Fax: 786-265-4362 

www.ahm.aero 

PURCHASE ORDER iillilillllllllllilllillilllilUI 

PiinlDato ;M.r.Jt-200e 12:01:22 PM 

For : Account No. [5438] 

AKZO NOBEL AEROSPACE 

PO BOX 73488 

CHICAGO, IL6067S-7488 

Tel,: 347-623-4200 

Fax:847-625-3222 

Remit To : 

AKZO NOBEL AEROSPACE 

PO BOX 73488 

CHICAGO, IL 60673-7488 

Tel.: 847-6234200 

Fax-.847-625-3222 

OttJar Date : Mar-24-2008 

Ship Date : See below 

Noj;Q56225;\';P\';;\:::" 

PlinlodBy : 2378 Print No, : 5 

::::•''•" ..y^^- i 

Bill To : 1 

Avborne 1 

5300 NW 36th Street 

PO Box 52-2602 

Miami,, FL 33152 

Tel.: Tet: 305-871-2104 

Fax: Purchasing Fax: 786-2654362 

Ship To : 

Avborne Heavy Maintenance 

5300 NW 36th Street 

Miami, FL 33122 

USA 

Tel,: 305-871-2104 

Fax: Purchasing 786-2654362 

P.O.B. : ORIGIN 

Prolecl* :IU=C 

Tail# :N2e5VA 

Our Contact : lleana M Janssen 

Line 

1 

2 

3 

4 

5 

6 

7 

8 • 

P/N & Description 

10P20-44M-RK4G 

PRIMER 

ECL-G.1649 

SIGNAL WHITE 

ECL-0-26229 

SIGNAL BLUE 

ECL.G.3637 

TRAFFIC RED 

ECL-G-11161 

PAPYRUS WHITE 

ECL-G.92 , 

TRAFFIC BL^CK 

ECL.G-6688 

SIGNAL ORANGE 

HAZMAT PACKAGING 

HAZMAT PACKAGING CHARGES 

end 

NE 

NE 

NE 

NE 

NE 

NE 

NE 

NE 

, Qty Order 

4.00 KT 

2.00 KT 

2.00 KT 

2.00 KT 

5.00 KT 

2.00 KT 

1.00 KT 

17.00 EA 

§/)/p Date . 

Mar-24-2008 

IVIar-24-2008 

Mar-24-2a08 

Mar-24-2008 

Mar.24-2008 

Mar-24-2008 

Mar-24'2008 

:Mar-24-2008 

CopyrUhK c) FEHTAQON » M S»ftw«n,lnc PO Rw.1 Dale;06 m i m 

Unit Price. 

$ 448.1000 EA 

$ 669.5000 EA 

$ 787.3500 EA 

$ 987.7500 EA 

$411.8500 EA 

$261.2000 EA 

$ 327.0500 EA 

S 22.5000 EA 

Amount 

$1,792,40 

$1,339.00 

11,534.70 

$1,975.50 

$2,059.25 

$ 522.40 

$327.05 

$382.50 

Continued on next page... 

noiaiuAi /rrw i 
AVB0RNE 

'^^tf'"^ HEAVY MAINTENANCE 

FAA Repair Station # XE4R64SI\^ 

5300 NW 36th Street 

PO Box 52-2602 

Miami, FL33152 

Tel: 305-871-2104 Accounting Fax: 786-265-4360 

Purchasing Fax: 786-265-4362 

www.ahm.aero 

PURCHASE ORDER 

Project* :ILFC P.O. No, 056225/Page: 2 

Tall# :N265VA 

Une P/N& Description Chd .".;:.•'-.Qty. Orfler 

1. "While this Purchase Order/Contract is in effect, yoar 

Aviation Administration to have access to its facifit' 

performance of work under this Purchase Order/C 5ntrac|, 

during these inspections. Nothing in this paragrap h 

it Is directly related to the specific work being perfc^rmed 

2. "Nothwithstanding the provisions of paragraph 1 yourtonfipanys 

Maintenance, Inc. to have access to Its facility duifng noj-mal 

performance of work under this Purchase 

the premises of your company upon reasonable 

company agrees to allow 

normal business hours 

A representative of 

authorize the FAA to 

inder this Purchase 

durin; 

notice 

yoir 

make 

Ship Date Uriit Price- Arrtpunt 

dulylauthorized aviati jn safety inspector(s) of th' i 

fpr ttie purpose c f inspecting and observing 

company may accompany the FAA 

any inspection or observation of your 

Onder/Contract" 

duly authorized 

purpose of ins||iecting 

agrees to allow s 

business hours for th 

Order/OontraiL In additbn, Avborne Heavy Maintenanct: 

or the purpose of auditind the quality contipl 

•epresenative of Avborne 

and observing the 

, Inc, shall have access to 

system of your compan', 

Sub Total: $mm 

DtMUSam. OfR OFTECH SEMCES 

Tt)tal: [USDl 39,932.80 

CepyrltM(t) PENTAGON 2000 Solhmra.lne. PO Rew.i Dat9:0»2»20Q5 ORIGINAL (COPY.) 
AVBG^RNE g?? 

n u n nuunmiAiict 

FAA Repair Station # >E<RWS M 

NWSetttStrae t 

P O eox 52-2802 

Miami, FL331S2 

Tel: 30S-671-2104 Accounting Fax: 796-265-4360 

Purchasing Fax: 786-265^*362 

www a/i/n aero 

PURCHASE ORDER Hiifiaiiiiiiimiiiiiimiiiiiii 

PAtOtt :MV4VMI lOMtAM 

For'-.'AccoURt No. (84381 

AKZO NOBR AEROSPACE 

PO BOX 73488 

CHICAGO.! 60673-7488 

Tel.: 647-6234200 

Fax: 847-625^222 

Rmnltro : 

AKZO NOe a AEROSPACE 

PO BOX 73488 

CHfCAGO, 160673-7468 

Tel.: e47-«234200 

Fax, 847-625-3222 

ORNrM i :Mar-31-2O08 

$MpD«* tSwbalow 

ismpis6S9\^' 

PrhMfil : tSWPitNMa. : i 

i'^-"^ . ''y ,,.. ;^:' ' 

Bliifo : 

Avborne 

5300 MWSeih Street 

PO Bo* 52-2602 

Marni„FL 33152 

Trt.: Tet 306^71-2104 

Fax: Purchasng Fax: 786-26&4362 

Ship To : 

Avborne Heevy Msintenanee 

.5300NW36lhStrae( 

Waml.FL 33122 

USA 

Tel : 305-871-2104 

Fax:Purchasing 786-2654362 

F.OB. ; CRtOlN 

W 0 # :26108 

T8l# :N285VA 

OwCeatMt tVantMJansMn 

•iJf»ijifJi 

10P2044lli^lK46 

PRtkER 

ECU»-11161 

PAPYRUS WHITE 

HAZUATPACKAGMG 

HAZMAT PACKA6IN6 CHARGES 

1. IMNte Ihb PuKluM OnMConfeBd is In elite , yoilr conibiny 

AvtaBon AdnJuMntua to haw access to la tsdR; durir ] 

CrxH 

NE 

NE 

NE 

cxjc^Siii^: 

SXOEA 

lOME A 

15X0 EA 

agnas to allow duly KJtraiijsd 

nomtat busmen hours f v the purpoee 

Sli^^g0^ 

ttar31-2008 

llBr-31-2008 

llar-31.2008 

cumiQNw perMON M M SDteMkc PQ ta«,t oMeceanoos 

$448.1000 EA 

$411,8500 EA 

$22.5000 EA 

«MI»safet y lnspedQr(s) of Ih I 

(f hspoding end obsentng 

j^OfiOiJrit 

$2,240.50 

$4,118^0 

$337.80 

ContbHMd on next papL . 

OnOMM.)COt>V.) 
AVB0RNE 

W ^ HEAVY IMWTOUNeE 

FAA Repair StatlOfi itXe4Fl64SM 

5300 t<tW 3eth Street 

PO Box 52-2602 

Miami, FL 33152 

Tet: 305-S71-21O4 Accounting Feoc 766-265-4360 

Purchasb^ Fax: 786-265-4362 

wwv/.ahm.aam 

PURCHASE ORDER iillilllllllHIillililllllllillillU 

vwo* 

Tailt 

: 28108 

:N289VA 

P.O,No,056»1/Page: 

0m .Q(y Ordof s%p;#ir» AttKWiA. 

parioimanceofWMkunderlhlsPurchaseOnta/Cwtrac. Areftttsantsthmofyoircompaiymay 

durhg these Inspsdom, Nothing in ttils paragrap :i8hal euttuftzatheFAAtomtiBanyinspectior 

it Is dkiectly related to 8w spedtc wori< being periqnwd {Jndar this Pun:tiase On^ ^ 

xxompanytheFAA 

orobserffltionof your 

"rMtYvMttiandlng the provisions of paraQratihl, jyour 

MaMenance. Inc. to have access to its faci ^ d u ng 

perfomienee of wwk under this Purchase OideryC onMtthepi«(nise6o( your compaiy upon reasonable liotlce 

c onpany agrees to allow 

nofmal business hours tor th^ 

In addition, Mboma 

or the purpose of audHtns 

a duly { atdhoitzed 

punwGeofin^iecllns 

htejavyMaintenano, 

liequ^contilj l 

Bttresensih'e of Avborne 

and obsarvins the 

Inc. shai have access lo 

system of yourc«npan+. 

^JSTToEr '^SM^ 

iPuncHUMaMR 

Total: [USm" $6,686.50 

OvftiftM KMrAQoN »m PO no. I (MKOioaim oisaHN.t(»n.t 
AIRBUS 

Customer: ENV 

Type : A318/A319/A320/A321 

Rev. Date : February 1, 2010 

Manual: SRM_A320 

Selected effectivity: ALL 

51-75-12 - REPAIR OF PAINT COATINGS (Revdate = Jun 01/09) 

CAUIIQN: 

51-75-12 REPAIR OF PAINT COATINGS 

DO NOT USE METAL TOOLS TO REMOVE THE UNWANTED MATERIAL. METAL TOOLS CAN CAUSE 

DAMAGE TO THE SURFACE OF THE COMPONENT. 

CAUTION: AVOID TO CUT PROTECTIVE FILMS, TAPES, MASKS OR MARKINGS ON THE AIRCRAFT SKIN TO 

PREVENT SCRIBE MARKS. IF THIS OPERATION IS REQUIRED USE SCISSORS OR A PLATE BETWEEN 

THE FILM (0.6 MM (0.024 IN.) THICKNESS MINIMUM WITH METAL AND 2 MM (0.079 IN.) THICKNESS WITH 

HARD PLASTIC) AND THE AIRCRAFT SKIN OR USE A SPECIAL CUTTER (REFERENCE MARTORPOLYPICK NO. 469 FROM 3M), THEN INSPECT. 

1. General 

NOTE: It is recommended to use all materials from one supplier for compatibility reasons. 

A. The following paint repairs are described in Paragraph 3^ thru 1 ^ : 

- Repair of damaged top coat for metal, composite and glare parts 

- Renewal of paint build-up after damage to metal and glare parts 

- Renewal of paint build-up of composite components that require no anti-erosion paint 

- Renewal of paint build-up of composite components that require anti-erosion paint 

- Repair of peeled-off paint coatings on fastener heads 

- Application of anti-erosion tape on vertical and horizontal stabilizer leading edge 

- Renewal of damaged fuel tank top coating on center tank and horizontal stabilizer tank 

- Renewal of external paint build-up with AMS 3095 external paint scheme 

Except for radome, antennas and areas covered with anti erosion coating. The maximum recommended paint 

thickness is 350 microns and 400 microns for nacelles, for antennas refer to SIL 34-058. If recommended paint 

thickness is exceeded, this may cause electrical discharge which may interfere with communication and 

navigation systems. 

Around static ports and pitot probes (RVSM), the step between unpainted and painted area should not exceed 

400 microns. 

2. Safety Precautions 

NOTE: When you do repainting near AOA sensors, we recommend that you put a protective cover (Part No. 

98D5310300000) on the sensors. 

WARNING: OBEY THE MATERIAL MANUFACTURER'S INSTRUCTIONS WHEN YOU USE PAINTS, CHROMATE 

AGENTS, CLEANING AGENTS AND SPECIAL COATINGS. MOST OF THESE MATERIALS ARE 

DANGEROUS AND FLAMMABLE. 

CAUTION: IF THE STANDARD CERTIFIED COLOR BAG 707 IS NOT TO BE USED TO RESTORE PAINT OR 

REPAINTING OF THE UPPER SURFACES OF: THE HORIZONTAL TAILPLANE, ELEVATOR, AILERONS, 

SPOILERS AND FLAPS PLEASE CONTACT AIRBUS FOR APPROVAL OF THE NONSTANDARD PAINT 

COLOR. 

CAUTION: MAKE SURE THAT THE MATERIALS, AREAS AND PARTS GIVEN BELOW ARE PROPERLY PROTECTED 

AGAINST PAINT MATERIALS BY: 

MASKING: RUBBER, ALL COMPOSITE PARTS, ACRYLIC MATERIALS, AERODYNAMIC SMOOTHER, 

METAL BONDED EDGES, PITOT PROBES, SENSORS, STATIC PORTS, ENGINE AIR INTAKE, 

PRECOOLER AIR OUTLET SCREEN, ENGINE EXHAUST DUCT, APU EXHAUST, APU INTAKES AND 

OUTLETS, AIR CONDITIONING FRESH AIR INTAKE, CABIN PRESSURIZATION CONTROL SYSTEM 

OUTFLOW VALVE (ZONE 172), LANDING GEARS, DOOR SEALS, ACCESS DOORS, CABIN WINDOW AND 

WINDSHIELD PANELS AND SEALS, ELECTRICAL EQUIPMENT AND CABLES, PLASTIC MATERIALS, 

EXTERNAL SKIN PANEL JOINTS, HIGH STRENGTH STEEL PARTS, AVIONICS SKIN TEMPERATURE 

SENSOR (28HQ) SUPPORT EXTERNAL FACE AND BALL LOCK FITTINGS. 

Print Date: July 16, 2010 Local Time Page 1 of 19 
AIRBUS 

Customer: ENV 

Type : A318/A319/A320/A321 

Rev. Date : February 1, 2010 

Manual: SRM_A320 

Selected effectivity: ALL 

51-75-12 - REPAIR OF PAINT COATINGS (Revdate = Jun 01/09) 

PLUGGING: DRAIN HOLES, VENTS. 

CAUTION: MASK ANTENNAS. FOR MORE INFO ON ANTENNA PAINTING REFER TO SIL 34-058. 

CAUTION: MAKE SURE THAT THE PAINT MATERIALS DO NOT COME IN CONTACT WITH: 

- TEFLON-LINED SELF-LUBRICATED BEARINGS, 

- ELECTRICAL TERMINAL PLUGS, 

- NYLON-COATED WIRES, 

- NYLON BRUSHES. 

THE CHEMICALS IN THE PAINT MATERIALS CAN AFFECT THESE ITEMS. 

CAUTION: ENSURE THAT ALL MASKING MATERIALS ARE REMOVED FROM THE REPAIR AREA ON COMPLETION 

OF WORK, PAY SPECIAL ATTENTION TO PITOT HEADS AND STATIC PORTS. 

3. Repair of damaged top coat for metal, composite and glare parts 

A. Before you start with the repair procedure examine the depth of the damaged area. If primer is damaged refer to 

Paragraph 4,. If antistatic paint on composite surfaces is damaged refer to Paragraph 5, or 6,. 

B. Materials 

ITEM 

-

-

-

-

-

-

-

-

NOMENCLATURE 

Cleaning agent 

Polyurethane primer 

Epoxy primer 

Epoxy primer 

Polyurethane top coat 

Masking tape and paper 

Emery cloth 

Plastic scraper 

QTY 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

MATERIAL/REMARKS 

Material No. 11-003 (Refer to the CML) 

Material No. 16-001 (Refer to the CML) 

Material No. 16-006 (Refer to the CML) 

Material No. 16-060 (Refer to the CML) 

According to SRM 51 -23-11 

320 grade 

C. Repair 

(1) Remove any loose paint with a plastic scraper. 

(2) Use an adhesive tape to check the adhesion of the remaining paint. 

(3) Mask off the adjacent area, which will not be treated, with masking tape and paper. 

(4) Abrade the surface with emery cloth (320 grade) and chamfer the edges of the remaining paint around the 

damaged area. 

WARNING: CLEANING AGENT (MATERIAL NO. 11-003 ) IS DANGEROUS. 

(5) Remove the abrasive grit, clean and degrease the surface with cleaning agent (Material No. 11-003 ). 

WARNING: STRUCTURE PAINT (MATERIAL NO. 16-001 ) IS DANGEROUS. 

(6) Apply epoxy primer (Material No. 16-006 or 16-060 ) or polyurethane primer (Material No. 16-001 ) to the 

abraded area. 

(7) Apply the appropriate polyurethane top coat (Refer to Chapter 51-23-11 ). 

4. Renewal of paint build-up after damage to metal and glare parts or after paint stripping of metallic and glare parts 

A. General 

Print Date: July 16, 2010 Local Time Page 2 of 19 
AIRBUS 

Customer: ENV 

Type : A318/A319/A320/A321 

Rev. Date : February 1, 2010 

Manual: SRM_A320 

Selected effectivity: ALL 

51-75-12 - REPAIR OF PAINT COATINGS (Revdate = Jun 01/09) 

(1) You must restore the surface protection after the removal of corrosion, or a structural repair or paint stripping. 

(2) Before you start with the procedure refer to SRM 51-23-11 and determine the required paint build-up. 

WARNING: STRUCTURE PAINT (MATERIAL NO. 16-002 ) IS DANGEROUS. 

(3) Make sure that the internal repair parts are completely painted before they are assembled. When the parts are 

assembled, the fastener heads have to be reprotected with epoxy primer (Material No. 16-006 ) and additionally 

with polyurethane top coat (Material No. 16-002 ) in Category C (Refer to Chapter 51-21-00 ). 

B. Materials 

ITEM 

-

-

-

-

-

-

-

-

-

,-

-

NOMENCLATURE 

Cleaning agent 

Chemical conversion coating 

Polyurethane primer 

Epoxy primer 

Polyurethane top coat 

Wash primer 

Anti erosion paint 

Low VOC primer 

Low VOC top coat 

Clear coat varnish UVR 

Elastomeric coating 

SCOTCH-BRITE 

Masking tape 

Masking paper 

QTY 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

MATERIAL/REMARKS 

Material No. 11-003 (Refer to the CML) 

Material No. 13-002 (Refer to the CML) 

Material No. 16-001 (Refer to the CML) 

Material No. 16-006 or 16-049 ( Refer to the CML) 

Material No. 16-018 or 16-048 (Refer to the CML) 

Material No. 16-020 (Refer to the CML) 

Material No. 16-031 (Refer to the CML) 

Material No. 16-060 (Refer to the CML) 

Material No. 16-059 (Refer to the CML) 

Material No. 07-018 (Refer to the CML) 

Material No. 07-004 (Refer to the CML) 

Local purchase 

Local purchase 

Local purchase 

C. Repair 

(1) Mask off the adjacent area, which will not be treated, with masking tape and paper. 

WARNING: CLEANING AGENT (MATERIAL NO. 11-003 ) IS DANGEROUS. 

(2) Clean and degrease the surface with cleaning agent (Material No. 11-003 ). 

NOTE: Alternative solvent can be used, refer to SIL 20-010 and AIMS 09-00-002. 

NOTE: If excessive sanding or acid type paint stripper stripper (Material No. 12-014 ) has been used for paint 

stripping, then inspect the metal pretreatment. If the metal pretreatment, the CAA layer, is not damaged 

then proceed to Paragraph 4.C.(4). 

(3) Pretreat the surface of the repair area in accordance with Chapter 51-21-11 . 

WARNINGi STRUCTURE PAINT (MATERIAL NO. 16-001 ) IS DANGEROUS. 

WARNING: STRUCTURE PAINT (MATERIAL NO. 16-020 ) IS DANGEROUS. 

WARNING: STRUCTURE PAINT (MATERIAL NO. 16-001 ) IS DANGEROUS. 

WARNING: PRETREATMENT FOR PAINTING (MATERIAL NO. 13-002 ) IS POISONOUS. 

(4) Apply the appropriate primer as follows: 

Print Date: July 16, 2010 Local Time Page 3 of 19 
AIRBUS 

Customer: ENV 

Type : A318/A319/A320/A321 

Rev. Date : February 1, 2010 

Manual: SRM_A320 

Selected effectivity: ALL 

51-75-12 - REPAIR OF PAINT COATINGS (Revdate = Jun 01/09) 

- Polyurethane primer (Material No. 16-001 ) on top of wash primer (Material No. 16-020 ). 

- Polyurethane primer (Material No. 16-001 ) or epoxy primer (Material No. 16-006 or 16-049 ) or Low VOC 

primer (Material No. 16-060 ) on top of chemical conversion coating (Material No. 13-002 ). 

WARNING: PRETREATMENT FOR PAINTING (MATERIAL NO. 13-002 ) IS POISONOUS. 

WARNING: STRUCTURE PAINT (MATERIAL NO. 16-001 ) IS DANGEROUS. 

WARNING: STRUCTURE PAINT (MATERIAL NO. 16-031 ) IS DANGEROUS. 

(5) When erosion damage occurs on the wing leading edges above the pylons, the wing tips and the wing tip 

fences, apply: 

- If the bare metal is exposed apply chemical conversion coating (Material No. 13-002 ). 

- Polyurethane primer (Material No. 16-001 ) 

- Anti-erosion paint (Material No. 16-031 ) 

- Polyurethane top coat (Refer to Chapter 51-23-11 ). 

(6) Apply further layers of paint in accordance with the required paint build-up, which is given in Chapter 51-23-11. 

WARNING: STRUCTURE PAINT (MATERIAL NO. 16-020 ) IS DANGEROUS. 

WARNING: STRUCTURE PAINT (MATERIAL NO. 16-001 ) IS DANGEROUS. 

WARNING: STRUCTURE PAINT (MATERIAL NO. 16-018 ) IS DANGEROUS. 

WARNING: STRUCTURE PAINT (MATERIAL NO. 16-020 ) IS DANGEROUS. 

WARNING: STRUCTURE PAINT (MATERIAL NO. 16-001 ) IS DANGEROUS. 

WARNING: LAQUER (MATERIAL NO. 07-004 ) IS DANGEROUS. 

WARNING: CLEANING AGENT (MATERIAL NO. 11-003 ) IS DANGEROUS. 

WARNING: PRETREATMENT FOR PAINTING (MATERIAL NO. 13-002 ) IS POISONOUS. 

(7) Apply further layers of paint in accordance with the required paint build-up, which is given in Chapter 51-23-11 . 

The typical external paint scheme applied (except on wing box upper surfaces) is as follows: 

- Standard: Wash primer (Material No. 16-020 ) + polyurethane primer (Material No. 16-001 ) + polyurethane 

top coat (Material No. 16-018 ). 

- Alternate 1: Chemical conversion coation (Material No. 13-002) + epoxy primer (Material No. 16-049 ) + top 

coat (Material No. 16-048 ). 

- Alternate 2: Chemical conversion coation (Material No. 13-002) + low VOC primer (Material No. 16-060) + 

low VOC top coat (Material No. 16-059). 

The typical external paint scheme applied on wing box upper surfaces is as follows: 

- Standard: wash primer (Material No. 16-020 ), polyurethane primer (Material No. 16-001 ), elastomeric 

coating (Material No. 07-004 ) 

- Alternate 1: Wash primer (Material No. 16-020) + Low VOC wing coatinmg (Material No. 16-061) or 

- Alternate 2: Low VOC primer (Material No. 16-060A ) + Low VOC wing coating (Material No. 16-061A ). 

NOTE: If steps L and 4.C.(4). have been omitted, lightly abrade the surfaces with SCOTCH-BRITE and clean 

with lint free cloth soaked with cleaning agent (Material No. 11-003 or alternative solvents according to 

SIL 20-010). Before the application of epoxy primer (Material No. 16-049 ) or (Material No. 16-060 ) 

apply chemical conversion coating (Material No. 13-002 ) on bare exposed aluminum parts, refer to 

Chapter 51-21-11 , Paragraph 2. B.. 

NOTE: For external paint scheme use a paint system from the same manufacturer. 

Print Date: July 16, 2010 Local Time Page 4 of 19 
AIRBUS 

Customer: ENV 

Type : A318/A319/A320/A321 

Rev. Date : February 1, 2010 

Manual: SRM_A320 

Selected effectivity: ALL 

51-75-12 - REPAIR OF PAINT COATINGS (Revdate = Jun 01/09) 

5. Renewal of paint build-up of composite components that require no anti-erosion paint 

A. General 

(1) After a structural repair of composite components it is necessary to restore the removed or damaged paint 

layers. In case of paint damage to composites, reprotect immediately to avoid fiber erosion and water 

entrapment. 

(2) The following paint procedure must be adhered to. 

B. Materials 

ITEM 

-

-

-

-

-

-

-

-

1-

-

-

-

i-

-

NOMENCLATURE 

Antistatic paint 

Cleaning agent 

Polyurethane primer 

Epoxy primer 

Polyurethane primer 

Pore filler 

Antistatic paint (low resistivity) 

Antistatic paint (high resistivity) 

Polyurethane top coat 

Plastic scraper 

Abrasive alumine powder 

Emery cloth 

Adhesive tape 

Masking tape and paper 

QTY 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

MATERIAUREMARKS 

Material No. 07-005 , 07-006 or 16-030 ) (Refer to 

the CML) 

Material No. 11 -003 (Refer to the CML) 

Material No. 16-001 (Refer to the CML) 

Material No. 16-006 , 16-006B or 16-006C (Refer to 

the CML) 

Material No. 16-024 (Refer to the CML) 

Material No. 16-024 without thinner (Refer to the 

CML) 

Material No. 07-005 (Refer to the CML) 

Material No. 07-006 (Refer to the CML) 

According to Chapter 51 -23-11 

325 mesh 

320 grade 

C. Preparation 

(1) Remove any loose paint with a plastic scraper. 

(2) Use an adhesive tape to check the adhesion of the remaining paint. 

(3) In case of repainting, mask the surface around the touch up area, leaving an overlap of approximately 10 mm 

(0.394 in.) with the existing paint. 

CAUTION: DO NOT DAMAGE THE FIBERS, TEDLAR FOIL (WHERE EXISTENT) OR ALUMINUM FOIL 

(WHERE EXISTENT) DURING THIS PROCESS. 

(4) If it is required to repaint the part completely, the remaining paint has to be abraded down to the tedlar foil 

(where existent) or aluminum foil (where existent) or first layer of primer on composite materials. 

WARNING: CLEANING AGENT (MATERIAL NO. 11-003 ) IS DANGEROUS. 

(5) Clean and degrease the surface with cleaning agent (Material No. 11-003 ). 

(6) Abrade the surface where the paint has peeled off from the composite with emery cloth (320 grade) or abrasive 

alumine powder 325 mesh or equivalent. 

(7) Smooth down the edges of the remaining paint if necessary with emery cloth (320 grade). 

Print Date: July 16, 2010 Local Time Page 5 of 19 
AIRBUS 

Customer: ENV 

Type: A318/A319/A320/A321 

Rev. Date : February 1, 2010 

Manual: SRM_A320 

Selected effectivity: ALL 

51-75-12 - REPAIR OF PAINT COATINGS (Revdate = Jun 01/09) 

WARNING: LAQUER (MATERIAL NO. 07-005 ) IS DANGEROUS. 

WARNING: LAQUER (MATERIAL NO. 07-006 ) IS DANGEROUS. 

(8) In case of local reprotection, a stripe of antistatic paint (Material No. 07-005 or 07-006 ) 15 mm (0.591 in.) wide 

should be visible all around the area. 

NOTE: The use of antistatic paint is not necessary on to Carbonfiber Reinforced Plastic (CFRP) components. 

(9) Rinse with water and carry out a water break test. 

(a) Once the abrading process is complete, wash the area with water. If the water covers the area as an 

unbroken film, the area is clean. 

(b) If the water forms small droplets on the surface this is an indication that the area is contaminated and that 

cleaning is not complete. In this case repeat steps 5.C.(6). thru 5.C.(9).. 

(c) Dry the area with a clean cloth. 

D. Reprotection 

(1) Surfaces covered with aluminum foil: 

(a) Pretreat the surface of the repair area in accordance with ChapteL51-23-1_l. 

WARNING: STRUCTURE PAINT (MATERIAL NO. 16-001 ) IS DANGEROUS. 

WARNING: STRUCTURE PAINT (MATERIAL NO. 16-020 ) IS DANGEROUS. 

WARNING: STRUCTURE PAINT (MATERIAL NO. 16-001 ) IS DANGEROUS. 

WARNING: PRETREATMENT FOR PAINTING (MATERIAL NO. 13-002 ) IS POISONOUS. 

(b) Apply the appropriate primer as follows: 

- Polyurethane primer (Material No. 16-001 ) on top of wash primer (Material No. 16-020 ) 

- Polyurethane primer (Material No. 16-001 ) or epoxy primer (Material No. 16-006 ), on top of chemical 

conversion coating (Material No. 13-002 ) 

- Polyurethane top coat in accordance with Chapter 51-23-11 . 

CAUTION: DO NOT COVER THE 15 MM (0.591 IN.) WIDE STRIP OF ANTISTATIC PAINT WITH PRIMER 

(REFER TO PARAGRAPH 5.C.(8). . 

WARNING: STRUCTURE PAINT (MATERIAL NO. 16-006B ) IS DANGEROUS. 

WARNING: STRUCTURE PAINT (MATERIAL NO. 16-006C ) IS DANGEROUS. 

WARNING.: STRUCTURE PAINT (MATERIAL NO. 16-001 ) IS DANGEROUS. 

WARNING: LAQUER (MATERIAL NO. 07-005 ) IS DANGEROUS. 

WARNING: LAQUER (MATERIAL NO. 07-006 ) IS DANGEROUS. 

(2) Surfaces covered with tedlar foil: 

- Apply epoxy primer (Material No. 16-006B or 16-006C ) or Polyurethane primer (Material No. 16-001 ), 

- antistatic paint (Material No. 07-005 , 07-006 or 16-030 ), 

- polyurethane top coat in accordance with Chapter 51-23-11 . 

WARNING: STRUCTURE PAINT (MATERIAL NO. 16-024 ) IS DANGEROUS. 

Print Date: July 16, 2010 Local Time Page 6 of 19 
AIRBUS 

Customer: ENV 

Type : A318/A319/A320/A321 

Rev. Date : February 1, 2010 

Manual: SRM_A320 

Selected effectivity: ALL 

51-75-12 - REPAIR OF PAINT COATINGS (Revdate = Jun 01/09) 

WARNING: STRUCTURE PAINT (MATERIAL NO. 16-018C ) IS DANGEROUS. 

(3) CFRP (Carbonfiber Reinforced Plastic) parts: 

- Apply polyurethane primer as a pore filler (Material No. 16-024 ) where necessary, 

- polyurethane primer (Material No. 16-040 ), 

- polyurethane finish paint (Material No. 16-018C ). 

CAUTION: DO NOT COVER THE 15 MM (0.591 IN.) WIDE STRIP OF ANTISTATIC PAINT WITH PRIMER 

(REFER TO PARAGRAPH 5.C.(8). . 

WARNING: STRUCTURE PAINT (MATERIAL NO. 16-024) IS DANGEROUS. 

WARNING: STRUCTURE PAINT (MATERIAL NO. 16-024 ) IS DANGEROUS. 

WARNING: LAQUER (MATERIAL NO. 07-005 ) IS DANGEROUS. 

WARNING: LAQUER (MATERIAL NO. 07-006 ) IS DANGEROUS. 

(4) AFRP (Aramidfiber Reinforced Plastic) or GFRP (Glassfiber Reinforced Plastic) parts: 

- Apply Polyurethane primer (Material No. 16-024 ) or epoxy primer (Material No. 16-006 ), 

- pore filler (Material No. 16-024 without thinner) where necessary, 

- antistatic paint (Material No. 07-005 , 07-006 or 16-030 ) as required, 

- polyurethane top coat in accordance with Chapter 51-23-11 . 

NOTE: To achieve a sufficient paint coverage it can be necessary to apply primer prior to top coat to avoid an 

overthickness of the top coat. 

6. Renewal of paint build-up of composite components that require anti-erosion paint 

A. General 

(1) After a structural repair of composite components, it is necessary to restore the removed or damaged paint 

layers. In case of paint damage to composites, reprotect immediately to avoid fiber erosion and water 

entrapment. 

B. Materials 

ITEM 

-

-

-

-

-

-

" 

-

-

-

-

NOMENCLATURE 

Antistatic paint (low resistivity) 

Antistatic paint (high resistivity) 

Cleaning agent 

Polyurethane primer 

Pore filler 

Polyurethane top coat 

Anti-erosion paint 

Plastic scraper 

Abrasive alumine powder 

Emery cloth 

Adhesive tape 

Masking tape and paper 

QTY 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

MATERIAL/REMARKS 

Material No. 07-005 (Refer to the CML) 

Material No. 07-006 (Refer to the CML) 

Material No. 11-003 (Refer to the CML) 

Material No. 16-024 (Refer to the CML) 

Material No. 16-024 without thinner (Refer to the 

CML) 

According to Chapter 51-23-11 

Material No. 16-031 (Refer to the CML) 

325 mesh 

320 grade 

C. Preparation 

Print Date: July 16, 2010 Local Time Page 7 of 19 
AIRBUS 

Customer: ENV 

Type : A318/A319/A320/A321 

Rev. Date : February 1, 2010 

Manual: SRM_A320 

Selected effectivity: ALL 

51-75-12 - REPAIR OF PAINT COATINGS (Revdate = Jun 01/09) 

(1) Remove any loose paint with a plastic scraper. 

(2) Use an adhesive tape to check the adhesion of the remaining paint. 

(3) Mask off the adjacent area, which will not be treated, with masking tape and paper. 

CAUTION: DO NOT DAMAGE THE FIBERS DURING THIS PROCESS. 

(4) If it is required to repaint the part completely, the remaining paint has to be abraded down to the basic primer. 

WARNING: CLEANING AGENT (MATERIAL NO. 11-003 ) IS DANGEROUS. 

(5) Clean and degrease the surface with cleaning agent (Material No. 11-003 ). 

(6) In case of partial repainting, mask the surface around the repair area, leaving an overlap of approximately 10 

mm (0.394 in.) with the existing paint. 

(7) Abrade the surface where the paint has peeled off from the composite with abrasive alumine powder 325 mesh 

or equivalent. 

(8) Smooth down the edges of the remaining paint if necessary with emery cloth grade 320. 

WARNING: LAQUER (MATERIAL NO. 07-005 ) IS DANGEROUS. 

WARNING: LAQUER (MATERIAL NO. 07-006 ) IS DANGEROUS. 

(9) In case of local reprotection, abrade the adjacent areas until a strip of antistatic paint (Material No. 07-005 or 07-

006 ) 15 mm (0.591 in.) wide shows around the area. 

NOTE: The use of antistatic paint is not necessary on CFRP (Carbonfiber Reinforced Plastic) components. 

(10) Rinse with water and carry out a water break test. 

(a) Once the abrading process is complete, wash the area with water. If the water covers the area as an 

unbroken film, the area is clean. 

(b) If the water forms small droplets on the surface this is an indication that the area is contaminated and that 

cleaning is not complete. In this case repeat steps 6.C.(6). thru 6.C.(10).. 

WARNING: CLEANING AGENT (MATERIAL NO. 11-003 ) IS DANGEROUS. 

(c) Degrease the surface with cleaning agent (Material No. 11-003 ). 

D. Reprotection 

CAUTION: DO NOT COVER THE 15 MM (0.591 IN.) WIDE STRIP OF ANTISTATIC PAINT WITH PRIMER 

(REFER TO PARAGRAPH 6.C.(9). 

WARNING: STRUCTURE PAINT (MATERIAL NO. 16-024 ) IS DANGEROUS. 

(1) Apply Polyurethane primer (Material No. 16-024 ). 

WARNING: STRUCTURE PAINT (MATERIAL NO. 16-024 ) IS DANGEROUS. 

(2) Apply pore filler (Material No. 16-024 without thinner) where necessary and abrade. 

WARNINGi LAQUER (MATERIAL NO. 07-005 ) IS DANGEROUS. 

Print Date: July 16, 2010 Local Time Page 8 of 19 
AIRBUS 

Customer: ENV 

Type : A318/A319/A320/A321 

Rev. Date : February 1, 2010 

Manual: SRM_A320 

Selected effectivity: ALL 

51-75-12 - REPAIR OF PAINT COATINGS (Revdate = Jun 01/09) 

WARNING: LAQUER (MATERIAL NO. 07-006 ) IS DANGEROUS. 

(3) Apply antistatic paint (Material No. 07-005 or 07-006 ) if necessary. 

(4) Mask countersunk holes with masking tape for conductivity reasons. 

WARNING: STRUCTURE PAINT (MATERIAL NO. 16-031 ) IS DANGEROUS. 

(5) Apply anti-erosion paint (Material No. 16-031 ) in ram area as required. 

NOTE: Ram area is that area designated as being most directly opposed to the airflow. 

(6) Apply polyurethane top coat in accordance with Chapter 51-23-11 . 

NOTE: To achieve a sufficient paint coverage it can be necessary to apply primer prior to top coat to avoid an 

overthickness to the top coat. 

7. Repair of peeled-off paint coatings on fastener heads 

A. General 

(1) If you find peeled-off paint coatings on fastener heads, it is often the result of corrosion or poor paint adhesion, 

which breaks the surface protection. 

(2) Therefore it is necessary to examine the fastener and the adjacent area for corrosion damage. If you find 

corrosion, refer to Chapter 51-74-00 and Chapter 51-43-00 for removal of corrosion and oversize replacement. 

(3) Before you start with the procedure refer to Chapter 51-23-11 and determine the required paint build-up. 

B. Materials 

ITEM 

-

-

-

-

-

-

-

NOMENCLATURE 

Cleaning agent 

Chemical conversion coating 

Epoxy primer 

Final paint system 

Masking tape and paper 

Emery cloth 

SCOTCH-BRITE pads 

QTY 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

MATERIAL/REMARKS 

Material No. 11-003 (Refer to the CML) 

Material No. 13-002 (Refer to the CML) 

Material No. 16-006 (Refer to the CML) 

According to Chapter 51-23-11 

320 Grade 

C. Repair 

(1) Mask off the adjacent area, which will not be treated, with masking tape and paper. 

(2) Remove and abrade the loose, broken paint layers with emery cloth until the surface is smooth. 

WARNING: CLEANING AGENT (MATERIAL NO. 11-003 ) IS DANGEROUS. 

(3) Remove the abrasive grit and degrease the surface of the repair area with cleaning agent (Material No. 11 -003 ). 

WARNING: PRETREATMENT FOR PAINTING (MATERIAL NO. 13-002 ) IS POISONOUS. 

(4) If the components and fasteners are made of aluminum alloy, apply chemical conversion coating (Material No. 

13-002 ). Other materials have only to be slightly abraded with Scotchbrite pads. 

(5) Apply epoxy primer (Material No. 16-006 ). 

Print Date: July 16, 2010 Local Time Page 9 of 19 
AIRBUS 

Customer: ENV 

Type : A318/A319/A320/A321 

Rev. Date : February 1, 2010 

Manual: SRM_A320 

Selected effectivity: ALL 

51-75-12 - REPAIR OF PAINT COATINGS (Revdate = Jun 01/09) 

(6) Apply the final paint system according to Chapter 51-23-11 . 

8. Application of anti erosion tape on vertical stabilizer leading edge 

A. General 

(1) Anti-erosion tape may be used as a preventive measure against paint erosion or as a temporary repair solution. 

(2) In case of paint damage to composites, reprotect immediately to avoid fiber erosion and water entrapment. 

(3) The tape can be temporarily directly on top of the fibers, provided the surface is abraded to smooth down the 

paint edges. 

(4) In case of erosion, which caused damage to the fiber, the structure must be repaired to restore the outside 

contour and structural integrity before tape application. 

B. Materials 

ITEM 

-

-

-

-

-

-

-

NOMENCLATURE 

Cleaning agent 

Polyurethane anti-erosion tape 

Polyurethane anti-erosion tape (erosion 

protection for HTP leading edge) 

Abrasive sand 

Adhesive tape 

Masking tape and paper 

Plastic spatula 

QTY 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

MATERIAL/REMARKS 

Material No. 11 -003 (Refer to the CML) 

Material No. 05-132 or Material No. 05-065 (Refer to 

the CML) 

Material No. 05-096 (Refer to the CML) 

C. Preparation of Leading Edges for Tape Application 

(1) Cut the polyurethane tape to the required length, refer to Figure 5 

(2) Do not remove the release paper from the polyurethane tape. Put this tape in position on the leading edge. 

(3) Fix the polyurethane tape in position with adhesive tape and mark the area. 

(4) Enlarge the marked area on each side by approximately 5 mm (0.2 in.) longitudinal direction and mask off the 

area with an adhesive tape, refer to Figure 001. 

L5JFigure 001 (sheet 1) Application of Anti - erosion Tape 

(5) Remove the polyurethane tape subsequent to masking and marking. 

(6) Lightly abrade the application area with dry abrasive sand. 

WARNING.: CLEANING AGENT (MATERIAL NO. 11-003 ) IS DANGEROUS. 

(7) Remove the sanding residues and clean with cleaning agent (Material No. 11-003 ). 

D. Tape Application 

Apply self-adhesive transparent polyurethane tape to leading edges as follows: 

(1) Immediately after cleaning, however only after the complete evaporation of the cleaning agent (allow 20 to 30 

minutes for evaporation then wipe the area with a clean absorbent cloth to avoid any condensation), place the 

adhesive tape with release paper in final position on the leading edges. Tack along the full length on both sides. 

(2) Gradually remove the adhesive tacking on one side and peel off an approximately 50 mm (2.0 in.) wide strip of 

release paper from the polyurethane tape, refer to Figure Q02 . 

Print Date: July 16, 2010 Local Time Page 10 of 19 
AIRBUS 

Customer: ENV 

Type : A318/A319/A320/A321 

Rev. Date : February 1, 2010 

Manual: SRM_A320 

Selected effectivity: ALL 

51-75-12 - REPAIR OF PAINT COATINGS (Revdate = Jun 01/09) 

(3) Slightly press the polyurethane tape against the leading edge. 

L^JFlgure 002 (sheet 1) Application of Anti-erosion Tape 

lj*jFigure 003 (sheet 1) Application of Anti-erosion Tape 

[jLlFigure 004 (sheet 1) Application of Anti-erosion Tape 

(4) Remove the adhesive tacking on the opposite side and turn up the polyurethane tape. Peel off the remaining 

release paper, refer to Figure 003 . 

CAUTION: DO NOT STRETCH THE POLYURETHANE ANTI-EROSION TAPE DURING APPLICATION. 

(5) Gradually press the polyurethane anti-erosion tape against the leading edge, refer to Figure 004 . 

(6) Check if the polyurethane tape has been applied without the formation of bubbles. 

CAUTION: DO NOT APPLY EXCESSIVE PRESSURE. 

(7) If necessary, carefully squeeze out any trapped air using a plastic spatula or roller. 

(8) Allow bonding of the tape to cure for at least 1 hour at a minimum temperature of 15 C ° (59. F °). 

LjLlFigure 005 (sheet 1) Application of Anti-erosion Tape 

9. Renewal of damaged fuel tank top coating on center tank and horizontal stabilizer center tank 

A. In the event of a fuel leak from the center tank (Section 21) or the horizontal stabilizer-center tank it is necessary to 

renew the external coating (Material No. 16-015 ), as well as the internal sealing in the area of the leak. Refer to 

Chapter 51-76-12 for information concerning the internal sealing. 

B. Materials 

ITEM 

-

-

-

-

-

-

-

-

NOMENCLATURE 

Cleaning agent 

Primer coating epoxy 

Fuel tank top coating 

Polyurethane coating (protective coating) 

Wash primer 

Masking tape and paper 

Abrasive cloth/paper 

Plastic scrapers 

QTY 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

MATERIAL/REMARKS 

Material No. 11 -003 (Refer to the CML) 

Material No. 16-006 (Refer to the CML) 

Material No. 16-015 or 09-032 (Refer to the CML) 

Material No. 16-042A or 16-021 (Refer to the CML) 

Material No. 16-020 (Refer to the CML) 

Local supply 

Grade 100 and 280 

Local supply 

C. Repair 

(1) Remove the fuel tank top coating (Material No. 16-015 ) from around the area of the fuel leak by abrading. Use 

abrasive cloth/paper 100 grade and finish with 280 grade. Chamfer the edges of the abraded paint to give a 

smooth finish. 

NOTE: It is necessary to remove the paint down to the metal surface to ensure good adhesion of the new paint 

coat. 

WARNING: CLEANING AGENT (MATERIAL NO. 11-003 ) IS DANGEROUS. 

(2) Clean the abraded and surrounding area with cleaning agent (Material No. 11-003 ). 

(3) Mask off the area that is to be repainted. 

Print Date: July 16, 2010 Local Time Page 11 of 19 
AIRBUS 

Customer: ENV 

Type : A318/A319/A320/A321 

Rev. Date : February 1, 2010 

Manual: SRM_A320 

Selected effectivity: ALL 

51-75-12 - REPAIR OF PAINT COATINGS (Revdate = Jun 01/09) 

WARNING: STRUCTURE PAINT (MATERIAL NO. 16-020 ) IS DANGEROUS. 

WARNING: PRETREATMENT FOR PAINTING (MATERIAL NO. 13-002 ) IS POISONOUS. 

(4) Apply wash primer (Material No. 16-020 ) to the exposed metal surface, allow wash primer to dry for a minimum 

of 1 hour but not exceeding 24 hours or apply Chemical Conversion Coating (Material No. 13-002 ) (Refer to 

Chapter 51-21-11 ). 

WARNING: PRETREATMENT FOR PAINTING (MATERIAL NO. 13-002 ) IS POISONOUS. 

WARNING: STRUCTURE PAINT (MATERIAL NO. 16-001 ) IS DANGEROUS. 

WAR.N1NG: STRUCTURE PAINT (MATERIAL NO. 16-020 ) IS DANGEROUS. 

(5) On top of Chemical Conversion Coating (Material No. 13-002 ) apply Primer Coating Epoxy (Material No. 16-

006 ) to the area including any fastener heads, or apply Polyurethane Primer (Material No. 16-001 ) on top of 

Wash Primer (Material No. 16-020 ). Allow to dry under ambient conditions for a minimum of 2 hours but not 

exceeding 24 hours. 

CAUTION: THE AREA THAT IS TO BE REMASKED SHOULD ENSURE THAT THE FUEL TANK COATING 

THAT IS TO BE APPLIED DOES NOT CONTACT ANY OTHER EXISTING PAINT FINISH EXCEPT 

THE EPOXY PRIMER OR EXISTING FUEL TANK COATING. 

(6) Remove masking tape and paper, remask the area to include an overlap on to the existing fuel tank coating 

(Material No. 16-015 or 09-032 ), but observe the CAUTION given above. 

(7) Apply fuel tank coating (Material No. 16-015 or 09-032 ) with a soft hair brush as follows: 

- 2 coats on horizontal surfaces 

- 3 coats on vertical surfaces. 

After each coat has dried for approximately 15 minutes, smooth out by brush any bubbles or runs. 

Allow 3 to 4 hours drying time under ambient conditions between coats. This time can be reduced to 2 hours if 

forced drying is used. 

NOTE: Final paint thickness should be 300 to 400 microns (11811 to 15748 microinches). 

(8) Allow a final drying time of 24 hours under ambient conditions. 

10. Renewal of external paint build-up with AMS 3095 external paint scheme 

A. General 

NOTE: Do not renew with AMS 3095 for the following parts: 

- Radome, 

- Antennas (Refer to SIL 34-058), 

- All areas covered with anti-erosion coating. 

NOTE: The maximum recommended paint thickness is 350 to 400 microns on nacelles. 

NOTE: Around static ports and pitot probes (RVSM), the step between unpainted and painted areas must not 

exceed 400 microns. 

NOTE: If the recommended paint thickness is exceeded, this can cause electrical discharge, which can interfere 

with communication and navigation systems. 

CAUTION: THIS PROCEDURE IS NOT APPLICABLE TO RADOME, ANTENNAS AND IS NOT RECOMMENDED 

FOR UPPER WING BOX. 

Print Date: July 16, 2010 Local Time Page 12 of 19 
AIRBUS 

Customer: ENV 

Type : A318/A319/A320/A321 

Rev. Date : February 1, 2010 

Manual: SRM_A320 

Selected effectivity: ALL 

51-75-12 - REPAIR OF PAINT COATINGS (Revdate = Jun 01/09) 

(1) This procedure is applicable after complete paint stripping according to Chapter 51-75-11 . 

(2) The work consists in applying an external paint scheme qualified according to AMS 3095 instead of AIRBUS 

approved external paint scheme on external surfaces only. 

(3) Before you start with the procedure refer to Chapter 51-23-11 and determine the required paint build-up. 

(4) For horizontal composite surfaces ensure that the top coat color requirements are met, contact AIRBUS. 

B. Materials 

ITEM 

-

-

-

-

-

-

-

-

-

-

NOMENCLATURE 

Cleaning agent 

Final paint system 

Chemical conversion coating 

Polyurethane primer 

Epoxy primer 

Wash primer 

Anti static coating 

Anti erosion coating 

Masking tape Masking paper 

Abrasive paper 

QTY MATERIAL/REMARKS 

Material No. 11-003 (Refer to the CML or to SIL 20-

010) 

according to AMS 3095 

Material No. 13-002 (Refer to the CML) 

Material No. 16-001 (Refer to the CML) 

Material No. 16-006 (Refer to the CML) 

Material No. 16-020 (Refer to the CML) 

Material No. 07-005 or Material No. 07-006 or 

Material No. 16-030 (Refer to the CML) 

Material No. 16-031 (Refer to the CML) 

Local purchase Local purchase 

Local purchase Grade 100 and 280 

C. Repair 

- For Renewal of external paint build-up on metallic parts, refer to Paragraph lO.C.(l). . 

- For Renewal of external paint build-up on composite parts requiring no anti erosion coating, refer to Paragraph 

10.C.(2V . 

- For Renewal of external paint build-up on composite parts requiring anti erosion coating, refer to Paragraph 10 ^ 

(3).. 

(1) Renewal of external paint build-up on metallic parts 

(a) Mask off areas which will not be repainted, refer to Paragraph 4,. 

WARNING: PRETREATMENT FOR PAINTING (MATERIAL NO. 13-002 ) IS POISONOUS. 

WARNING: STRUCTURE PAINT (MATERIAL NO. 16-001 ) IS DANGEROUS. 

WARNING: STRUCTURE PAINT (MATERIAL NO. 16-020 ) IS DANGEROUS. 

WARNING: STRUCTURE PAINT (MATERIAL NO. 16-001 ) IS DANGEROUS. 

WARNING: PRETREATMENT FOR PAINTING (MATERIAL NO. 13-002 ) IS POISONOUS. 

(b) If C/V\ anodic coating on aluminum parts has been damaged during paint stripping, reprotect exposed bare 

metal as follows: 

- with chemical conversion coating (Material No. 13-002 ) and primer (Material No. 16-001 or 16-006 ), 

refer to Chapter 51-21-11 , Paragraph 2.B.. or 

- with wash primer (Material No. 16-020 ) and primer (Material No. 16-001 ). 

NOTE: On titanium parts follow the same instructions except do not apply chemical conversion coating 

(Material No. 13-002). 

Print Date: July 16, 2010 Local Time Page 13 of 19 
AIRBUS 

Customer: ENV 

Type : A318/A319/A320/A321 

Rev. Date : February 1, 2010 

Manual: SRM_A320 

Selected effectivity: ALL 

51-75-12 - REPAIR OF PAINT COATINGS (Revdate = Jun 01/09) 

(c) Prepare the surface according to AMS 3095 and paint manufacturer's instructions. 

(d) Apply AMS 3095 external paint scheme according to paint manufacturer's instructions. 

NOTE: For areas requiring anti erosion paint, refer to Chapter 51-23-11 . 

(2) Renewal of external paint build-up on composite parts requiring no anti erosion coating 

(a) Repeat Paragraph 4^ thru 5,. 

(b) Apply external paint scheme according to AMS 3095 and paint manufacturer's instructions. 

(3) Renewal of external paint build-up on composite parts requiring anti erosion coating 

(a) Repeat Paragraph 6.A. thru 6.C. . 

(b) Repeat Paragraph 6.D.(1). thru 6.0.(5). . 

(c) Apply external paint scheme (primer and top coat) according to AMS 3095 and paint manufacturer's 

instructions. 

Print Date: July 16, 2010 Local Time Page 14 of 19 
I ' 

AIRBUS 

Customer: ENV 

Type : A318/A319/A320/A321 

Rev. Date : February 1, 2010 

Manual: SRM_A320 

Selected effectivity: ALL 

51-75-12 - REPAIR OF PAINT COATINGS (Revdate = Jun 01/09) 

: I 

%' i 

Print Date: July 16, 2010 Local Time Page 15 of 19 
iX 

Customer: ENV 

Type : A318/A319/A320/A321 

Rev. Date : February 1, 2010 

Manual: SRM_A320 

Selected effectivity: ALL 

51-75-12 - REPAIR OF PAINT COATINGS (Revdate = Jun 01/09) 

I 

3 

Print Date: July 16, 2010 Local Time Page 16 of 19 
AIRBUS 

Customer: ENV 

Type : A318/A319/A320/A321 

Rev. Date : February 1, 2010 

Manual: SRM_A320 

Selected effectivity: ALL 

51-75-12 - REPAIR OF PAINT COATINGS (Revdate = Jun 01/09) 

Print Date: July 16, 2010 Local Time Page 17 of 19 
AIRBUS 

Customer: ENV 

Type : A318/A319/A320/A321 

Rev. Date : February 1, 2010 

Manual: SRM_A320 

Selected effectivity: ALL 

51-75-12 - REPAIR OF PAINT COATINGS (Revdate = Jun 01/09) 

3 

\ 

:• I 

•:. i 

': i 

r I 

:'• I 

r J 

Print Date: July 16, 2010 Local Time Page 18 of 19 
AIRBUS 

Customer: ENV 

Type : A318/A319/A320/A321 

Rev. Date : February 1, 2010 

Manual: SRM_A320 

Selected effectivity: ALL 

51-75-12 - REPAIR OF PAINT COATINGS (Revdate = Jun 01/09) 

'.;! 

Figure 005 (sheet 1) Application of Anti-erosion Tape 

Print Date: July 16, 2010 Local Time Page 19 of 19 
AIRBUS 

Customer: ENV 

Type : A318/A319/A320/A321 

Rev. Date : February 1, 2010 

Manual: SRM_A320 

Selected effectivity: ALL 

51-75-11 - STRIPPING/PAINT REMOVAL (Revdate = May 01/06) 

51-75-11 STRIPPING/PAINT REMOVAL 

CAUTION: AVOID TO CUT PROTECTIVE FILMS, TAPES, MASKS OR MARKINGS ON THE AIRCRAFT SKIN TO 

PREVENT SCRIBE MARKS. IF THIS OPERATION IS REQUIRED, USE SCISSORS OR A PLATE BETWEEN 

THE FILM 0.6 MM (0.024 IN.) MINIMUM THICKNESS WITH METAL AND 2 MM (0.079 IN.) THICKNESS WITH 

HARD PLASTIC) AND THE AIRCRAFT SKIN, OR USE A SPECIAL CUTTER (REFER TO MANUFACTURER 

CODE 3M MARTOR-POLYPICK N0.469), THEN INSPECT. REFER TO FIGURE 001 . 

1. General 

A. The removal of paint from metal surfaces is done by either chemical stripping or by abrasion (top coat only). 

B. Composite surfaces must not be chemically stripped as the strippers may attack the resins. Therefore, only abrasion 

should be used. 

C. Alternative stripping processes not referred to in Chapter 51 -75-11 to remove external paint systems can be 

evaluated and qualified by the user and approved by national airworthiness authorities as documented in SAE 

MA4872 plus additional tests specific to AIRBUS requirements. When using the SAE MA4872 procedure it is 

mandatory to first contact AIRBUS to ascertain which additional tests will be required for the process to be qualified. 

The document SAE MA4872 is available from: 

SAE400 Commonwealth DriveWarrendalePA A5096-0001USA 

L^Jpigure 001 (sheet 1) Protected cutting procedure 

2. Chemical Paint Stripping Procedure - Metallic Structure Only - Methylene Chloride Based Paint Stripper 

A. General 

(1) The work consists of, through application of chemical strippers, removing the external paint system down to the 

basic primer (for the paint buildup, refer to Chapter 51-23-11 ). After preparation of the stripped surface, the new 

paint system will be applied. 

(2) Make sure that the stripper is removed within 30 minutes after application. To ensure this limit, it is 

recommended that one person should only apply the stripper to an area not greater than 4 m ^ (43 sq. ft.) at one 

time. 

B. Safety Precautions 

C. Repair Materials 

WARNING: OBEY THE MANUFACTURER'S INSTRUCTIONS WHEN YOU USE STRIPPERS. THE STRIPPERS 

ARE DANGEROUS. 

WARNING: OBEY THE MANUFACTURER'S INSTRUCTIONS WHEN YOU USE THE CLEANING AGENTS (MAT. 

NO. 11-003 AND 11-004 ). THESE CLEANING AGENTS ARE DANGEROUS. 

CAUTION: MAKE SURE THAT THE RUBBER, ALL COMPOSITE PARTS, ACRYLIC MATERIALS, 

AERODYNAMIC SMOOTHER, METAL BONDED EDGES, PITOT PROBES, SENSORS, STATIC 

PORTS, ENGINE AIR INTAKE, PRECOOLER AIR OUTLET SCREEN, ENGINE EXHAUST DUCT, 

APU EXHAUST, APU INTAKES AND OUTLETS, AIR CONDITIONING FRESH AIR INTAKE, 

LANDING GEARS, DOOR SEALS, ACCESS DOORS, CABIN WINDOW AND WINDSHIELD PANELS 

AND SEALS, ELECTRICAL EQUIPMENT AND CABLES, PLASTIC MATERIALS, EXTERNAL SKIN 

JOINTS, AVIONICS SKIN TEMPERATURE SENSOR (28HQ) SUPPORT EXTERNAL FACE 

CAUTION: MASK ANTENNAS. FORE MORE INFO ON ANTENNA PAINTING REFER TO SIL 34-058. 

CAUTION: MAKE SURE THAT DRAIN HOLES AND VENTS ARE PROPERLY PROTECTED AGAINST 

STRIPPERS BY PLUGGING. 

Print Date: July 16, 2010 Local Time Pagel of 14 
AIRBUS 

Customer: ENV 

Type : A318/A319/A320/A321 

Rev. Date : February 1, 2010 

Manual: SRM_A320 

Selected effectivity: ALL 

51-75-11 - STRIPPING/PAINT REMOVAL (Revdate = May 01/06) 

CAUTION: MAKE SURE THAT THE PAINT STRIPPERS DO NOT COME IN CONTACT WITH TEFLON-LINED 

SELF-LUBRICATED BEARINGS, ELECTRICAL TERMINAL PLUGS, NYLON-COATED WIRES AND 

NYLON BRUSHES. THE CHEMICALS IN THE PAINT STRIPPERS WILL ATTACK THESE ITEMS. 

CAUTION: ENSURE THAT ALL MASKING MATERIALS ARE REMOVED FROM THE REPAIR AREA ON 

COMPLETION OF WORK, PAY SPECIAL ATTENTION TO PITOT HEADS AND STATIC PORTS. 

ITEM 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

NOMENCLATURE 

Stripper 

Cleaning agent 

Clean doth 

Synthetic sponge 

Emery cloth 

Polyethylene film 

Adhesive aluminum tape 

Masking paper 

Plastic scraper 

SCOTCH-BRITE 

Brush 

QTY 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

MATERIAL/REMARKS 

Material No. 12-005 or 12-010 (Refer to Chapter 51-

.35j:0g ) <^1, > 

Material No. 11-003 or 11-004 (Refer Chapter 51-35-

00) 

Grade 220 or 320 

CHEMTEX AT 166, TESAfilm 132, TESAfilm 659 

Material No. 05-015C (Refer to Chapter 51-35-00 ), 

3M-425 

Soft 

Very fine 

c1> Use only strippers that are permitted by your national regulations. 

NOTE: The quantity of stripper required should be enough for three applications. The stripper should be stored in 

accordance with the Manufacturer's data sheets before being used. 

D. Paint Stripping 

(1) Mask areas not to be stripped, and areas that must be protected against strippers with polyethylene film 

(CHEMTEX AT 166 or TESA film 132 or TESA film 659) and adhesive aluminum tape (Material No. 05-015C or 

3M-425). 

NOTE: External skin panel joints (except fuel tank areas) do not have to be masked if: 

- there are no bonded doublers in the joints, 

- the total time of stripper application is less than 4 hours. If masking is not used, the skin joint sealant 

beads have to be renewed (Refer to Chapter 51-76-00 ). 

WARNING: CLEANING AGENT (MATERIAL NO. 11-004 ) IS DANGEROUS. 

WARNING: CLEANING AGENT (MATERIAL NO. 11-003 ) IS DANGEROUS. 

WARNING: CLEANING AGENT (MATERIAL NO. 11-004 ) IS DANGEROUS. 

(2) Clean the area to be stripped with cleaning agent (Material No. 11-003 or 11-004 ) and a clean cloth. 

NOTE: Make sure that the cleaned surfaces to be stripped are perfectly dry before you start the next step. 

WARNING: STRIPPERS ARE DANGEROUS. 

(3) Apply a thick coat of stripper in accordance with the manufacturer's instructions. 

Print Date: July 16, 2010 Local Time Page 2 of 14 
AIRBUS 

Customer: ENV 

Type : A318/A319/A320/A321 

Rev. Date : February 1, 2010 

Manual: SRM_A320 

Selected effectivity: ALL 

51-75-11 - STRIPPING/PAINT REMOVAL (Revdate = May 01/06) 

NOTE: It is preferable to strip at temperatures above 20 ° C (68 ° F) but not in hot sunlight or rain. Below 18 ° C 

(64 ° F), the stripper takes much longer to react (up to twice as long). 

WARNING: STRIPPERS ARE DANGEROUS. 

(4) Within 30 minutes remove paint and stripper residues carefully with a soft plastic scraper. This will reduce the 

risk of damage to masking and the basic primer. 

WARNING: STRIPPERS ARE DANGEROUS. 

(5) If the top coat is only partially removed repeat steps 2.D.(3). and 2.0.(4). , but only in the areas where the paint 

was not removed. 

(a) Between the stripper applications, inspect and repair masking, if necessary, as described in step 2.0.(1). 

above. 

(b) Rinse carefully with a water hose, brush the surface and rinse again and let the surface dry. 

WARNING: CLEANING AGENT (MATERIAL NO. 11-003 ) IS DANGEROUS. 

WARNING: CLEANING AGENT (MATERIAL NO. 11-004 ) IS DANGEROUS. 

(6) After the last stripper application, clean with a clean cloth soaked in cleaning agent (Material No. 11 -003 or 11 -

004). 

(7) Remove all masking tape, films and plugs. 

WARNING: CLEANING AGENT (MATERIAL NO. 11-003 ) IS DANGEROUS. 

WARNING: CLEANING AGENT (MATERIAL NO. 11-004 ) IS DANGEROUS. 

(8) Inspect the areas that were masked for damaged paint and presence of stripper. Any stripper remaining must be 

removed with cleaning agent (Material No. 11-003 or 11-004 ) and a clean cloth. If the paint has been damaged, 

refer to step 2.D.(10). below. 

WARNING: CLEANING AGENT (MATERIAL NO. 11-003 ) IS DANGEROUS. 

WARNING: CLEANING AGENT (MATERIAL NO. 11-004 ) IS DANGEROUS. 

(9) Clean the exposed primer with cleaning agent (Material No. 11 -003 or 11 -004 ) and dry it with a clean cloth. 

(10) Mechanically lightly abrade areas that were masked during the stripping and which also require paint removal. 

Abrade also any remaining local spots of the old paint systems. Do this with emery cloth (grade 220 or 320). 

(11) Lightly abrade the stripped areas with SCOTCH-BRITE prior to repainting. 

WARNING: CLEANING AGENT (MATERIAL NO. 11-003 ) IS DANGEROUS. 

WARNING: CLEANING AGENT (MATERIAL NO. 11-004 ) IS DANGEROUS. 

(12) Clean the abraded area with cleaning agent (Material No. 11 -003 or 11 -004 ) and dry it with a clean cloth. 

(13) Repair the sealant beads as described in Chapters 51-76-11 and 51-76-12 . 

(14) For repainting the stripped area and 'touch up' of any damaged paint in adjacent areas, refer to Chapter 51 -23-

00 and Chapter 51-75-12 . 

3. Paint Removal by Abrasion 

Print Date: July 16, 2010 Local Time Page 3 of 14 
AIRBUS 

Customer: ENV 

Type : A318/A319/A320/A321 

Rev. Date : February 1, 2010 

Manual: SRM_A320 

Selected effectivity: ALL 

51-75-11 - STRIPPING/PAINT REMOVAL (Revdate = May 01/06) 

A. General 

(1) This procedure is used primarily on composite surfaces but could also be used on metal surfaces as an 

alternative to chemical stripping. 

(2) The purpose of this procedure is to remove the top coat partially or completely, but not to remove the basic 

primer (for the paint buildup, refer to Chapter 51-23-11 ). 

B. Safety Precautions 

WARNING: OBEY THE MANUFACTURER'S INSTRUCTIONS WHEN YOU USE THE CLEANING AGENTS 

(MATERIAL NO. 11-003 AND 11-004 ). THESE CLEANING AGENTS ARE DANGEROUS. 

CAUTION: MAKE SURE THAT THE MATERIAL SURFACES, ESPECIALLY COMPOSITES, ARE NOT DAMAGED 

WHEN ABRADING. 

CAUTION: ENSURE THAT ALL MASKING MATERIALS ARE REMOVED FROM THE REPAIR AREA ON 

COMPLETION OF WORK, PAY SPECIAL ATTENTION TO PITOT HEADS AND PORTS. 

C. Repair Materials 

ITEM 

1 

2 

3 

4 

5 

NOMENCLATURE 

Cleaning agent 

Clean cloth 

Emery cloth 

SCOTCH-BRITE 

Masking tape and paper 

QTY 

AR 

AR 

AR 

AR 

AR 

MATERIAL/REMARKS 

Material No. 11-003 or 11-004 (Refer to Chapter 51-

35_-50 ) 

Grade 320 

Very fine 

D. Paint Removal 

(1) Mask off the adjacent area, which will not be abraded, with masking tape and paper. 

(2) Lightly abrade the surface with emery cloth (grade 320) until the layer of primer is exposed. 

WARNING: CLEANING AGENT (MATERIAL NO. 11-003 ) IS DANGEROUS. 

WARNING: CLEANING AGENT (MATERIAL NO. 11-004 ) IS DANGEROUS. 

(3) Remove the abrasive grit, clean and degrease the surface with a clean cloth, soaked with cleaning agent 

(Material No. 11-003 or 11-004 ). 

(4) Lightly abrade the area with SCOTCH-BRITE prior to repainting. 

(5) Remove all masking paper. 

WARNING: CLEANING AGENT (MATERIAL NO. 11-003 ) IS DANGEROUS. 

WARNING: CLEANING AGENT (MATERIAL NO. 11-004 ) IS DANGEROUS. 

(6) Clean the abraded area with a clean cloth soaked with cleaning agent (Material No. 11-003 or 11-004 ). 

(7) Repair sealant beads as described in Chapter 51-76-11 and Chapter 51-76-12 . 

(8) For repainting the abraded area, refer to Chapter 51-23-00 and Chapter 51-75-12 . 

Print Date: July 16, 2010 Local Time Page 4 of 14 
AIRBUS 

Customer: ENV 

Type : A318/A319/A320/A321 

Rev. Date : February 1, 2010 

Manual: SRM_A320 

Selected effectivity: ALL 

51-75-11 - STRIPPING/PAINT REMOVAL (Revdate = May 01/06) 

(9) Inspect the areas, that were masked, for damaged paint. If the paint has been damaged repeat steps 3.0.(1). 

thru 3.0.(9). . 

4. One-Time Full Chemical Paint Stripping Procedure - Fuselage Metallic Structure Only - Acid Activated Paint Stripper 

A. General 

(1) The work consists of, through application of chemical strippers, removing the external paint system down to the 

basic primer (for the paint buildup, refer to Chapter 51-23-11 ). After preparation of the stripped surface, the new 

paint system will be applied. 

WARNING: STRUCTURE PAINT (MATERIAL NO. 16-020 ) IS DANGEROUS. 

WARNING: STRUCTURE PAINT (MATERIAL NO. 16-001 ) IS DANGEROUS. 

WARNING: STRUCTURE PAINT (MATERIAL NO. 16-018 ) IS DANGEROUS. 

(2) Acid activated paint stripper (Material No. 12-014) was formulated to strip 3 coats paint system (Material No. 16-

020 , 16-001 , 16-018 ) and 2 coats paint system (Material No. 16-059 and 16-060). 

(3) This procedure is limited to one-time stripping of fuselage only for each aircraft. Make sure that the maximum 

contact time allowed is not exceeded. Due to the aggressiveness of acid activated paint stripper it is possible 

that there may be a reduction of the corrosion protection therefore ensure that thorough rinsing is performed. 

B. Safety Precautions 

WARNING: OBEY THE MANUFACTURER'S INSTRUCTIONS WHEN YOU USE STRIPPERS. THE STRIPPERS ARE 

DANGEROUS. 

WARNING: OBEY THE MANUFACTURER'S INSTRUCTIONS WHEN YOU USE THE CLEANING AGENTS (MAT. 

NO. 11-003 AND 11-004 ). THESE CLEANING AGENTS ARE DANGEROUS. 

CAUTION: MAKE SURE THAT THE RUBBER, ALL COMPOSITE PARTS, ACRYLIC MATERIALS, AERODYNAMIC 

SMOOTHER, METAL BONDED EDGES, PITOT PROBES, SENSORS, STATIC PORTS, ENGINE AIR 

INTAKE, PRECOOLER AIR OUTLET SCREEN, ENGINE EXHAUST DUCT, APU EXHAUST, APU 

INTAKES AND OUTLETS, AIR CONDITIONING FRESH AIR INTAKE, LANDING GEARS, DOOR SEALS, 

ACCESS DOORS, CABIN WINDOW AND WINDSHIELD PANELS AND SEALS, ELECTRICAL 

EQUIPMENT AND CABLES, PLASTIC MATERIALS, EXTERNAL SKIN JOINTS, HIGH STRENGTH 

STEEL PARTS HEAT TREATED ABOVE 1400MPA, AVIONICS SKIN TEMPERATURE SENSOR (28HQ) 

SUPPORT EXTERNAL FACE AND BALL LOCK FITTINGS ARE PROPERLY PROTECTED AGAINST 

STRIPPERS BY MASKING. 

CAUTION: MAKE SURE THAT DRAIN HOLES AND VENTS ARE PROPERLY PROTECTED AGAINST STRIPPERS 

BY PLUGGING. 

CAUTION: MAKE SURE THAT THE PAINT STRIPPERS DO NOT COME IN CONTACT WITH TEFLON-LINED SELFLUBRICATED BEARINGS, ELECTRICAL TERMINAL PLUGS, NYLON-COATED WIRES AND NYLON 

BRUSHES. THE CHEMICALS IN THE PAINT STRIPPERS WILL ATTACK THESE ITEMS. 

CAUTION: ENSURE THAT ALL MASKING MATERIALS ARE REMOVED FROM THE REPAIR AREA ON 

COMPLETION OF WORK, PAY SPECIAL ATTENTION TO PITOT HEADS AND STATIC PORTS. 

CAUTIONl ENSURE THAT ROOMS FOR PAINT REMOVAL HAVE ADEQUATE VENTILATION 

C. Repair Materials 

Print Date: July 16, 2010 Local Time Page 5 of 14 
AIRBUS 

Customer: ENV 

Type : A318/A319/A320/A321 

Rev. Date : February 1, 2010 

Manual: SRM_A320 

Selected effectivity: ALL 

51-75-11 - STRIPPING/PAINT REMOVAL (Revdate = May 01/06) 

ITEM 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

NOMENCLATURE 

Stripper 

Cleaning agent 

Clean white cloth 

Synthetic sponge 

Emery cloth 

Polyethylene film 

Adhesive aluminum tape 

Masking paper 

Plastic scraper 

SCOTCH-BRITE 

Brush 

Cleaning agent 

QTY 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

MATERIAL/REMARKS 

Material No. 12-014 (Refer to Chapter 51-35-00 ) 

<1> 

Material No. 11-003 or 11-004 (Refer Chapter 51-35-

00) 

Grade 220 or 320 

CHEMTEX AT 166, TESA film 132, TESA film 659 

Material No. 05-015C or 08-052 (Refer to Chapter 

51-35-00 ), 3M-425 

KRAFT Paper Tape 

Soft 

Very fine 

Suitable for application type strippers 

Material No. 11-001 (Refer to Chapter 51-35-00) 

<1> Use only strippers that are permitted by your national regulations. 

NOTE: The quantity of stripper required should be enough for two applications. The stripper should be stored in 

accordance with the manufacturer's data sheets before being used. 

D. Paint Stripping 

WARNING: CLEANING AGENT (MATERIAL NO. 11-001 ) IS DANGEROUS. 

(1) Depending on the degree of contamination clean the area to be stripper with cleaning agent (Material No. 11-

001 ), refer to AMM Chapter 12-21-11-301. Wet surfaces must be dried. 

NOTE: Make sure that the cleaned surfaces to be stripped are perfectly dry before you start the next step. 

WARNING: BONDING AND ADHESIVE COMPOUND (MATERIAL NO. 08-052 ) IS DANGEROUS. 

(2) Mask areas not to be stripped, and areas that must be protected against strippers with polyethylene film 

(CHEMTEX AT 166 or TESA film 132 or TESA film 659) and adhesive aluminum tape (Material No. 05-015C or 

08-052). 

NOTE: External skin panel joints (except fuel tank areas) do not have to be masked if there are no bonded doublers 

in the joints. If masking is not used, the skin joint sealant beads can be damaged and have to be renewed 

(Refer to Chapter 51-76-00). 

NOTE: Check that all repairs made with high strength steel fasteners (heat treated above 1400Mpa) are protected. 

WARNING: STRIPPERS ARE DANGEROUS. 

(3) Apply a thick uniform coat of stripper (Material No. 12-014 with a non-atomizing spray or with a brush in 

accordance with manufacturer's instructions. 

NOTE: The skin surface temperature must not exceed 30 C ° (86 F °). Do not heat the skin with the stripper using 

an air blower in the direction of the surface to be stripped. It is preferable to strip at temperatures above 20 

C ° (68 F ° ) but not in hot sunlight or rain. Below 18 C ° (64 F ° ) takes much longer to react and becomes 

inefficient. 

WARNING: STRIPPERS ARE DANGEROUS. 

Print Date: July 16, 2010 Local Time Page 6 of 14 
AIRBUS 

Customer: ENV 

Type : A318/A319/A320/A321 

Rev. Date : February 1, 2010 

Manual: SRM_A320 

Selected effectivity: ALL 

51-75-11 - STRIPPING/PAINT REMOVAL (Revdate = May 01/06) 

(4) Within 8 to 12 hours or sooner if the paint have loosened, remove stripper and paint residues with a soft plastic 

scraper. This will reduce the risk of damage to basic primer and the stripper will not dry on the surface. 

WARNING: STRIPPERS ARE DANGEROUS. 

(5) If the external paint system is only partially removed repeat one time only steps 4.0.(3). and 4.D.(4)., but only in 

the areas where the paint was not removed. 

(a) Between the stripper applications, inspect and repair masking, if necessary, as described in step 4JD^2)^ 

above. 

(b) Optional: between the stripper applications rinse carefully as described in 4.0.(6)., let the surface dry and 

reapply the stripper. 

NOTE: Make sure that the total application time does not exceed 24 hours. 

(6) After the last stripper application, rinse carefully the surface, to completely remove paint and stripper residues 

and to neutralize the stripped areas. Use one of the following procedures: 

WARNING: CLEANING AGENT (MATERIAL NO. 11-001 ) IS DANGEROUS. 

(a) Preferred procedure: 

- clean difficult areas with water and SCOTCH-BRITE, rinse carefully the stripped areas with cold or warm 

water up to 65 C ° (149 F ° ) with a water hose (pressure limited to 6 bar (87 psi)) or a water high 

pressure cleaner (pressure max. 50 bar (725.7 psi), distance/angle nozzle/part 250 mm (9.84 in.)min. 

and not at 90 ° ) then rinse with cleaning agent (Material No. 11-001 ) according to AMM Chapter 12-21-

11 -301. Let the surface dry. 

(b) Alternative procedure: 

- clean difficult areas with water and SCOTCH-BRITE, rinse carefully the stripped areas with water up to 

65 C ° (149 F ° ) with a water hose (pressure limited to 6 bar (87 psi) or a water high pressure cleaner 

(pressure max. 50 bar (725.7 psi), distance/angle nozzle/part 250 mm (9.84 in.)min. and not at 90 ° ), 

rinsing is finished when the spent water reaches a neutral ph of 7. Let the surface dry. 

(7) Remove all masking tape, films and plugs. 

(8) Inspect the areas that were stripped for any damage or corrosion. 

(9) Inspect the areas that were masked for damaged paint and presence of stripper. Any stripper remaining must be 

removed with a clean cloth or sponge dampened with water. If the paint has been damaged, refer to step 4.D. 

(11). below. 

WARNING: CLEANING AGENT (MATERIAL NO. 11-003 ) IS DANGEROUS. 

WARNING: CLEANING AGENT (MATERIAL NO. 11-004 ) IS DANGEROUS. 

(10) Clean the exposed primer with cleaning agent (Material No. 11 -003 or Material No. 11 -004 ) and dry it with a 

clean cloth. 

(11) Mechanically lightly abrade areas that were masked during the stripping and which also require paint removal. 

Abrade also any remaining local spots of the old paint systems. Do this with emery cloth (grade 220 or 320). 

(12) Lightly abrade the stripped areas with SCOTCH-BRITE prior to repainting. 

WARNING: CLEANING AGENT (MATERIAL NO. 11-003 ) IS DANGEROUS. 

WARNING: CLEANING AGENT (MATERIAL NO. 11-004 ) IS DANGEROUS. 

Print Date: July 16, 2010 Local Time Page 7 of 14 
AIRBUS 

Customer: ENV 

Type : A318/A319/A320/A321 

Rev. Date : February 1, 2010 

Manual: SRM_A320 

Selected effectivity: ALL 

51-75-11 - STRIPPING/PAINT REMOVAL (Revdate = May 01/06) 

(13) Clean the abraded area with cleaning agent (Material No. 11 -003 or Material No. 11 -004 ) and dry it with a 

clean cloth. 

(14) Repair the sealant beads as described in Chapters 51-76-11 and 51-76-12 . 

(15) For repainting the stripped area and 'touch up' of any damaged paint in adjacent areas, refer to Chapter 51-23-

00 and Chapter 51-75-12 . 

(16) Record the stripping operation. 

5. Chemical Paint Stripping Procedure - Fuselage Metallic Structure Only - Hydrogen Peroxide based Paint Stripper 

A. General 

(1) The work consists of, through application of chemical strippers, removing the external paint system down to the 

basic primer (for the paint buildup, refer to Chapter 51-23-11 ). After preparation of the stripped surface, the new 

paint system will be applied. 

WARNING: STRUCTURE PAINT (MATERIAL NO. 16-020 ) IS DANGEROUS. 

WARNING: STRUCTURE PAINT (MATERIAL NO. 16-001 ) IS DANGEROUS. 

WARNING: STRUCTURE PAINT (MATERIAL NO. 16-018 ) IS DANGEROUS. 

(2) Hydrogen peroxide based paint stripper (Material No. 12-015 ) formulated to strip 2 coats paint system (Material 

No. 16-049 and 16-048 ) or (Material No. 16-060 and 16-059 ), can be used also for 3 coats paint system 

(Material No. 16-020 , 16-001 , 16-018 ). 

(3) Due to the agressiveness of hydrogen peroxide based paint stripper it is possible that there may be a reduction 

of the corrosion protection therefore ensure that thorough rinsing is performed. 

B. Safety Precautions 

WARNING: OBEY THE MANUFACTURER'S INSTRUCTIONS WHEN YOU USE STRIPPERS. THE STRIPPERS ARE 

DANGEROUS. 

WARNING: OBEY THE MANUFACTURER'S INSTRUCTIONS WHEN YOU USE THE CLEANING AGENTS (MAT. 

NO. 11-003 AND 11-004 ). THESE CLEANING AGENTS ARE DANGEROUS. 

CAUTION: MAKE SURE THAT THE RUBBER, ALL COMPOSITE PARTS, ACRYLIC MATERIALS, AERODYNAMIC 

SMOOTHER, METAL BONDED EDGES, PITOT PROBES, SENSORS, STATIC PORTS, ENGINE AIR 

INTAKE, PRECOOLER AIR OUTLET SCREEN, ENGINE EXHAUST DUCT, APU EXHAUST, APU 

INTAKES AND OUTLETS, AIR CONDITIONING FRESH AIR INTAKE, LANDING GEARS, DOOR SEALS, 

ACCESS DOORS, CABIN WINDOW AND WINDSHIELD PANELS AND SEALS, ELECTRICAL 

EQUIPMENT AND CABLES, PLASTIC MATERIALS, EXTERNAL SKIN JOINTS, HIGH STRENGTH 

STEEL PARTS HEAT TREATED ABOVE 1400MPA, AVIONICS SKIN TEMPERATURE SENSOR (28HQ) 

SUPPORT EXTERNAL FACE 

CAUTION: MAKE SURE THAT DRAIN HOLES AND VENTS ARE PROPERLY PROTECTED AGAINST STRIPPERS 

BY PLUGGING. 

CAUTION: MAKE SURE THAT THE PAINT STRIPPERS DO NOT COME IN CONTACT WITH TEFLON-LINED SELFLUBRICATED BEARINGS, ELECTRICAL TERMINAL PLUGS, NYLON-COATED WIRES AND NYLON 

BRUSHES. THE CHEMICALS IN THE PAINT STRIPPERS WILL ATTACK THESE ITEMS. 

CAUTION: ENSURE THAT ALL MASKING MATERIALS ARE REMOVED FROM THE REPAIR AREA ON 

COMPLETION OF WORK, PAY SPECIAL ATTENTION TO PITOT HEADS AND STATIC PORTS. 

Print Date: July 16, 2010 Local Time Page 8 of 14 
AIRBUS 

Customer: ENV 

Type : A318/A319/A320/A321 

Rev. Date : February 1, 2010 

Manual: SRM_A320 

Selected effectivity: ALL 

51-75-11 - STRIPPING/PAINT REMOVAL (Revdate = May 01/06) 

CAUTION: ENSURE THAT ROOMS FOR PAINT REMOVAL HAVE ADEQUATE VENTILATION 

CAUTION: ENSURE THAT PERSONNEL WEAR SUITABLE PROTECTIVE CLOTHING, GLOVES AND EYE/FACE 

PROTECTION AND RESPIRATORY PROTECTION 

C. Repair Materials 

ITEM 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

NOMENCLATURE 

Stripper 

Cleaning agent 

Clean white cloth 

Synthetic sponge 

Emery cloth 

Polyethylene film 

Adhesive aluminum tape 

Masking paper 

Plastic scraper 

SCOTCH-BRITE 

Brush 

Cleaning agent 

QTY 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

MATERIAL/REMARKS 

Material No. 12-015 (Refer to Chapter 51-35-00 ) 

<1> 

Material No. 11-003 or 11-004 (Refer Chapter 51-35-

00) 

Grade 220 or 320 

CHEMTEX AT 166, TESAfilm 132, TESAfilm 659 

Material No. 05-015C or 08-052 (Refer to Chapter 

51-35-00). 3M-425 

KRAFT Paper Tape 

Soft 

Very fine 

Suitable for application type strippers 

Material No. 11-001 (Refer to Chapter 51-35-00) 

<1> Use only strippers that are permitted by your national regulations. 

NOTE: The stripper should be stored in accordance with the manufacturer's data sheets before being used. 

D. Paint Stripping 

WARNING: CLEANING AGENT (MATERIAL NO. 11-001 ) IS DANGEROUS. 

(1) Depending on the degree of contamination clean the area to be stripper with cleaning agent (Material No. 11-

001 ), refer to AMM Chapter 12-21-11-301. Wet surfaces must be dried. 

NOTE: Make sure that the cleaned surfaces to be stripped are perfectly dry before you start the next step. 

WARNING.: BONDING AND ADHESIVE COMPOUND (MATERIAL NO. 08-052 ) IS DANGEROUS. 

(2) Mask areas not to be stripped, and areas that must be protected against strippers with polyethylene film 

(CHEMTEX AT 166 or TESA film 132 or TESA film 659) and adhesive aluminum tape (Material No. 05-015C or 

08-052 ). Mask all cadmium plated steel fasteners using aluminum tape (Material No. 05-015C 08-052). Contact 

AIRBUS for detection procedure and localisation. 

NOTE: External skin panel joints (except fuel tank areas) do not have to be masked if there are no bonded doublers 

in the joints. If masking is not used, the skin joint sealant beads can be damaged and have to be renewed 

(Refer to Chapter 51-76-00). 

NOTE: Check that all repairs made with high strength steel fasteners (heat treated above 1400Mpa) are protected. 

WARNING: STRIPPERS ARE DANGEROUS. 

Print Date: July 16, 2010 Local Time Page 9 of 14 
AIRBUS 

Customer: ENV 

Type : A318/A319/A320/A321 

Rev. Date : February 1, 2010 

Manual: SRM_A320 

Selected effectivity: ALL 

51-75-11 - STRIPPING/PAINT REMOVAL (Revdate = May 01/06) 

(3) Apply a thick uniform coat of stripper (Material No. 12-015 with a non-atomizing spray or with a brush in 

accordance with manufacturer's instructions. 

NOTE: The skin surface temperature must not exceed 30 C ° (86 F °). Do not heat the skin with the stripper using 

an air blower in the direction of the surface to be stripped. It is preferable to strip at temperatures above 20 

C ° (68 F ° ) but not in hot sunlight or rain. Below 18 C ° (64 F ° ) takes much longer to react and becomes 

inefficient. 

WARNING: STRIPPERS ARE DANGEROUS. 

(4) Within 8 to 12 hours or sooner if the paint have loosened, remove stripper and paint residues with a soft plastic 

scraper. This will reduce the risk of damage to basic primer and the stripper will not dry on the surface. 

WARNING: STRIPPERS ARE DANGEROUS. 

(5) If the external paint system is only partially removed repeat steps 5.0.(3). and 5.D.(4)., but only in the areas 

where the paint was not removed between the stripper applications, inspect and repair masking, if necessary, as 

described in step 5.0.(2). above. 

WARNING: CLEANING AGENT (MATERIAL NO. 11-001 ) IS DANGEROUS. 

(6) After the last stripper application, rinse carefully the surface, to completely remove paint and stripper residues. 

Clean difficult areas with water and SCOTCH-BRITE, rinse carefully the stripped areas with cold or warm water 

up to 65 C ° (149 F "^) with a water hose (pressure limited to 6 bar (87 psi) or a water high pressure cleaner 

(pressure max. 50 bar (725.7 psi), distance/angle nozzle/part 250 mm (9.84 in.)min. and not at 90 ° ), then as an 

option rinse with with cleaning agent (Material No. 11-001 ) according to AMM Chapter 12-21-11-301. Let the 

surface dry. 

(7) Remove all masking tape, films and plugs. 

(8) Inspect the areas that were stripped for any damage or corrosion. 

(9) Inspect the areas that were masked for damaged paint and presence of stripper. Any stripper remaining must be 

removed with a clean cloth or sponge dampened with water. If the paint has been damaged, refer to step 5.D. 

(11), below. 

WARNING: CLEANING AGENT (MATERIAL NO. 11-003 ) IS DANGEROUS. 

WARNING: CLEANING AGENT (MATERIAL NO. 11-004 ) IS DANGEROUS. 

(10) Clean the exposed primer with cleaning agent (Material No. 11-003 or Material No. 11-004 ) and dry it with a 

clean cloth. 

(11) Mechanically lightly abrade areas that were masked during the stripping and which also require paint removal. 

Abrade also any remaining local spots of the old paint systems. Do this with emery cloth (grade 220 or 320). 

(12) Lightly abrade the stripped areas with SCOTCH-BRITE prior to repainting. 

WARNING: CLEANING AGENT (MATERIAL NO. 11-003 ) IS DANGEROUS. 

WARNING: CLEANING AGENT (MATERIAL NO. 11-004 ) IS DANGEROUS. 

(13) Clean the abraded area with cleaning agent (Material No. 11 -003 or Material No. 11 -004 ) and dry it with a 

clean cloth. 

(14) Repair the sealant beads as described in Chapters 51-76-11 and 51-76-12 . 

(15) For repainting the stripped area and 'touch up' of any damaged paint in adjacent areas, refer to Chapter 51-23-

Print Date: July 16, 2010 Local Time Page 10 of 14 
AIRBUS 

Customer: ENV 

Type : A318/A319/A320/A321 

Rev. Date : February 1, 2010 

Manual: SRM_A320 

Selected effectivity: ALL 

51-75-11 - STRIPPING/PAINT REMOVAL (Revdate = May 01/06) 

00 and Chapter 51-75-12 . 

6. Chemical Paint Stripping Procedure - Metallic Structure Only - Alkaline Benzyl Alcohol based Paint Stripper -

Intermediate Coat Paint System 

A. General 

(1) The work consists of, through application of chemical strippers, removing the external paint system down to the 

primer (for the paint buildup, refer to Chapter 51-23-11 ). After preparation of the stripped surface, the new paint 

system will be applied. 

WARNING: STRUCTURE PAINT (MATERIAL NO. 16-006B ) IS DANGEROUS. 

(2) Paint Stripper (Material No. 12-013) was formulated to strip intermediate coat paint system (Material No. 16-

006B , 16-062 and 16-059 ). This stripper allows stripping of top coat and intermediate coat without stripping the 

primer. 

(3) The entire fuselage can be treated at the same time or divided in sections. If paint stripper (Material No. 12-013) 

intends to dry, keep the surface wet by applying a light coat of stripper over the existing layer of stripper. 

B. Safety Precautions 

WARNING: OBEY THE MANUFACTURER'S INSTRUCTIONS WHEN YOU USE STRIPPERS. THE STRIPPERS ARE 

DANGEROUS. 

WARNING: OBEY THE MANUFACTURER'S INSTRUCTIONS WHEN YOU USE THE CLEANING AGENTS (MAT. 

NO. 11-003 AND 11-004 ). THESE CLEANING AGENTS ARE DANGEROUS. 

CAUTION: MAKE SURE THAT THE RUBBER, ALL COMPOSITE PARTS, ACRYLIC MATERIALS, AERODYNAMIC 

SMOOTHER, METAL BONDED EDGES, PITOT PROBES, SENSORS, STATIC PORTS, ENGINE AIR 

INTAKE, PRECOOLER AIR OUTLET SCREEN, ENGINE EXHAUST DUCT, APU EXHAUST, APU 

INTAKES AND OUTLETS, AIR CONDITIONING FRESH AIR INTAKE, LANDING GEARS, DOOR SEALS, 

ACCESS DOORS, CABIN WINDOW AND WINDSHIELD PANELS AND SEALS, ELECTRICAL 

EQUIPMENT AND CABLES, PLASTIC MATERIALS, EXTERNAL SKIN JOINTS, HIGH STRENGTH 

STEEL PARTS HEAT TREATED ABOVE 1400MPA, AVIONICS SKIN TEMPERATURE SENSOR (28HQ) 

SUPPORT EXTERNAL FACE 

CAUTION: MAKE SURE THAT DRAIN HOLES AND VENTS ARE PROPERLY PROTECTED AGAINST STRIPPERS 

BY PLUGGING. 

CAUTION: MAKE SURE THAT THE PAINT STRIPPERS DO NOT COME IN CONTACT WITH TEFLON-LINED SELFLUBRICATED BEARINGS, ELECTRICAL TERMINAL PLUGS, NYLON-COATED WIRES AND NYLON 

BRUSHES. THE CHEMICALS IN THE PAINT STRIPPERS WILL ATTACK THESE ITEMS. 

CAUTION: ENSURE THAT ALL MASKING MATERIALS ARE REMOVED FROM THE REPAIR AREA ON 

COMPLETION OF WORK, PAY SPECIAL ATTENTION TO PITOT HEADS AND STATIC PORTS. 

CAUTION: ENSURE THAT ROOMS FOR PAINT REMOVAL HAVE ADEQUATE VENTILATION 

C. Repair Materials 

ITEM 

1 

2 

NOMENCLATURE 

Stripper 

Cleaning agent 

QTY 

AR 

AR 

AR 

MATERIAL/REMARKS 

Material No. 12-013 (Refer to Chapter 51-35-00 ) 

<1> 

Material No. 11-003 or 11-004 (Refer Chapter 51-35-

00) 

Print Date: July 16, 2010 Local Time Page 11 of 14 
AIRBUS 

Customer: ENV 

Type : A318/A319/A320/A321 

Rev. Date : February 1, 2010 

Manual: SRM_A320 

Selected effectivity: ALL 

51-75-11 - STRIPPING/PAINT REMOVAL (Revdate = May 01/06) 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

Clean white cloth 

Synthetic sponge 

Emery cloth 

Polyethylene film 

Adhesive aluminum tape 

Masking paper 

Plastic scraper 

SCOTCH-BRITE 

Brush 

Cleaning agent 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

AR 

Grade 220 or 320 

CHEMTEX AT 166, TESA film 132, TESA film 659 

Material No. 05-015C or 08-052 (Refer to Chapter 

51-35-00). 3M-425 

KRAFT Paper Tape 

Soft 

Very fine 

Suitable for application type strippers 

Material No. 11-001 (Refer to Chapter 51-35-00) 

<1> Use only strippers that are permitted by your national regulations. 

NOTE: The stripper should be stored in accordance with the manufacturer's data sheets before being used. 

D. Paint Stripping 

WARNING: CLEANING AGENT (MATERIAL NO. 11-001 ) IS DANGEROUS. 

(1) Depending on the degree of contamination clean the area to be stripper with cleaning agent (Material No. 

(Material No. 11-001 ), refer to AMM Chapter 12-21-11-301. Wet surfaces must be dried. 

NOTE: Make sure that the cleaned surfaces to be stripped are perfectly dry before you start the next step. 

WARNING: BONDING AND ADHESIVE COMPOUND (MATERIAL NO. 08-052 ) IS DANGEROUS. 

(2) Mask areas not to be stripped, and areas that must be protected against strippers with polyethylene film 

(CHEMTEX AT 166 or TESA film 132 or TESA film 659) and adhesive aluminum tape (Material No. 05-015C or 

08-052 ). 

NOTE: External skin panel joints (except fuel tank areas) do not have to be masked if there are no bonded doublers 

in the joints. 

WARNING: STRIPPERS ARE DANGEROUS. 

(3) Apply a thick closed uniform coat of stripper (Material No. 12-013 ) with a non-atomizing spray or with a brush in 

accordance with manufacturer's instructions. 

NOTE: It is recommended to apply paint stripper (Material No. 12-013) by spraying using airless pump with 10:1 

ratio and spray nozzle creating a wide fan type spraying pattern. 

NOTE: The skin surface temperature mut not exceed 35 C " (95 F °). It is preferable to strip at temperatures above 

20 C ° (68 F ° ) but not in hot sunlight or rain. Below 18 C ° (64 F ° ) it takes much longer to react. 

(4) Allow to dwell for sufficient time to lift the paint. Typically starts to react after 1 to 2 hours with standard thin top 

coat but less than 10 hours when paint has loosened. Remove stripper and paint residues with a soft plastic 

scraper (ensure not to rebond the residues on the surface with the scraper). 

NOTE: Do not use metallic scraper. 

NOTE: Keep the surface wet if stripper intends to dry by reapplying a mist coat of stripper. Stripper tends to dry as 

the solvent reacts with the interdediate coat. 

NOTE: An excessive application time (superior to 20 hours) may degrade the primer. 

Print Date: July 16, 2010 Local Time Page 12 of 14 
AIRBUS 

Customer: ENV 

Type : A318/A319/A320/A321 

Rev. Date : February 1, 2010 

Manual: SRM_A320 

Selected effectivity: ALL 

51-75-11 - STRIPPING/PAINT REMOVAL (Revdate = May 01/06) 

(5) If the external paint system is only partially removed and to ensure that ail intermediate coat has been removed, 

repeat steps 6.D.(3). and 6.D.(4). . In the areas where the paint was not removed between the stripper 

applications, inspect and repair masking, if necessary, as described in step 6.D.(2). above. 

WA_RNING: CLEANING AGENT (MATERIAL NO. 11-001 ) IS DANGEROUS. 

(6) After the last stripper application, rinse carefully the surface, to completely remove paint and stripper residues. 

Clean difficult areas with water and SCOTCH-BRITE, rinse carefully the stripped areas with cold or warm water 

up to 65 C ° (149 F ° ) with a water hose (pressure limited to 6 bar (87 psi) or a water high pressure cleaner 

(pressure max. 50 bar (725.7 psi), distance/angle nozzle/part 250 mm (9.84 in.) min. and not at 90 °), then as 

an option rinse with with cleaning agent (Material No. 11-001 ) according to AMM Chapter 12-21-11-301. Let the 

surface dry. 

(7) Remove all masking tape, films and plugs. 

(8) Inspect the areas that were stripped. 

(9) Inspect the areas that were masked for damaged paint and presence of stripper. Any stripper remaining must be 

removed with a clean cloth or sponge dampened with water. If the paint has been damaged, refer to step 6.D. 

(XIX below. 

WARNING: CLEANING AGENT (MATERIAL NO. 11-003 ) IS DANGEROUS. 

WARNING: CLEANING AGENT (MATERIAL NO. 11-004 ) IS DANGEROUS. 

(10) Clean the exposed primer with cleaning agent (Material No. 11 -003 or Material No. 11 -004 ) and dry it with a 

clean cloth. 

(11) Mechanically lightly abrade areas that were masked during the stripping and which also require paint removal. 

Abrade also any remaining local spots of the old paint systems. Do this with emery cloth (grade 220 or 320). 

(12) Lightly abrade the stripped areas with SCOTCH-BRITE prior to repainting. 

WARNING: CLEANING AGENT (MATERIAL NO. 11-003 ) IS DANGEROUS. 

WARNING: CLEANING AGENT (MATERIAL NO. 11-004 ) IS DANGEROUS. 

(13) Clean the abraded area with cleaning agent (Material No. 11 -003 or Material No. 11 -004 ) and dry it with a 

clean cloth. 

(14) After paint stripping any exposed sealant i.e. not covered with primer, is considered as damaged. Repair any 

damaged sealant beads as described in Chapter 51-76-11 and 51-76-12 . 

(15) For repainting the stripped area and 'touch up' of any damaged paint in adjacent areas, refer to Chapter 51-23-

OQ and Chapter 51-75-12 . 

Print Date: July 16, 2010 Local Time Page 13 of 14 
AIRBUS 

Customer: ENV 

Type : A318/A319/A320/A321 

Rev. Date : February 1, 2010 

Manual: SRM_A320 

Selected effectivity: ALL 

51-75-11 - STRIPPING/PAINT REMOVAL (Revdate = May 01/06) 

P 

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x\ 

'• } 

' • \ 

Figure 001 (sheet 1) Protected cutting procedure 

Print Date: July 16, 2010 Local Time Page 14 of 1