FAA recently published a 41-page advisory circular intended to clarify the new SDR rule, which was supposed to go into effect this past January. But public protest over the rule convinced FAA to push the effective date back six months. Industry's main complaint was that a huge increase in the amount of data being requested would not clearly translate into tangible safety benefits. Industry believed that FAA's demands for mounds of data would force major changes to current internal reporting systems, resulting in significantly increased administrative costs that would continue to be high as more manpower was dedicated to meeting the agency's requirements.
Carriers remain puzzled over apparent conflicts within the rule.
In one paragraph there is language that calls for collecting SDR data on structural failures or defects that may be a hazard to the safe operation of the aircraft. The criteria for reporting behind each of these statements is quite different and can easily lead to inconsistent practices. Under the rule as written, every clip, bracket, and standoff that is replaced because of crack or corrosion will have to be reported. Northwest echoed Evergreen's complaints, saying that FAA's language seems to call for even the most routine failures, such as actuator leaks uncovered during testing, be considered SDR candidates. Normal degradation on actuator seals will produce a failure at some point in the life of an actuator.