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  3. NTSB A-04-028
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NTSB · Safety Recommendation

Safety Recommendation A-04-028

Recommendation

TO THE FEDERAL AVIATION ADMINISTRATION: Require the installation of carbon monoxide (CO) detectors meeting the standards developed as a result of Safety Recommendation A-04-27 in all single-engine reciprocating-powered airplanes with forward-mounted engines and enclosed cockpits that are already equipped with any airplane system needed for the operation of such a CO detector.

Safety Issue and Context

On December 17, 2000, about 1821 central standard time, a Beech BE-23, N2324J, impacted hilly, wooded terrain en route from Spirit of St. Louis Airport (SUS), Chesterfield, Missouri, to Tulsa, Oklahoma.1 The commercial-rated pilot, the sole occupant of the airplane, was killed, and the airplane was destroyed. Radar data indicate that about 1 hour after its departure from SUS, the airplane’s heading and altitude became erratic. Between 1809 and 1821, the airplane descended from 8,500 feet mean sea level (msl) to 2,500 feet msl, and its flightpath was a series of irregular descending turns in an easterly direction. The last radar return was about 0.5 mile from the accident site.

Visual meteorological conditions prevailed, and no flight plan was filed for the 14 Code of Federal Regulations (CFR) Part 91 flight.

Response History

December 1, 2020 · NTSB Correspondence · FAA

Location: Guthrie Center, Iowa Accident Number: WPR19FA022 Date & Time: November 9, 2018, 17:15 Registration: N91770 Aircraft: Piper PA28 Aircraft Damage: Substantial Defining Event: Powerplant sys/comp malf/fail Injuries: 4 Fatal Flight Conducted Under: Part 91: General aviation

Analysis

About 45 minutes into the cross-country flight, the student pilot passenger reported to air traffic control that the pilot was having a heart attack and that he was going to take control of the airplane and divert to an airport about 20 miles away; however, another airport was much closer, and controllers received no further communications from the pilot. The student then reported over the nearby airport’s common traffic advisory frequency that he would attempt to divert there. GPS flight track data indicated that, a short time later, the airplane began to fly in an erratic manner, climbing and descending over the area of the diversion airport.

The airplane subsequently collided with terrain in a wings-level attitude.

All four occupants sustained fatal injuries, and toxicology testing indicated that all had high levels of carboxyhemoglobin, which is caused by the inhalation of carbon monoxide (CO), an odorless, tasteless, colorless, nonirritating gas formed by hydrocarbon combustion. Levels in both pilots and one passenger where high enough to have caused confusion, seizures, or loss of consciousness. There was no evidence the pilot had a heart attack, so his symptoms were likely due to the CO poisoning.

The engine was equipped with three identical exhaust mufflers. Examination of the aft muffler revealed a crack that allowed engine exhaust gases to enter the cabin through the cabin heating system.

The muffler’s crack developed as a result of corrosion and thinning of the muffler wall. The crack and small perforations in the muffler wall were likely present at the time of the last inspection, which occurred shortly before the accident; however, due to damage from impact, it could not be determined if the extent of cracking was readily visible at the time of inspection. Also, the crack could have opened just before the accident flight due to an engine backfire that occurred during startup.

Use of a pressure check during an inspection could help identify cracks and small perforations that can be obscured by oxides and deposits during a visual inspection; however, the manufacturer's service manual only recommended a pressure check when a visual inspection could not be accomplished.

July 5, 2011 · NTSB Correspondence · FAA

The FAA indicated that, as the proper inspection and maintenance of mufflers and exhaust system components is the primary method of preventing CO contamination, installing a CO detector is not necessary to correct an unsafe condition as defined by 14 CFR Part 39. Accordingly, the FAA does not plan to require the installation of such devices in all single-engine reciprocating-powered airplanes with forward-mounted engine and enclosed cockpits, as recommended.

Although SAIB CE-10-19 R1 recommends that owners and operators of these aircraft review the FAA’s technical report and also use a CO detector while operating their aircraft, the NTSB does not believe that issuance of the SAIB alone is satisfactory. Accordingly, because the FAA indicated that its actions in response to this recommendation are complete, Safety Recommendation A-04-28 is classified CLOSED—UNACCEPTABLE ACTION.

January 20, 2011 · Recipient Response · FAA

CC# 201100035: - From J. Randolph Babbitt, Administrator: FAA report DOI/FAAIAR-09/49 states, "Placing a suitable CO detector at the instrument panel would serve as the secondary prevention method to further prevent CO exposure" and "that CO contamination in the cabin is primarily a consequence of inadequate maintenance and inspection of exhaust systems." We agree that CO detectors provide an additional layer of protection for those who fly on general aviation aircraft. However, the primary prevention method is the proper inspection and maintenance of mufflers and exhaust system components.

Since the lack of a CO detector alone is not unsafe, installing a CO detector is not necessary to correct an unsafe condition as defined by 14 CFR Part 39. However we are promoting the purchase, installation, and use of CO detectors. We published SAIB CE-l 0-19 RI recommending owners and operators of general aviation aircraft consider the information in the technical report and use a CO detector while operating their aircraft. I believe that the FAA has effectively addressed these safety recommendations, and I consider our actions complete.

June 11, 2009 · NTSB Correspondence · FAA

The NTSB notes that to mandate installation of CO detectors, the FAA must first determine that an unsafe condition exists. Once the FAA’s evaluation is complete, it will determine the resulting action that needs to be taken. Pending completion of the FAA’s evaluation and its taking the recommended action, Safety Recommendation A-04-28 remains classified OPEN -- ACCEPTABLE RESPONSE.

May 15, 2008 · Recipient Response · FAA

Letter Mail Controlled 5/28/2008 10:53:40 AM MC# 2080270: - From Robert A. Sturgell, Acting Administrator: Through the research described in our response to Safety Recommendation A-04-26, we will pursue engineering guidance for proper installation procedures for carbon monoxide detectors meeting FAA TSO C-48, Carbon Monoxide Detector Instruments. The ongoing research project includes development of a streamlined method of installing carbon monoxide detectors meeting TSO C-48 in general aviation products and possible regulatory considerations for carbon monoxide detectors. The technical report from this research is scheduled to be completed by the end of 2008.

When this research is completed, the FAA will determine if a change to 14 CFR Part 23 is necessary to mandate installation of CO detectors as required equipment on newly designed aircraft. The FAA will also determine the need for airworthiness directive action if an unsafe condition exists with any specific type design in the existing general aviation fleet. I will keep the Board informed of the FAA’s progress on this safety recommendation.

April 7, 2005 · NTSB Correspondence · FAA

The Safety Board notes that to mandate installation of CO detectors, the FAA must first determine that an unsafe condition exists. The FAA is currently conducting this evaluation and will determine the resulting action that needs to be taken. Pending completion of the FAA's evaluation and the FAA's taking the recommended action, Safety Recommendation A-04-28 is classified OPEN -- ACCEPTABLE RESPONSE.

September 9, 2004 · Recipient Response · FAA

Letter Mail Controlled 9/16/2004 1:07:32 PM MC# 2040566 - From Marion C. Blakey, Administrator: Mandating installation of carbon monoxide detectors in all single-engine reciprocating-powered airplanes would require either rulemaking or an airworthiness directive. The FAA is conducting an investigation to determine if an unsafe condition exists and what action needs to be implemented. I will inform the Board of the FAA's proposed actions to address these recommendations once the evaluation is completed.

Read Recommendation

Recommendation Facts

Status
Closed - Unacceptable Action
Issued
June 24, 2004
Priority
CLASS II
Recipient
FAA
Adopted
February 27, 2004
Closed
July 5, 2011
Related Investigation
CHI01FA052
Related Report
None

The manufacturer and Federal Aviation Administration (FAA) both recommended that the mufflers be replaced at or near 1,000 hours time in service (TIS). Although maintenance records revealed that three mufflers were replaced over the previous 27 years, the records did not indicate if the cracked muffler was one of those that had been replaced. Review of the available records indicated that the cracked muffler likely had at least 752 hours TIS, but due to missing records, it could have had over 1,033 hours TIS. Additionally, one of the mufflers was replaced at 549 hours TIS, well before the manufacturer's recommended interval, and likely an indication of premature failure.

The hazard of CO poisoning via leaks in reciprocating engine exhaust systems that are used to provide cabin heat has long been known to the industry. In 2004, the NTSB issued a safety recommendation to the FAA to require the installation of CO detectors in all single-engine airplanes such as the accident type.

In response, the FAA undertook extensive research on the detection and prevention of CO exposure in general aviation aircraft, created a technical standard order specifying minimum performance standards for CO detectors, and recommended, but did not require, that all operators install CO detectors.

The FAA concluded that the primary method to prevent CO contamination in the cabin is through proper inspection and maintenance of mufflers and exhaust system components and that CO detectors are a secondary method of preventing CO exposure. The FAA further stated that since a lack of a CO detector alone is not unsafe, installing a CO detector would not correct an unsafe condition.

Because the FAA did not require installation of CO detectors, the safety recommendation was classified "Closed – Unacceptable Action."