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  3. NTSB A-20-004
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NTSB · Safety Recommendation

Safety Recommendation A-20-004

Recommendation

TO THE CIVIL AVIATION AGENCY OF BRAZIL: Once Embraer revises design and maintenance documentation for Embraer EMB-170/175/190/195/Lineage 1000 series airplanes as requested in Safety Recommendation A-20-3, require operators of these airplanes to incorporate these changes.

Safety Issue and Context

On November 6, 2019, the flight crew of Republic Airways flight 4439, an Embraer EMB-175, declared an emergency shortly after takeoff from ATL with six passengers on board, reporting a pitch trim-related flight control issue and difficulty controlling the airplane. The captain (who was in the left seat and the pilot flying) later reported recognizing the flight control issue after a failed attempt to engage the autopilot about 2,200 ft mean sea level.

The captain stated that he conducted the single memory item on Republic’s Pitch Trim Runaway checklist to push and hold the autopilot/trim disconnect button on his side (figure 1 shows Republic’s quick reference handbook [QRH] checklist for a pitch trim runaway).1 The captain then asked the first officer to push and hold the right-side autopilot/trim disconnect button. The flight crewmembers reported that they did not notice any change in the pitch condition and continued to have difficulty holding the nose down.

The captain and first officer later reported that they both needed to use both hands to counter the airplane’s nose-up pitch motion and that doing so involved such effort that neither felt that they could reach for the QRH to troubleshoot the problem. Ultimately, the flight crew was able to trim the airplane with the first officer’s trim switch, return to ATL, and land the airplane safely about 15 minutes after declaring the emergency.

Review of data from the incident flight revealed that the airplane was in a mistrim condition for a portion of the flight. While this incident is still under investigation, three areas of concern have been identified: wire chafing, application of Embraer service bulletins (SB) related to the pitch trim switch, and potential limitations in checklist memory item(s) to help Embraer pilots address unintended operation of the pitch trim system.

Response History

February 24, 2025 · NTSB Correspondence · Foreign, Brazil, Departamento de Aviacao Civil

We are aware that you asked Embraer to review the design and maintenance documentation for EMB-170/175/190/195/Lineage 1000 series airplanes and, following its review, Embraer improved its procedures for installing and maintaining the control column and associated electrical wiring on these airplanes. These improvements are detailed in SBs 170-27-0060, 190-27-0046, and 190LIN-27-0018; revised Fault Isolation Manual (FIM) Tasks 27-43-00-810-801-A and 27-43-00-810-802-A; and Aircraft Maintenance Manual (AMM) Tasks 27-31-01-820-801-A and 27 11-01-400-801-A.

Although the inspections outlined in the SBs developed by Embraer in response to Safety Recommendation A-20-1 have not been completed on all affected airplanes, we believe Embraer’s proactive actions, including reviewing the design and maintenance documentation for affected airplanes and revising its procedures to prevent wire chafing, are an acceptable alternate solution to Safety Recommendation A-20-3.

In addition, although you did not require operators of these airplanes to incorporate these changes, we believe regulators’ oversight of operators’ maintenance practices will ensure that operators have incorporated Embraer’s revised manual procedures and, therefore, represent an acceptable alternate solution to Safety Recommendation A-20-4. Accordingly, the Board has classified Safety Recommendations A-20-3 and -4 CLOSED-- ACCEPTABLE ALTERNATE ACTION.

May 13, 2024 · Recipient Response · Foreign, Brazil, Departamento de Aviacao Civil

-From Major General Marcelo Moreno, Chief of the Aeronautical Accident Investigation and Prevention Center: EMBRAER published modifications in maintenance procedures and design changes to be implemented by worldwide operators, and current field data did not suggest any need for more mandatory actions regarding modifications designed according to the recommendation A-20-3.

February 5, 2024 · NTSB Correspondence · Foreign, Brazil, Departamento de Aviacao Civil

We note that, so far, no damaged wiring has been discovered during the inspections that are being completed in response to Safety Recommendation A-20-2. We also note that you asked Embraer to review the design and maintenance documentation for EMB-170/175/190/195/Lineage 1000 series airplanes and, following its review, Embraer improved procedures for installing the control column and associated electrical wiring.

Read Recommendation

Recommendation Facts

Status
Closed - Acceptable Alternate Action
Issued
January 29, 2020
Priority
CLASS II
Recipient
Foreign, Brazil, Departamento de Aviacao Civil
Adopted
January 16, 2020
Closed
February 24, 2025
Related Investigation
DCA20IA014
Related Report
ASR-20-01

These improvements are detailed in Embraer SB 170-27-0060 and SB 190-27-0046, which were published on March 18, 2021, and SB 190LIN-27-0018, which was published on April 30, 2021; and revised Fault Isolation Manual (FIM) Tasks 27-43-00-810-801-A and 27-43-00-810-802-A, and Aircraft Maintenance Manual (AMM) Tasks 27-31-01-820-801, 27-11-01-400-801-A, and 27-40-00-710-801-A, which were all published on October 23, 2020.

We believe Embraer’s proactive actions, including reviewing the design and maintenance documentation for affected airplanes and revising its procedures, could be an acceptable alternate solution to Safety Recommendation A-20-3. We also believe the ANAC’s oversight of operators’ maintenance practices will ensure that operators have incorporated Embraer’s revised procedures and, therefore, could represent an acceptable alternate solution to Safety Recommendation A-20-4. However, before either of these recommendations can be closed, you must first complete the inspections in response to Safety Recommendation A-20-2.

In the meantime, pending completion of those inspections and work to address any hazards identified, Safety Recommendations A-20-3 and -4 are classified OPEN-- ACCEPTABLE ALTERNATE RESPONSE.

July 4, 2023 · Recipient Response · Foreign, Brazil, Departamento de Aviacao Civil

-From Major General Marcelo Moreno, Chief of the Aeronautical Accident Investigation and Prevention Center (CENIPA), Ministry of Defense, Command of Aeronautics: The response to this recommendation depends on the conclusion of the recommendation A-20-3. Up to this moment, field data did not suggest any need for mandatory actions regarding modifications designed according to the recommendation A-20-3.

September 2, 2020 · NTSB Correspondence · Foreign, Brazil, Departamento de Aviacao Civil

We note that Embraer plans to review the results of the inspections conducted in response to SB 170-27-0058 and SB 190-27-0045. We also note that you have asked Embraer to review the design and maintenance documentation for Embraer EMB-170/175/190/195/Lineage 1000 series airplanes to determine if any improvements need to be made to the current design and maintenance documents. Pending our review of Embraer’s findings and completion of the recommended action, Safety Recommendation A-20-3 is classified “Open—Acceptable Response.”

We believe the actions you described in response to Safety Recommendation A-20-3 are also the first step toward addressing Safety Recommendation A-20-4. Pending our review of Embraer’s findings and completion of the recommended action, Safety Recommendation A-20-4 is classified OPEN--ACCEPTABLE RESPONSE.

April 28, 2020 · Recipient Response · Foreign, Brazil, Departamento de Aviacao Civil

-From Brigadier Adolfo Aleixo Da Silva Junior, Chief of CENIPA: The response to this recommendation depends on the conclusion of the recommendation A-20-3.

January 29, 2020 · NTSB Correspondence · Foreign, Brazil, Departamento de Aviacao Civil

The National Transportation Safety Board (NTSB) is an independent federal agency charged by Congress with investigating every civil aviation accident in the United States and significant accidents in other modes of transportation—railroad, highway, marine, and pipeline. We determine the probable cause of the accidents and issue safety recommendations aimed at preventing future accidents. In addition, we carry out special studies concerning transportation safety and coordinate the resources of the federal government and other organizations to provide assistance to victims and their family members affected by major transportation disasters.

The attached letter from the NTSB Chairman provides information about the NTSB’s January 16, 2020, report Reported Flight Control System Difficulty on Embraer EMB-175, NTSB/ASR-20-01. The details of this accident investigation and the resulting safety recommendations may be found in the attached report, which can also be accessed at http://www.ntsb.gov. For more information about NTSB and our recommendation process, please see the attached one-page summary.

The NTSB is vitally interested in these recommendations because they are designed to prevent accidents and save lives. We would appreciate a response within 90 days of the date of this letter, detailing the actions you have taken or intend to take to implement these recommendations. When replying, please refer to the safety recommendations by number (for example, A-20-1 through -6). We encourage you to submit your response to ExecutiveSecretariat@ntsb.gov. If your reply exceeds 20 megabytes, including attachments, please e mail us at the same address for instructions on how to send larger documents. Please do not submit both an electronic copy and a hard copy of the same response.

All communications regarding safety recommendations will be stored by the NTSB and viewable by the public. Please do not send privileged or confidential communications in response to this/these recommendation(s). Responses marked as confidential or privileged (or similar designations) will be considered nonresponsive. If you have concerns about this protocol, please contact us at ExecutiveSecretariat@ntsb.gov or call (202) 314-6290 and ask to be directed to the Safety Recommendations Division.

The National Transportation Safety Board (NTSB) is an independent federal agency charged by Congress with investigating every civil aviation accident in the United States and significant accidents in other modes of transportation—railroad, highway, marine, and pipeline. We determine the probable cause of the accidents and issue safety recommendations aimed at preventing future accidents. In addition, we carry out special studies concerning transportation safety and coordinate the resources of the federal government and other organizations to assist victims and their family members affected by major transportation disasters.

We are providing the following information to urge the National Civil Aviation Agency of Brazil (ANAC) to act on the safety recommendations in this letter because we believe your organization can help reduce the risk of future accidents. For more information about the NTSB and our recommendation process, please see the attached one-page summary.

This letter also includes information about the NTSB’s January 16, 2020, report, Reported Flight Control System Difficulty on Embraer EMB-175, NTSB/ASR-20-01. The preliminary findings of this ongoing incident investigation and the resulting safety recommendations may be found in the attached report, which can also be accessed at http://www.ntsb.gov.

As a result of our preliminary findings in this ongoing investigation, we identified the following safety issues:

• Chafing of pitch trim system switch wiring. • Lack of a requirement to incorporate service bulletins intended to prevent the inverted installation of pitch trim switches on EMB-170/175/190/195/Lineage 1000 series airplanes. • Potential limitations in the checklist memory items addressing pitch trim runaway.

Accordingly, the NTSB makes the following safety recommendations to ANAC:

Require Embraer to develop instructions for operators of Embraer EMB 170/175/190/195/Lineage 1000 series airplanes to inspect the wiring in the captain’s and first officer’s control columns for damage, replace where needed, and ensure proper clearance from adjacent components, including the forward mechanical stop bolt and its safety wire. (A-20-1)

Once Embraer develops inspection instructions for the wiring in the captain’s and first officer’s control columns as requested in Safety Recommendation A-20-1, require operators of Embraer EMB-170/175/190/195/Lineage 1000 series airplanes to inspect that wiring for damage, in compliance with Embraer’s instructions, replace where needed, and ensure proper clearance from adjacent components, including the forward mechanical stop bolt and its safety wire. (A-20-2)

Once inspections are completed as outlined in the instructions developed in response to Safety Recommendation A-20-1, require Embraer to review the inspection results and revise design and maintenance documentation for Embraer EMB 170/175/190/195/Lineage 1000 series airplanes as necessary to prevent any hazards identified during the inspections. (A-20-3) Once Embraer revises design and maintenance documentation for Embraer EMB 170/175/190/195/Lineage 1000 series airplanes as requested in Safety Recommendation A-20-3, require operators of these airplanes to incorporate these changes. (A 20-4)

Mandate the incorporation of Embraer Service Bulletins (SB) 170-27-0051, 190 27 0039, and 190LIN-27-0019 on all applicable airplanes, as specified in the SBs. (A 20 5) In coordination with the Federal Aviation Administration, Embraer, and US operators, determine if changes to the Embraer EMB 170/175/190/195/Lineage 1000 series airplane Pitch Trim Runaway checklists are required to adequately address all potential trim system failures, and make such changes as necessary. (A 20-6)

The NTSB is vitally interested in these recommendations because they are designed to prevent accidents and save lives. We would appreciate a response within 90 days of the date of this letter, detailing the actions you have taken or intend to take to implement these recommendations. When replying, please refer to the safety recommendations by number (Safety Recommendations A-20-1 through -6). We encourage you to submit your response to ExecutiveSecretariat@ntsb.gov. If your reply, including attachments, exceeds 20 megabytes, please e mail us at the same address for instructions on how to send larger documents. Please do not submit both an electronic copy and a hard copy of the same response.

All communications regarding safety recommendations are stored by the NTSB and viewable by the public. Please do not send privileged or confidential communications in response to this/these recommendation(s). Responses marked as confidential or privileged (or similar designations) will be considered nonresponsive. In the likely event that your organization uses auto generated and/or preformatted confidentiality statements on letterhead or outgoing e-mails, please include a statement in your letter indicating that the information can be publicly released.

If you have concerns about this protocol, please contact us at ExecutiveSecretariat@ntsb.gov or call (202) 314-6290 and ask to be directed to the Safety Recommendations Division.