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NTSB · Safety Recommendation

Safety Recommendation A-21-052

Recommendation

TO EUROPEAN UNION AVIATION SAFETY AGENCY: Identify all currently certificated transport-category airplanes for which system safety assessments for landing gear systems did not consider human error that could lead to cross-wiring of antiskid brake system components, including the wheel speed transducers, and require manufacturers of transport-category airplanes without such assessments to perform the assessments and then implement mitigations to prevent cross-wiring of antiskid brake system components.

Safety Issue and Context

This report discusses the October 17, 2019, accident involving a Saab SA-2000 airplane, operated by Peninsula Aviation Services Inc. d.b.a. PenAir flight 3296, which overran the end of runway 13 at Unalaska Airport, Unalaska, Alaska. The airplane was substantially damaged during the runway overrun; as a result, of the 3 crewmembers and 39 passengers aboard, 1 passenger sustained fatal injuries, and 1 passenger sustained serious injuries. Eight passengers sustained minor injuries, most of which occurred during the evacuation.

Safety issues identified in this report include the potential for cross-wiring of airplane antiskid brake systems; insufficient Federal Aviation Administration (FAA) guidance to identify safety risks for air carriers experiencing significant organizational changes, including bankruptcy, acquisition, and merger; lack of FAA consideration of runway safety area dimensions during the process of authorizing an air carrier to operate its aircraft at a specific Title 14 Code of Federal Regulations Part 139 certificated airport, and the benefits of safety management systems for design, manufacturing, and maintenance organizations.

As a result of this investigation, the National Transportation Safety Board makes six new safety recommendations to the FAA, three new safety recommendations to the European Union Aviation Safety Agency, and one new recommendation to the Saab Group.

Response History

January 28, 2025 · NTSB Correspondence · European Aviation Safety Agency

You previously informed us that you had distributed Continuing Airworthiness Review Item (CASI) 25-10, which asked Airbus, Leonardo, Dassault, Fokker, and Saab to assess their current antiskid brake system components, including the wheel speed transducers, for potential electrical misconnections and the effect of any potential cross-wiring. The CASI also directed manufacturers to ensure that their SSAs include all identified failure conditions and, if the failure condition is critical, mitigations to prevent or minimize the effect of cross-wiring.

We note that, although you are still reviewing manufacturers’ responses to the CASI, the responses you have reviewed indicate that most product designs incorporate hardware or procedural solutions that adequately protect against potential electrical misconnections and the effect of any potential cross-wiring. We also note that the CASI has resulted in some manufacturers updating their aircraft maintenance manuals.

Although we continue to believe your work to distribute the CASI and review manufacturers’ responses are responsive, my staff would like to meet with your staff to discuss the following items:

• How many total product designs were reviewed and how many of those did not consider human error in their SSA for the landing gear system? • For those product designs that have since performed the SSA, as recommended, we would like to review the portion of the SSA related to the mitigations that were implemented. • For the product designs that did not consider human error in their initial SSA and have not performed another SSA, as recommended, we would like to review the documentation showing how the manufacturer determined that any mitigations they have implemented adequately protect against potential electrical misconnections and the effect of any potential cross-wiring.

My staff has reached out to your staff to schedule a meeting. Pending our review of this additional information and completion of the recommended actions, Safety Recommendation A-21-52 remains classified OPEN-- ACCEPTABLE RESPONSE.

March 22, 2024 · Recipient Response · European Aviation Safety Agency

-From Ralf Erckmann, Head of Safety Intelligence & Performance Department: Since the issuance of the Continued Airworthiness Review Item (CARI) 25-10 (March 2022), inquiring if their landing gear systems / architecture is robust to potential cross-wiring of antiskid brake system components, and how their system safety assessments considered those failure condition(s), and the potential need for mitigation, the European Union Aviation Safety Agency (EASA) received feedback from the Large Aeroplane EU Type Certificate holders.

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Recommendation Facts

Status
Open - Acceptable Response
Issued
November 18, 2021
Priority
CLASS II
Recipient
European Aviation Safety Agency
Adopted
November 2, 2021
Related Investigation
DCA20MA002
Related Report
AAR-21-05

Among those manufacturers’ outcomes, most of the product designs have been confirmed as mitigating adequately the threat identified, whether per hardware and/or procedural solutions. However, some manufacturers have initiated maintenance data (AMM, …) updates, which are monitored by EASA.

The particular case of the SAAB 2000 architecture has been reassessed and enhanced by the mandate of design change (through EASA Airworthiness Directive 2023-0135, effective Date: 24 July 2023) to avoid the mis-connection of the anti-skid harnesses.

Following the completion of the few remaining actions (maintenance data update, remaining feedback to be analysed, …), a final reply to this recommendation will be issued to confirm that the products in the scope of the CARI 25-10, and for which EASA is the Primary Certification Authority, have been evaluated and confirmed as satisfactorily protected against the issue of the mis-connection of the anti-skid harnesses.

July 3, 2023 · NTSB Correspondence · European Aviation Safety Agency

We note that you have developed and distributed continuing airworthiness review item (CASI) 25-10, which asks Airbus, Leonardo, Dassault, Fokker, and Saab to assess their current antiskid brake system components, including the wheel speed transducers, for potential electrical misconnections and the effect of any potential cross-wiring. We also note that CASI 25-10 directs manufacturers to ensure that their safety analyses include all identified failure conditions and, if the failure condition is critical, mitigations to prevent or minimize the effect of cross-wiring.

We believe CASI 25-10 will allow EASA to identify transport-category airplanes for which SSAs for landing gear systems did not consider human error that could lead to cross-wiring of antiskid brake system components, including the wheel speed transducers, and is responsive to the first part of this recommendation. Pending our review of your findings, and a plan for ensuring that manufacturers of any airplanes identified without such system safety assessments perform the recommended assessment and implement mitigations to prevent cross-wiring of antiskid brake system components, Safety Recommendation A-21-54 is classified OPEN-- ACCEPTABLE RESPONSE.

November 7, 2022 · Recipient Response · European Aviation Safety Agency

-From Erick Ferrandez, Head of Safety Intelligence and Performance Department, European Union Aviation Safety Agency: The European Union Aviation Safety Agency (EASA) has sent the Continuing Airworthiness Review Item (CARI) 25-10 to Airbus SAS, Airbus DS, Leonardo, ATR, Dassault, Deutsche Aircraft, Fokker, SAAB, between June and October 2022.

CARI 25-10 requests a review of the current antiskid brake system components, including the wheel speed transducers, to assess any possible electrical misconnection (i.e., due to human error, and irrespective of any support of the technical/maintenance documentation). Furthermore, it also requests assessments of the effect of cross-wiring for all cases where this has been determined to be physically possible. In addition, the current Safety Analyses are to be checked to ensure they consider the effect of such cross-wiring and if needed, the failure condition(s) are to be updated accordingly.

Depending on the criticality of the identified failure condition(s), CARI 25-10 requests the definition of the necessary mitigations preventing, or minimizing, the effect of cross-wiring.

The above-mentioned manufacturers have been asked to send their feedback to EASA within six months.

October 31, 2022 · NTSB Correspondence · European Aviation Safety Agency

We note that you are reviewing this safety recommendation and determining an appropriate plan of action; however, you did not indicate if you intend to take the recommended action or describe how you will decide if your plan of action is appropriate. Therefore, we are unable to determine if your action is responsive to this recommendation. Consequently, pending our receipt of this additional information, Safety Recommendation A-21-52 remains classified OPEN--AWAIT RESPONSE.

February 15, 2022 · Recipient Response · European Aviation Safety Agency

-From Erick Ferrandez, Head of Safety Intelligence and Performance Department, European Union Aviation Safety Agency: The European Union Aviation Safety Agency is analysing this safety recommendation. An update will be provided once a decision has been reached on the orientation to be given to this topic.

December 2, 2021 · Recipient Response · European Aviation Safety Agency

-From Joanna Vogel, Administrative Assistant, ED Office, EASA: We acknowledge receipt of your email.

The letters have been registered and dispatched to the concerned services.

November 18, 2021 · NTSB Correspondence · European Aviation Safety Agency

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 November 2, 2021, report Runway Overrun During Landing, Peninsula Aviation Services Inc. d.b.a. PenAir Flight 3296, Saab 2000, N686PA, Unalaska, Alaska, October 17, 2019, NTSB/AAR 21/05. The details of this accident investigation and the resulting safety recommendation 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 recommendation by number (for example, A-21-52 through 54). 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 recommendation. 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.

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 European Union Aviation Safety Agency 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 our November 2, 2021, report Runway Overrun During Landing, Peninsula Aviation Services Inc. d.b.a. PenAir Flight 3296, Saab 2000, N686PA, Unalaska, Alaska, October 17, 2019, NTSB/AAR 21/05. The details of this 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 this investigation, we identified the following safety issues:

• Potential for cross-wiring of airplane antiskid brake systems • Safety management systems for organizations that design, manufacture, and maintain aircraft

Accordingly, the NTSB makes the following safety recommendations to the European Union Aviation Safety Agency. Additional information regarding these recommendations can be found in the noted sections of the report.

• Identify all currently certificated transport-category airplanes for which system safety assessments for landing gear systems did not consider human error that could lead to cross-wiring of antiskid brake system components, including the wheel speed transducers, and require manufacturers of transport-category airplanes without such assessments to perform the assessments and then implement mitigations to prevent cross-wiring of antiskid brake system components. (A-21-52) (See section 2.3.4.1.)

• Require the submission and consideration of system safety assessments addressing the landing gear antiskid system for the certification of future transport-category airplane designs. The certification should ensure that the system safety assessments are consistent with the intent of Acceptable Means of Compliance 25.1309, System Design and Analysis, and that the assessments evaluate and mitigate the potential for human error that can lead to a cross wiring error. (A 21-53) (See section 2.3.4.1.)

• Require organizations that design, manufacture, and maintain aircraft to establish a safety management system. (A-21-54) (See section 2.3.4.2.)

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-21-52 through -54). 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. 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 these recommendations. Responses marked as confidential or privileged (or similar designations) will be considered nonresponsive. In the likely event that your company uses autogenerated 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.