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NTSB · Safety Recommendation

Safety Recommendation A-21-053

Recommendation

TO THE EUROPEAN UNION AVIATION SAFETY AGENCY: 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, Systems Design and Analysis, and that the assessments evaluate and mitigate the potential for human error that can lead to a cross-wiring error.

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

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

We note that you are reviewing existing requirements for evaluating and mitigating the potential for human error during the design and certification activities specified in CS-25. We also note that, as part of this review, you are considering methods to better mitigate the risk of human errors that could lead to cross-wiring of antiskid brake system components, including the wheel speed transducers. Pending our review of your findings and a plan for completing the recommended actions, Safety Recommendation A-21-53 is classified OPEN--ACCEPTABLE RESPONSE.

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

-From Erick Ferrandez, Head of Safety Intelligence and Performance Department: The European Union Aviation Safety Agency (EASA) has initiated a review of existing provisions related to the consideration of human errors (in particular maintenance errors) during design and certification activities in CS-25 (Certification Specifications and Acceptable Means of Compliance for Large Aeroplanes). As an initial indication, some provisions are already present in AMC 25.1309 (System design and analysis) (refer to CS-25 Amendment 27):

-Section 6.b(2) presents the principles and techniques that need to be used in the fail-safe design concept incorporated in CS-25. This includes the ‘Error-Tolerance that considers adverse effects of foreseeable errors during the aeroplane's design, test, manufacture, operation, and maintenance’.

-Section 9.b(1)(v) states that the analyses done to substantiate the probabilities of failures conditions must consider, among other items, ‘the effect of reasonably anticipated errors when performing maintenance actions’.

-Section 10.c specifies that ‘the requirements of CS 25.1309(b) are intended to ensure an orderly and thorough evaluation of the effects on safety of foreseeable failures or other events, such as errors or external circumstances, separately or in combination, involving one or more system functions. The interactions of these factors within a system and among relevant systems should be considered’.

-Appendix 1 (Assessment methods) section f (Common cause analysis) provides the following:

o‘(1) Zonal Safety Analysis. This analysis has the objective of ensuring that the equipment installations within each zone of the aeroplane are at an adequate safety standard with respect to design and installation standards, interference between systems, and maintenance errors. In those areas of the aeroplane where multiple systems and components are installed in close proximity, it should be ensured that the zonal analysis would identify any failure or malfunction which by itself is considered sustainable but which could have more serious effects when adversely affecting other adjacent systems or components.

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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

o(3) Common Mode Analysis. This analysis is performed to confirm the assumed independence of the events, which were considered in combination for a given failure condition. The effects of specification, design, implementation, installation, maintenance, and manufacturing errors, environmental factors other than those already considered in the particular risk analysis, and failures of system components should be considered’.

EASA will further analyse the issue highlighted in this safety recommendation and consider appropriate action(s) that could be used to better mitigate the risk of human errors leading to the crosswiring of antiskid brake system or other systems.

An update of this reply will be provided when progress is made.

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.