Safety Recommendation A-72-122

-From M.W. Eastburn, Director- Safety, American Airlines: This is in response to Safety Recommendations A-72-119 through 122 issued August 24, 1972. We wish to inform you that each of the recommendations have been reviewed and action taken to insure that they have been incorporated in the appropriate Maintenance, Flight Equipment Operating Manuals and in each of our recurrent annual training programs. All of the Safety Recommendations issued by the Board are thoroughly reviewed within American Airlines and we have found them to be of great value and benefit in the review and improvement of our operation.

Thank you very much for your recent letter in which you supported the National Transportation Safety Board's recommendations as to methods to help ensure deactivation and task priorities of a more pressing nature than deacticating the CVR. As you know, our primary concern at this time is the infrequent case where the CVT is inadvertently allowed to operator or bulk erated subsequent to an incident of Board interest. We believe that the establishment of approved operating an training procedures covered by checklists would go far toward ensuring compliance with the intent of 121.359(e) which currently imposes the burden of record retention on the air carrier.

However, we are concerned, as we indicated to the Federal Aviation Administation in our letter of August 24, 1972, that 121.359 should be ammended to state that the pilot-in-command would take all reasonable actions to assure that the CVR record would be available for study by our investigators after a reportable incident. We would not antipicate tha the FASA would even initiate enforcement action in those instances where it was evident that the pilot was acting to preserve his own life or the lives of others and failed to preserve a CVR record. We appreciate your comments and willingness to work to improve aviation safety.