Simple Simon Says…

Air Safety Week,  July 17, 2006  

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Simon says is a game for three or more players. One of the players is "it" -- i.e., Simon. The others must do what Simon tells them to do. The catch is the magic phrase of "Simon says". If Simon says "Simon says jump", you jump (if you don't jump, you're out). However, if Simon says simply "jump", without first saying "Simon says", you don't jump (if you do jump, you're out). In general, it's the spirit of the command, not the actions that matters; if Simon says "Simon says touch your toes", you only have to show you're trying to touch your toes. It's the ability to distinguish between valid and invalid demands, rather than an ability to comply, that matters here. Some might see it as a form of charades. Others might draw parallels with Ring around the Rosey, a rhyme of the Great Plague in which at the end, everybody falls in a heap.

If our Simon is the FAA, "Simon says" is an FAA final ruling and the players are the airline industry and aviation regulators worldwide, then perhaps we can see a corollary in the hoops that the players are jumping through on a daily basis with non-mandatory Service Bulletins, compulsory Airworthiness Directives and wide-ranging collaborative Regulations. I'm talking about such regs such as SFAR 88 and FRS (the proposed fuel-tank inerting measures). SFAR88 was a Special Federal Airworthiness Reg that earlier sought to eliminate all sources of ignition in airliner fuel tanks. Once it became obvious that this would be unable to be guaranteed, the FAA fell back upon a novel way of enriching the nitrogen levels in tanks in order to stifle flammability of high flash-point fumes in tank "ullage" (that being the extra volume of gas above the liquid propellant held in sealed tanks). It was all an outcome of the TWA800 climb-out explosion on July 17, 1996. That event was 10 years ago this week. Curative things have been moving slowly over the intervening period and at times, Simon was quietly saying very little...but the need for a TWA800 closure fix was never going to "go away".

Remedial Rigor Mortis

Under carping pressure from the NTSB, Simon now appears to be again saying that it's time to bite the bullet on fuel-tank flammability. Ten years later and the FRS or Flammability Reduction System is the next major hoop for the industry to jump through--yet at this point they're mostly either balking or unenthused. Who are the they (that count)? EASA (Europe's answer to the FAA), Airbus, and quite importantly the very widely respected and influential Sandia Corp.

Sandia has long been the repository of America's nuclear safety rigmaroles. They are masters of risk management, threat probability and constructive chance. In their reasoned comments on the current inerting Notice of Proposed Rule-making (NPRM), they have largely dismantled the basis for many of the FAA's deliveries on fuel-tank explosion risk factors and Monte Carlo probability deductions. Airbus has seized upon similar points, drawn a few bottom lines of their own and made an overall reasonable case for having done more than enough to guarantee fuel-tank safety without inerting. Who is right, who is wrong? Is it just a game of "pass the parcel" or have "they" invented a new form of cooperative quasi-grandfathering of the status quo? (i.e., shall we all agree to disagree then, and get together again here same time next year? All in favor?) Is there now to be a new delaying round of research and development? Keep watching this space and the Federal Register, to see what Simon Says next.

"Simon Says" is an FAA final ruling and the players are the airline industry.

Boeing is making a flammability reduction system a basic feature in the design of the new 787 Dreamliner aircraft and is working with the FAA to require retrofit of this system in certain fuel tanks on other transport-category aircraft that it manufactures. The European Aviation Safety Agency (EASA) will certify the new Airbus A380 transport aircraft without a fuel tank inerting system, instead relying on minimizing ignition sources and maintaining the fuel tank temperature below the ignition point. Both the Safety Board and the FAA submitted comments opposing the Airbus approach.

(from the NTSB's "most wanted" commentary)

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