Case #2: Confusion reigns supreme

Air Safety Week, Jan 19, 2004

The word has gone forth, to paraphrase: Visit every operator in your district and see if it has done the inspection of the T-34 Mentor wing spars, and also determine if these inspections have been done properly. That is the essence of the mandate contained in a Dec. 31, 2003, flight standards information bulletin for airworthiness (FSAW No. 03-11). The document issued by the Federal Aviation Administration was sent to each of its flight standards district offices (FSDOs).

Inspectors have 30 days to inspect all T-34s in their region engaged in simulated air combat and upset recovery training. No more discussion about doing the inspections within 80 hours or 12 months - whichever occurs later (per the wording of airworthiness directive No. AD 2001-13-18 published July 2, 2001).

Regarding the T-34 that lost its wing Nov. 19, 2003, killing pilots Don Wylie and William Eisenhaur, the operator had not completed the inspections called for in the AD, according to the FSAW. In other words, the accident airplane was flying outside the compliance window of the AD, in which wingspar inspections were mandatory (see ASW, Dec. 8, 2003). In fact, the FSAW reveals, of 423 T-34 aircraft registered in the U.S., 203 were not in compliance with the AD. In other words, nearly 48 percent of the fleet had not complied with initial and recurrent inspections required some 29 months after the AD was published, which generously gave operators 12 months or 80 flying hours to comply with the initial inspection (with repetitive inspections at 80-hour intervals following if cracks were found). The FSAW remarked critically, "This lack of compliance with an AD represents a significant safety problem."

It is important to recall the reason for publishing the AD in the first place. It was issued to prevent a recurrence of the T-34 crash April 19, 1999, at Rydal, Ga. The right wing broke off as the airplane was engaged in mock combat maneuvers. By August 1999, T-34 manufacturer Raytheon [NYSE: RTN] had issued two safety communiqus recommending the immediate grounding of the T-34 fleet, according to a situation report published by General Aviation Modifications, Inc. (GAMI) of Ada, Okla. (see http://www.gami.com/t34form.html ). While the FAA imposed flight restrictions on the T-34 fleet a month after the Rydal accident (AD 99-12-02), note that AD 2001-13-18 imposing wingspar inspections was not published until after 26 months of discussions with operators and various interest groups.

The most recent accident airplane was engaged in upset recovery training, which placed it in the more severe of two operating categories outlined by the FAA. The surviving fleet of such aircraft is now the subject of the FAA's accelerated inspection action.

The FSAW also reveals that of the airplanes inspected, some of the inspections weren't done in accordance with approved procedures, dye penetrant instead of fluorescent penetrant having been used, the latter having been called for in the manufacturer's service bulletins.

Moreover, alternate methods of compliance (AMOCs) have not been incorporated into the AD. Rather, they have been outlined in separate letters issued by the FAA. The FAA disagrees with the suggestion that a more direct approach would have outlined alternate methods of compliance within the AD. "We believe that a better course is to note in the AD that AMOCs will be considered, and [to] let the specifics be approved by the ACO [aircraft certificate manager]," the FAA said.

"This was the course pursued with the T-34 AD. We are, of course, continuing to investigate the recent T-34 accident and will take whatever safety action is warranted by the results," the FAA added.

In the meantime, confusion reigns supreme. The revelations in the FSAW provide direct evidence of three things: (1) the AD and its generous compliance time lacked meat, (2) the quality of inspection and maintenance in the general aviation community varies hugely and, (3) a crackdown is needed. Intervention by consultative decree failed.

After attempting to accommodate all the lobbying from the T-34 community, the FAA is now staring at a second fatal accident and an urgent need to demand action. By the way, that lobbying continues. On Jan. 2 the T-34 Association asked the FAA to allow a year to complete the spar inspections demanded in the FAA's Dec. 31, 2003, decree.

At this point, what makes the most sense? Perhaps a decisive statement from the FAA along the following lines: T-34 wing spars are proven to be at risk of breaking due to accumulated fatigue with deadly results. The manufacturer agrees that urgent action is required. The following two/three firms have been contracted by the FAA to provide developed and approved STCs to rectify this basic structural concern. The firms are X, Y & Z. They are providing, at a number of convenient venues, competitive pricing and will offer two schemes. The first will effectively zero-time the airplane and the second, cheaper scheme, will provide 10,000 hours of further utilization before additional action will be required. Modifications carried out by these companies under FAA STC 123456 will meet the requirements of the SAIBs (special airworthiness information bulletins outlining the AMOCs), the FSAW and the associated AD. Timing dispensations for incorporating the work are limited and commercial owners will be accorded priority. Bookings for modification made through your FSDO will ensure that individual registrations will not be suspended.