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Attributes | |
ACN | 1243189 |
Time | |
Date | 201502 |
Local Time Of Day | 1801-2400 |
Place | |
Locale Reference | ZZZ.Airport |
State Reference | US |
Environment | |
Light | Night |
Aircraft 1 | |
Make Model Name | A300 |
Operating Under FAR Part | Part 121 |
Flight Phase | Parked |
Flight Plan | None |
Component | |
Aircraft Component | Fuel Distribution System |
Person 1 | |
Function | Technician |
Qualification | Maintenance Airframe Maintenance Powerplant |
Person 2 | |
Function | Technician |
Qualification | Maintenance Airframe Maintenance Powerplant |
Events | |
Anomaly | Aircraft Equipment Problem Critical Deviation - Procedural Published Material / Policy Deviation - Procedural Maintenance Deviation - Procedural FAR |
Narrative:
These are the events as I; [maintenance controller X]; recall them for an A300 aircraft concerning deferrals MXXXX74 and DXXXX77. Maintenance control was contacted by ZZZ line maintenance to report the scavenge fuel pump control circuit breaker on panel 132VU at location K63 (fin # 13QQ) was tripped. My responsibility in these events was to approve the actions taken to address this issue by way of the completion of the audit process per maintenance control procedures 04.02.01. My refusal to complete the audit process was based on the following: 1). Aircraft maintenance manual (amm) 28-11-4-0401 for the replacement of the fuel scavenge pump begins with a blanket warning that this is a critical design configuration control limitation (cdccl) item and 'you must keep all cdccl items in the approved configuration'. The company's position to me was this cdccl warning only applies to the replacement of this pump. I disagree. If you were to change the connector on this pump would not the cdccl warning still apply? This circuit breaker was powering the control relays that are external to the tank; but are they still not part of the scavenge fuel pump system? Is this system as a whole not part of the cdccl concept? Would not the same cdccl warnings apply? The cdccl warnings in amm 28-11-41-0401 do not identify the procedure of replacing the pump as the cdccl concern. Rather; amm 28-11-41-0401 says the procedure of replacing the pump 'uses' a fuel system 'item' that is in a category known as cdccl. The 'item/system' itself is the cdccl concern. The deferrals MXXXX74 and DXXXX77 together; change the approved configuration of this cdccl system. 2). In my view the actions taken were out of the scope of the general maintenance manual (gmm) 03.05.01 by using a simple 'D' item and required an engineering order (eo) to address the issue. Per gmm 03.05.01; 'if the recommended action is not contained within an applicable manual it will be necessary to obtain concurrence and instruction from engineering through the issuance of an eo.' what manual was produced by ZZZ line maintenance or engineering allowing maintenance control to pull this circuit breaker or deviate from the cdccl warning? 3). Per gmm 03.05.01; 'additional engineering concurrence may be necessary'. What has developed out of this process is a pattern of engineering telling maintenance control and line maintenance that the issue at hand can be handled using gmm 03.05.01 by 'just put a 'D' item on it per the gmm'. This is an overreach by the engineering department. Per gmm 03.02.01; 'maintenance control will administer and control deferred items (MEL; cdl and dmi)'. This gmm is clear that the responsibility for the legality of the deferral process is with maintenance control. That decision may or may not require engineering concurrence. It may require the engineering department to produce an eo to address the fault. Engineering should not be telling maintenance control what procedure is needed to defer any item. 4). What was causing the circuit breaker to trip? Proper troubleshooting was not applied to find the root cause for the circuit breaker to trip. Do we have a short? Per airbus A300 electrical standards practices manual (espm) manual 20-10-00; para 2; this is a violation. Lastly I felt very pressured to agree to this process. Even more so after I expressed my concerns. I was told by the maintenance control management to work as directed and complete the audit process. Under the threat of discipline I completed the audit process and submitted this report. In the safety first environment of maintenance control; the pressure I felt to agree to these deferrals runs counterproductive and does not build bridges for better working relations. Aircraft delay. Fuel distribution system. Fuel system: general. Extreme cold.
Original NASA ASRS Text
Title: Two Maintenance Controllers are directed under threat of discipline to issue two deferrals under their General Maintenance Manual (GMM) for a water scavenge system in an A300's aircraft fuel tank and a Scavenge Fuel Pump Control Circuit Breaker (CB) K63 that would not reset. Both Controllers believed an Engineering Order (EO) was required due to the scavenge pump control CB's association with Special Federal Aviation Regulation 88 and Critical Design Configuration Control Limitation (CDCCL). The Line Mechanic also requests clarification of the two contradicting statements in their GMM as to the necessity of an EO when deviating from an MEL.
Narrative: These are the events as I; [Maintenance Controller X]; recall them for an A300 aircraft concerning deferrals MXXXX74 and DXXXX77. Maintenance Control was contacted by ZZZ Line maintenance to report the Scavenge Fuel Pump Control circuit breaker on panel 132VU at location K63 (FIN # 13QQ) was tripped. My responsibility in these events was to approve the actions taken to address this issue by way of the completion of the Audit Process per Maintenance Control procedures 04.02.01. My refusal to complete the audit process was based on the following: 1). Aircraft Maintenance Manual (AMM) 28-11-4-0401 for the replacement of the Fuel Scavenge Pump begins with a blanket warning that this is a Critical Design Configuration Control Limitation (CDCCL) item and 'You must keep all CDCCL items in the approved configuration'. The company's position to me was this CDCCL warning only applies to the replacement of this pump. I disagree. If you were to change the connector on this pump would not the CDCCL warning still apply? This circuit breaker was powering the control relays that are external to the tank; but are they still not part of the Scavenge Fuel Pump System? Is this system as a whole not part of the CDCCL concept? Would not the same CDCCL warnings apply? The CDCCL warnings in AMM 28-11-41-0401 do not identify the procedure of replacing the pump as the CDCCL concern. Rather; AMM 28-11-41-0401 says the procedure of replacing the pump 'USES' a fuel system 'ITEM' that is in a category known as CDCCL. The 'ITEM/SYSTEM' itself is the CDCCL concern. The deferrals MXXXX74 and DXXXX77 together; change the approved configuration of this CDCCL system. 2). In my view the actions taken were out of the scope of the General Maintenance Manual (GMM) 03.05.01 by using a simple 'D' item and required an Engineering Order (EO) to address the issue. Per GMM 03.05.01; 'If the recommended action is not contained within an applicable manual it will be necessary to obtain concurrence and instruction from Engineering through the issuance of an EO.' What manual was produced by ZZZ Line Maintenance or Engineering allowing Maintenance Control to pull this circuit breaker or deviate from the CDCCL warning? 3). Per GMM 03.05.01; 'Additional engineering concurrence may be necessary'. What has developed out of this process is a pattern of Engineering telling Maintenance Control and Line Maintenance that the issue at hand can be handled using GMM 03.05.01 by 'just put a 'D' item on it per the GMM'. This is an overreach by the Engineering Department. Per GMM 03.02.01; 'Maintenance Control will administer and control deferred items (MEL; CDL and DMI)'. This GMM is clear that the responsibility for the legality of the deferral process is with Maintenance Control. That decision may or may not require engineering concurrence. It may require the Engineering department to produce an EO to address the fault. Engineering should not be telling Maintenance Control what procedure is needed to defer any item. 4). What was causing the circuit breaker to trip? Proper troubleshooting was not applied to find the root cause for the circuit breaker to trip. Do we have a short? Per Airbus A300 Electrical Standards Practices Manual (ESPM) Manual 20-10-00; Para 2; this is a violation. Lastly I felt very pressured to agree to this process. Even more so after I expressed my concerns. I was told by the Maintenance Control management to work as directed and complete the audit process. Under the threat of discipline I completed the audit process and submitted this report. In the safety first environment of Maintenance Control; the pressure I felt to agree to these deferrals runs counterproductive and does not build bridges for better working relations. Aircraft delay. Fuel Distribution System. Fuel System: General. Extreme Cold.
Data retrieved from NASA's ASRS site and automatically converted to unabbreviated mixed upper/lowercase text. This report is for informational purposes with no guarantee of accuracy. See NASA's ASRS site for official report.