Narrative:

The company announced that logo lights were deactivated on all aircraft for cost savings. Inquired via e-mail to safety director as to rationale on may/mon with no response. During flight jun/wed, further researched company manuals. Found several discrepancies, but cannot determine legality or pilot responsibility for company maintenance action. Awaiting response to following formal flight crew report, submitted to company jun/fri. Deactivation of airplane logo lights appears to be in direct conflict with FAA policy (advisory circular 120-74, 'part 121, 125, and 135 flight crew procedures during taxi operations,' dated jun/xa/01) and pilots union safety department research, (bulletin dated dec/xa/95), and in violation of the 747-400 or, 747-400 or, and company fom. FAA advisory circular 120-74 (part 6, paragraph 7.B(2), pages 11-12) and pilots union operations bulletin 95-9 both recommend use of logo lights for conspicuity, especially 'during periods of darkness and low visibility,' as part of conducting safe aircraft operations during taxiing.' the company 747-400 or agrees with and implements advisory circular 120-74 by mandating 'logo light (on for night operation) -- as required' in the captain's preflight flows. The 747-400 or (item 33-45-1) specifies 'repair interval D -- 120 days' for inoperative logo lights. Company fom further specifies that 'dispatch will issue a deferred item number for all ddpg items to the flight crews'. By deactivating logo lights on all aircraft, and announcing the action without appropriate fom and fhb bulletins and ddpg revision management has exposed the company and individual pilots to possible FAA certificate action for violations of the fhb, ddpg, and fom. Besides the potential for certifiate action, how does management reconcile the safety issue addressed by advisory circular 120-74 and bulletin? What are the ramifications for the involved pilots and the company if a runway incursion, ground collision, or other incident -- that might have been prevented by the additional visibilty provided by logo lights -- occurs. Is the cost savings worth the possibility of even a single incident, especially when airplane conspicuity and avoidance of runway incursions are 'hot topics' with the FAA? Recommend logo lights be reactivated on all company airplanes as soon as possible. Further recommend tail logos be restored to all airplanes, so that easily visible, light-color, identing logos are illuminated by those lights.

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Original NASA ASRS Text

Title: RPTR FEELS THAT COMPANY DECISION TO DEACTIVATE LOGO LIGHTS ON ALL ACFT IS UNSAFE AND VIOLATES COMPANY POLICY, PLT'S UNION BULLETINS AND FAA ADVISORY CIRCULARS.

Narrative: THE COMPANY ANNOUNCED THAT LOGO LIGHTS WERE DEACTIVATED ON ALL ACFT FOR COST SAVINGS. INQUIRED VIA E-MAIL TO SAFETY DIRECTOR AS TO RATIONALE ON MAY/MON WITH NO RESPONSE. DURING FLT JUN/WED, FURTHER RESEARCHED COMPANY MANUALS. FOUND SEVERAL DISCREPANCIES, BUT CANNOT DETERMINE LEGALITY OR PLT RESPONSIBILITY FOR COMPANY MAINT ACTION. AWAITING RESPONSE TO FOLLOWING FORMAL FLT CREW RPT, SUBMITTED TO COMPANY JUN/FRI. DEACTIVATION OF AIRPLANE LOGO LIGHTS APPEARS TO BE IN DIRECT CONFLICT WITH FAA POLICY (ADVISORY CIRCULAR 120-74, 'PART 121, 125, AND 135 FLT CREW PROCS DURING TAXI OPS,' DATED JUN/XA/01) AND PLTS UNION SAFETY DEPARTMENT RESEARCH, (BULLETIN DATED DEC/XA/95), AND IN VIOLATION OF THE 747-400 OR, 747-400 OR, AND COMPANY FOM. FAA ADVISORY CIRCULAR 120-74 (PART 6, PARAGRAPH 7.B(2), PAGES 11-12) AND PLTS UNION OPS BULLETIN 95-9 BOTH RECOMMEND USE OF LOGO LIGHTS FOR CONSPICUITY, ESPECIALLY 'DURING PERIODS OF DARKNESS AND LOW VISIBILITY,' AS PART OF CONDUCTING SAFE ACFT OPS DURING TAXIING.' THE COMPANY 747-400 OR AGREES WITH AND IMPLEMENTS ADVISORY CIRCULAR 120-74 BY MANDATING 'LOGO LIGHT (ON FOR NIGHT OP) -- AS REQUIRED' IN THE CAPT'S PREFLIGHT FLOWS. THE 747-400 OR (ITEM 33-45-1) SPECIFIES 'REPAIR INTERVAL D -- 120 DAYS' FOR INOP LOGO LIGHTS. COMPANY FOM FURTHER SPECIFIES THAT 'DISPATCH WILL ISSUE A DEFERRED ITEM NUMBER FOR ALL DDPG ITEMS TO THE FLT CREWS'. BY DEACTIVATING LOGO LIGHTS ON ALL ACFT, AND ANNOUNCING THE ACTION WITHOUT APPROPRIATE FOM AND FHB BULLETINS AND DDPG REVISION MGMNT HAS EXPOSED THE COMPANY AND INDIVIDUAL PLTS TO POSSIBLE FAA CERTIFICATE ACTION FOR VIOLATIONS OF THE FHB, DDPG, AND FOM. BESIDES THE POTENTIAL FOR CERTIFIATE ACTION, HOW DOES MGMNT RECONCILE THE SAFETY ISSUE ADDRESSED BY ADVISORY CIRCULAR 120-74 AND BULLETIN? WHAT ARE THE RAMIFICATIONS FOR THE INVOLVED PLTS AND THE COMPANY IF A RWY INCURSION, GND COLLISION, OR OTHER INCIDENT -- THAT MIGHT HAVE BEEN PREVENTED BY THE ADDITIONAL VISIBILTY PROVIDED BY LOGO LIGHTS -- OCCURS. IS THE COST SAVINGS WORTH THE POSSIBILITY OF EVEN A SINGLE INCIDENT, ESPECIALLY WHEN AIRPLANE CONSPICUITY AND AVOIDANCE OF RWY INCURSIONS ARE 'HOT TOPICS' WITH THE FAA? RECOMMEND LOGO LIGHTS BE REACTIVATED ON ALL COMPANY AIRPLANES ASAP. FURTHER RECOMMEND TAIL LOGOS BE RESTORED TO ALL AIRPLANES, SO THAT EASILY VISIBLE, LIGHT-COLOR, IDENTING LOGOS ARE ILLUMINATED BY THOSE LIGHTS.

Data retrieved from NASA's ASRS site as of July 2007 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.