Narrative:

The primary concerns with these deferrals: M&east (mgmt and engineering) expects its amt's to repeatedly open/close access panels performing undocumented maintenance procedures on primary system appliances after dispatch of ETOPS aircraft; expressly for the purpose of logbook convenience. This is in direct conflict with far 121.701; 121.709 and gpm 5-01. If engines are started on the gate when APU air is inoperative; for example; then what exactly is the convenience issue here? The mpm for the l-hand and r-hand and center isolation valves should be similar in content; but are in fact written differently with respect to initial deferral and logbook signoff procedures. All address locking the valves closed; but no specific procedures are given for subsequent engine starts. Also; valve locations are not clearly idented as the r-hand and center isolation valves are in close proximity to one another. Also; no alternate flight deck verification procedures are given in the event that MEL item is not operative. This mpm as currently implemented by our M&east department locks in the initiating amt as ultimately responsible for the correct lockout procedure and panel closures even though many more repetitive maintenance functions will go undocumented on the very same valve. Finally; the MEL items in question currently do not require a documentation to be used. Gpm requires this form on all MEL items that require repetitive maintenance actions. Please note that a large majority of our other fleets require these signatures and verifications prior to each departure.

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Original NASA ASRS Text

Title: A B777 TECHNICIAN POINTS OUT AREAS OF CONFLICT BTWN THE MAINT PROCS MANUAL; MEL AND FAR'S. AREA IN CONFLICT IS DEFERRAL OF PNEUMATIC ISOLATION OF BLEED VALVES.

Narrative: THE PRIMARY CONCERNS WITH THESE DEFERRALS: M&E (MGMT AND ENGINEERING) EXPECTS ITS AMT'S TO REPEATEDLY OPEN/CLOSE ACCESS PANELS PERFORMING UNDOCUMENTED MAINT PROCS ON PRIMARY SYS APPLIANCES AFTER DISPATCH OF ETOPS ACFT; EXPRESSLY FOR THE PURPOSE OF LOGBOOK CONVENIENCE. THIS IS IN DIRECT CONFLICT WITH FAR 121.701; 121.709 AND GPM 5-01. IF ENGS ARE STARTED ON THE GATE WHEN APU AIR IS INOP; FOR EXAMPLE; THEN WHAT EXACTLY IS THE CONVENIENCE ISSUE HERE? THE MPM FOR THE L-HAND AND R-HAND AND CTR ISOLATION VALVES SHOULD BE SIMILAR IN CONTENT; BUT ARE IN FACT WRITTEN DIFFERENTLY WITH RESPECT TO INITIAL DEFERRAL AND LOGBOOK SIGNOFF PROCS. ALL ADDRESS LOCKING THE VALVES CLOSED; BUT NO SPECIFIC PROCS ARE GIVEN FOR SUBSEQUENT ENG STARTS. ALSO; VALVE LOCATIONS ARE NOT CLRLY IDENTED AS THE R-HAND AND CTR ISOLATION VALVES ARE IN CLOSE PROX TO ONE ANOTHER. ALSO; NO ALTERNATE FLT DECK VERIFICATION PROCS ARE GIVEN IN THE EVENT THAT MEL ITEM IS NOT OPERATIVE. THIS MPM AS CURRENTLY IMPLEMENTED BY OUR M&E DEPT LOCKS IN THE INITIATING AMT AS ULTIMATELY RESPONSIBLE FOR THE CORRECT LOCKOUT PROC AND PANEL CLOSURES EVEN THOUGH MANY MORE REPETITIVE MAINT FUNCTIONS WILL GO UNDOCUMENTED ON THE VERY SAME VALVE. FINALLY; THE MEL ITEMS IN QUESTION CURRENTLY DO NOT REQUIRE A DOCUMENTATION TO BE USED. GPM REQUIRES THIS FORM ON ALL MEL ITEMS THAT REQUIRE REPETITIVE MAINT ACTIONS. PLEASE NOTE THAT A LARGE MAJORITY OF OUR OTHER FLEETS REQUIRE THESE SIGNATURES AND VERIFICATIONS PRIOR TO EACH DEP.

Data retrieved from NASA's ASRS site as of January 2009 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.