Narrative:

After the completion of our flight, the captain was advised by our chief pilot that an FAA inspector had been aboard and filed a violation because our smoke barrier door lock had been rendered inoperative. This lock had been deactivated by maintenance because they could not find a key to fit the lock. These locks are a recent requirement mandated by the FAA in order to prevent passenger from gaining access to the cargo carried forward of the passenger compartment. At the time of the incident, our company NOTAM's indicated that the locks were not mandatory until installed. My interpretation of this was that the installation process was not yet completed, and that we would be told when the locks must be fully functional. The problem is a lack of communication between the company and the mechanics and pilots. In a related development, 6 months prior to this, the FAA required that we install the escape slide retention bar for the forward service door when in the passenger/freight confign. When asked why they wanted this done, they said that it might allow passenger to come forward through the smoke barrier door and use these exits as needed. Obviously, somebody forgot about this when they required that the door be locked. This is just another case of the FAA not paying attention to the real safety issues. I'm sure this incident will create lots of paperwork, which will make it appear that the FSDO office in anchorage is doing a top notch job. Supplemental information from acn 96384: additional confusion was caused by the FAA recently requiring that the girt bars on the forward cabin entry and service door be armed so that they may be used for egress in an emergency. The FAA then locks the access to these doors by making a smoke barrier door lock mandatory. Callback conversation with reporter revealed the following: aircraft is a quick change confign which enables the carrier to handle 2 pallets plus 72 seats, or up to 5 pallets plus 15 seats. The smoke barrier is always placed just forward of the most forward row of seats. This barrier is a very lightwt material, probably fiberglass, with a panel roughly 3' wide by about 1' high, large enough to crawl through to gain access to the cabin. This door swings and is locked on the cabin side, so access to the cargo area is not available unless you have a key. Problem arose when the lock was inoperative. The air carrier agreed to attach the emergency slide girt bars for cockpit egress in an emergency and passenger evacuate/evacuation if necessary. Reporter feels this is redundant since movement through this door is so restr and that the FAA is making a mountain of a mole hill with the fact the door was not locked. Has received a memo from the company they are trying to resolve the issue with the FAA. Would like to see something official in the MEL reference this problem. Report sent in primarily as a cya.

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Original NASA ASRS Text

Title: SMOKE BARRIER SEPARATING PASSENGER CABIN AND FREIGHT AREA LOCK INOPERATIVE.

Narrative: AFTER THE COMPLETION OF OUR FLT, THE CAPT WAS ADVISED BY OUR CHIEF PLT THAT AN FAA INSPECTOR HAD BEEN ABOARD AND FILED A VIOLATION BECAUSE OUR SMOKE BARRIER DOOR LOCK HAD BEEN RENDERED INOP. THIS LOCK HAD BEEN DEACTIVATED BY MAINT BECAUSE THEY COULD NOT FIND A KEY TO FIT THE LOCK. THESE LOCKS ARE A RECENT REQUIREMENT MANDATED BY THE FAA IN ORDER TO PREVENT PAX FROM GAINING ACCESS TO THE CARGO CARRIED FORWARD OF THE PAX COMPARTMENT. AT THE TIME OF THE INCIDENT, OUR COMPANY NOTAM'S INDICATED THAT THE LOCKS WERE NOT MANDATORY UNTIL INSTALLED. MY INTERP OF THIS WAS THAT THE INSTALLATION PROCESS WAS NOT YET COMPLETED, AND THAT WE WOULD BE TOLD WHEN THE LOCKS MUST BE FULLY FUNCTIONAL. THE PROB IS A LACK OF COM BTWN THE COMPANY AND THE MECHS AND PLTS. IN A RELATED DEVELOPMENT, 6 MONTHS PRIOR TO THIS, THE FAA REQUIRED THAT WE INSTALL THE ESCAPE SLIDE RETENTION BAR FOR THE FORWARD SVC DOOR WHEN IN THE PAX/FREIGHT CONFIGN. WHEN ASKED WHY THEY WANTED THIS DONE, THEY SAID THAT IT MIGHT ALLOW PAX TO COME FORWARD THROUGH THE SMOKE BARRIER DOOR AND USE THESE EXITS AS NEEDED. OBVIOUSLY, SOMEBODY FORGOT ABOUT THIS WHEN THEY REQUIRED THAT THE DOOR BE LOCKED. THIS IS JUST ANOTHER CASE OF THE FAA NOT PAYING ATTN TO THE REAL SAFETY ISSUES. I'M SURE THIS INCIDENT WILL CREATE LOTS OF PAPERWORK, WHICH WILL MAKE IT APPEAR THAT THE FSDO OFFICE IN ANCHORAGE IS DOING A TOP NOTCH JOB. SUPPLEMENTAL INFO FROM ACN 96384: ADDITIONAL CONFUSION WAS CAUSED BY THE FAA RECENTLY REQUIRING THAT THE GIRT BARS ON THE FORWARD CABIN ENTRY AND SVC DOOR BE ARMED SO THAT THEY MAY BE USED FOR EGRESS IN AN EMER. THE FAA THEN LOCKS THE ACCESS TO THESE DOORS BY MAKING A SMOKE BARRIER DOOR LOCK MANDATORY. CALLBACK CONVERSATION WITH RPTR REVEALED THE FOLLOWING: ACFT IS A QUICK CHANGE CONFIGN WHICH ENABLES THE CARRIER TO HANDLE 2 PALLETS PLUS 72 SEATS, OR UP TO 5 PALLETS PLUS 15 SEATS. THE SMOKE BARRIER IS ALWAYS PLACED JUST FORWARD OF THE MOST FORWARD ROW OF SEATS. THIS BARRIER IS A VERY LIGHTWT MATERIAL, PROBABLY FIBERGLASS, WITH A PANEL ROUGHLY 3' WIDE BY ABOUT 1' HIGH, LARGE ENOUGH TO CRAWL THROUGH TO GAIN ACCESS TO THE CABIN. THIS DOOR SWINGS AND IS LOCKED ON THE CABIN SIDE, SO ACCESS TO THE CARGO AREA IS NOT AVAILABLE UNLESS YOU HAVE A KEY. PROB AROSE WHEN THE LOCK WAS INOP. THE ACR AGREED TO ATTACH THE EMER SLIDE GIRT BARS FOR COCKPIT EGRESS IN AN EMER AND PAX EVAC IF NECESSARY. RPTR FEELS THIS IS REDUNDANT SINCE MOVEMENT THROUGH THIS DOOR IS SO RESTR AND THAT THE FAA IS MAKING A MOUNTAIN OF A MOLE HILL WITH THE FACT THE DOOR WAS NOT LOCKED. HAS RECEIVED A MEMO FROM THE COMPANY THEY ARE TRYING TO RESOLVE THE ISSUE WITH THE FAA. WOULD LIKE TO SEE SOMETHING OFFICIAL IN THE MEL REF THIS PROB. RPT SENT IN PRIMARILY AS A CYA.

Data retrieved from NASA's ASRS site as of August 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.