FAA Confirms Shift to 90-Day Underwater Locating Devices

They are likely to have a lithium battery large enough that it will be considered hazardous material and shipped accordingly, the agency acknowledged. It granted more time to phase in the new requirement.

A notice published by the Federal Aviation Administration confirms that its existing Technical Standard Order authorizations for the production of acoustic underwater locating devices (ULDs) are being revoked to make way for a new authorization that will increase the devices' minimum battery operating life from 30 days to 90 days.

The agency proposed this in August 2011 and received comments asking for a longer phase-in period, which FAA granted, and noting a ULD that can meet the 90-day performance criteria will have a lithium battery large enough that it will be considered hazardous material, which means the manufacturer will have to ship them according to DOT Hazardous Material Class 9 regulations.

The commenter, L-3 Communications Aviation Recorders, said this burden would place considerable constraints on available carriers and the destinations to which they will ship, and thus would negatively affect its customers. FAA simply acknowledged that hazmat shipping regulations for lithium batteries will need to be obeyed.

Boeing Commercial Airplanes filed the comment seeking more time to come into compliance. There are multiple flight data recorder suppliers with varying procurement methods and contractual details that must be addressed, and the new SAE AS8045A performance standards referenced in the proposed FAA authorization include new testing requirements; Boeing said one ULD manufacturer has indicated its existing 90-day ULD will not meet the SAE standards, so a complete redesign of the unit will be necessary. Agreeing, FAA changed the date for withdrawing the existing authorizations to March 1, 2015.

All manufacturers of Underwater Locating Devices (Acoustic) (Self-Powered) seeking TSO authorization will then need to obtain a new authorization to manufacture in accordance with the new authorization.

L-3 Communications said it may take up to six years to replace a locator beacon battery, so there will be years of both 30-day and 90-day beacons in service once the new authorization is in effect. L-3 said following a crash, time would be unnecessarily spent determining whether a 90-day beacon was aboard before deciding to undertake an extended search effort.

But FAA disagreed, although it acknowledged this change will result in a mixture of ULD equipment across the fleet. Manufacturers currently produce both 30-day and 90-day ULDs, and the agency said it believes no additional burden is imposed to identify whether a 30-day or a 90-day ULD is installed on an aircraft for an operator during an over-water accident investigation.

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