Brian Seck

This is a Comment on the Federal Aviation Administration (FAA) Proposed Rule: Airworthiness Directives: The Boeing Company Airplanes

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Docket No. FAA-2013-0095: Directorate Identifier 2011-NM-197-AD

United Airlines is presently accomplishing the requirements of SB 767-27-0186/-0187 and SB 767-27-0200/-0201 and SB 767-27-0202/-0203 as an alternative method of compliance for AD 2001-04-09.
Both pre-merger airlines (Continental and United) had pursued this path independently, including reworking all off-wing assemblies to prevent installation of a bellcrank with shear rivets (proposed new paragraph (p)). Effectively we are complying with the proposed rule, and other airlines may also be, for safety and other reasons.

For United and other airlines, there may be no benefit for a new superseding AD. Current actions provide an equivalent level of safety.

UAL suggests the FAA assess the level of airline incorporation of the SB 767-27-0186/-0187 AMOC and consider not releasing the proposed new AD.

Note: In our history of checks per the current AD requirements, we have evidence of one case of a failed rivet.
Comment Period Closed
Apr 12 2013, at 11:59 PM ET
ID: FAA-2013-0095-0006
Tracking Number: 1jx-84qm-jxxm

Document Information

Date Posted: Apr 15, 2013
RIN: 2120-AA64
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Submitter Information

Submitter Name: Brian Seck
Mailing Address: United Airlines
City: San Francisco
Country: United States
State or Province: CA
Organization Name: United Airlines