Airworthiness Directives; Robinson Helicopter Company Model (Robinson) R22, R22 Alpha, R22 Beta, R22 Mariner, R44, and R44 II Helicopters
Requires a visual inspection for skin separation along the leading edge of blade skin aft of the skin-to-spar bond line on the lower surface of each main rotor blade (blade) and in the tip cap area.
[Federal Register Volume 76, Number 117 (Friday, June 17, 2011)]
[Rules and Regulations]
[Pages 35330-35334]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2011-14246]
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DEPARTMENT OF TRANSPORTATION
Federal Aviation Administration
14 CFR Part 39
[Docket No. FAA-2011-0588; Directorate Identifier 2010-SW-074-AD;
Amendment 39-16717; AD 2011-12-10]
RIN 2120-AA64
Airworthiness Directives; Robinson Helicopter Company Model
(Robinson) R22, R22 Alpha, R22 Beta, R22 Mariner, R44, and R44 II
Helicopters
AGENCY: Federal Aviation Administration, DOT.
ACTION: Final rule; request for comments.
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SUMMARY: This amendment supersedes an existing airworthiness directive
(AD) for the specified Robinson model helicopters that currently
requires a visual inspection for skin separation along the leading edge
of blade skin aft of the skin-to-spar bond line on the lower surface of
each main rotor blade (blade) and in the tip cap area. The existing AD
also requires a ``tap test'' for detecting a separation or void in both
bonded areas and repainting any exposed area of the blades. If any
separation or void is detected, the AD requires, before further flight,
replacing the blade. Thereafter, before each flight, the existing AD
also requires checking for any exposed (bare) metal along the skin-to-
spar bond line on the lower surface of each blade near the tip. If any
bare metal is found, that AD requires an inspection by a qualified
mechanic. This amendment contains the same requirements but expands the
applicability to include all serial-numbered model helicopters and
limits the applicability to specific blade part numbers. This amendment
also requires a repetitive inspection of the blade and any necessary
rework. This amendment is prompted by a fatal accident in Israel. We
have also included responses to comments objecting to the recording
requirements in the current AD relating to the pilot checks before each
flight and to comments that the burden of the before-each-flight pilot
check exceeds the benefit. We have concluded that a check before the
first flight of each day is sufficient for aviation safety. The actions
specified by this AD are intended to provide more specific AD actions,
to relieve the burdens associated with the before-each-flight check by
changing it to a daily check, to detect blade skin debond, and to
prevent blade failure and subsequent loss of control of the helicopter.
DATES: Effective July 5, 2011.
The incorporation by reference of certain publications listed in
the regulations is approved by the Director of the Federal Register as
of July 5, 2011.
We must receive comments on this AD by August 16, 2011.
ADDRESSES: Use one of the following addresses to comment on this AD.
Federal eRulemaking Portal: Go to http://www.regulations.gov. Follow the instructions for submitting comments.
Fax: (202) 493-2251.
Mail: U.S. Department of Transportation, Docket
Operations, M-30, West Building Ground Floor, Room W12-140, 1200 New
Jersey Avenue, SE., Washington, DC 20590.
Hand Delivery: U.S. Department of Transportation, Docket
Operations, M-30, West Building Ground Floor, Room W12-140, 1200 New
Jersey Avenue, SE., Washington, DC 20590, between 9 a.m. and 5 p.m.,
Monday through Friday, except Federal holidays.
You may get the service information identified in this AD from
Robinson Helicopter Company, 2901 Airport Drive, Torrance, CA 90505,
telephone (310) 539-0508, fax (310) 539-5198, or at http://www.robinsonheli.com/servelib.htm.
Examining the Docket: You may examine the docket that contains the
AD, any comments, and other information on the Internet at http://www.regulations.gov, or in person at the Docket Operations office
between 9 a.m. and 5 p.m., Monday through Friday, except Federal
holidays. The Docket Operations office (telephone (800) 647-5527) is
located in Room W12-140 on the ground floor of the West Building at the
street address stated in the ADDRESSES section. Comments will be
available in the AD docket shortly after receipt.
FOR FURTHER INFORMATION CONTACT: Eric D. Schrieber, Aviation Safety
Engineer, telephone (562) 627-5348, fax (562) 627-5210 (regarding Model
R22 helicopters), or Fred Guerin, Aviation Safety Engineer, telephone
(562) 627-5232, fax (562) 627-5210 (regarding Model R44 helicopters).
SUPPLEMENTARY INFORMATION: On December 17, 2007, we issued AD 2007-26-
12, Amendment 39-15314 (73 FR 397, January 3, 2008). That AD requires a
one-time visual inspection for skin
[[Page 35331]]
separation along the leading edge of the blade skin aft of the skin-to-
spar bond line on the lower surface of each blade and in the tip cap
area. That AD also requires a ``tap test'' for detecting a separation
or void in both bonded areas. That AD also requires repainting any
exposed area of the blades and replacing the blade before further
flight if any separation or void occurs. Thereafter, the AD requires,
before each flight, checking for any exposed (bare) metal along the
skin-to-spar bond line on the lower surface of each blade near the tip.
If any bare metal is found, a mechanic must visually inspect the area,
perform a ``tap test,'' remove both blade tip covers, and inspect the
area. That AD was prompted by 11 reports of blade debond, some
occurring in flight and some found during routine maintenance. Blades
that develop a debond at the tip may continue to debond causing failure
of the blade. This condition most often results from erosion of the
protective layer of paint that exposes the edge of the skin, which
allows the skin to erode and eventually peel back. In one of the
reported incidents, the debond was caused by corrosion from the lower
surface of the aluminum tip cap, which is bonded to the inside of the
blade tip. The corrosion caused bubbles under the skin but no peeling
back of the skin from the spar. The condition was found during
inspection and not in flight. The condition, if not corrected, could
result in blade failure and subsequent loss of control of the
helicopter.
Since issuing AD 2007-26-12, a fatal accident due to blade
delamination occurred in Israel. The accident investigation revealed
that the operator was in possession of both the United States AD and
the service information but apparently failed to follow the United
States AD requirements and the service information. However, due to the
severity of the unsafe condition, we have determined that modification
of the AD requirements is necessary to further aid in correcting the
unsafe condition by performing the checks and inspections to prevent
further fatalities.
We have reviewed the following Robinson service information:
Letter titled ``Additional Information Regarding Main
Rotor Blade Skin Debonding,'' dated May 25, 2007, discussing blade skin
debonding;
Rotorcraft Flight Manual (RFM) changes to the Normal
Procedures Section 4 and Systems Description Section 7, revised April
20, 2007, for each applicable model helicopter containing a ``caution''
about skin-to-spar bond line erosion;
One Service Letter with two different Nos.: R22 SL-56B and
R44 SL-32B, revised April 30, 2010, specifying proper inspection and
protection (refinishing) of bonded areas; and
Service Bulletins SB-103, dated April 30, 2010, for the
Model R22, and SB-72, dated April 30, 2010, for the Model R44
helicopters specifying proper inspection and protection (refinishing)
of bonded areas for certain affected blades.
Although not required by this AD, Robinson has developed
replacement blades, part number C016-7, for the Model R44 helicopter,
and part number A016-6 for the Model R22 helicopter. The FAA may
require installing these replacement blades in a future AD.
Also, since issuing AD 2007-26-12, we have received various
comments from 32 commenters and have given due consideration to each
one. We have identified 13 unique issues and addressed those issues as
follows:
Twenty-six commenters state that requiring a maintenance logbook
entry before each flight to document the blade check for the exposed
skin-to-spar bonded area on the lower surface of each blade is
unnecessary and burdensome. The commenters also state that the
requirement does not add to safety, will require keeping the
maintenance logbook in the aircraft, and will ``visually pollute'' the
logbook distracting from seeing real maintenance trends.
Upon reconsideration, we agree that making a logbook entry at each
preflight check may not be necessary. Therefore, we are replacing the
``before each flight'' check and maintenance logbook entry with a daily
``before the first flight of each day'' check and logbook entry. A
``caution'' to check for paint erosion on the lower surface of the
blade along the skin-to-spar bond line will be a part of the pre-flight
check section of the revised FAA-approved RFM. We do not agree that
maintenance logbook entries ``pollute the logbook'' and distract from
seeing real maintenance trends. Operators may make the entries on a
separate maintenance record sheet and keep that record sheet as an
appendix to the logbook.
Seventeen commenters state that requiring logbook entries during
each preflight effectively prohibits student pilots from performing
these visual checks and restricts them from flying cross-country
flights.
We agree that preflight entries into the logbook will prohibit
student pilots from flying solo cross-country flights. Changing the
logbook entry requirement from pre-flight to daily will allow the
student's flight instructor or a mechanic to make the required logbook
entry before the days cross country activity. This will allow the
student to fly solo on cross-country flights.
Six commenters state that either the AD is unclear as to whether a
pilot or a mechanic should do the checks or that the visual check is
difficult without a ladder to see the blade closely.
The FAA agrees that the AD is not specific as to whether a pilot or
a mechanic may do the daily check. The ``Daily or Preflight Check''
section of the FAA-Approved RFM is intended to facilitate the paint
erosion check by the pilot, and the pilot or a mechanic may perform the
check before each flight. The FAA does not agree that a ladder is
required to perform this check. When viewing the blade, the requirement
is to look at the lower surface of the blade in the area of the bond
line for missing paint. This detail should be obvious to any one with
normal vision from several feet away.
One commenter states that if this issue is due to a manufacturing
problem, the FAA should mandate that Robinson pay to replace the
blades.
We do not believe that this blade debond is due to a manufacturing
problem. This debond issue appears to be due to the basic design and
maintenance, and the actions taken in AD 2007-26-12 have been shown to
detect and to prevent the debond problem. However, reliance on
continued inspections is an inadequate long term solution. We are
considering a subsequent AD to terminate the inspection requirement by
mandating the replacement of these rotor blades.
One commenter suggests that Robinson send out kits for abrasion
resistant tape to fix the erosion problem.
We do not agree that blade tape will resolve the unsafe condition
even though tape is designed to provide longer resistance to erosion
than paint. The same unsafe condition exists with both.
Two commenters state this problem was known for 10 months before
the AD's release and should not be an immediately adopted rule (IAR).
Also, the commenters state more information was made available before
issuing the AD to change the requirements.
We agree that we were aware of the safety concern even though the
AD had not been issued. We do not agree that the AD should not have
been an IAR. As stated in the preamble to the AD, the ``very short time
intervals'' required by the AD made notice and the opportunity for
prior public comment impracticable and justified issuing the IAR. The
AD was issued after considering all known
[[Page 35332]]
information pertaining to the safety concern.
Two commenters state that the AD applies to helicopter serial
numbers rather than blade serial numbers, which could result in missed
initial checks if the blades from helicopters addressed by the AD are
reinstalled on helicopters not subject to the AD.
We agree and are revising the ``Applicability'' section to apply to
certain part-numbered blades instead of certain serial-numbered
helicopters. This will also result in different part-numbered blades
not being affected by this AD.
One commenter states that repainting of the blade is difficult,
burdensome, expensive, and increases downtime.
We do not consider repainting of the blade costly relative to the
safety risk. Inspecting and maintaining the integrity of the spar-to-
blade bond line with paint corrects the unsafe condition that could
result from erosion of the bond between the spar and the blade skin,
which could cause failure of the blade.
Five commenters state the Pilot's Operating Handbook has been
updated to include the visual inspections outlined in the AD.
We recognize the preflight check exists in the FAA Approved RFM,
and we expect pilots and operators to monitor the erosion on the blades
when they make this check before each flight.
One commenter states the AD is not applicable to blades that are
not eroded, and many operators can fly 2,200 hours without exposing the
bond line. The commenter asks why they are subject to this AD since
their blades are not eroded.
We agree that blades that are not eroded will not have this debond
condition, and if they continue to be noneroded, many operators can fly
2,200 hours without exposing the bond line. Erosion of the paint is
dependent upon the amount of erosive particles in the air and varies
widely from one flight environment to another. Since there is no
limitation on which environment a helicopter may be operated, checks
are necessary to maintain an awareness of the condition of the paint at
the bond line. In addition to the environmental concerns, we have
determined that some bonded end caps experience corrosion where they
contact the lower skin, and with both factors at work, checking all
blades is warranted.
One commenter states the order of the inspection should be reversed
to do the inspection immediately and then do a check every 10 to 20
hours.
We do not agree that it should be reversed. The 10-hour time before
the first inspection is common practice to allow for AD action
implementation if there is an acceptably low risk of failure in those
10 hours. Additionally, that time is granted to allow enough time for
remotely located helicopters to fly to an appropriate maintenance base.
Performing and recording a check before the first flight of each day,
instead of every 10 to 20 hours, is a better way to allow the pilot to
monitor any erosion trend that may occur. This way, the operator will
be aware if the bond line is near exposure and plan accordingly.
One commenter states the AD requires repainting any exposed bare
metal on the blade and asks what if the bare metal is elsewhere than
the bond line.
We agree that only the exposed area of the bond line needs to be
painted. The incorporated Robinson Service Bulletin refers to the
Service Letter that specifies the area of inspection and repaint.
The Australian Civil Aviation Safety Authority gave an oral comment
to the FAA that instead of using a 1965 or later U.S. quarter dollar
coin to perform the tap test, they would like to require alternate
tools.
The FAA agrees that an equivalent and appropriate tool other than a
1965 or later U.S. quarter dollar may be used, and we included in the
AD a statement that other equivalent and appropriate tools may be used
for the inspection.
After careful review of the available data, including the comments
noted above, the FAA has determined that air safety and the public
interest require adopting the rule. This AD supersedes AD 2007-26-12 to
revise the applicability to include all serial-numbered helicopters and
to limit the applicability to specify part-numbered blades and to
require the following:
Before the first flight of each day, visually checking for
any bare metal skin-to-spar joint area on the lower surface of each
blade. An owner/operator (pilot) holding at least a private pilot
certificate may perform this visual check and must enter compliance
into the aircraft maintenance records in accordance with 14 CFR 43.11
and 91.417(a)(2)(v).
If you find any bare metal in the area of the skin-to-spar
bond line, before further flight, inspecting the blade by following the
requirements of this AD.
At specified intervals, inspecting each blade for
corrosion, a separation, a void, a gap, or a dent.
Before further flight, refinishing any exposed area of a
blade.
Before further flight, replacing any unairworthy blade
with an airworthy blade.
Accomplish the actions by following specified portions of the
service bulletins described previously.
The short compliance time involved is required because the
previously described critical unsafe condition can adversely affect the
controllability and structural integrity of the helicopter. Therefore,
visually checking for any bare metal is required before further flight,
and this AD must be issued immediately. The 100-hour inspection is
required based upon the utilization rate of the helicopters because
some operators could fly 100 hours within 30 days. Since a situation
exists that requires the immediate adoption of this regulation, it is
found that notice and opportunity for prior public comment hereon are
impracticable, and that good cause exists for making this amendment
effective in less than 30 days.
We estimate that this AD will affect 2,690 helicopters on the U.S.
registry. We also estimate the following:
Time to perform the before flight each day is negligible.
3 work hours to inspect 2 blades and
10 work hours to replace each unairworthy blade, with an
estimated 10 blades to be replaced (based on reports of 10 affected
blades in the past 2 years) at an average labor rate of $85 per work
hour.
Required parts will cost about $18,130 for a Model R22
blade and about $24,800 for a Model R44 blade.
We estimate an average of 7 recurrent annual or 100-hour inspections
before blade retirement. Based on these figures, we estimate the total
cost of the AD on U.S. operators to be $5,024,800. This figure includes
$4,801,650 to inspect all the blades 7 times; plus $94,900 to replace 5
of the Model R22 blades; plus $128,250 to replace 5 of the Model R44
blades.
Comments Invited
This AD is a final rule that involves requirements affecting flight
safety, and we did not precede it by notice and an opportunity for
public comment. We invite you to send any written relevant data, views,
or arguments regarding this AD. Send your comments to an address listed
under the ADDRESSES section. Include the docket number ``FAA-2011-0588;
Directorate Identifier 2010-SW-074-AD'' at the beginning of your
comments. We specifically invite comments on the overall regulatory,
economic, environmental, and energy aspects of the AD. We will consider
all comments received by the closing date and may amend the AD in light
of those comments.
[[Page 35333]]
We will post all comments we receive, without change, to http://www.regulations.gov, including any personal information you provide. We
will also post a report summarizing each substantive verbal contact we
receive concerning this AD. Using the search function of the docket Web
site, you can find and read the comments to any of our dockets,
including the name of the individual who sent the comment. You may
review the DOT's complete Privacy Act Statement in the Federal Register
published on April 11, 2000 (65 FR 19477-78).
Regulatory Findings
We have determined that this AD will not have federalism
implications under Executive Order 13132. This AD will not have a
substantial direct effect on the States, on the relationship between
the national Government and the States, or on the distribution of power
and responsibilities among the various levels of government.
For the reasons discussed above, I certify that the regulation:
1. Is not a ``significant regulatory action'' under Executive Order
12866;
2. Is not a ``significant rule'' under the DOT Regulatory Policies
and Procedures (44 FR 11034, February 26, 1979); and
3. Will not have a significant economic impact, positive or
negative, on a substantial number of small entities under the criteria
of the Regulatory Flexibility Act.
We prepared an economic evaluation of the estimated costs to comply
with this AD. See the AD docket to examine the economic evaluation.
Authority for This Rulemaking
Title 49 of the United States Code specifies the FAA's authority to
issue rules on aviation safety. Subtitle I, section 106, describes the
authority of the FAA Administrator. Subtitle VII, Aviation Programs,
describes in more detail the scope of the Agency's authority.
We are issuing this rulemaking under the authority described in
subtitle VII, part A, subpart III, section 44701, ``General
requirements.'' Under that section, Congress charges the FAA with
promoting safe flight of civil aircraft in air commerce by prescribing
regulations for practices, methods, and procedures the Administrator
finds necessary for safety in air commerce. This regulation is within
the scope of that authority because it addresses an unsafe condition
that is likely to exist or develop on products identified in this
rulemaking action.
List of Subjects in 14 CFR Part 39
Air transportation, Aircraft, Aviation safety, Incorporation by
reference, Safety.
Adoption of the Amendment
Accordingly, under the authority delegated to me by the
Administrator, the FAA amends 14 CFR part 39 as follows:
PART 39--AIRWORTHINESS DIRECTIVES
0
1. The authority citation for part 39 continues to read as follows:
Authority: 49 U.S.C. 106(g), 40113, 44701.
Sec. 39.13 [Amended]
0
2. The FAA amends Sec. 39.13 by removing Airworthiness Directive (AD)
2007-26-12, Amendment 39-15314 (73 FR 400; January 3, 2008),
Directorate Identifier 2007-SW-04-AD; and by adding a new AD to read as
follows:
2011-12-10 Robinson Helicopter Company: Amendment 39-16717; Docket
No. FAA-2011-0588, Directorate Identifier 2010-SW-074-AD. Supersedes
AD 2007-26-12, Amendment 39-15314, Docket No. FAA-2007-0378,
Directorate Identifier 2007-SW-04-AD.
Applicability: Model R22, R22 Alpha, R22 Beta, and R22 Mariner
helicopters, with main rotor blade (blade), part number (P/N) A016-
4; and Model R44 and R44 II helicopters, with blade, P/N C016-2 or
C016-5, certificated in any category.
Compliance: Required as indicated.
To detect blade skin debond and prevent blade failure and
subsequent loss of control of the helicopter, do the following:
(a) Before the first flight of each day, visually check for any
exposed (bare metal) skin-to-spar joint area on the lower surface of
each blade. The actions required by this paragraph may be performed
by the owner/operator (pilot) holding at least a private pilot
certificate and must be entered into the aircraft records showing
compliance with this AD in accordance with 14 CFR 43.9(a)(1)-(4) and
14 CFR 91.417(a)(2)(v). The record must be maintained as required by
14 CFR 91.417, 121.380, or 135.439. This authorization is an
exception to our standard maintenance regulations.
(b) If you find any bare metal in the area of the skin-to-spar
bond line, before further flight, inspect the blade by following the
requirements of paragraph (d) of this AD.
(c) Within 10 hours time-in-service (TIS), unless done
previously, and at intervals not to exceed 100 hours TIS or at each
annual inspection, whichever occurs first, inspect each blade for
corrosion, a separation, a gap, or a dent by following the
Compliance Procedure, paragraphs 1 through 6 and 8, of Robinson R22
Service Bulletin SB-103, dated April 30, 2010 (SB103) for the R22
series helicopters, and Robinson R44 Service Bulletin SB-72, dated
April 30, 2010 (SB72), for the R44 series helicopters. Although the
Robinson service information limits the magnification to 10 x, a
higher magnification is acceptable for this inspection. Also, an
appropriate tap test tool which provides similar performance,
weight, and consistency of tone may be substituted for the ``1965 or
later United States Quarter-dollar coin,'' which is specified in the
Compliance Procedure, paragraph 2, of SB-72 and SB-103.
(d) Before further flight, refinish any exposed area of a blade
by following the Compliance Procedure, paragraphs 2 through 6, of
Robinson R22 Service Letter SL-56B and R44 Service letter SL-32B,
dated April 30, 2010, for both the R22 and R44 series helicopters.
(e) Before further flight, replace any unairworthy blade with an
airworthy blade.
Note: The Robinson letter titled ``Additional Information
Regarding Main Rotor Blade Skin Debonding,'' dated May 25, 2007,
which is not incorporated by reference, contains additional
information about the subject of this AD. This document is available
at http://www.robinsonheli.com.
(f) To request a different method of compliance or a different
compliance time for this AD, follow the procedures in 14 CFR 39.19.
Send your request to the Manager, Los Angeles Aircraft Certification
Office, FAA, Airframe Branch, 3960 Paramount Blvd., Lakewood,
California 90712, regarding Model R22 helicopters ATTN: Eric D.
Schrieber, Aviation Safety Engineer, telephone (562) 627-5348, fax
(562) 627-5210, or regarding Model R44 helicopters Attn: Fred
Guerin, Aviation Safety Engineer, telephone (562) 627-5232, fax
(562) 627-5210.
(g) Special flight permits will not be issued.
(h) The Joint Aircraft System/Component (JASC) Code is: 6210
Main Rotor Blades.
(i) The inspections shall be done following the specified
portions of Robinson R22 Service Bulletin SB-103, dated April 30,
2010, or R44 Service Bulletin SB-72, dated April 30, 2010, as
appropriate for each model helicopter. Repaint the exposed area of a
blade by following Robinson R22 Service letter SL-56B and R44
Service Letter SL-32B (combined in one document), dated April 30,
2010. The Director of the Federal Register approved this
incorporation by reference in accordance with 5 U.S.C. 552(a) and 1
CFR part 51. Copies may be obtained from Robinson Helicopter
Company, 2901 Airport Drive, Torrance, CA 90505, telephone (310)
539-0508, fax (310) 539-5198, or at http://www.robinsonheli.com/servelib.htm. Copies may be inspected at the FAA, Office of the
Regional Counsel, Southwest Region, 2601 Meacham Blvd., Room 663,
Fort Worth, Texas, or at the National Archives and Records
Administration (NARA). For information on the availability of this
material at NARA, call 202-741-6030, or go to: http://www.archives.gov/federal_register/code_of_federal_regulations/ibr_locations.html.
(j) This amendment becomes effective on July 5, 2011.
[[Page 35334]]
Issued in Fort Worth, Texas, on June 2, 2011.
Kim Smith,
Manager, Rotorcraft Directorate, Aircraft Certification Service.
[FR Doc. 2011-14246 Filed 6-16-11; 8:45 am]
BILLING CODE 4910-13-P
Sources. Section 1 is written by AircraftDirectives from the record below and is a reading aid only. Section 2 is the United States Government's own text, reproduced without edit.
Federal Register: https://www.federalregister.gov/documents/2011/06/17/2011-14246/airworthiness-directives-robinson-helicopter-company-model-robinson-r22-r22-alpha-r22-beta-r22
Official PDF: https://www.govinfo.gov/content/pkg/FR-2011-06-17/pdf/2011-14246.pdf
Packet generated 2026-08-19 00:56 UTC.
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Responsibility remains with the owner/operator. Under 14 CFR §91.403 and §91.417 the owner or operator is responsible for maintaining airworthiness and for required records; under §39.7 no person may operate a product to which an airworthiness directive applies except in accordance with that directive. Determining applicability to a specific serial number and configuration, and performing or supervising any required action, is the responsibility of the owner/operator and appropriately certificated personnel.
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