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Sunday, August 17, 2014

Fuel Gauges: Do they Indicate Properly


Fuel Gauges: Do they Indicate Properly?

by Tom Bennett, Civil Aviation Safety Inspector, Aircraft Maintenance and Manufacturing, Prairie and Northern Region, Civil Aviation, Transport Canada
There have been multiple incidents of fuel exhaustion over the past few years. In the last issue of the Aviation Safety Letter (ASL), you read about fuel starvation due to improper fuel selector condition. In this article, I would like to talk about another common factor in fuel starvation incidents: fuel gauges that do not indicate properly.
Some incidents were very public, whereas most incidents went unnoticed with the exception of being listed in the Civil Aviation Daily Occurrence Reporting System (CADORS). Some incidents were directly related to poor fuel management by the flight crew(s); however a few came as a surprise to the flight crew, as the fuel gauge(s) still indicated there was fuel in the tanks. An accurate reading of the fuel gauge may have prevented many of these occurrences.
There is some confusion about the need for serviceable fuel gauges. This confusion is especially prominent in the general aviation world. As both an aircraft maintenance and manufacturing inspector and an enforcement investigator, I have heard statements like: “The gauges have never worked properly. I just keep track of time in my tanks,” many times.
Such a statement is contrary to Canadian Aviation Regulation (CAR) 605.14(j)(i), which states: “No person shall conduct a take-off in a power-driven aircraft for the purpose of a day VFR flight unless it is equipped with a means for the flight crew, when seated at the flight controls to determine the fuel quantity in each main fuel tank […]”. This regulation is then carried through in sections 605.14, 605.15, 605.16 and 605.18 of the CARs, to apply to all power-driven aircraft in all nature of flights (day/night visual flight rules [VFR]/instrument flight rules [IFR]).
Furthermore, many aircraft must have their fuel gauges working as per their type certificates. For larger aircraft, especially transport category aircraft, the fuel gauges can be deferred by means of the minimum equipment list; however, this usually involves using other measuring devices installed on the aircraft and making complex calculations.

Fuel Gauges that indicate incorrect fuel levels
A common factor in fuel starvation incidents:
fuel gauges that do not indicate properly

Recently, a commercial pilot was fined because one of his fuel gauges was not working while he was operating an aircraft. In this case, as in others, the fuel exhaustion caused substantial damage to the aircraft during the forced landing. The pilot applied to the Transportation Appeal Tribunal of Canada (TATC) to seek relief from the $750. The TATC upheld the Minister’s decision.
The Aviation Enforcement Branch has also sanctioned aircraft owners and operators for unserviceable fuel gauges found during Transport Canada’s oversight activities. The maximum sanctions for an infraction under CAR 605.14, 605.15, and 605.16 are $3,000 for an individual and $15,000 for a corporation. The maximum sanctions for an infraction under CAR 605.18 (IFR) is $5,000 for an individual and $25,000 for a corporation. Inspection, maintenance and repair of a fuel indication system seem less costly, in my opinion.
Another common excuse I hear is that the gauges have always displayed faulty readings or they are too difficult or expensive to calibrate. As an aircraft owner, if you rely on this flawed thinking you are exposing yourself to numerous risks. First and foremost, you risk running out of fuel. This can lead to personal injury/fatality and damage/loss to the aircraft. Second, you are exposed to regulatory action by enforcement (fine or suspension). I think we can all agree that none of these are pleasant outcomes.
For the aircraft maintenance engineers (AME) in this scenario, I have not yet seen an inspection where the functionality of the fuel quantity indication system is not checked. Be careful what you sign for on the inspection forms and subsequently, the maintenance release. Following manufacturers’ instructions for inspection, maintenance and repairs will never lead you astray.
Most pilots and AMEs are aware that any accident or incident results from a series of events; there is never just one cause. Anything we can to do tighten up against the possibility of an error is a step in the right direction. 


Crown Copyright and Licensing, Public Works and Government Services Canada
Crown Copyright Clearance CCL FILE # 2011-33369
(c)Transport Canada, Aviation Safety Letter Issue 1/2011

Sunday, July 6, 2014

USA Today - Unfit for Flight - An In-Depth look at the Editorial Opinion

The USA Today statement suggests that juries awarded in all the aircraft manufacturer cases presented by the author of  Unfit for Flight.  That is simply not true, most of the cases were resolved with judgements.  Having been involved in several aviation product liability cases,  I know personally that these judgements are accepted to mitigate the economics of both time and money.  It is not as USA Today suggests proof positive of conviction in these product liability matters,  it is just another shade of grey as to where the fault might lie and as we know,  shades of grey imply reasonable doubt.

There is a significant issue here - Several law firms target the aviation market, as the issues and procedures of aviation are arcane and not well known among the general public.  This issue was well documented in the discussions surrounding the General Aviation Revitalization Act of 1995.  

The aviation specific trial attorneys know this very well and work to be depicted as experts or teachers as they explain to the juries what they should know about aviation.   It is a definitive bias and a slip of the blindfold on justice.  Whenever a significant aviation tragedy occurs you will find these lawyers set up as media aviation experts across the spectrum of video entertainment.  Expert recognition of these lawyers by the public is key to their sucess rate.

If these trials were held with a "jury of peers" i.e. other pilots - rarely would some of these cases ever darken a courtroom. In keeping with the Opinion aspect of the reports and editorial follow on  -  that is mine.

Case in point - In the three part expose - the author Thomas Frank  talks with a pilot and his crash story.  In this story the pilot relates that a bolt on his engine sheared in flight causing him to lose power.  The FAA and NTSB were all over this pilot about fuel exhaustion and maybe rightfully so.  So let's look a little closer as to why their line of questioning shouldn't have been dismissed offhand.

In the story,  the owner found an expert to redirect the responsibility in this crash.  This aviation expert related that all the fuel was lost when the wing hit a tree - just prior to hitting the ground.  Nice story for non pilots / non aviation savvy people and a good example of talking "aviation" around the general public.  Like I related above,  this story might hold up in front of a jury - just as it was presented to the readership of USA Today. 

The fact that most aircraft have fuel tanks in both wings - makes you question the pilots assertions about his fuel quantity, it also opens a line of questions and thoughts.  This tree did not stop the aircraft, but only damaged a wing.   Did the tree damage both wings?   All the fuel was gone - the only logical conclusion is that the tree damaged both wings equally and in the similar location.    Aircraft fuel tanks in this pilots wing are segregated into separate cells,  some of which have check valves to keep fuel flowing to the engine.  So now having a little information about aircraft, this is what the author Thomas Frank is telling us ....  

  • This pilot hit a tree,  that significantly damaged, but did not stop the aircraft.
  • The damage was significant enough to empty the remaining fuel and was symmetrical to both wings.
  • This damage opened up both multi cell fuel tanks in a similar manner  and in the milliseconds between hitting the tree and ground - all of the fuel disappeared from those fuel tanks and leaked down the trunk of that tree. 

Really...... the limited facts of this story don't hold up to investigative reporting ... Thomas Frank did aviation a disservice by not digging deeper than only the superficial elements of this example.   Mr Frank simply accepted these pilot statements as factual with the support of a court judgement, and an FAA Airworthiness Directive.   If Mr Frank sought out an unbiased aviation expert to discuss these issues, he might have developed a better understanding.

So blindly accepting the expert opinion of what happened to the fuel and knowing that the bolts in question were indicated to have issues in acrobatic and helicopter aircraft just added literal fuel to the fire of Mr. Frank's article. 

One could make an equal unsupported story that the engine starved for fuel and coughing and bucking with the uneven fuel distribution - could have created similar stresses to those encountered in acrobatic or helicopter operations  -  and thus sheared the bolt.  This bolt that the pilot proudly holds, now appears as an icon, saving this pilots dignity.

The above is a story - I believe equal to the author Mr Frank's expose'.   Neither may be true - but there are facts in his story that make a pronouncement of absolute guilt on the part of the engine manufacturer in this case difficult to buy.

Ok so while we are on the subject of fuel starvation - The FAA's rebuttal of the Mr Frank's opus needs a similar examination.  The FAA Administrator clearly indicates "running out of fuel"  is a pilot issue.  This blanket statement piece really needs a closer examination by the FAA.

This comment exposes an issue that has not been handled correctly by the FAA, in my opinion.   By her statement, it indicates that this issue is being ignored from the top down - The admonition that fuel according to the FAA  is a "Preflight" pilot issue.  This line of reasoning ignores that aircraft are required to have working fuel indication by the regulations.  The idea that "preflight" is the only time you know how much fuel you have,  indicates the general lack of satisfaction of fuel indication systems in aircraft.  

Fuel indication in aviation is loathsome at best - it is a dark secret that most aircraft fuel indication systems are marginal from the start.  When you compound a marginal system with poor or no maintenance,  you can make a general statement that an inoperative fuel gauge is common place in aviation.  

Fuel starvation then becomes an aviation issue - and maybe - just not a pilot issue.  

So given Mr. Frank's expose - yes there are issues of safety and yes they need to be improved.  But are we all asking the right questions.

 

Monday, June 23, 2014

USA Today "Unfit for Flight"


There has been a lot of discussion in the aviation community about this 3 Part Expose' Series in      USA Today - Most of our aviation community agree that - we should strive to make aviation safer.  Most of us on this side of the fence,  also agree that the condemnation of manufacturers in this industry was - just a little slanted.  I happen to know several of the players and the other side to many of the examples and lawsuits presented.   It is not as cut and dried as the articles suggest.

Mr Bertorelli - who I respect as an aviation journalist and pilot - made several good points in his Blog  As most people are aware - Aviation is the "most regulated business in the world".  In this industry we laugh at drug and medical device companies - because they have it easy.    In this environment how could an outside news agency find fault with our industry.    Given the economics of this particular business,  it isn't profitable to do a bad job.   Paul stated all of this in his blog very clearly:
There’s wide agreement that over regulation has had a hand in getting us into this mess, so further regulation — of manufacturers or more stringent training requirements —won’t get us out of it.   The entire community just doesn’t have the stomach for it. And neither do I, frankly.  Not to mention the utter lack of any economic engine to drive it all.
I was however struck today with one of Mr. Bertorelli's responses to this safety issue - and because an element of the rebuttal involved a segment of the aviation industry that I have become quite familiar.

At this point, we work on fuel level systems in aviation and most recently the automotive industry.

We have a unique but very narrow viewpoint.

GA Safety: All Heat, No Light

Excerpt from Paul Bertorelli's Blog 

As a refreshing change, the USA Today report almost tried to cast pilots as steely eyed but hapless victims of shoddy manufacturing and outdated aircraft designs. Were it only so. None of us have to look in the mirror to know that although out-of-the-blue mechanicals do cause accidents, preventing every one of that category wouldn’t change the accident rate much.
Even in some of the egregiously poorly prepared reports, the pilot obviously did something stupid—like flying into bad weather, overloading the airplane or, a perennial favorite, running the tanks dry because the fuel gauges aren’t accurate.  

That last item is a cultural thing in which automotive knowledge contaminates aviation thinking. It’s like that GEICO commercial; everybody knows the gauges aren’t accurate and we have means to work around this deficiency.
 
Using a crash as a means of highlighting it seems somehow unsporting. Yeah, the stupid gauges should work, but no, they don’t.  So buy a totalizer or learn to use a watch.
But unless you, as the owner or pilot, take personal responsibility, your 35-year-old Cessna 172 is not going to be fitted with more accurate fuel gauges. 

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Unfortunately neither the NTSB or FAA equate "Bad Fuel Gauges" to Fuel Exhaustion,  but it is interesting that Paul does state this in his blog.  It is quite common to report to the NTSB or FAA after an accident that the fuel gauges are not accurate in your damaged aircraft.  There is no consequence to those statements.  If your flight plan did not indicate average fuel burn - look out.  

I also agree that fuel level is a cultural thing in aviation - I am not familiar with the GIECO reference Paul equates - but fuel level in automotive applications is barely adequate, the website tankonempty.com illustrates this very well.  The issue in aviation, is that for most small aircraft, the fuel level system was taken from a ground vehicle system, think automotive, tractor, truck - This system, was barely adequate for an automotive application as illustrated by the website above  - and this system really struggles with fuel quantities that are 3 times larger, and the fuel and vehicle movement that occurs in aviation.

When we talk to people outside aviation - and we state things like Paul's statement "Yeah the stupid gauges should work, but no, they don't"     - they look at first puzzled and then to a each non aviation person we have stated this quizzes us back "Don't small aircraft run out of fuel"  Yes they do. 
   The National Highway Transportation and Safety Administration - NHTSA in a recent automotive recall for bad automotive fuel fuel gauges on Chevrolet Trucks stated that the there was an obvious safety issue with having bad fuel gauges  - specifically from the recall announcement:
"If a customer runs out of fuel without any warning from the fuel gauge, it will cause the vehicle to stall and increase the risk of a crash, the company said."
In aviation, as Paul Bertorelli stated for fuel level  - "we have work arounds". 

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As I am focussed on a small aspect of the aviation safety issue - and this is seemingly the common aviation response to a significant issue. 

Because from where I am sitting -  maybe the pilot of the 35 year old Cessna 172 should at the least have the fuel gauges checked and calibrated at annual. 

If the gauges are too far gone - he should have the maintenance facility send in a Service Difficulty Report to the FAA - let the Feds know we have an issue out here in the field.   Let's quit making excuses or work arounds for equipment that should and by law be required to function correctly. 

I think we as a community should start questioning these common assertions and take off the cultural blinders.  

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I think we all want to make aviation safer - including USA Today.


Friday, June 13, 2014

Fuel Gauge INOP for initial CFI Check Ride

A Posting from Pilot Instructor Forum 


Hi all,


I am taking my initial CFI check ride this weekend. I went out to fly the airplane (C-R182) from the right seat to practice some maneuvers before the check ride. But, I realized the left fuel gauge is indicating zero no matter how much fuel is in the tank.

It sounds to me like the issue is somewhat controversial. I've heard "fuel guages only need to be accurate when the tank is are empty" and I've also heard that per 14 CFR 91.205 (b) 9 the airplane needs to be equipped with an operable "Fuel gauge indicating the quantity of fuel in each tank".

I tend to agree that the fuel gauge needs to be operable, but there's no time to get the fuel gauge repaired before the check ride. Any advice?


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Yes, per §91.205 a fuel guage for each fuel tank is required for day / night VFR and IFR flight is required to be operational.
You could argue as others did that it only has to “correct” when on empty and I would agree but it has to read something. The other way of looking at it is that the fuel guage has to read something other than empty when their is fuel in the fuel tank.
If your airplane has an approved MEL, it might be allowed to be inoperative provided you verify the amount of fuel in the tank, but for your initial CFI test do not take a chance of busting because of an unairworthy aircraft.
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Remember the Tomato Flames acronym.  F is for fuel gauge.  You must have a functioning fuel gauge.  The acid test is safety.  Do you feel safe flying an airplane with an inop fuel gauge.  I would tend to want to get a ferry permit to get it to a repair facility, or better yet, get it fixed where it sits if you can.  There are too many fuel exhaustion accidents (preventable) per year to take a chance like this.  I know this sounds a little over-reaching, but as a CFI, you are the prime example to the flying public.  To show your willingness to take a chance on an inop fuel gauge sends a dangerous example to your potential students that the Pilot Examiner or FAA Safety Inspector should flunk you for.  Get it fixed then take your exam.
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“I tend to agree that the fuel gauge needs to be operable, but there’s no time to get the fuel gauge repaired before the check ride. Any advice? ”Seems like a no-brainer to me.  You have an unairworthy airplane you’ve been training in and you’re contemplating taking a checkride in it?  for a CFI? BTW, Part 23 says the fuel gauge must be *calibrated* to read 0 when there is no usable fuel in the tank.  Being calibrated to read 0 doesn’t mean that this is the only indication that needs to be accurate.  All scales must be calibrated at a certain weight, and the error increases the further away from that weight that you get.  Even so, the error is usually required to be within a certain range.  Part 23 doesn’t publish that range, but likely there is one.  Someone I know has requested an LOI on the topic from the FAA’s General Counsel’s Office, but it won’t be available until October.
Note: That letter was not published by the FAA General Counsel 
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In reading the above responses a couple of thoughts come to mind.  While by regulation the fuel indicators must function, relying on them for anything other then an indication of possible fuel present is more dangerous then not having a guage at all.  Our flight school had 36 aircraft and there wasn’t a guage in any of them that was even close to accurate.   Many times a student pilot or CFI would request fuel for a plane by reading the guages (without comfirming visually) only to find the tanks topped off.   And conversely, taking off with what they thought were full tanks only to land an hour later with one tank dry.The comment:” There are too many fuel exhaustion accidents (preventable) per year to take a chance like this.  I know this sounds a little over-reaching, but as a CFI, you are the prime example to the flying public.  To show your willingness to take a chance on an inop fuel gauge sends a dangerous example”
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While I wholly agree with the assertions that physically checking and monitoring the fuel quantity using known values is the best practice, the reg is very clear about what is required to be working at all times.  If you fly with a fuel indicator broken (which it clearly is), then you are essentially shooting yourself in the foot.  Yeah, you might get away with it, but then again, you might not.Also, in regard to MEL’s, 91.213 is very specific that any equipment required to be in operation by regulation (such as 91.205) by default can’t be included among the inoperative equipment in an MEL.

Friday, June 6, 2014

Flying with an Inoperative Fuel Gauge - Legal or Not?

A Forum Dialogue about Fuel Gauges in Aircraft

I'm not sure where to post this so I guess I'll just post it here.

So today while pre-flighting my club's 172. I flipped on the master switch to check the fuel gauges. The right fuel gauge, indicated correctly. While the left fuel gauge however, was pegged on empty, even though there was full fuel in the left tank.   I know that fuel gauges should only be accurate when they are empty,  however under 91.205 it states that an operative fuel gauge(s) indicating the quantity of fuel in each tank has to work for a VFR day flight.

I asked the mechanic and he frowned upon me and gave me a lecture on how "fuel gauges should only read zero when empty blah blah," and that I could still fly the airplane.
Wearily I went and asked of one of the CFI's in the FBO and he told me If there is fuel in the tank and the gauge indicates zero or empty then its just an inaccurate gauge. If however, there is no fuel in the tank and the gauge indicates fuel, then that is an inoperative guage.

My question is, I am legal to fly? And what are you thoughts on this? I really dont want to be nit-picky about regulations on the airplane that I fly but, that is my name going into that logbook and I just didn't want to risk it.
Thanks!


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"You wrote this, so it should answer your question.  A further question could be: What is so critical about flying the particular mission you're seeking to (a pleasure flight), that would require you to go against the above? Especially if something were to happen on that flight that attracted Fed attention, related or even unrelated to the inop gauge? Would the club back you then?"


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"Tell the club to fix their stuff. There's no excuse for that kind of Mx laziness, and allowing it or making excuses for it with the "kick the can down the road" mentality they seemingly have, only perpetuates the problem."

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I'd say no, till it is either fixed or deactivated in accordance with the MMEL.The whole "it only has to be accurate at zero" argument to me is moot, It is currently at zero AND it is not accurate.   A broken clock is right twice a day.
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Dip your tanks and use those numbers in your calculations. Flt time x Rate of fuel burn = Gallons of fuel needed then add in your fuel reserves. I don't rely on what a fuel gauge in a 172 says.
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Personally, I wouldn't fly it. I certainly don't want to nitpick a plane apart, but the thing is, the fuel gauge isn't doing anything *at all*!
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I'd fly a plane that had a gauge reading "some fuel" when there was, indeed, some fuel in the tanks, and reading "empty" when it's empty.
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But having a gauge sitting on "empty" 100% of the time isn't acceptable, in my opinion. What's the point in even having the gauge then? Might as well just draw a picture of a gauge on the panel with magic marker, because it would be just as useful.
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Ultimately, I'd pull the "would you rent this plane to a fed?" question on them. If they wouldn't be willing to show it to a FSDO inspector, they need to fix it.

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Notice where the "zero" comes from. It is a guideline for when the fuel gauge must read zero. This is to keep manufacturers from using zero "total" fuel when calibrating the gauge instead of "usable". Other than that there is no mention of gauge "accuracy" in the reg
Also.
Notice the word "operable" in the Part 91 reg?Is the gauge in an "operable" condition if it is always reading zero? No.
Is the gauge in an "operable" condition when reading inaccurately? No.

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I've talked to the maintenance officer for the club and he said he will check it out tomorrow. But I'll definately crank her over and taxi her next time if it ever happens again. Thanks! For all your guys input, it really helps a lot. I knew it wasn't legal,


But yet for some strange reason the mechanics and CFI's at the FBO had a million ways to explain and get around it.