No Fire in the Hole - Revisited

July 1, 2001

No Fire in the Hole - Revisited

New regulations affecting aircraft fuel tanks

By Fred Workley July 2001

Editor’s note: Workley’s original "No Fire in the Hole" article discussed currently installed technologies used for fire prevention, fire suppression, and monitoring in cargo compartments and it appeared in AMT Feb. 2000. The article is also available in the Article Search link at

On May 7, 2001, the Federal Aviation Administration issued Special Federal Aviation Regulation (SFAR) No. 88 to minimize the potential for failures that could cause ignition sources in fuel tanks on new and existing airplanes. The new rules require airplane operators and manufacturers to change how airplane fuel tanks are designed, maintained and operated. For the first time, there are mandated requirements to minimize flammability in new airplanes.
The Trans World Airlines (TWA) 800 accident in July 1996 was the start of an extensive review by the FAA and industry that has focused on three areas of concern:
1. Preventing ignition from any source within the fuel tank
2. Fuel flammability
3. Fuel tank inerting
Fuel tank inerting recommendations are expected to be available from the FAA in July 2001.
SFAR 88 is applicable to 6,971 turbine-powered, transport category airplanes that are manufactured by Airbus, Aerospatiale (ATR), Boeing, British Aerospace, Bombardier, DeHavilland, Dornier, Embraer, Fokker, Lockheed, Saab and Shorts that have 30 or more seats. The new rule does two things. First, for existing airplanes, it requires manufacturers to conduct a one-time design review of the fuel tank system for each transport airplane model in the current fleet to ensure that failures could not create ignition sources within the fuel tank. Also, manufacturers must design specific programs for the maintenance and inspection of fuel tanks to ensure the continued safety of the systems. There are also operational changes for existing airplanes, like not running the fuel boost pumps on the B-737 when a tank is empty.

Minimizing ignition sources
Aircraft manufacturers will be required to further minimize the possibility of ignition sources in the fuel tanks on new aircraft designs. This means that transport category airplanes developed in the future will have to address potential failures in the fuel tank system that could result in possible ignition sources. Furthermore, fuel tank safety must be developed and supported by the manufacturer for the operators’ maintenance and inspection programs that identify safety-critical maintenance actions. Manufacturers will need to reduce the time fuel tanks operate with flammable vapors in the tank by designing fuel tank systems that consider adjacent heat sources. This can be done by one of two ways:
1. Minimizing the development of flammable vapors
2. Developing another means, such as onboard fuel tank inerting to prevent catastrophic damage in the unlikely event that ignition might occur
The effective date of the rule is June 6, 2001. Manufacturers have 18 months to conduct the safety review and to develop maintenance and inspection programs as required by the SFAR. Likewise, operators have 36 months from the effective date to incorporate an FAA-approved maintenance and inspection program into their operating procedures. To date, the FAA has issued or proposed about 40 airworthiness directives (ADs) on fuel tank safety. Many of these ADs are a result of lessons learned from the TWA 800 accident investigation and subsequent analysis. Adverse service experience has also shown that if specific maintenance procedures are not carried out on certain airplane fuel systems, there may be a degradation of the design features intended to preclude ignition of vapors within the tank (i.e. bonding, grounding and shielding). This means that technicians will be performing mandatory fuel system maintenance required by the limitations section of the Instructions for Continued Airworthiness for each airplane model. Additional ADs are an expected result of feedback received from the design review of existing aircraft that is required by the new SFAR.

Features of SFAR 88
Fail-Safe Design Methods - The SFAR has the effect of mandating the use of "fail-safe" design methods, which require that the effect of failures and combinations of failures be considered in defining a safe design. Detailed methods of compliance with 25.1309(b), (c), and (d) are described in Advisory Circular (AC) 25.1309-1A, System Design Analysis, and are intended as a means to evaluate the overall risk, on average, of an event occurring within a fleet of aircraft. The following guidance involving failures is offered in that AC:
• In any system or subsystem, a single failure of any element or connection during any one flight must be assumed without consideration as to its probability of failing. This single failure must not prevent the continued safe flight and landing of the airplane.
• Additional failures during any one flight following the first single failure must also be considered when the probability of occurrence is not shown to be extremely improbable. The probability of these combined failures includes the probability of occurrence of the first failure.

Flammability Characteristics -The flammability characteristics of the various fuels approved for use in transport airplanes result in the presence of flammable vapors in the vapor space of fuel tanks at various times during the operation of the airplane. Vapors from Jet A fuel (the typical turbojet engine fuel), at temperatures below approximately 100 degrees F, are too lean to be flammable at sea level; at higher altitudes the fuel vapors become flammable at temperatures above approximately 45 degrees F (at 40,000 feet altitude).
However, the regulatory authorities and aviation industry have always presumed that a flammable fuel air mixture exists in the fuel tanks at all times and have adopted the philosophy that the best way to ensure airplane fuel tank safety is to preclude ignition sources within fuel tanks. This philosophy has been based on the application of fail-safe design requirements to the airplane fuel tank system to preclude ignition sources from being present in fuel tanks when component failures, malfunctions, or lightning encounters occur.

Ignition sources - Possible ignition sources that have been considered include:
• Electrical arcs
• Friction sparks
• Auto ignition. (The auto ignition temperature is the temperature at which the fuel/air mixture will spontaneously ignite due to heat in the absence of an ignition source).
Some events that could produce sufficient electrical energy to create an arc include:
• Lightning
• Electrostatic charging
• Electromagnetic interference (EMI)
• Failures in airplane systems or wiring that introduce high-power electrical energy into the fuel tank system.
Friction sparks may be caused by mechanical contact between certain rotating components in the fuel tank, such as a steel fuel pump impeller rubbing on the pump inlet check valve. Auto ignition of fuel vapors may be caused by failure of components within the fuel tank, or external components or systems that cause components or tank surfaces to reach a high enough temperature to ignite the fuel vapors in the fuel tank.

Fuel Tank Protection - Another source of information on fuel tank protection is the FAA – Fire Safety Section: Systems Fire Group web site. Here, you can find information on fuel flammability and inerting, either completed, or on-going, and planned research by visiting /intro.stm.
To learn more about this SFAR, you can view it on the FAAs website at

New advisory circulars for fuel tanks
Two new Advisory Circulars (AC) entitled Fuel Tank Ignition Source Prevention Guidelines, AC 25.9811-1B, and Fuel Tank Flammability Minimization, AC 25.981-2, both dated 4/18/01, were released by the FAA and support the new SFAR. The first AC provides guidance for demonstrating compliance with the certification requirements for prevention of ignition sources within fuel tanks of transport airplanes. The second pertains to minimizing the formation or mitigation of hazards from flammable fuel air mixtures within fuel tanks. This AC has a section on fuel tank inerting using inert gas, like nitrogen, to keep the oxygen level in the tank ullage below a combustible level to prevent fuel tank flammability.
These efforts at minimizing the chances of fuel tank incidents will help Keep ’em Flying! AMT