ATA 38 Waterwaste

LEGEND

Procedures Required

(O) – An operational procedure
(M) or (M#) – A maintenance procedure
(O)(M) or (O)(M#) – Both operational and maintenance procedures

Repair Interval Categories

Category A

Items in this category shall be repaired within the time interval specified in the "Remarks or Exceptions" column of the air operator's approved MEL. Whenever the proviso in the "Remarks or Exceptions" column of the MMEL states cycles or flight time, the time interval begins with the next flight. Whenever the time interval is listed as flight days, the time interval begins on the flight day following the day of discovery.

Time Limited Dispatch - Some MMEL's for aircraft that are equipped with FADEC engines have relief that is subject to time limited dispatch expressed as a specific number of engine hours, and will start in accordance with the times established by the engine manufacturer or as indicated in the remarks column of the MMEL. Time limited relief cannot be extended.

Category B

Items in this category shall be repaired within 3 consecutive calendar days excluding the day of discovery.

Category C

Items in this category shall be repaired within 10 consecutive calendar days, excluding the day of discovery.

Category D

Items in this category shall be repaired within 120 consecutive calendar days, excluding the day of discovery. To be considered for placement in Category D, the item must be of an optional nature, or excess equipment which an air operator may, at his/her discretion, deactivate, remove from or install on an aircraft.

To be approved for Category D, the item must meet the following criteria:

  1. the absence of the item does not adversely affect crew member's workload;
  2. the crew members do not rely on the function of that item on a routine or continuous basis; and,
  3. the crew members' training, subsequent habit patterns and procedures do not rely on the use of that item.

Category D relief will generally not be approved for equipment which is considered to increase the level of safety, even if that equipment is of an optional nature.

ITEM:  38-10-1  POTABLE WATER SYSTEMS

System and Sequence No. Item Repair
Interval
Category
Number
Installed
Number
required
for
dispatch
Procedures
required
Remarks or Exceptions
Potable Water Systems C - 0 (M)(O)

System may be inoperative provided:

a) Tank is drained and inspected to ensure no leakage, and

b) Procedures are established to deactivate applicable system components to prevent its use or servicing.

NOTES:
1. The (O) procedure addresses other means for water provision for crew members as well as the need to advise of system status during crew changes.

2. Aviation Occupational Health & Safety (AOH&S) requirements should be addressed.

C - 0 (M)(O)

Individual components may be inoperative provided:

a) Associated components are deactivated or isolated, and

b) Associated system components are verified not to have leaks.

NOTE:
Any portion of the system that operates normally may be used.

DISCUSSION:

References:  FAA PL 83 (Rev. 4, 15 Oct. 2001)

Because there are two possible designs, one with the lavatory and potable water systems completely independent and one with the two systems linked, the MEL will need to provide appropriate system specific relief.  The (M) procedure will need to address deactivation of components to include electrical and pressurization systems.

There is no change to this item with FAA PL 83 (Rev. 4, October 15, 2001).

FAA Differences:  TCCA does not limit this relief to only air carrier aircraft.  TCCA also changed wording for completeness and clarification.

ITEM:  38-30-1  LAVATORY WASTE SYSTEMS

System and Sequence No. Item Repair
Interval
Category
Number
Installed
Number
required
for
dispatch
Procedures
required
Remarks or Exceptions
Lavatory Waste Systems
If more than one lavatory (includes wheelchair accessible lavatories) C - 1 (M)(O)

May be inoperative provided:

a) Waste is drained and system is inspected for leakage,

b) Procedures are established to deactivate system components,

c) Lavatory door is locked closed and placarded “INOPERATIVE - DO NOT ENTER”,

d) The Pilot in Command will determine if flight duration is acceptable with a FWD/Upper Deck lavatory unusable, and

e) There is at least one serviceable lavatory on the aircraft.

If one lavatory (includes wheelchair accessible lavatories) C - 0 (M)(O)

May be inoperative provided:

a) Waste is drained and system is inspected for leakage,

b) Procedures are established to deactivate system components,

c) Lavatory door is locked closed and placarded “INOPERATIVE - DO NOT ENTER”.

NOTES:
1. The (O) procedure addresses other means for water provision for crew members as well as the need to advise of system status during crew changes.

2. Aviation Occupational Health & Safety (AOH&S) requirements should be addressed.

Lavatory Waste Systems (M)(O)

Individual components may be inoperative provided:

a) Associated components are deactivated or isolated, and

b) Associated system components are verified not to have leaks.

NOTE:
Any portion of the system that operates normally may be used.

DISCUSSION:

References:  FAA PL 83 (Rev. 4, 15 Oct. 2001)

Because there are two possible designs, one with the lavatory and potable water systems completely independent and one with the two systems linked, the MEL will need to provide specific system relief.

The (O) procedures must also address details for lavatory inspections.

It is noted that Civil Aviation, Cabin Safety discussed this item with Aviation Occupational Health & Safety (AOH&S) and it was agreed that some relief could be permitted.  However, the subsequent opposing inputs to Flight Test on this item made it apparent that agreement could not be reached without further discussion.  The proposed AOH&S relief was cat B and A, one flight day, respectively while one industry input was for a ”self regulated by off loading passengers” cat D.

Rather than try to resolve these opposing positions and in view of the fact that lavatories were considered a passenger convenience item a short time ago, it has been decided to assign a cat C.
This will also harmonize with the FAA categorization for passengers.

FAA Differences:  TCCA added some detail to the item for clarification and required one lavatory to be operative for multi-lavatory equipped aircraft.

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