Aircraft
Certification Service Washington, DC U.S. Department of Transportation Federal Aviation Administration
CE-10-25
April 5, 2010
This is information only. Recommendations
aren’t mandatory.
Introduction
This Special Airworthiness Information Bulletin (SAIB) alerts type
certificate, amended type certificate, and supplemental type
certificate applicants of an airworthiness concern regarding the issue
of fluid flammability for TKS fluid.
At this time, this airworthiness concern is not considered an unsafe
condition that would warrant an airworthiness directive action under
Title 14 of the Code of Federal Regulations (14 CFR part 39).
Background
In prior certifications of TKS systems on board aircraft, the issue
of fluid flammability was not a concern; the fluid was simply
considered to be non-flammable. However, recent testing has shown that
the fluid is in fact flammable under certain conditions. As a result,
the concerns of 14 CFR, part 23, § 23.853(e), § 23.863, and
§ 23.1365(c) should be appropriately addressed.
Per 14 CFR §23.863(b)(2), it is appropriate to consider the
flammability characteristics of the specific fluid in question. In
2008, flammability testing of TKS fluid was documented by the FAA
Technical Center in Report No. DOT/FAA/AR-TN08/9. The document is
available at http://www.fire.tc.faa.gov/pdf/TN08-9.pdf. The findings of
the Technical Center report are that the TKS fluid is flammable only
under very specific conditions:
Sustained surface ignition
will sometimes occur if a pool of fluid is heated to approximately
150°F and an ignition source is introduced. Above approximately
150°F the ignition is self-extinguishing. However, sustained
surface ignition will occur if a pool of fluid is heated to
approximately 250°F and an ignition source is introduced.
A spray mist will ignite when exposed to a flame, but is not self-sustaining when the ignition source is removed.
A spray mist will undergo “sporadic ignitions” confined to small areas when exposed to a spark, but is not self-sustaining.
A drip or stream directed onto a hot surface will not ignite.
In short, the fluid is only
self-sustainingly flammable when allowed to both pool and heat.
Further, a spray mist is only flammable in the presence of a sustained
ignition source. In essence the report supports the argument that it is
appropriate in certain conditions to treat the fluid as non-flammable.
Recommendations
We recommend that all type certificate, amended type certificate,
and supplemental type certificate applicants assess the pertinent
regulations (14 CFR, part 23, §23.853(e), §23.863, and
§23.1365(c)) for their TKS system and take any appropriate action.
Specifically:
14 CFR, part 23,
§23.853(e), which requires lines, tanks, and other equipment
containing flammable fluids not be installed in passenger compartments
unless shielded, isolated, or otherwise protected such that the fluid
is not a hazard.
14 CFR, part 23,
§23.863, which requires minimization of the probability of
ignition of fluids and vapors for each area where flammable fluids or
vapors could escape.
14 CFR, part 23,
§23.1365(c), which requires main power cables be separated from
TKS fluid lines or be shrouded by electrically insulated flexible
conduct or equivalent, in addition to the normal cable insulation.
In summary:
TKS anti-icing fluid
requires consideration of flammability characteristics in order to
determine its appropriate classification. FAA testing has revealed that
the fluid must be considered as flammable under certain conditions.
Specifically, TKS fluid must be considered flammable when fluid pooling
may occur under conditions that may then elevate the temperature of the
pool to a level that would support sustained combustion.
TKS fluid must also be
considered flammable when conditions could present a situation where a
fine spray is directed onto a sustained flame source.
For Further Information Contact
Leslie B. Taylor, Aerospace Engineer, FAA Small Airplane
Directorate, 901 Locust Street, Room 301, Kansas City, MO 64106; phone:
(816) 329-4134; email: leslie.b.taylor@faa.gov