DEPARTMENT OF TRANSPORTATION
Federal Aviation Administration
14 CFR Part 39
[Docket No. FAA-2021-0843; Project Identifier MCAI-2020-00256-Q]
Airworthiness Directives; Umlaut Engineering GmbH (Previously P3
Engineering GmbH) HAFEX (Halon-Free) Hand-Held Fire Extinguishers
AGENCY: Federal Aviation Administration (FAA), DOT.
ACTION: Notice of proposed rulemaking (NPRM).
SUMMARY: The FAA proposes to adopt a new airworthiness directive
for certain Umlaut Engineering GmbH (previously P3 Engineering GmbH)
HAFEX (Halon-free) hand-held P3HAFEX fire extinguishers (fire
extinguishers). This proposed AD was prompted by reports of a quality
control issue on certain fire extinguishers, where the spindle
geometries of the fire extinguishers were found to be out of tolerance.
This proposed AD would require removing affected fire extinguishers
from service. The FAA is proposing this AD to address the unsafe
condition on these products.
DATES: The FAA must receive comments on this proposed AD by November
ADDRESSES: You may send comments, using the procedures found in
11.43 and 11.45, by any of the following methods:
Federal eRulemaking Portal: Go to https://www.regulations.gov. Follow
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: Deliver to Mail address between 9 a.m. and
5 p.m., Monday through Friday, except Federal holidays.
For service information identified in this NPRM, contact Umlaut
Engineering, Blohmstrasse 12, Hamburg, Germany 21079, Phone: 49 0 40 75
25 779 0, email: email@example.com, or web: https://www.umlaut.com/hafex.
may view this service information at the FAA, Office of the
Regional Counsel, Southwest Region, 10101 Hillwood Pkwy., Room 6N-321,
Fort Worth, TX 76177. For information on the availability of this
material at the FAA, call (817) 222-5110.
Examining the AD Docket
You may examine the AD docket at https://www.regulations.gov by
searching for and locating Docket No. FAA-2021-0843; or in person at
Docket Operations between 9 a.m. and 5 p.m., Monday through Friday,
except Federal holidays. The AD docket contains this NPRM, the European
Union Aviation Safety Agency (EASA) AD, any comments received, and
other information. The street address for Docket Operations is listed
FOR FURTHER INFORMATION CONTACT: Andrea Jimenez, Aerospace Engineer,
COS Program Management Section, Operational Safety Branch, Compliance
Airworthiness Division, FAA, 1600 Stewart Ave., Suite 410, Westbury, NY
11590; telephone (516) 228-7330; email firstname.lastname@example.org.
The FAA invites you to send any written relevant data, views, or
arguments about this proposal. Send your comments to an address listed
under ADDRESSES. Include ``Docket No. FAA-2021-0843; Project Identifier
MCAI-2020-00256-Q'' at the beginning of your comments. The most helpful
comments reference a specific portion of the proposal, explain the
reason for any recommended change, and include supporting data. The FAA
will consider all comments received by the closing date and may amend
this proposal because of those comments.
Except for Confidential Business Information (CBI) as described in
the following paragraph, and other information as described in 14 CFR
11.35, the FAA will post all comments received, without change, to
https://www.regulations.gov, including any personal information you
provide. The agency will also post a report summarizing each
substantive verbal contact received about this NPRM.
Confidential Business Information
CBI is commercial or financial information that is both customarily
and actually treated as private by its owner. Under the Freedom of
Information Act (FOIA) (5 U.S.C. 552), CBI is exempt from public
disclosure. If your comments responsive to this NPRM contain commercial
or financial information that is customarily treated as private, that
you actually treat as private, and that is relevant or responsive to
this NPRM, it is important that you clearly designate the submitted
comments as CBI. Please mark each page of your submission containing
CBI as ``PROPIN.'' The FAA will treat such marked submissions as
confidential under the FOIA, and they will not be placed in the public
docket of this NPRM. Submissions containing CBI should be sent to
Andrea Jimenez, Aerospace Engineer, COS Program Management Section,
Operational Safety Branch, Compliance & Airworthiness Division, FAA,
1600 Stewart Ave., Suite 410, Westbury, NY 11590; telephone (516) 228-
7330; email email@example.com. Any commentary that the FAA
receives which is not specifically designated as CBI will be placed in
the public docket for this rulemaking.
EASA, which is the Technical Agent for the Member States of the
European Union, has issued EASA AD 2020-0013, dated January 29, 2020
(EASA AD 2020-0013), to correct an unsafe condition for Airbus
Helicopters Model AS 332 C, C1, L, L1, and L2, AS 365 N2 and N3, EC 155
B and B1, EC 175 B, EC 225 LP, SA 330 J, and SA 365 C1, C2, C3, N, and
N1 helicopters; Airbus Helicopters Deutschland GmbH Model EC135 P1, P2,
P2+, P3, T1, T2, T2+, and T3, EC635 P2+, P3, T1, T2+, and T3, and MBB-
BK117 A-1, A-3, A-4, B-1, B-2, C-1, C-2, and D-2 helicopters; Leonardo
S.p.A. Model AB139, AB 204B, AB 205 A-1, AB 212, AB 412, AB 412EP, AS-
61N, AS-61N1, AW139, AW169, and AW189 helicopters; and WSK PZL--
[Sacute]WIDNIK S.A. Model PZL W-3A and PZL W-3AS helicopters. EASA
advises of occurrences that have been reported of a quality issue on
certain fire extinguishers, manufactured by Umlaut Engineering GmbH
(formerly P3 Engineering GmbH), where the spindle geometries of the
extinguishers were found to be out of tolerance. The manufacturing
defect identified in certain serial-numbered fire extinguisher part
numbers (P/Ns) P3APP003010A and P3APP003010C with a manufacturing date
of March 2019 through July 2019 inclusive, where prolonged exposure (12
hours or more) to high temperature conditions of more than 68 [deg]C
(154.4 [deg]F) could cause a non-detectable seizure of the spindle that
could cause the fire extinguisher to be inoperative. This condition, if
not addressed, could prevent proper extinguishing of a fire in the cabin,
possibly resulting in damage to the helicopter and injury to the
Accordingly, EASA AD 2020-0013 requires replacing affected fire
extinguishers and prohibits installing an affected fire extinguisher on
These products have been approved by EASA and are approved for
operation in the United States. Pursuant to the FAA's bilateral
agreement with the European Union, EASA has notified the FAA about the
unsafe condition described in its AD. The FAA is proposing this AD
after evaluating all known relevant information and determining that
the unsafe condition described previously is likely to exist or develop
on other products.
Related Service Information Under 1 CFR Part 51
The FAA reviewed Umlaut Vendor Service Bulletin Doc. No.
P3VSB000001, Issue C, dated December 13, 2019 (VSB P3VSB000001). This
service information specifies procedures for identifying P3HAFEX fire
extinguisher P/Ns P3APP003010A and P3APP003010C, with a date of
manufacture between March 2019 through July 2019, and an S/N listed in
its Appendix 1, to determine if the fire extinguisher should be
replaced. VSB P3VSB000001 also specifies procedures for removing,
installing, and tracking affected P3HAFEX fire extinguishers.
This service information is reasonably available because the
interested parties have access to it through their normal course of
business or by the means identified in the ADDRESSES section.
Proposed AD Requirements in This NPRM
This proposed AD would require removing affected fire extinguishers
from service and prohibit installing affected fire extinguishers on any
Differences Between This Proposed AD and the EASA AD
EASA AD 2020-0013 is issued against various model helicopters and
defines an affected part, whereas this proposed AD is an appliance AD
action against affected fire extinguishers because the unsafe condition
exists in the appliance itself and not in the installation of the
appliance on certain aircraft. EASA AD 2020-0013 identifies some
helicopter models that are affected by this unsafe condition that are
not identified as possibly affected in this proposed AD because those
model helicopters are not FAA type-certificated.
Costs of Compliance
The FAA estimates that this proposed AD affects 762 helicopters of
U.S. Registry. Labor rates are estimated at $85 per work-hour. Based on
these numbers, the FAA estimates that operators may incur the following
costs in order to comply with this proposed AD.
Replacing a fire extinguisher would take about 0.25 work-hour and
parts would cost about $1,200 for an estimated cost of $1,221 per fire
According to Umlaut Engineering GmbH service information, some of
the costs of this proposed AD may be covered under warranty, thereby
reducing the cost impact on affected individuals. The FAA does not
control warranty coverage by Umlaut Engineering GmbH; accordingly, all
costs are included in this cost estimate.
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.
The FAA is 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.
The FAA determined that this proposed AD would not have federalism
implications under Executive Order 13132. This proposed AD would 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, I certify this proposed regulation:
(1) Is not a ``significant regulatory action'' under Executive
(2) Would not affect intrastate aviation in Alaska, and
(3) Would not have a significant economic impact, positive or
negative, on a substantial number of small entities under the criteria
of the Regulatory Flexibility Act.
List of Subjects in 14 CFR Part 39
Air transportation, Aircraft, Aviation safety, Incorporation by
The Proposed Amendment
Accordingly, under the authority delegated to me by the
Administrator, the FAA proposes to amend 14 CFR part 39 as follows:
PART 39--AIRWORTHINESS DIRECTIVES
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]
2. The FAA amends Sec. 39.13 by adding the following new airworthiness