head in February 1979. Again the carrier evaluation indicated that the cause of the damage was related to personnel error, and that there was apparently no extensive effort to evaluate the enginepylon assembly removal and reinstallation procedures. The bulkhead was also repaired using the procedure previously approved by McDonnell Douglas.
The carrier did not report the repairs that were made to the two bulkheads to return them to service, and there was no regulatory requirement to do so. What constitutes a major repair may be subject to interpretation, but what is to be reported is not. The bulkheads were not altered; they were repaired. Even had the repairs been classified by the carrier as major, 14 CFR 121.707(b) only requires that a report be prepared and kept available for inspection by a representative of the FAA. Second, the regulation does not indicate that the contents of the required report include a description of the manner in which the damage was inflicted. The regulation and the evidence indicated that the purpose of the reports was to permit the FAA to evaluate the end-product to insure that the basic design of the repaired or altered part had not been changed.
The Mechanical Reliability Reporting criteria of 14 CFR 121.703 requires the certificate holder to report "the occurrence or detection of each failure, malfunction, or defect concerning. . .' and then lists 16 criteria to which these apply. The FAA and apparently the aviation industry have traditionally interpreted 121.703 to apply to only service-related problems, which would therefore exclude reporting-of the flange damage caused by maintenance. In view of this interpretation, the board concludes that there is a serious deficiency in the reporting requirements which should be corrected.
Therefore, the safety board concludes that neither the air carrier nor the manufacturer interpreted the regulation to require further investigation of the damages or to report the damage to the FAA. However, the safety board views the omission of such requirements as a serious deficiency in the regulations.
McDonnell Douglas did not investigate Continental Airlines' maintenance procedures and accepted its finding that the damage was due to maintenance error. However, two months later McDonnell Douglas received the report that a second bulkhead was damaged, that the location and type of damage was almost identical to the damage inflicted on the first bulkhead, and that the damage was again due to maintenance error. McDonnell Douglas then had the opportunity to question whether maintenance error was the result of a procedural problem rather than accepting personnel error
A