OFFICE OF Dy.

CONTINUING AIRWORTHINESS MANAGER,

FLEET-A, WR, MUMBAI
ENGINEERING DEPARTMENT
NEC, Sahar, Mumbai –400 099. Ph:91-22-26811110 E-mail: dgmqatswr@airindia.com

AIRBUS A321 TECHNICAL CIRCULAR NO. 02 OF 2023

Dated: 23/01/2023

ATA: 26
Status: INFORMATORY
Applicability: AIRBUS A321 CEO fleet
Subject: Unintentional activation of cargo fire extinguishing bottle No.1 on
ground
Objective: To apprise all concerned
References: AMM / MEL
AIL Publication affected, if any: Complements A321 TC No. CAMO/WR/04/2014 of 26/06/2014

BACKGROUND:
Air India A321 CEO aircraft certified for EDTO was scheduled to operate a domestic flight from Delhi to
Chennai when unintentional activation of Cargo Fire Extinguishing Bottle No.1 occurred on ground at Delhi.

Similar occurrences have been reported by other operators of Airbus A320 family fleet having twin-cargo
fire extinguishing bottle configuration. No unintentional cargo fire bottle discharge events have been
reported on aircraft having single-cargo fire extinguishing bottle configuration.

These events may occur anytime due to the head of the F/O seat occupant inadvertently touching the
guarded FWD CARGO three-position toggle switch while getting up from the F/O seat. Since upward
movement of each toggle switch from guarded neutral position is for activating fire Bottle No.1, invariably
unintentional activation occurs in FWD cargo compartment.

Probability of accidentally touching AFT CARGO three-position toggle switch while vacating F/O seat is
extremely low by virtue of its switch location on the panel.

DESCRIPTION:
Cockpit panel of A321 aircraft certified for EDTO has one “guarded three-position toggle switch” for each
cargo compartment which is used to discharge the agent from each of the two bottles one at a time.

In case of FWD / AFT cargo fire, applicable toggle switch is used first to discharge Bottle No. 1 into the
relevant cargo compartment by selection to AGENT 1 position. Once the bottle is discharged, DISCH 1 light
comes on. Then after a time delay of 60 minutes from discharge of Bottle No. 1, circuit for activation of
remaining Bottle No.2 is armed and DISCH AGENT 2 reminder light comes on. Crew may then select the
same toggle switch to AGENT 2 position for discharge of the remaining Bottle No.2 in the same cargo
compartment to ensure continuation of EDTO. With Bottle No.2 discharged, DISCH 2 light comes on.

Cockpit panel of A321 Non-EDTO aircraft has one “guarded push button switch” for each cargo
compartment which is used for agent discharge from the single bottle into relevant cargo compartment.
With bottle discharged, DISCH light near applicable push button comes on.

During investigation of this incident, statements of concerned certifying staff as well as cockpit crew were
obtained but none claimed accidental contact with the guarded agent discharge switch.

Review of surveillance video provided by the airport operator revealed baggage handlers / loaders rushing
out of FWD cargo compartment in panic indicative of unexpected event inside the cargo compartment.
Although human presence in the cockpit at the time of incident could not be conclusively ascertained from

A321 TC 02 of 2023 v Page 1 of 4

 OFFICE OF Dy. CONTINUING AIRWORTHINESS MANAGER,
FLEET-A, WR, MUMBAI
ENGINEERING DEPARTMENT
NEC, Sahar, Mumbai –400 099. Ph:91-22-26811110 E-mail: dgmqatswr@airindia.com

the video recording, root cause of cargo fire bottle activation was attributed to unintentional human
contact with the agent discharge switch in the cockpit.

Investigation also revealed that prior to release of flight from Delhi, certifying staff and cockpit crew failed
to report this occurrence to all concerned authorities as per standard procedure. Downloading of SSCVR /
SSFDR data had not been ensured by the certifying staff prior to release of aircraft from Delhi. It was
observed that after the ground occurrence at Delhi, aircraft had operated flight to Chennai with passenger
baggage and cargo although invoked MEL 26-23-01A prohibited carriage of the same.

ACTION:
In view of the observations, it is re-emphasized that meticulous compliance of following guidelines by
certifying staff shall preclude recurrence of similar incidents and subsequent procedural lapses in future:

1) Certifying staff shall be careful of inadvertent contact with cargo fire agent discharge switches during
their presence in the cockpit while performing their assigned duties.
In case of such inadvertent contact and subsequent agent discharge, the occurrence shall be pro-
actively reported by certifying staff to concerned authorities as per laid down “Occurrence
Reporting Procedure”. Further, certifying staff shall also ensure download of SSCVR / SSFDR data
for incident investigation prior to release of aircraft as per regulatory requirement.

2) If discharged cargo fire bottle/s is/are observed during maintenance:

 Certifying staff shall report such occurrence to all concerned through laid down “Occurrence
Reporting Procedure”. Further, certifying staff shall also ensure download of SSCVR / SSFDR
data for incident investigation prior to release of aircraft as per regulatory requirement.
 It is possible to dispatch an aircraft with discharged cargo fire bottle/s under MEL 26-23-01A
provided applicable dispatch criterion is ensured by cockpit crew prior to acceptance of aircraft
for flight.
For EDTO certified aircraft, MEL 26-23-01A stipulates that “One or both fire extinguisher
bottles may be inoperative for a series of flights for return to Base station where maintenance
can be done provided that the cargo compartments are empty or do not contain flammable or
combustible materials”.
The definition of “Flammable or combustible material” is available in the preamble section of
Air India A320 family MEL for the benefit of certifying staff and cockpit crew. By this definition,
passenger baggage is considered flammable and shall not be carried on board as per the
dispatch requirements of MEL 26-23-01A.

(A.D.Chande)
Dy.CAM, Fleet-A, WR
Air India Ltd.
Cc: CAM - HQRS, AIL, Delhi / Dy.CAM-NR/ Dy.CAM-ER
Cc: QM, AIL, Delhi
Cc: All contracted AMOs (As per list of current approved AMOs)
Cc: ED CTE, HYD.
Cc: Air India Technical Library for uploading on Server

A321 TC 02 of 2023 v Page 2 of 4

 OFFICE OF Dy. CONTINUING AIRWORTHINESS MANAGER,
FLEET-A, WR, MUMBAI
ENGINEERING DEPARTMENT
NEC, Sahar, Mumbai –400 099. Ph:91-22-26811110 E-mail: dgmqatswr@airindia.com

ANNEXURE- 1

A321 TC 02 of 2023 v Page 3 of 4

 OFFICE OF Dy. CONTINUING AIRWORTHINESS MANAGER,
FLEET-A, WR, MUMBAI
ENGINEERING DEPARTMENT
NEC, Sahar, Mumbai –400 099. Ph:91-22-26811110 E-mail: dgmqatswr@airindia.com

ANNEXURE- 2

A321 TC 02 of 2023 v Page 4 of 4