Narrative:

Upon arrival in sfb, following the passenger deplaning, the aircraft was boarded by an FAA inspector from the regional FSDO. As part of his ramp inspection, he requested that I turn on the emergency lights to verify the operation of all installed lights in the emergency lighting system. As the inspector requested, I moved the emergency light switch for the normally 'armed' position to the 'on' position. The inspector proceeded to visually check all the emergency lights. Having found an inoperative bulb, the inspector notified me. I moved the emergency light switch back to the armed position. I then coordinated with our company maintenance control department via cell phone to have the local maintenance contractor send someone out to the aircraft to facilitate repair of the inoperative bulb. The mechanic(south) arrived, opened the light fixture, and found the electrical contacts to be in need of cleaning. The mechanic(south) cleaned the contacts, reinserted the bulb, and asked that I again turn the emergency lights on to verify the bulb was now operating. I again turned on the emergency lights, and the bulb was operating. The following day I became aware of our company policy of not turning on the emergency lights for any reason by the flight crew's, (barring an emergency). This is due to the fact that if the emergency lights are on for approximately 1 1/2 mins or longer, it will take from 1 1/2 to 2 hours to fully recharge the batteries which power the emergency lights. During the course of the FAA inspection/repairs I would estimate that the emergency lights were on for 4-5 mins. I was also told by our flight operations department that company policy dictates that I should have called maintenance control prior to switching on the emergency lights at the FAA's request, and that the maintenance department would communicate directly with the FAA inspector and together they would collectively make a decision about switching on the emergency lights. In summary, by having the emergency lights on for 4-5 mins, and then departing sfb approximately 45 mins later, the batteries which power the emergency lights would not have had enough time to fully recharge. This, as I now understand it, would expose myself to (possible) violation for departing prior to the time required to fully recharge the emergency light batteries. In discussing the situation, after the fact, further with my company flight department, I mentioned that I was fully aware that the flight crew's do not test the emergency lights in the course of normal operations, and that I was aware that testing the emergency lights was solely a maintenance function. However, in the manuals issued to the flight crew's, there is no reference made as to the company policy regarding switching the emergency lights on at the request of an FAA inspector during a ramp inspection. Neither myself, nor the first officer had any knowledge of this company policy, and also no mention of the policy was made during my communication with our maintenance control department during the course of the inspection. Issue a revision to the company operations manual that explains the company policy. This would provide the flight crew's with the knowledge of the company policy, and would also provide documentation that the flight crew's could present to the FAA inspector showing the company policy in writing.

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Original NASA ASRS Text

Title: AFTER FAA INSPECTOR RAMP CHK OF A DC9-32, WHERE IN THE EMER LIGHTING SYS WAS OPERATED WITHOUT PERMISSION FROM COMPANY MAINT PER COMPANY PROCS.

Narrative: UPON ARR IN SFB, FOLLOWING THE PAX DEPLANING, THE ACFT WAS BOARDED BY AN FAA INSPECTOR FROM THE REGIONAL FSDO. AS PART OF HIS RAMP INSPECTION, HE REQUESTED THAT I TURN ON THE EMER LIGHTS TO VERIFY THE OP OF ALL INSTALLED LIGHTS IN THE EMER LIGHTING SYS. AS THE INSPECTOR REQUESTED, I MOVED THE EMER LIGHT SWITCH FOR THE NORMALLY 'ARMED' POS TO THE 'ON' POS. THE INSPECTOR PROCEEDED TO VISUALLY CHK ALL THE EMER LIGHTS. HAVING FOUND AN INOP BULB, THE INSPECTOR NOTIFIED ME. I MOVED THE EMER LIGHT SWITCH BACK TO THE ARMED POS. I THEN COORDINATED WITH OUR COMPANY MAINT CTL DEPT VIA CELL PHONE TO HAVE THE LCL MAINT CONTRACTOR SEND SOMEONE OUT TO THE ACFT TO FACILITATE REPAIR OF THE INOP BULB. THE MECH(S) ARRIVED, OPENED THE LIGHT FIXTURE, AND FOUND THE ELECTRICAL CONTACTS TO BE IN NEED OF CLEANING. THE MECH(S) CLEANED THE CONTACTS, REINSERTED THE BULB, AND ASKED THAT I AGAIN TURN THE EMER LIGHTS ON TO VERIFY THE BULB WAS NOW OPERATING. I AGAIN TURNED ON THE EMER LIGHTS, AND THE BULB WAS OPERATING. THE FOLLOWING DAY I BECAME AWARE OF OUR COMPANY POLICY OF NOT TURNING ON THE EMER LIGHTS FOR ANY REASON BY THE FLC'S, (BARRING AN EMER). THIS IS DUE TO THE FACT THAT IF THE EMER LIGHTS ARE ON FOR APPROX 1 1/2 MINS OR LONGER, IT WILL TAKE FROM 1 1/2 TO 2 HRS TO FULLY RECHARGE THE BATTERIES WHICH PWR THE EMER LIGHTS. DURING THE COURSE OF THE FAA INSPECTION/REPAIRS I WOULD ESTIMATE THAT THE EMER LIGHTS WERE ON FOR 4-5 MINS. I WAS ALSO TOLD BY OUR FLT OPS DEPT THAT COMPANY POLICY DICTATES THAT I SHOULD HAVE CALLED MAINT CTL PRIOR TO SWITCHING ON THE EMER LIGHTS AT THE FAA'S REQUEST, AND THAT THE MAINT DEPT WOULD COMMUNICATE DIRECTLY WITH THE FAA INSPECTOR AND TOGETHER THEY WOULD COLLECTIVELY MAKE A DECISION ABOUT SWITCHING ON THE EMER LIGHTS. IN SUMMARY, BY HAVING THE EMER LIGHTS ON FOR 4-5 MINS, AND THEN DEPARTING SFB APPROX 45 MINS LATER, THE BATTERIES WHICH PWR THE EMER LIGHTS WOULD NOT HAVE HAD ENOUGH TIME TO FULLY RECHARGE. THIS, AS I NOW UNDERSTAND IT, WOULD EXPOSE MYSELF TO (POSSIBLE) VIOLATION FOR DEPARTING PRIOR TO THE TIME REQUIRED TO FULLY RECHARGE THE EMER LIGHT BATTERIES. IN DISCUSSING THE SIT, AFTER THE FACT, FURTHER WITH MY COMPANY FLT DEPT, I MENTIONED THAT I WAS FULLY AWARE THAT THE FLC'S DO NOT TEST THE EMER LIGHTS IN THE COURSE OF NORMAL OPS, AND THAT I WAS AWARE THAT TESTING THE EMER LIGHTS WAS SOLELY A MAINT FUNCTION. HOWEVER, IN THE MANUALS ISSUED TO THE FLC'S, THERE IS NO REF MADE AS TO THE COMPANY POLICY REGARDING SWITCHING THE EMER LIGHTS ON AT THE REQUEST OF AN FAA INSPECTOR DURING A RAMP INSPECTION. NEITHER MYSELF, NOR THE FO HAD ANY KNOWLEDGE OF THIS COMPANY POLICY, AND ALSO NO MENTION OF THE POLICY WAS MADE DURING MY COM WITH OUR MAINT CTL DEPT DURING THE COURSE OF THE INSPECTION. ISSUE A REVISION TO THE COMPANY OPS MANUAL THAT EXPLAINS THE COMPANY POLICY. THIS WOULD PROVIDE THE FLC'S WITH THE KNOWLEDGE OF THE COMPANY POLICY, AND WOULD ALSO PROVIDE DOCUMENTATION THAT THE FLC'S COULD PRESENT TO THE FAA INSPECTOR SHOWING THE COMPANY POLICY IN WRITING.

Data retrieved from NASA's ASRS site as of July 2007 and automatically converted to unabbreviated mixed upper/lowercase text. This report is for informational purposes with no guarantee of accuracy. See NASA's ASRS site for official report.