Operational Policy 15 - Oil and Grease Leaks

The current language in Operational Policy 15 indicates the following: OIL AND GREASE LEAKS - Regulatory Guidance b.(3) At what point should an oil and/or grease leak be written as a violation of 396.5? ANSWER: A violation should not be written until the seepage or leak is great enough to form drops and drip during an inspection.

Discussion has come up as to whether or not this guidance includes hub seal leaks. The minutes and results of the initial issue requests does not specify what leaks this guidance pertains to. If the guidance does not apply to all leaks, it needs to be amended to clarify that hub seal leaks are not included.

Amend Operational Policy 15 to exclude hub seal leaks. Leaks in inner wheel seals are often active but not dripping during inspection, particularly those that are grease packed. Discussion in committee at the time of the addition was that the dripping leak portion in Ops 15 referred to general leaks (oil pan leaks, transmission leaks, PS fluid leaks, etc.). An “active leak” on a hub is anything that includes fresh oil/grease. They frequently don’t drip during the inspection, but they will spray all over when the wheels are rotating and inertia kicks in. The OOS adequately quantifies the leak by indicating that it must be to the extent of contaminating the brake linings. If the evidence of fresh oil or grease is present, it should be considered leaking without a requirement of a drip or drops. Suggest an amendment as follows: OIL AND GREASE LEAKS - Regulatory Guidance b.(3) At what point should an oil and/or grease leak (other than a hub seal leak) be written as a violation of 396.5? ANSWER: A violation should not be written until the seepage or leak is great enough to form drops and drip during an inspection.