Published 2024-10-24 · Federal Register document 2024-24465
Airworthiness Directives; Airbus SAS Airplanes
Publication summary
The FAA is superseding Airworthiness Directive (AD) 2023-07-13 which applied to certain Airbus SAS Model A350-941 and -1041 airplanes. AD 2023-07-13 required repetitive detailed inspections of the lower attachment studs on the AFT galley complex and, depending on findings, replacement of the lower attachment studs. This AD was prompted by a determination that additional airplanes are affected, and that all affected parts must be replaced with serviceable parts. This AD continues to require the actions in AD 2023-07-13, adds airplanes to the applicability, and requires the replacement of all affected parts; as specified in European Union Aviation Safety Agency (EASA) AD, which is incorporated by reference. The FAA is issuing this AD to address the unsafe condition on these products.
Why this record is shown
Source: Federal Register annual FAA metadata. Acquired 2026-09-03T22:24:17.530091+00:00. The title, summary and date are source facts.
- Source revision
- federal_register_ad_metadata_2024-766a4e72ab891edd
- Source row
- results[240]
- Raw source SHA-256
- 766a4e72ab891edde7194caaae181bc9ea3fd0d54e65313e290f97067e3b7c5a
Final-rule publication
Recorded publication clauses
- AD identifier printed in this edition
- 2024-20-01
- Effective date printed in this edition
- 2024-11-29
Read 11 complete recorded clauses
Effective Date
(a) Effective Date
This airworthiness directive (AD) is effective November 29,
2024.
Exact source excerpt. Text positions 9855–9947, end exclusive, in the original decoded publication. SHA-256: c2656455c501abb8e87ccdcc7ac5175c67e60e148432eb103a570cfc3a3bafe3
Affected ADs
(b) Affected ADs
This AD replaces AD 2023-07-13, Amendment 39-22415 (88 FR 31169,
May 16, 2023) (AD 2023-07-13).
Exact source excerpt. Text positions 9947–10067, end exclusive, in the original decoded publication. SHA-256: de536c06cd5a0de4a931c3cf42411b09b5abfaee22e1b3636d1282159d755ff6
Applicability wording · Applicability
(c) Applicability
This AD applies to Airbus SAS Model A350-941 and -1041
airplanes, certificated in any category, as identified in European
Union Aviation Safety Agency (EASA) AD 2024-0078, dated March 20,
2024 (EASA AD 2024-0078).
Exact source excerpt. Text positions 10067–10308, end exclusive, in the original decoded publication. SHA-256: 33bc7cac96243d563766d638e91dffd5d17791e4448afc1c0d3686c6a9a85c76
Subject
(d) Subject
Air Transport Association (ATA) of America Code 25, Equipment/
furnishings.
Exact source excerpt. Text positions 10308–10402, end exclusive, in the original decoded publication. SHA-256: cd842d64513c20d1d1bce522de9bad2824ec75abe7ad967bbaaaf7decc400437
Unsafe Condition
(e) Unsafe Condition
This AD was prompted by reports of broken lower attachment studs
having P/N XP14-070-007800 on the AFT galley complex. The FAA is
issuing this AD to address broken lower attachment studs having
XP14-070-007800 on the AFT galley complex. The unsafe condition, if
not addressed, could lead to galley module detachment, resulting in
injury to airplane occupants and reduced capacity for emergency
evacuation of the airplane.
Exact source excerpt. Text positions 10402–10857, end exclusive, in the original decoded publication. SHA-256: 61ae96a6fb9bd05577fb9e01100eadfa2d03f90259adf2f53bf722974ce7140a
Compliance
(f) Compliance
Comply with this AD within the compliance times specified,
unless already done.
Exact source excerpt. Text positions 10857–10959, end exclusive, in the original decoded publication. SHA-256: 00fbfa31932483f627d0ce0a11cbd2e35e15d9231842b91ac85623ce533912d3
Requirements
(g) Requirements
Except as specified in paragraph (h) of this AD: Comply with all
required actions and compliance times specified in, and in
accordance with, EASA AD 2024-0078.
Exact source excerpt. Text positions 10959–11144, end exclusive, in the original decoded publication. SHA-256: aab188846eb1f1798067f496ddef404665dfa122afc618c7a193b80062c70228
Exceptions to EASA AD 2024-0078
(h) Exceptions to EASA AD 2024-0078
(1) Where EASA AD 2024-0078 refers to ``04 October 2022 [the
effective date of EASA AD 2022-0196],'' this AD requires using June
20, 2023 (the effective date of AD 2023-07-13).
(2) Where EASA AD 2024-0078 refers to its effective date, this
AD requires using the effective date of this AD.
(3) Where paragraphs (1), (2), (3), and (4) of EASA AD 2024-0078
specify actions ``in accordance with approved instructions issued by
Airbus DOA,'' this AD requires replacing that text with ``in
accordance with approved instructions issued by the Manager, Large
Aircraft Section, International Validation Branch, FAA; or EASA; or
Airbus SAS's EASA Design Organization Approval (DOA). If approved by
the DOA, the approval must include the DOA-authorized signature.''
(4) This AD does not adopt the ``Remarks'' section of EASA AD
2024-0078.
Exact source excerpt. Text positions 11144–12036, end exclusive, in the original decoded publication. SHA-256: ea7c06ecfbbdeacf3f99ceac3f79b0756547d9011db79b6ccb7243d0fd9ee113
Additional AD Provisions
(i) Additional AD Provisions
The following provisions also apply to this AD:
(1) Alternative Methods of Compliance (AMOCs): The Manager,
International Validation Branch, FAA, has the authority to approve
AMOCs for this AD, if requested using the procedures found in 14 CFR
39.19. In accordance with 14 CFR 39.19, send your request to your
principal inspector or responsible Flight Standards Office, as
appropriate. If sending information directly to the manager of the
International Validation Branch, mail it to the address identified
in paragraph (j) of this AD. Information may be emailed to:
[email protected].
(i) Before using any approved AMOC, notify your appropriate
principal inspector, or lacking a principal inspector, the manager
of the responsible Flight Standards Office.
(ii) AMOCs approved previously for AD 2023-07-13 are approved as
AMOCs for the corresponding provisions of EASA AD 2024-0078 that are
required by paragraph (g) of this AD.
(2) Contacting the Manufacturer: For any requirement in this AD
to obtain instructions from a manufacturer, the instructions must be
accomplished using a method approved by the Manager, International
Validation Branch, FAA; or EASA; or Airbus SAS's EASA DOA. If
approved by the DOA, the approval must include the DOA-authorized
signature.
(3) Required for Compliance (RC): Except as required by
paragraph (i)(2) of this AD, if any material contains paragraphs
that are labeled as RC, the instructions in RC paragraphs, including
subparagraphs under an RC paragraph, must be done to comply with
this AD; any paragraphs, including subparagraphs under those
paragraphs, that are not identified as RC are recommended. The
instructions in paragraphs, including subparagraphs under those
paragraphs, not identified as RC may be deviated from using accepted
methods in accordance with the operator's maintenance or inspection
program without obtaining approval of an AMOC, provided the
instructions identified as RC can be done and the airplane can be
put back in an airworthy condition. Any substitutions or changes to
instructions identified as RC require approval of an AMOC.
Exact source excerpt. Text positions 12036–14221, end exclusive, in the original decoded publication. SHA-256: 4545ca1b17c2ae08c44f3b643b5275da2bdc7a532d3e0eb690a68e98a2d81ab9
Additional Information
(j) Additional Information
For more information about this AD, contact Dat Le, Aviation
Safety Engineer, FAA, 1600 Stewart Avenue, Suite 410, Westbury, NY
11590; telephone 516-228-7300; email [email protected].
Exact source excerpt. Text positions 14221–14440, end exclusive, in the original decoded publication. SHA-256: 72bee16439f1c8cc4e5db385130e8072525f5b5a1f9a60aa754e6a21066db98f
Material Incorporated by Reference
(k) Material Incorporated by Reference
(1) The Director of the Federal Register approved the
incorporation by reference (IBR) of the material listed in this
paragraph under 5 U.S.C. 552(a) and 1 CFR part 51.
(2) You must use this material as applicable to do the actions
required by this AD, unless this AD specifies otherwise.
(i) European Union Aviation Safety Agency (EASA) AD 2024-0078,
dated March 20, 2024.
(ii) [Reserved]
(3) For EASA AD 2024-0078, contact EASA, Konrad-Adenauer-Ufer 3,
50668 Cologne, Germany; telephone +49 221 8999 000; email
[email protected]; website easa.europa.eu. You may find this EASA
AD on the EASA website ad.easa.europa.eu.
(4) You may view this material at the FAA, Airworthiness
Products Section, Operational Safety Branch, 2200 South 216th
Street, Des Moines, WA. For information on the availability of this
material at the FAA, call 206-231-3195.
(5) You may view this material at the National Archives and
Records Administration (NARA). For information on the availability
of this material at NARA, visit www.archives.gov/federal-register/cfr/ibr-locations or email [email protected].
Exact source excerpt. Text positions 14440–15608, end exclusive, in the original decoded publication. SHA-256: 2bb7cd6423c39d0269ee078a5ec5272f0f10cdca911c1d72bced8ef99fcabe89
Explicit historical replacement wording
Find all recorded historical references to AD 2024-20-01 · 0 printed reference observations in this pinned collection.
These are observations from one dated publication. Current legal status is unknown; aircraft applicability, installed configuration, compliance and burden require separate evidence. Missing or unparsed conditions remain unknown.
Why these observations are shown
They were extracted offline from the same immutable official HTML source as the complete recorded text. The dated source wording, original text coordinates and exact quote digests are retained. PDF/text agreement and current regulatory effect have not been qualified.
Observation revision: whole-ad-publication-clause-observations-1.0.1. Text SHA-256: 37c7ec5baa30add48cb40ece08963272a070a14d143231e4b5abccd0279acceb. Source manifest: f0e3862924322ab0812eca77edb77d929ce9f2a874d7f0f7c75cbba76180b7c6.
Official source · 2024-10-24
Publication text
This is the complete recorded text of this dated publication.
Current legal effect is unknown. Aircraft applicability, installed configuration and compliance require separate evidence. PDF/text agreement has not been evaluated.
Read the complete official publication text
[Federal Register Volume 89, Number 206 (Thursday, October 24, 2024)]
[Rules and Regulations]
[Pages 84801-84803]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2024-24465]
-----------------------------------------------------------------------
DEPARTMENT OF TRANSPORTATION
Federal Aviation Administration
14 CFR Part 39
[Docket No. FAA-2024-1892; Project Identifier MCAI-2024-00198-T;
Amendment 39-22860; AD 2024-20-01]
RIN 2120-AA64
Airworthiness Directives; Airbus SAS Airplanes
AGENCY: Federal Aviation Administration (FAA), DOT.
ACTION: Final rule.
-----------------------------------------------------------------------
SUMMARY: The FAA is superseding Airworthiness Directive (AD) 2023-07-13
which applied to certain Airbus SAS Model A350-941 and -1041 airplanes.
AD 2023-07-13 required repetitive detailed inspections of the lower
attachment studs on the AFT galley complex and, depending on findings,
replacement of the lower attachment studs. This AD was prompted by a
determination that additional airplanes are affected, and that all
affected parts must be replaced with serviceable parts. This AD
continues to require the actions in AD 2023-07-13, adds airplanes to
the applicability, and requires the replacement of all affected parts;
as specified in European Union Aviation Safety Agency (EASA) AD, which
is incorporated by reference. The FAA is issuing this AD to address the
unsafe condition on these products.
DATES: This AD is effective November 29, 2024.
The Director of the Federal Register approved the incorporation by
reference of a certain publication listed in this AD as of November 29,
2024.
ADDRESSES:
AD Docket: You may examine the AD docket at regulations.gov under
Docket No. FAA-2024-1892; 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 final rule, the mandatory continuing airworthiness
information (MCAI), any comments received, and other information. The
address for Docket Operations is U.S. Department of Transportation,
Docket Operations, M-30, West Building Ground Floor, Room W12-140, 1200
New Jersey Avenue SE, Washington, DC 20590.
Material Incorporated by Reference:
<bullet> For EASA material identified in this AD, contact EASA,
Konrad-Adenauer-Ufer 3, 50668 Cologne, Germany; telephone +49 221 8999
000; email [email protected]; website easa.europa.eu. You may find
this material on the EASA website at ad.easa.europa.eu.
<bullet> You may view this material at the FAA, Airworthiness
Products Section, Operational Safety Branch, 2200 South 216th St., Des
Moines, WA. For information on the availability of this material at the
FAA, call 206-231-3195. It is also available at regulations.gov under
Docket No. FAA-2024-1892.
FOR FURTHER INFORMATION CONTACT: Dat Le, Aviation Safety Engineer, FAA,
1600 Stewart Avenue, Suite 410, Westbury, NY 11590; telephone 516-228-
7300; email [email protected].
SUPPLEMENTARY INFORMATION:
[[Page 84802]]
Background
The FAA issued a notice of proposed rulemaking (NPRM) to amend 14
CFR part 39 to supersede AD 2023-07-13, Amendment 39-22415 (88 FR
31169, May 16, 2023) (AD 2023-07-13). AD 2023-07-13 applied to certain
Airbus SAS Model A350-941 and -1041 airplanes. AD 2023-07-13 required
repetitive detailed inspections of the lower attachment studs on the
AFT galley complex for damage (i.e., stress marks, dents, bumps,
corrosion, contamination, cracks, and scratches) and correct
installation and, depending on findings, replacement of the lower
attachment stud. The FAA issued AD 2023-07-13 to address broken lower
attachment studs having Part Number (P/N) XP14-070-007800 on the AFT
galley complex.
The NPRM published in the Federal Register on July 23, 2024 (89 FR
59709). The NPRM was prompted by AD 2024-0078, dated March 20, 2024,
issued by EASA, which is the Technical Agent for the Member States of
the European Union (EASA AD 2024-0078) (also referred to as the MCAI).
The MCAI states that additional airplanes are affected, and that all
lower attachment studs having P/N XP14-070-007800, on the AFT galley
complex must be replaced. Broken lower attachment studs on the AFT
galley complex, if not addressed, could lead to galley detachment,
resulting in injury to airplane occupants and reduced capacity for
emergency evacuation of the airplane.
In the NPRM, the FAA proposed to continue to require the actions in
AD 2023-07-13, add airplanes to the applicability, and require the
replacement of all affected parts, as specified in EASA AD 2024-0078.
The FAA is issuing this AD to address the unsafe condition on these
products.
You may examine the MCAI in the AD docket at regulations.gov under
Docket No. FAA-2024-1892.
Discussion of Final Airworthiness Directive
Comments
The FAA received no comments on the NPRM or on the determination of
the cost to the public.
Conclusion
This product has been approved by the aviation authority of another
country and is approved for operation in the United States. Pursuant to
the FAA's bilateral agreement with this State of Design Authority, it
has notified the FAA of the unsafe condition described in the MCAI
referenced above. The FAA reviewed the relevant data and determined
that air safety requires adopting this AD as proposed. Accordingly, the
FAA is issuing this AD to address the unsafe condition on this product.
Except for minor editorial changes, this AD is adopted as proposed in
the NPRM. None of the changes will increase the economic burden on any
operator.
Material Incorporated by Reference Under 1 CFR Part 51
EASA AD 2024-0078 specifies repetitive detailed inspections for
damaged and incorrectly installed lower attachment studs having P/N
XP14-070-007800 on the AFT galley complex and, depending on findings,
replacement of the lower attachment studs, and eventual replacement of
all affected lower attachment studs having P/N XP14-070-007800. EASA AD
2024-0078 specifies that replacement of all lower attachment studs
having P/N XP14-070-007800 on all affected AFT galleys constitutes a
terminating action for the repetitive detailed inspections.
This material 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.
Costs of Compliance
The FAA estimates that this AD affects 13 airplanes of U.S.
registry. The FAA estimates the following costs to comply with this AD:
----------------------------------------------------------------------------------------------------------------
Cost per Cost on U.S.
Action Labor cost Parts cost product operators
----------------------------------------------------------------------------------------------------------------
Retained actions from AD 2023-07-13...... 2 work-hours x $85 per hour $0 $170 $2,210
= $170.
New actions.............................. 7 work-hours x $85 per hour 95 690 8,970
= $595.
----------------------------------------------------------------------------------------------------------------
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.
Regulatory Findings
This AD will not have federalism implications under Executive Order
13132. This AD will 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 above, I certify that this AD:
(1) Is not a ``significant regulatory action'' under Executive
Order 12866,
(2) Will not affect intrastate aviation in Alaska, and
(3) Will 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
reference, Safety.
The Amendment
Accordingly, under the authority delegated to me by the
Administrator, the FAA amends 14 CFR part 39 as follows:
PART 39--AIRWORTHINESS DIRECTIVES
0
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]
0
2. The FAA amends Sec. 39.13 by:
0
a. Removing Airworthiness Directive (AD) 2023-07-13, Amendment 39-22415
(88 FR 31169, May 16, 2023); and
0
b. Adding the following new AD:
[[Page 84803]]
2024-20-01 Airbus SAS: Amendment 39-22860; Docket No. FAA-2024-1892;
Project Identifier MCAI-2024-00198-T.
(a) Effective Date
This airworthiness directive (AD) is effective November 29,
2024.
(b) Affected ADs
This AD replaces AD 2023-07-13, Amendment 39-22415 (88 FR 31169,
May 16, 2023) (AD 2023-07-13).
(c) Applicability
This AD applies to Airbus SAS Model A350-941 and -1041
airplanes, certificated in any category, as identified in European
Union Aviation Safety Agency (EASA) AD 2024-0078, dated March 20,
2024 (EASA AD 2024-0078).
(d) Subject
Air Transport Association (ATA) of America Code 25, Equipment/
furnishings.
(e) Unsafe Condition
This AD was prompted by reports of broken lower attachment studs
having P/N XP14-070-007800 on the AFT galley complex. The FAA is
issuing this AD to address broken lower attachment studs having
XP14-070-007800 on the AFT galley complex. The unsafe condition, if
not addressed, could lead to galley module detachment, resulting in
injury to airplane occupants and reduced capacity for emergency
evacuation of the airplane.
(f) Compliance
Comply with this AD within the compliance times specified,
unless already done.
(g) Requirements
Except as specified in paragraph (h) of this AD: Comply with all
required actions and compliance times specified in, and in
accordance with, EASA AD 2024-0078.
(h) Exceptions to EASA AD 2024-0078
(1) Where EASA AD 2024-0078 refers to ``04 October 2022 [the
effective date of EASA AD 2022-0196],'' this AD requires using June
20, 2023 (the effective date of AD 2023-07-13).
(2) Where EASA AD 2024-0078 refers to its effective date, this
AD requires using the effective date of this AD.
(3) Where paragraphs (1), (2), (3), and (4) of EASA AD 2024-0078
specify actions ``in accordance with approved instructions issued by
Airbus DOA,'' this AD requires replacing that text with ``in
accordance with approved instructions issued by the Manager, Large
Aircraft Section, International Validation Branch, FAA; or EASA; or
Airbus SAS's EASA Design Organization Approval (DOA). If approved by
the DOA, the approval must include the DOA-authorized signature.''
(4) This AD does not adopt the ``Remarks'' section of EASA AD
2024-0078.
(i) Additional AD Provisions
The following provisions also apply to this AD:
(1) Alternative Methods of Compliance (AMOCs): The Manager,
International Validation Branch, FAA, has the authority to approve
AMOCs for this AD, if requested using the procedures found in 14 CFR
39.19. In accordance with 14 CFR 39.19, send your request to your
principal inspector or responsible Flight Standards Office, as
appropriate. If sending information directly to the manager of the
International Validation Branch, mail it to the address identified
in paragraph (j) of this AD. Information may be emailed to:
[email protected].
(i) Before using any approved AMOC, notify your appropriate
principal inspector, or lacking a principal inspector, the manager
of the responsible Flight Standards Office.
(ii) AMOCs approved previously for AD 2023-07-13 are approved as
AMOCs for the corresponding provisions of EASA AD 2024-0078 that are
required by paragraph (g) of this AD.
(2) Contacting the Manufacturer: For any requirement in this AD
to obtain instructions from a manufacturer, the instructions must be
accomplished using a method approved by the Manager, International
Validation Branch, FAA; or EASA; or Airbus SAS's EASA DOA. If
approved by the DOA, the approval must include the DOA-authorized
signature.
(3) Required for Compliance (RC): Except as required by
paragraph (i)(2) of this AD, if any material contains paragraphs
that are labeled as RC, the instructions in RC paragraphs, including
subparagraphs under an RC paragraph, must be done to comply with
this AD; any paragraphs, including subparagraphs under those
paragraphs, that are not identified as RC are recommended. The
instructions in paragraphs, including subparagraphs under those
paragraphs, not identified as RC may be deviated from using accepted
methods in accordance with the operator's maintenance or inspection
program without obtaining approval of an AMOC, provided the
instructions identified as RC can be done and the airplane can be
put back in an airworthy condition. Any substitutions or changes to
instructions identified as RC require approval of an AMOC.
(j) Additional Information
For more information about this AD, contact Dat Le, Aviation
Safety Engineer, FAA, 1600 Stewart Avenue, Suite 410, Westbury, NY
11590; telephone 516-228-7300; email [email protected].
(k) Material Incorporated by Reference
(1) The Director of the Federal Register approved the
incorporation by reference (IBR) of the material listed in this
paragraph under 5 U.S.C. 552(a) and 1 CFR part 51.
(2) You must use this material as applicable to do the actions
required by this AD, unless this AD specifies otherwise.
(i) European Union Aviation Safety Agency (EASA) AD 2024-0078,
dated March 20, 2024.
(ii) [Reserved]
(3) For EASA AD 2024-0078, contact EASA, Konrad-Adenauer-Ufer 3,
50668 Cologne, Germany; telephone +49 221 8999 000; email
[email protected]; website easa.europa.eu. You may find this EASA
AD on the EASA website ad.easa.europa.eu.
(4) You may view this material at the FAA, Airworthiness
Products Section, Operational Safety Branch, 2200 South 216th
Street, Des Moines, WA. For information on the availability of this
material at the FAA, call 206-231-3195.
(5) You may view this material at the National Archives and
Records Administration (NARA). For information on the availability
of this material at NARA, visit www.archives.gov/federal-register/cfr/ibr-locations or email [email protected].
Issued on September 23, 2024.
Peter A. White,
Deputy Director, Integrated Certificate Management Division, Aircraft
Certification Service.
[FR Doc. 2024-24465 Filed 10-23-24; 8:45 am]
BILLING CODE 4910-13-P
Why this text is shown
The complete text was extracted from the official GovInfo HTML edition for this publication. Acquired 2026-10-09T01:27:24.981268+00:00. Text extraction preserves the recorded source wording; it does not determine current requirements.
Open the captured official edition
- Source SHA-256
- 2e81c13f2285ecbf5c8a43c1432338f7520cea2a9bb904681e43c75a4e92cc3a
- Text SHA-256
- 37c7ec5baa30add48cb40ece08963272a070a14d143231e4b5abccd0279acceb
Return to the full metadata catalog · Search complete publication text · Explore retained publication text and evidence
Coverage and limits
These are dated publication metadata, recorded clauses and literal source observations. Word, model-label, header and reference matches do not establish current legal effect, manufacturer/model identity, aircraft applicability, installed configuration or compliance.
The collection uses 33 explicit annual source snapshots. Source captures and operative-text qualifications have separate states. Missing information remains unknown.