House requests OIG report on Emergency Evacuation
Finds fault with FAA’s data collection and analysis
Inspector General ignores two important points
The US DOT Office of Inspector General (OIG) was requested by the Ranking Member of the House of Representatives Committee on Transportation and Infrastructure and the Ranking Member of the Subcommittee on Aviation :
“…to assess FAA’s process for developing and updating aircraft emergency evacuation standards, including how changes in passenger behavior, passenger demographics, and seating capacity affect the standards.”
The OIG issued a report [43 pages] (1) which did not address a research study on aircraft evacuations which is being completed and (2) which did not assess the requirements imposed on air carriers to perform emergency evacuation tests.
This review was also influenced by recent accidents in which passenger evacuations, while safely completed, raised the public interest in exiting aircraft. There have been suggestions that questions about seat size and pitch may REALLY reflect passenger resistance to the airlines’ reduction of seat dimensions.
- Civil Aeromedical Institute Review
The public’s interest in this area of aircraft safety resulted in Congress passing FAA Reauthorization Act of 2018 with sections related to Aircraft Evacuations:
Though slow, a very thoughtful, engineering experiment is likely to be released by CAMI by the end of 2020 or early 2021. The relevant sections of the 2018 Reauthorization are cited, but the IG report does not mention the progress of the most relevant research on the metrics of emergency evacuation.
- Airline Emergency Evacuation tests
14 CFR § 121.397 creates a significant resource for assessing the efficacy of the existing standards or not. The regulation mandates that each airline when it adds a new aircraft or model to its fleet to prove that the emergency procedures work. The NEW plane requirement assures that the current fleet can meet the 90 second rule:
- Each certificate holder shall, for each type and model of airplane, assigned to each category of required crewmember, as appropriate, the necessary functions to be performed in an emergency or a situation requiring emergency evacuation. The certificate holder shall show those functions are realistic, can be practically accomplished, and will meet any reasonably anticipated emergency including the possible incapacitation of individual crewmembersor their inability to reach the passenger cabin because of shifting cargo in combination cargo-passenger airplanes.
The OIG is known for being thorough. It is odd that the Report did not address either of these issues.
FAA’s Process for Updating Its Aircraft Evacuation Standards Lacks Data Collection and Analysis on Current Evacuation Risks
The Nation’s aviation system is among the safest in the world. Although evacuations of passenger aircraft are rare, FAA lacks comprehensive data on aircraft evacuations in emergencies and a data-driven, systematic process for updating its evacuation standards. This lack of data inhibits FAA’s ability to determine how to improve evacuation regulations and protect passenger safety in emergencies. In addition, FAA cannot rely on accidents to evaluate the adequacy of and make changes to its evacuation standards. By continuously collecting data on emergency evacuations and the state of aviation travel today, FAA would be better positioned to make data driven risk-based decisions to ensure the safety of our Nation’s air carrier passengers.
To improve FAA’s process for updating its standards for emergency aircraft evacuations, we recommend that the Federal Aviation Administrator:
- Develop and implement a systematic process to regularly collect and analyze data on emergency evacuations to determine whether evacuation standards need to be revised or updated based upon current risks.
- Develop a policy or procedures to maintain and analyze a record of critical data from aircraft manufacturers’ evacuation demonstrations and analyses to identify risks and ensure data used in analyses and computer modeling are accurate and up to date.
FAA response from OIG Appendix
The FAA has identified the following key points of disagreement with the draft report:
- Numerous requirements apply to evacuation, including addressing occupant protection, prolonging the time for egress, and enabling faster egress. The report is largely silent on these requirements and focuses only on what is addressed in the full-scale evacuation demonstration. Thus, the draft report creates the impression that the full-scale demonstration is the most important component; however, that conclusion is not consistent with a systems approach to the evaluation of evacuation requirements.
- FAA requirements address real world conditions by considering fires, landing gear collapse, and exit failure, among others.
- FAA retains selected evacuation data, including both test plans and reports, as well as the analyses. The FAA also has access to all certification data.
- Although the evacuation certification process is not covered by 14 CFR Part 5 Safety Management System (SMS) requirements, operators are required to identify hazards under SMS and mitigate them.
- Evacuation times in the accidents cited in the report bear no relation to the certification requirement for a given airplane. The certification standard is a benchmark, under a specific set of conditions, and is not relatable to an actual accident, unless all of the same conditions exist. In an actual event, the key parameter is whether the time required to evacuate is less than the time available to evacuate. The time required is particularly difficult to establish for evacuations in non-emergency conditions.
There are many variables to minimizing risk on emergency evacuations. Increased passenger girth, support animals, carry-on bags stored beneath seats, seat pitch and seat width are among the most prominent concerns.
The most RELIABLE, immediate, and easily implemented reduction of risks in these dangerous situation is WITHIN THE CONTROL OF EACH PASSENGER—LEAVE EVERYTHING ON THE PLANE WHEN YOU EGRESS.
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