Today’s Aircraft Seating Densities are “SAFE”, but are these Inflight Confrontations Symptoms of Needed Revision of Standards by FAA?

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The below headline is technically incorrect under the current FAA certification standards. Might the current assumptions which support that standard need to be reviewed/revised? Does the Knee Defender (above) diminish the existing margin of safety and therefore should it be subject to the certification standards applicable to the aircraft manufacturer and airplane operator?

The critical test at issue here is labeled “demonstration of emergency evacuation”. At first the requirement was placed on the airline in 14 CFR §121.291 and the test was to show that the passengers and flight attendants, working together, could evacuate the aircraft in 90 seconds or less with only half of the emergency exits operable. In essence it was a simulation of the conditions of an accident. It determined whether the seating geometry was adequate to meet the escape through the maze of seats and exits time test.

A similar rule was incorporated in the Type Certification standards, 14 CFR §25. 803 and the criteria were essentially the same. The history of these side-by-side regulations is laid out in AC 25.803, which reduced some of the redundancy and cross-referenced the two requirements.

The current situation involves the air carriers increasing the seating density of airplanes previously certificated with a lower number of seats. The requirements of §121.291(b)(1)(2) would require a new demonstration. Under these rules, the new seating arrangements have been found by the FAA to be safe.

Whether a passenger reclines a seat or not is technically not a matter of safety; it is a question of passenger convenience and/or passenger behavior. Those are solely within the airlines’ authority.

Perhaps the cramped quarters being complained of are actually symptoms of passengers’ problems? Maybe the reason why there are so many problems is that the customers’ bodies are consuming more space? Maybe the passengers are putting more carry-ons under the seat and thus limiting their own leg rooms? Perhaps the change in seating density, in and of itself, exacerbates the individual’s sense of claustrophobia? Another hypothesis is that with an aging population, the senior passengers are concerned about space and more importantly, more limited in their ability to move under stressful situations. These are questions the answers to which might change the equation of how the FAA determines whether the seating is safe.

The FAA’s standard for passengers’ weight comes from a critical safety function—calculation of the aircraft’s weight and balance. That procedure is found in AC 120.27D Aircraft Weight and Balance Control (dated 8/11/04). Based on 2000 data from the National Health and Nutrition Examination Survey the average male and female winter weights (with clothing) were 205# and 184# respectively (§2, 301, p. 21). The same CDC group noted in a 2004 report that the gain trend continued. Maybe there is reason for the FAA to reconsider its assumptions as to passenger weights?

Another question underlying this series of incidents involves the use of Knee Defender. This piece of equipment is being used without any FAA approval. It is designed to prevent a passenger in the seat in front of another passenger to recline the seat. The device is locked onto the tray table arms with a key. Superficially, the “apparatus” does not come from either the manufacturer or the operator; so the FAA’s normal jurisdictional tentacles do not catch the Knee Defender.

However, this lock, if not released by the key (risks scenarios; passenger is incapacitated, is away from the seat or has lost the key), blocks the passengers between it and the window in some rows. Its removal and/or blockage would add to the time needed to comply with 90 second rule test. If these are fair observations, does the device’s proliferation call into question the past passing grades under §121.291? Or does the Knee Protector pose such a threat to safety that the FAA can/should ban it?

The airlines’ dense seating configurations presumably have met the current safety standards. The frequent confrontations maybe symptoms of deeper problems—weight and age of today’s passengers plus the Knee Defender may require revision of the standards underlying §25.803 and §121.291.

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