FAA completes CAMI study and receives ARC report on aircraft evacuation
Issues ANPRM asking for comments on safety standards with numbers to refute the data record
Though comfort and convenience not within agency’s jurisdiction, public perception will insist a change in seat size!!!
The FAA has issued an ANPRM asking the public for comments on safety standards on seat width, pitch and length. This Federal Register notice preemptively dismissed submissions on comfort and convenience because such considerations are beyond its statutory authorities. Furthermore, the ease of or suitability of a chair’s dimension are highly subjective, incapable to justifiable regulatory decision.
Aviation and its regulations have always involved NUMBERS. Design, performance, planning and all aspects of flight require the use of hard data- largely because these figures provide the objective measures for making safety decisions. Recently, the world’s aviation regulators have been able to increasingly rely on numbers due more accurate, real time data bases. The Acting FAA Administrator, Billy Nolen, reinforced the need for and value of this SMS data-driven discipline—
“In the FAA, we’ve seen the benefits of SMS in driving down safety risk for commercial aviation, which is why we are working to expand SMS requirements to manufacturers, airports, and aviation service providers.
“And from proactive initiatives like SMS, fatigue risk management, safety reporting programs and others, we have collected a significant amount of safety data.
The more we can collect, analyze and share safety data, and discuss safety issues openly and transparently between stakeholders throughout the world, the better we can achieve a more predictive aviation safety system.
The FAA is actively expanding our portfolio of data collection and analytics tools. And we’re evolving toward using predictive analytics, machine learning and artificial intelligence to yield cleaner, consistent streams of safety data.
Through these tools, we’ll be able to more effectively share safety data with industry stakeholders and international partners.”
As the below articles make clear, the public has ignored SAFETY and focused on COMFORT and CONVENIENCE. Some very junior FAA employee will be tasked to read through a plethora of comments from every passenger who endured an incommodious flight on some airline-the data might include how long the flight was, the dimensions of the torture chairs and a 12.0 rating on the pain scale. While those are all numbers, they do not provide a comparable basis for a regulatory judgment. This Sisyphean chore will push all of these public comments out of consideration
Though the ANPRM made it clear that the docket was open to submissions about demonstrable delays in emergency evacuations. The notice cited the results of Effects of Airplane Cabin Interiors on Egress I: Assessment of Anthropometrics, Seat Pitch, and Seat Width on Egress and of the Emergency Evacuation Standards Aviation Rulemaking Committee Final Report, a combined 193 pages of research and analysis. These appear to provide the FAA with a more than adequate basis for retaining the existing rules. Any advocate for change should focus on refuting these studies. In particular, it should be noted that one of the global approaches to aviation safety has moved from prescriptive to performance rules. The emergency evacuation rule, i.e. the 90 second test, is precisely a measure relying on real result. Another hurdle to overcome is the CAMI analysis of emergency evacuations around the world- a sample of adequate size to incorporate passengers of all sizes, disabilities and other relevant variables.
As any seasoned Washington denizen can tell you, perception is reality particularly in public policy debates. In spite of the careful wording of the ANPRM, the press and the public will expect that the end result will be wider seats and increased pitch (plus no increase in fares)!!!
PUBLISHED JUL 29, 2022
Members of the public can offer feedback on minimum aircraft seat standards.
The Federal Aviation Administration (FAA) will solicit feedback from members of the public regarding a proposed minimum seat size regulation. The agency looks set to finally act on a Congressional mandate passed in September 2018.
FAA sizing up minimum seat size
The Federal Aviation Administration has announced an advance notice of proposed rulemaking (ANPRM) inviting members of the public to comment on minimum dimensions for airplane seats. There will be a 90-day comment period, during which time interested members of the public can submit feedback on possible airplane seat size standards.
The FAA said,
“Congress directed the FAA to, after notice and comment, issue such rules for minimum dimensions for passenger seats that are necessary for passenger safety. The FAA seeks public comment on the minimum seat dimensions that are necessary for passenger SAFETY.”
The aviation agency was given a year to establish a standard for minimum seat dimensions after a congressional mandate in 2018 but failed to do so.
Advocates have also called for a moratorium on airlines to stop further reductions in seat width and pitch if the FAA doesn’t take action soon.
Passenger as put forward to ensure passenger health and safety as airlines have gradually shrunk their seat sizes over the years.
Passenger safety and comfort
The idea for minimum size regulations was put forward to ensure passenger health and safety as airlines have gradually shrunk their seat sizes over the years.
There are concerns that tightly-packed aircraft could hinder evacuations in an emergency. Under current evacuation assessment standards, planes must be able to evacuate within 90 seconds.
In November 2019, the FAA conducted a series of evacuation tests as it sought to set a minimum size standard. The agency has also studied around 300 real-world evacuations to determine the effect seat size has on safety.
“Seats have continued to shrink by some airlines, and people are continuing to get larger. Our estimate is that only 20% of the population can reasonably fit in these seats now. It’s beyond a matter of comfort, or even emergency evacuation; there are serious health and safety issues when you’re put in cramped conditions for hours on end.”
Years of pressure
The FAA was ordered to move forward with minimum seat size regulations as part of a five-year funding reauthorization bill passed in September 2018.
Airline passenger advocacy group FlyersRights.org put forward a petition in 2015 for a minimum size standard which was eventually backed by Congress.
However, the agency has failed to establish any regulations and hasn’t explained why, although the COVID-19 pandemic is certain to have played a role in delays.
Paul Hudson, president of FlyersRights.org, said,
“At some point, enough is enough. The FAA has had three years to address this important safety issue. As we have seen with safety certification, particularly with the Boeing 737 MAX, the FAA chooses to continue to act as a tombstone agency, only acting after fatal accidents occur.”
While there is no guarantee that the FAA will indeed set a minimum seat size, its funding bill is up for reauthorization next year and the issue of seat sizing will be firmly on the agenda.
Professional travelers agree that tighter airplane cabins are a hazard.
“These smaller seats are a safety concern for people period,” said Jeff Jenkins, an award-winning content creator and founder of Chubby Diaries. “If somebody was caught up in the window seat and it takes them a while to get out, it can be bad very quickly.”
For plus-size travelers especially, densifying airplane cabins can be both a comfort and safety issue. Annette Richmond, founder of the Fat Girls Traveling Facebook group, said shrinking airplane seats are a health concern too.
As airplane seats get narrower, she said, “for someone who’s a little more hippy, it’s not uncomfortable, it’s painful. (The armrest is) pressing directly on the bone.”
Richmond added that there’s no standard length for airplane seat belts, which can further complicate things for plus-size travelers because it makes the necessity of a seat belt extender unpredictable.
“It does cause a big safety concern for plus-size people if they don’t have two seats,” Jenkins added.
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