Congressman demands FAA seat safety study-pitch is safe plus 12 evacuation recommendations -still disappointed

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Rep. Cohen sponsor of mandate for FAA to assess safety of seats

FAA creates ARC full of experts and they examine 300 recent evacuation events

No changes but 12 significant new recommendations

Congressman disappointed


A Congressman is disappointed because an FAA AIRCRAFT CABIN EVACUATION PROCEDURES study was flawed, he believes. The Representative from Tennessee asserts that it is fails because:  “study parameters..[ did not].. take into consideration the time it takes for elderly travelers, children and people who have disabilities to safely evacuate aircraft.”

What were the bona fides of the Civil Aerospace Medical Institute’s study?

  • Experts brought in to assure objectivity-
  • “… the FAA chartered the Emergency Evacuation Standards Aviation Rulemaking (ARC), which met between October 2019 and May 2020. The ARC included dozens of aviation stakeholders, including the National Transportation Safety Board (NTSB), the European Union Aviation Safety Agency, FlyersRights, the Allied Pilots Association, and the Association of Flight Attendants …”
  • seat evacuationWhat did the ARC recommend that CAMI do?
    • “The ARC reviewed nearly 300 real-world[1] evacuation events that occurred over the previous decade. The ARC found the overall level of safety in emergency evacuations to be very high, but made 27 recommendations to the FAA related to how the safety of such evacuations could be improved
  • In addition to the §337 mandated items, the ARC decided to consider factors identified by the FAA as potentially affecting an evacuation.

The 30 page response to Rep. Cohen and the Chairs of the relevant Senate and House Committee include 12 recommendations, which still caused the author of §337 to be disappointed:

recommendations  table



  1. Recommendation: The FAA recommends conducting, in coordination with other aviation authorities, a review of the requirements for marking the escape routes for over-wing exits in Section 25.810 to determine what actions are necessary to improve passenger recognition and allow for transition from the wing to the ground in a manner that is faster and safer than the current types of transitions
  2. Recommendation: The FAA recommends updating guidance for determining aircraft attitudes and measuring sill heights corresponding to the loss of one or more legs of landing gear.
  3. Recommendation: The FAA recommends conducting a review of Sections 25.1362 (“Electrical supplies for emergency conditions”), 25.1423 (“Public address system”), and 121.319 (“Crewmember interphone system”) to ensure the regulations adequately cover all aspects of the survivability and use of flightcrew communication systems. The FAA also recommends evaluating standards for communication system handsets and considering standardization of handsets for communication systems for all aircraft types.
  4. Recommendation: The FAA recommends considering revisions to Section 25.810(d) to make the requirements for off-wing assist means (escape slides) consistent with those in Section 25.810(a), which applies to assist means used at non-over-wing exits.
  5. Recommendation: The FAA recommends examining the existing requirements applicable to emergency lighting systems of transport category airplanes to determine whether the FAA should mandate higher illumination levels consistent with current state-of-the-art lighting systems.
  6. Recommendation: The FAA recommends reviewing Section 25.813(c) further to determine whether it should harmonize the regulation with EASA CS 25.813(c) or whether the FAA can accomplish the objective of EASA CS 25.813(c) by other means. (weight of removable hatch).
  7. Recommendation: The FAA recommends completing research and promoting essential actions for crewmembers to perform during an actual or potential emergency evacuation scenario and, based on the results of this review, as appropriate, issue guidance for:
  8. Aircraft manufacturers to review and revise, as necessary, the Emergency Evacuation Checklist to ensure the actions included on the Checklist are logical, necessary, and appropriately ordered.
  9. Aircraft operators to—
  • Revise the applicable Emergency Evacuation Checklist to align with manufacturer guidance;
  • o Revise procedures to align with industry best practices and FAA research, as described above;
  • o Update emergency procedures to remove ambiguity concerning the decision to initiate, continue, or stop an emergency evacuation;
  • o Ensure appropriate crewmembers complete initial and recurrent emergency evacuation training incorporating the findings of the FAA’s review.
  1. Recommendation: The FAA recommends that, in coordination with other aviation authorities and aircraft accident investigative agencies, it collect, catalogue, and analyze non-urgent evacuations to improve its understanding of the decision-making processes that lead to these events. Based on the results of this recommended review, the FAA might issue guidance to inform potential improvements to operator procedures.
  2. Recommendation: Guidance or oversight by the FAA should address the lack of uniformity in instructions about taking carry-on baggage during an emergency. As an unplanned emergency evacuation can occur either on takeoff or landing, improved briefings should apply to both pre-takeoff and pre-landing announcements. The FAA recommends revising Advisory Circular 121-24D, titled “Passenger Safety Information Briefing and Briefing Card” to include a new paragraph recommending that pre-flight safety announcements and pre-landing safety announcements include instructions that all carry-on bags.
  3. Recommendation: The FAA recommends reviewing Section 25.810(a)(1)(iv) to determine whether it should require the 25-knot wind standard be combined with the effects of an engine running at ground idle for the certification of an escape slide in close proximity to the engine inlet. The FAA may also examine other means to fulfill this intent.
  4. Recommendation: Rep. Cohen→ The FAA recommends implementing a process for periodic review of evacuation-related standards that are based on demographics and anthropometry, such that as those characteristics evolve, the FAA can anticipate the need for changes to the requirements and update the requirements when necessary. This includes regulatory requirements such as those for aisle width and exit size, as well as guidance for dimensions of seat and assist spaces.
  5. Recommendation: The FAA recommends using available data-gathering tools to work with organizations, companies, and individuals to improve evacuation certification and procedures through comprehensive data collection and analysis. Additional data will help identify survival factors in aviation accidents and incidents involving evacuation and will contribute to the periodic review of relevant requirements.

panel of seat info

The above 12 recommendations are valid responses to the ostensible purpose behind §337safety of passengers during an emergency evacuation. #12 recognizes the underlying premise of the Congressman’s visible complaint- the changing diameter of airline passengers over time.

The ARC careful examination of 300 recent passenger disembarkation events constitute expert assessment of a populations typical airline flights TODAY. No need to then subject elderly, handicapped and child test objects to  simulated drills and the validity of such a definition of  SEAT tests has been endorsed by the ARC’s participants.

Perhaps Rep. Cohen’s “disappointment” has more to do with the FAA’s proof that the existing seat pitch and aisle dimensions are safe!!!Rep. Cohen in a seat





Congressman Cohen Expresses Disappointment at FAA Airplane Seat Safety Study


Rep. Cohen

April 1, 2022

Press Release

Participants in the evacuation study were not representative of the flying public


WASHINGTON – Congressman Steve Cohen (TN-09), a senior member of the Committee on Transportation and Infrastructure and its Subcommittee on Aviation, expressed his disappointment at a Federal Aviation Administration (FAA) study of airplane seat sizes as it relates to the emergency evacuations of passengers.

CAMICongressman Cohen’s Seat Egress in Air Travel (SEAT) Act that was included in the Federal Aviation Administration (FAA) Reauthorization Act of 2018 directed the FAA to establish minimum seat size and distance between rows of seats to meet the 90-second emergency airplane evacuation time currently mandated by federal regulations.

The FAA report released today based on the Civil Aerospace Medical Institute (CAMI) study indicates that existing seat sizes do not affect evacuation time. In an accompanying letter to Congressman Cohen, FAA Administrator Dickson acknowledges that the people involved in the evacuation study were all able-bodied adults under 60 and not representative of the flying public. See the report to Congress here.

Congressman Cohen made the following statement:

I am disappointed but not surprised that the flawed study came to the foregone conclusion the airline industry dictated. I repeatedly called upon the FAA to reexamine its study parameters and take into consideration the time it takes for elderly travelers, children and people who have disabilities to safely evacuate aircraft. The flying public cannot rely on the results of this study nor should seat sizes be based solely on the study’s results. I look forward to participating in the FAA’s forthcoming public comment period and hope the input is taken seriously before the FAA makes its final determination on minimum seat dimensions that are necessary to ensure passenger safety.”


[1] With that sample size, it is HIGHLY likely that some of the passengers included “elderly travelers, children and people who have disabilities.”

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