Open Letter to Australian PM Re 1:50
OPEN LETTER TO:
Prime Minister, Kevin Rudd,
Attorney General, Robert McClelland
Foreign Minister, Steven Smith
Minister for Transport, Anthony Albanese
Dear Prime Minister and Ministers,
I am writing to alert your various departments to a situation which has the potential to bring as much discredit on the Federal Government as the recent home insulation debacle.
The Prime Minister Kevin Rudd, Attorney General Robert McClelland and Foreign Minister Stephen Smith trumpeted the 2010 Counter-Terrorism White Paper, “Securing Australia, Protecting Our Community”, which contained the following key point under the heading "Protection"
"Improving the security of our airports to enhance protection of the traveling public"
Totally contrary to this initiative, the Department of Transport through The Civil Aviation Safety Authority, has issued a Notice of Proposed Rule Making that will effectively negate any "enhanced protection of the traveling public”.
The rule change proposed by CASA to allow a reduction of the cabin crew to passenger ratio from 1 crew member to every 36 passengers, to “a ratio of 1 cabin crew member for every 50 passenger seats or part of that number. The proposed change will be applicable to aircraft with a passenger seat configuration of more than 36 but not more than 216,” CASA's intention can only be to legitimise their already flawed concessions given to low cost carriers. The current requirement in Australia is 1:36, the requirement is 1:40 in Canada and 1:50 in the USA, the very lowest standard in the world . CASA, in its race to the bottom, makes false claims that 1:50 is harmonisation with “world’s best practice”. World’s best practice, is in fact what Australia has always had. Why do we as Australians not acknowledge that in some instances we do better than the rest of the world! What is the cultural cringe that makes us lower our standards to placate cheap, mostly foreign owned carriers? Surely it is the role of CASA to enhance the safety of the Australian traveling public.
On the 6th of May 2008 the Minister for Infrastructure, Transport and Regional Development, Anthony Albanese announced there would be “more money for security upgrades at regional airports”. Who has been providing this security and surveillance to date? I put it to you that it is the current function of the regional and domestic cabin crew. Does the Government think that removing them on some commuter aircraft, and reducing their numbers on domestic aircraft and hence their capacity to do their job effectively, will enhance “the protection of the traveling public” as per your stated aim? No matter how many scanners or airport security personnel are employed, no single person whose feet stay firmly on the ground can share the same interest in passenger and aircraft safety as those who crew the aircraft. A case in point, on 19th March 2010
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Victoria’s police chief was detected carrying bullets on a flight. It was reported "Mr. Overland was found to be carrying the ammunition magazine at Canberra airport on the way back to Victoria, but had already passed through security in Melbourne and flown to the capital with the ammunition". It is a very inappropriate proposal to allow the reduction of numbers of the very people who have the most interest in theirs and the passenger’s survival and protection from security threats - the cabin crew.
As for CASA’s suggestion that passengers can safely self-evacuate when there is minimum crew, as determined by aircraft certification trials, I bring your attention to the following statement in relation to overwing (hatch style) exits submitted by the following organizations in 2002:
The Association of Flight Attendants (AFA), the Association of Professional Flight Attendants (APFA - not an ITF affiliate), the European Transport Workers' Federation (ETF), the Swedish Transport Worker' Federation (HTF), the International Association of Machinists & Aerospace Workers (IAM), the International Brotherhood of Teamsters (IBT), and the International Transport Workers' Federation with SCISAFE.
“The review document described several concerns with the various research projects, including the fact that the age and health status of test subjects did not reflect that of the flying public, and that the subjects were often either briefed multiple times on how to evacuate, or actually given practice sessions before their evacuations are timed. Whether or not the research methodologies are scientifically sound, it is our opinion that results collected under test conditions that do not reflect true emergency conditions, should not be used to justify or propose regulations that apply to true emergency conditions.”
I would suggest “optimum” crew numbers may be more appropriate in light of the following report:
Canadian Transport Safety Boards Report on the Air France Airbus A340-313 aircraft accident Toronto International Airport, Ontario, on 18th July 2005, with 297 passengers and 12 crew members on board. This crew to passenger ratio equates to 1:24.75 with the 297 passenger breakdown comprising of 168 adult males; 118 adult females; 8 children; and 3 infants. Adult passengers included: three wheelchair passengers and one blind passenger.
"2.6 Survivability 2.6.1 General
The evacuation was successful due to the training and actions of the whole cabin crew. With few exceptions, the performance of the cabin crew was exemplary and professional, and was a significant factor in the successful evacuation of the accident. There was effective communication between the flight crew and the cabin crew. Because the cabin crew were advised of the possibility of a missed approach, they were in a state of heightened awareness during the landing phase and were, therefore, prepared to respond immediately in the event of an emergency.
The availability of three supplemental cabin crew members on AFR358 undoubtedly contributed to the success of the evacuation, as evidenced by the roles they played during the evacuation. Two were in command of passenger evacuations at emergency exits and the third played a pivotal role in opening an emergency exit and subsequently assisted passengers at the foot of the R4 slide."
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To give you some insight into how proficient passengers are in self-evacuating an aircraft, I refer you to a report released by the Chairman of the US National Transportation Safety Board (NTSB) Survival Factors Group in December 1999. The report was on the American Airlines Flight 1420 that overran a runway and crashed in Little Rock, AR (NTSB, 1999). Eleven people were killed. Interviews with the passengers assigned to open the four overwing exits revealed that they all had considerable trouble doing so.
Male passenger seated at 21D reported that he "tried to throw the exit out, but it hit something, so he dropped it inside the airplane… Many of the passengers slipped or tripped at the opening. The exit plug was in the way…"
Male passenger seated at 22E reported that "he had not been told specifically that he was in an exit row, and did not realize it until the crash. He had never opened an emergency door before. He looked at the exit and saw the word "pull" on the handle. He assumed the door would open." (Page 25)
Unskilled passengers cannot be expected to perform in an emergency in place of trained cabin crew.
As for the process of "risk assessment" of cabin procedures, it is my experience that risk assessments are frequently made by people using Key Performance Indicators linked to the profitability of the airline or at the very least, under commercial pressure to achieve a positive economic result for their employer. These people lack subject matter expertise, thereby inhibiting their ability to adequately identify the risks and assign realistic probability and consequence in relation to those risks. It is my belief that a big part of the risk assessment process is for the purpose of diluting accountability and to ensure no one person could be made legally liable. Safety cases are often presented with minimal if any scientific basis, with proposed mitigating strategies little more than the subjective opinion of the very party that stands to gain from a successful submission. Analysis of disasters almost always shows a combination of technical and managerial flaws that have contributed to the event occurring, with the decision-making done by people who “don't know what they don’t know”.
A successful risk assessment or safety case system should have a competent and independent regulator with adequate legal powers. The regulator must ensure the operator will carry out the process of preparing the assessment/case in a rigorous manner, with the knowledge that if it is not done properly it will be challenged. Although CASA will argue they are proposing a process that does just that, I do not believe they have the level of experience or training programs required to equip their inspectorate to challenge where necessary the claims made by Airlines
Having spent 15 years as an active contributing member of the SAE Aerospace Committee, whose task it is, to develop Aerospace Recommended Practice documents which are used by the Federal Aviation Authority as the basis of their regulations, I am entirely familiar, with the regulatory process in America and the rationale behind it. America bases its system on risk, blame and litigation.
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The last CASA regulatory review under the Howard Government, subject to the economic rationalist thinking of the time, was extremely comprehensive. The review committee, of which I was a member, did a complete and thorough analysis of the case for reducing cabin crew ratios and as a result, the 1:36 crew to passenger ratio was deemed best practice and retained.. NOTHING has changed since that time except the advent of low cost carriers.
I think the Government must ask the relevant Ministers the following questions:
• Can the Minister for Transport direct CASA to explain why, shortly after a comprehensive review process and retention of the 1:36 rule, they began issuing/offering the airlines dispensations?
• Will the Minister explain how CASA is involved in an initiative that will undermine another government initiative aimed at enhancing the protection of the traveling public?
• Will the Minister advise if the Australian public has asked CASA for a lowering of Safety & Security standards?
• Will the Minister advise if the public knows when they fly on an aircraft with reduced crew numbers that their chances of surviving an accident are much reduced?
• Will the Minister direct the Australian Transport Safety Board to investigate CASA's process for accepting dispensations for reduced crew numbers?
• Will the Minister direct CASA to withdraw the NPRM?
Yours sincerely,
Beverley Maunsell
79 Louisa Rd
Birchgrove 2041 NSW
Monday 22 March 2010
Air Safety Investigator/Cabin Safety Specialist - retired
Past Chairperson S9C Cabin Safety Provisions Committee, SAE Aerospace (USA)
Founding member of the Australian Society of Air Safety Investigators
Cabin Safety Working Group.
cc
Andrew Heasley, The Age
The Editor, Crikey,
Mathew O’Sullivan, Sydney Morning Herald