It has always struck me as an unnecessary impediment to flight safety that aircraft manufacturers are not required to standardise aircraft cabin systems. Particularly lavatory smoke detection systems, evacuation signalling systems and emergency lighting systems. As many cabin crew operate on more than one type, they have to learn different audible warnings and a vast array of other warning indications for each aircraft type. In the interests of flight safety, surely it would make much more sense for regulators to insist that aircraft manufacturers, notably Boeing and Airbus, get together and agree to standardise these systems. Currently, Airbus themselves don't even have standardised warning indicators. Not even on a particular aircraft type! e.g. the A321 and A320 have weird and wonderful combinations that cabin crew have to commit to memory and be examined on during their initial and recurrent training courses.
Standardised systems should be mandatory for all passenger aircraft of the future and preferably systems adapted retrospectively for all existing aircraft of a specified passenger capacity.
I have always believed that, in the interests of flight safety, cabin crew should be well drilled and familiar with the fundamentals:
How to open a door/exit.
How to inflate an evacuation slide.
How to operate emergency equipment.
How to put out a fire.
How to don a smoke hood.
Actions in a decompression.
Evacuation drills and procedures
First aid and Basic Life Support (CPR)
Unfortunately, as well as the important aspects of their role, they are also required to memorise a virtually unlimited amount of SOP's and company policies based on current legislation and regulatory requirements. This information overload merely serves to dilute the cabin crew's knowledge of the fundamentals. The lawyers that determine aviation safety standards should consider this when determining future legislation and amendments. It is in the interest of the industry, the travelling public and safety for them to do so.
In my opinion, it should also be mandatory to have emergency equipment stowed in approved SEP equipment boxes with standardised contents located at each cabin crew station. The industry adopted practice of having safety equipment located 'randomly' throughout the aircraft cabin is not in the interests of flight safety. In an emergency situation, particularly an onboard fire, cabin crew should know EXACTLY where to go to find the required equipment. Time is one of the most important factors in any emergency situation. Reducing the amount of time it takes cabin crew to locate equipment could ultimately be the difference between life and death.
Legislation would be the only way to make airlines even consider actioning these recommendations retrospectively.
Emails duly dispatched to ICAO, EASA, CAA and FAA!
EASA replied: explaining why there is currently no requirement for standardisation. I think he kind of missed the point!
Hence my reply:
Hi Dagmar, thank you very much for your comprehensive reply.
This answers why there is currently no requirement for standardisation of cabin systems. It does not however address the issue. As a Cabin Crew & Pilot SEP Instructor for the past 22 years, my email was to highlight the need for such standardisation in the interests of flight safety. I consider it the responsibility of the EASA, FAA, national regulators and ultimately the ICAO, to strive for such, and seek changes in legislation which would result in the requirement for standardisation. Which is why I have sent the same email to all these regulatory bodies, plus Airbus, Boeing and Bombardier. I find it disappointing that you consider this to be outside EASA's remit and I refuse to accept that I am the only person that sees the potential benefit. But I suppose mine is a lone voice lost in the quagmire of commercial interest and legislative requirements.
Your further comments would be appreciated.
But nobody on PPrune cares to comment??
(Initial Reply from EASA)
Dear Sir,
Thank you for your email; it has been forwarded to me to answer.
In January 2014, the Agency published the rules on Operational Suitability Data (OSD):
The European Commission today published the rules for Operational Suitability Data (OSD) | EASA
One of the elements of the OSD relates to cabin crew – ED Decision 2014/006/R Certification Specifications Cabin Crew Data (CS-CCD):
CS-CCD / Initial issue | EASA
One of the tasks of the CS-CCD is Determination of a new type and a variant. It requires the aircraft manufacturer to make a thorough assessment of the newly produced aircraft in four type specific areas (cabin configuration, doors and exits, aircraft systems and normal and emergency operations) to determine whether this aircraft can be considered a variant of an already existing model in the manufacturer’s fleet or the extent of differences require that the aircraft be determined a new type for cabin crew operation. Type specific means those elements that are determined by the manufacturer and cannot be changed/modified by any operator (e.g. operation of door/exit, function of the evac alarm signalling system, etc.). This determination process is conducted on the manufacturer level – between the aircraft manufacturer and EASA during the aircraft certification process (please, refer to Subpart B and Appendix 1 to CS.CCD.200(b)(1)).
Airlines are free to order from a manufacturer an aircraft cabin configuration of their choice provided it is compliant with the existing airworthiness rules. Each cabin configuration must be approved by EASA on the basis of Reg. 748/2012 and must comply with the applicable safety standards including emergency evacuation.
The operator may customer-configure its aircraft, e.g. the sound of evac alarm signalling system, the number of additional evac alarm signalling panels, whether to have an escape slide or a slide-raft on doors/exits, etc.; therefore the amount of differences amongst the aircraft of the same model in the operator’s fleet may rise. As the operator is free to customer-configure its aircraft, Reg. 965/2012 AIR OPS requires the operator to conduct an assessment, similar to that conducted by the aircraft manufacturer and EASA, of the already configured aircraft – this is the operator level. Every operator has to assess the extent of differences of its customised aircraft configuration(s) and has to determine whether the aircraft can be considered a variant or a new type within the operator’s fleet. ORO.CC.250 requires an assessment of three areas, however the operator may decide to conduct the assessment in further areas, e.g. aircraft systems related to cabin crew. It is within the remit of the Member State via its Competent authority to approve the conclusion (the operator and the competent authority may come to the conclusion that e.g. A321 (determined on the manufacturer level as a variant of A320) will be considered a new type for cabin crew within that operator).
ORO.CC.250 Operation on more than one aircraft type or variant
(a) A cabin crew member shall not be assigned to operate on more than three aircraft types, except that, with the approval of the competent authority, the cabin crew member may be assigned to operate on four aircraft types if for at least two of the types:
(1) safety and emergency equipment and type-specific normal and emergency procedures are similar; and
(2) non-type-specific normal and emergency procedures are identical.
(b) For the purpose of (a) and for cabin crew training and qualifications, the operator shall determine:
(1) each aircraft as a type or a variant taking into account, where available, the relevant data established in accordance with Regulation (EC) No 1702/2003 for the relevant aircraft type or variant; and
(2) variants of an aircraft type to be different types if they are not similar in the following aspects:
(i) emergency exit operation;
(ii) location and type of portable safety and emergency equipment;
(iii) type-specific emergency procedures.
EU legislation does not contain any provisions on standardisation of cabin aircraft systems by manufacturers. EU legislation is applicable in the EU territory, therefore such mandate would be applicable to all EU manufacturers, not only to selected manufacturers. The aircraft manufacturing field is a competitive environment with a continuous development, let’s take an example of aircraft systems related to cabin crew on A300-600 vs. A330, e.g. communication system, smoke detection system, evac alarm signalling system, passenger address system, control panels, door/exit electrical warning system, etc. and such mandate could turn as counterproductive in terms of impeding the development of aircraft systems. Some manufacturers may decide to cooperate however this is outside EASA’s remit.
Hope the above answers your question. Should any further clarification be required please feel free to call or contact me by email. Alternatively, you may take advantage of the Rulemaking general enquiries on EASA website.
Kind regards,
cid:
[email protected]
Dagmar Dostalikova, MSc.
Cabin Crew Expert
Flight Standards
Rulemaking Directorate
European Aviation Safety Agency (EASA)
Ottoplatz 1, 50679 Cologne, Germany
tel: +49 221 89990 4135
e-mail:
[email protected]
EASA | European Aviation Safety Agency