CA BIN S A F ET Y
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aircraftinteriorsinternational.com
JUNE 2019
class – including doored mini-suite seats like the Qatar
Airways Qsuite produced by Collins Aerospace,
Thompson Vantage XL+ seat (as introduced by Delta Air
Lines as the Delta ONE Suite), and the fully enclosed
suites of Emirates’ latest first class also manufactured by
Collins – it is becoming increasingly clear that the
regulatory gap and ad hoc certification of these seats
must be rectified.
Regulators are currently certifying these seats on a
case-by-case basis using Special Conditions (SCs), with
the FAA stating in a recent set of SCs for the Boeing 777
that “the applicable airworthiness regulations do not
contain adequate or appropriate safety standards for this
interior configuration.”
The SCs, said the FAA, “contain the additional safety
standards that the Administrator considers necessary
Passenger group
reacts to FAA’s refusal
to regulate airline seats
In 2015, Washington DC-based
FlyersRights.org, a nonprofit airline
passenger organisation with 60,000
members, filed a petition to US Congress
calling for the FAA to set guidelines for
minimum seat pitch. The FAA denied the
petition, and in 2017 a federal appeal
court decision required the FAA to
reconsider its denial. However, according
to FlyersRights.org, the FAA has again
refused to regulate seats, holding that
evacuation tests show no problems.
According to FlyersRights.org, the FAA
has admitted that it does not actually
test airliners for compliance with its rule
that airliners must be able to evacuate a
fully occupied aircraft within 90 seconds,
with half the exits disabled in low light
conditions. Instead, the organisation says
that the FAA instead relies on partial
demonstrations by Boeing and Airbus.
Furthermore, it is claimed that the FAA
will not release the full tests for outside
safety experts’ review and does not
retain the actual video and detailed data
of tests, which aircraft makers claim are
proprietary trade secrets.
Paul Hudson, president of FlyersRights.
org and member of the FAA’s Aviation
Rulemaking Advisory Committee dealing
with safety, has questioned the FAA’s
safety evidence, “These censored
Airbus and Boeing video clips only show
younger physically fit test subjects
in exercise clothing. There is no video
showing subjects actually exiting any
aircraft. There are no overweight, obese,
elderly, infirm or child test subjects (or
adjustments made for their absence),
thereby excluding about 80% of US
passengers. The tests are supposed to
simulate panic as this is a major factor
in efficient evacuation, but the videos
show test subjects smiling. The tests are
supposed to require that 50% of carry-on
bags be in the aisles, but the videos show
this did not happen. There is apparently
no supervision or direct observation by
the FAA or outside safety experts.”
“Indeed these evacuation ‘tests’
are so questionable that a large
bipartisan majority of the US House
of Representatives passed legislation
in April 2018 mandating the FAA to set
seat standards (now pending Senate
action), and the DOT Inspector General
(charged with investigating agency
fraud, abuse, waste and misconduct)
recently opened an audit of FAA
evacuation testing.”
to establish a level of safety equivalent
to that established by the existing
airworthiness standards.”
This documentation is presumably
for the latest Emirates first class suites
manufactured by Collins Aerospace,
given that the product is described as “a
passenger cabin with six high-wall suites
arranged in two rows of three suites each,
in a 1–1–1 configuration. The suites have
doors and walls that are taller than has
been previously certified by the FAA on
B777 series airplanes. The walls extend
from the floor to the ceiling or close to the
ceiling.” Similar SCs have been used for
other premium doored products.
There are nine conditions and 18 subconditions
set by the FAA for this product
alone, covering everything from sizing of
aisles, structural integrity, stowage limits,
door frangibility and emergency egress to
passenger oxygen systems, and the fire
detection and firefighting requirements
for crew and aircraft systems.
Crucially, the SCs note that approval
covers “only certain novel or unusual
design features on one model series of
airplane. It is not a rule of general
applicability.”
EASA uses similar SCs, with one
example being the Airbus A380 Special
Condition D-54 ‘Installation of suite type
seating for two passengers’, presumably
for the Etihad Residence given it states
that “for this new customer layout, one
of the ‘mini suites’ should be allowed for
occupancy by two passengers”. EASA’s
SC D-54 adds four conditions to the
24 already included in A380 Special
Condition D-41, ‘Installation of suite
type seating’.
It is clear that there is work to be
done to update the actual standards
as we approach nearly a decade and
a half of modern aircraft suites. Yet
additional airworthiness standards work
has been slow, with SAE (named the
Society of Automotive Engineers until
2006) seemingly working on its
‘Performance Standard for Seat
Surrounding Furniture in Transport
Aircraft’, AS6960, since 2012, and indeed
there are questions as to the extent to
which this standard will address the
smaller mini-suites in business class.
THE FAA’S SPECIAL CONDITIONS
ENABLED THE CERTIFICATION OF
THE UNUSUALLY HIGH WALLS OF
EMIRATES’ B777 FIRST CLASS SUITES
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