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3 STANDARDS, REGULATIONS, AND INDUSTRY PRACTICES The Air Commerce Act of 19261 established for the first time federal responsibility for the regulation of civil aviation in the United States. The basic features of that act--registration, periodic examination, rating of aircraft as to airworthiness, and rating of the qualifications of crew members--were carried over into the Federal Aviation Act of 1958.2° The Federal Aviation Act established the Federal Aviation Administration (FAA) as an independent agency responsible for regulating the safety of aviation and the Civil Aeronautics Board (CAB) as an independent agency responsible for its economic regulation. Neither act assigned direct responsibility for health effects associated with air travel. For example, the statutory basis for the regulation of smoking on aircraft by CAB is Section 404(a) of the Federal Aviation Act, which requires airlines to provide "safe and adequate service." FAA was absorbed into the Department of Transportation in 1966, and CAB was disbanded under the Airline Deregulation Act of 19782 and the Civil Aeronautics Board Sunset Act of 1984. Many CAB responsibilities were transferred to the Office of the Secretary of Transportation. Today, the Secretary of Transportation is charged with responsibility for regulating air commerce so as to promote in the best way its development and safety in the United States and abroad by prescribing safety regulations and standards. But no federal office has direct responsibility for health effects associated with air travel. (For a historical description of relevant statutes, see Onstad and Roark. 3~) FAA's effort to satisfy this mandate is accomplished largely through the exercise of its regulatory powers in the promulgation of Federal Aviation Regulations (FARs) by headquarters in Washington, D.C., and the enforcement of FARs by regional offices. FARs are adopted in 64
65 accordance with rule-making procedures that provide for public participation--from preliminary determination of need, through development and publication, to final promulgation and application (except in special circumstances, such as safety emergencies that require immediate action). The processes by which FAA seeks to ensure the inherent safety and airworthiness of aircraft are type certification, which ensures that the design of particular new aircraft complies with statutes and applicable rules and regulations, and the establishment of standards that must be met by manufacturers and air carriers in the course of designing, producing, operating, and maintaining aircraft. Accordingly, FARs have been established that govern airworthiness standards for commercial transport airplanes and certification and operation of domestic, flag (foreign), and supplemental air carriers and commercial operators of large aircraft. (In keeping with the Committee's charge, regulations that govern noncommercial private aircraft and air taxi operators are not referred to here.) An earlier National Research Council study29 examined FARs and their implications for aircraft construction and maintenance. This chapter focuses on relevant sections of the FARs and their enforcement, especially with respect to their influence on the operating procedures of air carriers. Nevertheless, a few comments concerning type certification are appropriate. FAA engineers cannot review each of the thousands of drawings, calculations, reports, and tests involved in type certification. But it must be certain that each design for a new aircraft meets all appropriate regulatory requirements. Thus, the system relies not only on the FAA staff, but also on the assistance rendered by aircraft company employees called designated engineering representatives (DERs), who review the design and design process to ensure, on behalf of FAA, compliance with all aspects of the appropriate regulations.
66 Once an aircraft has received type certification, the manufacturer may continue to produce aircraft according to the approved design as long as it wishes or until the type certification is amended by FM . There is a strong incentive to produce according to the same design, in that substantial modifications must be submitted for certification. FARs often apply to designs certified after promulgation. Sometimes, however, a rule specifies that all aircraft type- certified after a particular date must be brought into compliance. For example, the requirement for escape- route markings near the floor applies to all aircraft certified after 1958 (virtually the entire commercial fleet). Other rules--mostly those governing air carriers, as opposed to manufacturers--apply to all passenger-carrying aircraft, regardless of the date of type certification; an example is the requirement that smoke detectors and automatic fire extinguishers be installed in all lavatories. These generally specify a time limit for compliance. The pattern of interaction between FAA and the aircraft manufacturers relies on mutual exchange and cooperation. The pattern of interaction with the carriers involves mainly continual surveillance and occasional sanctions, so it places more emphasis on inspection and enforcement than on review of design specifications and production. In 1979, a new set of regulations--Investigative and Enforcement Procedures of the Federal Aviation Regulations2s--established a mechanism for filing formal complaints and prescribed enforcement procedures for issuance of orders of denial, cease-and-desist orders, and orders of compliance. These regulations include provisions for formal fact-finding under the Federal Aviation Act of 1958, 2° the Airport and Airway Development Act of 1970,3 and the Hazardous Materials Transportation Act of 1974.22 This chapter reviews standards, regulations, and operating procedures with respect to several problems involving safety in the aircraft cabin. In particular, it examines regulations with respect to air quality itself, as well as regulations and guidelines that govern crew and passenger response to fire, Repressurization, medical emergency, and ditching and
67 evacuation. (Smoke and toxic fumes associated with cabin fires constitute one of the gravest hazards in aircraft emergencies, and rapid Repressurization exposes passengers and crew members to hypoxia. Fires and Repressurization directly involve aspects of cabin air quality and are addressed specifically in Chapter 4.) The airlines, in conjunction with the manufacturers and the FAA, establish minimal-equipment lists that define allowable operations for situations when equipment is inoperable. Compliance with this list dictates operations that will meet FAA regulations. Because relevant federal regulations necessarily leave considerable discretion to the air carrier in accommodating the different configurations of equipment on various aircraft, typical procedures of mayor North American air carriers with respect to these subjects are described here, as are similarities to and differences from foreign regulations. Most of the procedures and equipment relevant to safety and health in aircraft involve the behavior of passengers in some way, so the adequacy and efficacy of the provision of passenger safety information are also reviewed in this chapter U.S. REGULATIONS AND STANDARDS . The "Cabin Safety Subject Index" prepared by the FAA Civil Aeromedical Institute (CAMI) in January 1984 presents a long list of regulations and recommendations pertaining to safety standards and operating requirements of commercial aircraft.33 This extensive index includes such items as the specification of who may be admitted to the cockpit, the width of aisles giving access to emergency exits, storage and use of galley equipment during takeoff and landing, use of public- address systems, and actions related to encounters with air turbulence. From this long list of safety provisions, three categories emerge as particularly important for this study: standards for cabin air quality, response to incidents and accidents (including fires, Repressurization, and emergency landings), and other operating procedures (including those in medical emergencies).
68 Two parts of the FAR are relevant to the construction of aircraft and operation of commercial air carriers: Part 121, "Certification and Operations: Domentic, Flag, and Supplemental Air Carriers and Commercial Operators of Large Aircraft,"~° and Part 25, "Airworthiness Standards: Transport Category Airplanes."4 In addition, some Air Carrier Operations Bulletins (ACOBs), Advisory Circulars (ACs), and Airworthiness Directives (ADS) issued by FAA include relevant directions or recommendations for commercial air carrier operations. Many ACOBs have been collected in a consolidated reprint dated March 1985.37 VENTILATION The airworthiness standards require that cockpit and cabin air be free of harmful or hazardous concentrations of gases or vapors.47 They specify that carbon monoxide concentrations must be less than 1 part in 2D, 000 parts of air (50 ppm) and that carbon dioxide concentrations must not exceed 3% by volume (sea-level equivalent), or 30,000 ppm. The carbon monoxide and carbon dioxide standards were incorporated into the Federal Aviation Act of 1958. The carbon monoxide standard apparently originated in requirements related to exhausts from internal-combustion heaters.35 The carbon dioxide standard first appeared an an amendment to the Civil Air Regulations in 1952. 3 6 There are no requirements for monitoring of carbon monoxide or carbon dioxide in the cockpit or cabin during flight. Nor are there explicit requirements concerning ventilation rates for passenger cabins; the regulations state only that "each passenger or crew compartment must be suitably ventilated". 48 OZONE Ozone contamination of aircraft cabins is a problem during high-altitude or high-latitude flights. Ozone is a known irritant and has been associated with some health effects. The FARs specify that cabin ozone concentration must not exceed 0.1 ppm by volume sea-level equivalent (SLE) time-weighted average during any 3-h interval, nor exceed 0.25 ppm (SLE) at any time. 9 This standard is also found in the regulations governing air carriers,
69 which state that the ozone concentration requirement may be satisfied either by air treatment equipment (usually a catalytic converter) that maintains cabin ozone concentrations at or below this requirement or through appropriate scheduling of flight plans on the basis of average atmospheric ozone.9 This rule was promulgated in 1980 on the basin of extensive review of data concerning human and animal exposure to ozone and with opportunity for public input to the rule-making process. 3 9 There is no FAA requirement for in-flight monitoring of ozone (the United Kingdom requires monitoring on flights above 49,000 ft). Compliance with the federal regulation is based on performance of the air treatment equipment at the time of installation or on the flying of routes and altitudes that avoid high ozone concentrations. FIRES Onboard fire threatens passengers not only directly, because of the possibility of burn injury and inhalation of smoke and toxic fumes, but also indirectly, because of the possibility of damage to the structural integrity of the aircraft and its ability to remain in controlled flight and of increased difficulty of escape once the aircraft has landed and stopped. Much can be done to reduce the ease of ignition, inhibit the propagation of flame, and reduce smoke and toxic fumes by careful selection and use of materials. ~ addressed separately in Chapter 4. The procedures and equipment described in Appendix C deal with firefighting by the crew and with passenger behavior in fire and other emergencies. These issues are Of the regulations and recommendations referred to in this chapter, those concerning fires are the most extensive (see Table C-1. That was true even before the recent promulgation of rules and recommendations that followed the cabin fires near Cincinnati, Ohio on June 2, 1983, and at Tampa International Airport on June 25, 1983. Additional regulations have been proposed or implemented since those events. Neither the regulations nor the recommendations specify emergency procedures in case of fire. A few recommendations are made--for example, to review emergency procedures concerning operation of lower-lobe
70 galleys (below the main floor) in Jumbo jets. Current regulations specify some nonemergency procedures, such as prohibition of smoking while the "no smoking" sign is lighted3 2 or provisions for maintenance of fire- susceptible areas.38 There is extensive prescription of safety equipment with respect to fires, including provisions for the prevention of fires ("no smoking" signs in lavatoriesl4), for detection of fires (smoke detectors in lavatories and galleys38), for extinguishing of fires (automatic and hand fire extinguishers38), for protective breathing equipment and firefighting training for crew, 44 and for passenger escape from smoke-filled cabins (floor-proximity escape-route markings, i.e., exit routes visible when there are no sources of light more than 4 ft above the floored. Crew training is to include not only initial familiarization with equipment and procedures, but periodic "hands-on" refreshers. Passengers are to be briefed by announcements concerning smoking in the cabin and in lavatories.8 DEPRESSURIZATION Sudden Repressurization of the aircraft cabin threatens passengers with hypoxia. The regulations and standards for pressurization and Repressurization are somewhat less extensive than those for fires (see Table C-2. Emergency procedures are not specified, but minimal flows of supplemental oxygen are specified in terms of equipment, altitude, duration at altitude, and other factors. Equipment must be available to deliver supplemental oxygen for crew and passengers whenever the airplane is ^~~~-~~= ~^ ~ -I ~ ~~~ ~~~ ~ For flight up~raceu an an al~lcuce or over 10,000 ft. above 25,000 ft. an automatic system to deploy supplemental oxygen equipment in the event of sudden Repressurization is requires; and portable oxygen equipment with a 15-min supply must be provided for cabin crew. Proper use of continuous-flow passenger masks has proved to be a satisfactory intermediate measure for countering inadequate supply of oxygen for cabin altitudes of up to 40,000 ft. Most of the problems
~1 associated with these masks appear to be related to the lack of timely or proper use--activating the oxygen flow covering both nose and mouth, and ensuring a tight fit. Because of their higher degree of physical activity, cabin crew have only 15-20 s to don and activate masks before adverse effects set in at 40,000 ft; passengers have about 40 n. 2 3 Crew training includes both initial familiarization and periodic refreshers with respect to supplemental oxygen equipment and familiarization with medical symptoms associated with hypoxia and Repressurization. Before a flight above 2S,OOO ft. passengers must be briefed on the use of supplemental oxygen equipment. MEDICAL EMERGENCIES A recent court decision reversed an FAA decision that it did not have authority to make air carriers supply their aircraft with medicine and emergency medical equipment to treat general health emergencies6 and held that FAA can proceed with rule-making if it deems such action to be advisable. In response, a rule has been adopted that requires much more extensive medical kits than had been required.40 This new rule would considerably extend the scope of FAA regulations with respect to medical emergencies. No regulation of emergency procedures is specified (see Table C-3~. With respect to nonemergency procedures, conditions are determined under which a passenger may carry and operate oxygen equipment for medical reasons. The content and number of first-aid kits for injuries likely to occur in flight or in minor accidents are specified. The new regulation40 adds the requirement of a medical kit containing equipment and drugs required for life support during medical emergencies (including myocardial infarction, severe allergic reactions, acute asthma, insulin shock, protracted seizures, and childbirth).
72 Crew training includes instruction in emergency procedures and familiarization with first-aid equipment and practices. The regulation requires familiarization with the medical kit, although this does not include training in all the medical procedures possible with the equipment in the kit. It part, the purpose of the kit is to enable passengers with appropriate medical training to respond to medical emergencies, as well as to extend the crew's capability to provide advanced firm-aid techniques. No special provisions are made for passenger briefings concerning medical emergencies. DITCHING AND EVACUATION Because of the extensive requirements for appropriate design of the airframe and ancillary equipment, ditching and evacuation are subject to extensive regulations and recommendations (see Table C-4. Recommendations for emergency procedures include suggestions for preparation of passengers for an emergency landing. Procedural requirements include assurance that the crew are fully familiar with operation of emergency equipment and evaluation of proper bracing positions with due regard to seat spacing. Each passenger-carrying landplane emergency exit (except over-the-wing exits) that is more than 6 ft from the ground when the landing gear is extended must have equipment for assisting occupants in descending.17 On all flights that include extended over-water operation, flotation devices must be within easy reach of all passengers, and liferafts must be sufficient to accommodate all occupants.!' Crew training includes instruction and periodic refreshers in emergency procedures and equipment for each type of airplane. Passenger briefings are to include the location of emergency exits and, in over- water flights' the location of flotation devices and methods of donning and inflating life preservers.
73 ADDITIONAL PASSENGER BRIEFINGS Before takeoff, passengers are to be briefed concerning smoking, location of emergency exits, use of safety belts (including how they are fastened and unfastened), and location and use of required emergency flotation devices (see Table C-5~. After takeoff, an announcement must be made, immediately before or after the seatbelt sign is turned off, that passengers should keep their seatbelts fastened while seated.8 FOREIGN REGULATIONS Many foreign aviation standards and regulations draw heavily on the U.S. FARs , but there is also considerable activity in the field of air safety elsewhere. We will not attempt to include an exhaustive review of foreign standards and regulations here. However, we will review the European Civil Aviation Conference (ECAC) regulations to illustrate typical similarities and differences between U.S. and foreign regulations. For example, ECAC develops, for application by its member states as their own national regulations, "uniform requirements for the following emergency and safety airborne equipment for large aircraft: a) emergency oxygen equipment, b) evacuation equipment, c) sea rescue and survival equipment, and d) possible crash or fire survival equipment."19 The ECAC Working Group on Cabin Safety recently approved amendments to the ECAC regulations, but these were not available at the time of the Committee's deliberations. Most ECAC requirements are based on the U.S. FARs. However, there are differences.19 With respect to fires, the ECAC regulations prohibit the use of dry chemical extinguishers in the cockpit or in any compartment not separated by a partition from the cockpit. No attention is given to medical emergencies in ECAC requirements, nor are standards recommended for carbon monoxide, carbon dioxide, or ozone. However, regulations in the United Kingdom require continuous monitoring of ozone on all flights above 49,000 ft. (In practice, this applies only to the Concorde and a few corporate jets.)
74 Some ECAC requirements with respect to ditching and evacuation are different. An explicit formula is provided for reducing the number of passengers and seating distributions if an exit becomes inoperative at an airport where it is not practical for it to be repaired or replaced. Seat cushions are not considered to be acceptable flotation devices. There are also differences as to passenger briefing and crew training and responsibilities. For example, the oral briefing on the location of emergency exits may be omitted if the subject is covered by oral reference to the briefing cards. The number of airplane types in which cabin crew are qualified at any particular time is to be limited, and the crew is to receive training on survival at sea, on uninhabited terrain, and in extreme climatic conditions. INDUSTRY OPERATING PROCEDURES Airline operators are allowed considerable discretion in complying with safety regulations. That is largely inevitable, given the different configurations of airframe and equipment, ranging, for example, from large wide-body airplanes to smaller narrow aircraft. Most of the relevant FARs apply to airplanes with capacity for 20 or more passengers. Thus, to some degree, cabin safety depends on the standard operating procedures of the individual carriers for the different types of airplanes. The Committee attempted to elicit descriptions of operating procedures from U.S. and foreign flag air carriers. However, the response was not sufficient to be representative of the industry as a whole. It does appear, however, that ECU packs and other ventilation equipment are generally to be fully activated in case of smoke or fire. Table C-6 describes the firefighting procedures and training of one foreign carrier. From these examples, two issues emerge: the appropriateness of FAA standards and regulations and the degree to which the industry operating procedures satisfy those standards and regulations. FAA regulations were discussed earlier in this chapter. The determination of whether the carriers' procedures comply is the responsibility of FAA inspectors, who regularly inspect various aspects of carrier operations, as described in the next section.
75 FAA INVESTIGATION AND ENFORCEMENT FAA has the power and duty to investigate reported violations and to determine whether enforcement action is warranted. Any person who knows of a violation is encouraged to report it to appropriate personnel of any FAA regional or district office. 34 Air carriers are required to report accidents and incidents, as well as other interruptions to service. FAA is also empowered to initiate an investigation at any time with respect to any matter within its jurisdiction. Enforcement alternatives provided by the statutes and regulations include amendment, modification, suspension, or revocation of certificate if aviation safety and the public interest require it. Civil penalties of up to $1,000 for each violation (up to $10,000 for a violation associated with a hazardous material) can be imposed. There are several informal methods to seek relief from these enforcement processes; if these fail, more formal proceedings take place before FAA hearing officers, the National Transportation Safety Board (NTSB), or ~ U.S. district court. 3} INVESTIGATION OF VIOLATIONS . FAA relies primarily on the informal investigative process to obtain information. 3 ~ Most complaints received by FAA are informal and are acted on through informal investigation. If a formal complaint is received, the FAA administrator must determine within an allotted time whether there are reasonable grounds for investigating it. 2 1 If reasonable grounds exist, an informal investigation is initiated or an order of investigation issued. Formal fact-finding investigations may be initiated by FAA counsel whenever it is determined that informal procedures are inappropriate or inadequate. The sole purpose of formal proceedings is to determine whether the available facts warrant further action. If the evidence warrants no further action, the investigative file is closed. If the investigating office determines that enforcement action is justified, appropriate administrative or legal action is taken.
76 ENFORCEMENT ACTIONS The FAA enforcement program consists of administrative and legal enforcement actions. 3 ~ Administrative actions are analogous to a warning ticket, and there is no right of appeal. In legal actions, FAA has the burden of proof; in contrast, the applicant has the burden of proof in cases of discretionary denial of an application for a license or certificate on medical grounds. The nature of the violation and its impact on aviation safety determine the type of enforcement action taken. Administrative enforcement provides FAA field inspectors a means of dealing with minor violations and is used when there is no major unsafe condition and when a violation was inadvertent. In this situation, an alleged violator must have a "constructive attitude" toward complying with the regulations and must not have been involved in previous similar V5 orations. If corrective action is taken, the violator avoids further enforcement action. Failure of the violator to correct the problem can result in civil penalties or initiation of other legal enforcement proceedings. Legal action usually begins with certificate action, such as suspension or revocation, or with imposition of a civil penalty. 2 7 Other actions intended to achieve compliance are aircraft seizure, issuance of orders (such as cease-and-desist orders), injunctive relief, and imposition of criminal penalties. Suspension of a certificate usually occurs in a case of serious operational violation and when a possible lack of qualification could be corrected by remedial action or retraining; suspension can also be used for disciplinary purposes, if the nature of the violation warrants it. Civil penalties can be imposed if the facts and circumstances are too serious to be handled by administrative action and either the violator does not hold a current certificate or there is no question as to the qualification of the certificate holder. i2 i3 In most cases, violations involve questions of whether the certificate holder has carried out Its obligations under the regulations, rather than questions of qualification as a certificate holder. The maximal penalty is $1,000 for each violation. If a violation is continuing, each
77 operation constitutes a separate violation. In determination of the amount of the penalty, the nature, circumstances, extent, and gravity of the violation and the ability of the violator to absorb the sanction are taken into account. A civil penalty usually is not imposed if there has been a certificate action or criminal penalty for the same violation. If enforcement actions fail to deter repeated violations, a complaint can be filed in the appropriate U.S. district court requesting issuance of an injunction or other process to restrain the violator from further action. In emergency situations, issuance of such an order is preferred to all other enforcement actions. REVIEW AND APPEAL If the FAA administrator denies issuance or renewal of a crewman's certificate, the applicant can petition for the action to be reviewed by NTSB within 60 d. 3 ~ The burden of proof in denial of a medical certificate lies with the applicant. If a certificate is denied or revoked by the FAA administrator, an appeal can be made to NTSB within 20 d. In these actions, the administrator must show that the certificate was suspended or revoked Justifiably. On petition or appeal, an NTSB administrative law judge conducts a formal proceeding under the NTSB rules of practice and makes initial findings of fact and conclusions of law. Ultimately, all enforcement actions by FAA and NTSB are reviewable by U.S. courts of appeals. EFFECTIVENESS AND ADEQUACY OF FAA INSPECTION AND ENFORCEMENT The Committee has not been able to locate scientific, peer-reviewed studies of the implementation of the provisions for inspection and enforcement described above on which to base an evaluation of their effectiveness and adequacy. However, the General Accounting Office (GAO) has conducted an analysis of FAA inspection of a sample of commercial air carriers during 1984.46 The results of that analysis are the basis of the following discussion.
78 GAO studied the type, frequency, and results of FAA inspections. Five of FAA's nine regions were selected; they accounted for responsibility for inspection of about 70% of the nation'n approximately 500 scheduled Part 121 and Part 135 air carriers. At each district office, air carriers were randomly selected; 40 of 73 Part 121 carriers and 52 of 112 scheduled Part 135 carriers were selected. All FAA inspections of the 92 selected carriers in 1984, whether conducted by those offices or by other FAA units, were reviewed--about 12,000 inspection reports. The study did not examine FAA activities concerning certification or investigations of accidents and incidents. Data were grouped into FAA's three inspection categories: operations, maintenance, and avionics. On the basis of principles of descriptive statistics, GAO calculated that the data in its charts were at the 95% level of confidence. The GAO study distinguished inspections before the National Air Transportation Inspection (NATI) program, which lasted about 90 days, and those during and after it. Table 3-1 presents the percentages of inspections that were considered satisfactory and unsatisfactory and that were not classified. Concern has been expressed that commercial safety regulations are avoided by some aircraft operations. For example, one GAO report focused on the use of leased private aircraft (subject to less stringent Part 91 regulations) in situations that qualify as commercial operations. 45 In addition, although all in-flight fires must be reported to NTSB and FAA, the NTSB and FAA data bases concerning fires do not correspond exactly, because the FAA data also include incidents found only in the mechanical reliability reports. These differences might result from differing interpretations of the severity of a fire. Furthermore, a paper presented to a major conference on cabin safety in 1984 pointed out that United Airlines reported that it had about 60 fires in 1980-1984, but NTSB data contain only 40 fires over the 10 years before 1984. 24 This suggests that many incidents never enter the aviation safety reporting system.
79 TABLE 3-1 Results of PY 1984 FAA Inspections of 92 Sampled Air Carriern in Fire FM Regionsa Pre-NATI,b During and After NATI,b Category/ 10/1/83 - 2/29/84 3/1/84 - 9/30/84 FAA Region Z Sat. X Unsated % Remarked % Sat. % Unsat. X Ur~rnarked Operations: Alaska 90 10 0 8S 12 3 Eastern 99 1 0 95 5 0 Northwest Mt. 92 7 1 91 8 1 Southern 92 7 1 88 12 0 Western Pac. 96 4 1 92 7 1 Maintenance: Alaska 96 3 1 92 7 0 Easter- 62 22 16 73 26 1 Northwest Mc. 97 2 2 92 7 1 Southern 84 13 3 82 17 1 Western Pac. 87 11 2 88 11 1 Avionics: Alaska 100 0 0 95 2 3 Eastern 92 2 5 88 9 3 Northwest Mt. 94 4 2 93 6 1 Southern 87 10 3 87 9 3 Western Pac. 90 7 3 92 7 1 - a Data from U.S. General Accounting Office.46 b National Air Transportation Inspection program, conducted by FAA from about March 1, 1984, to June 1, 1984. On balance, it is not possible for the Committee to determine the facts concerning the effectiveness and adequacy of FAA enforcement and inspection. ADEQUACY AND EFFI CACY OF PASSENGER SAFETY INFORMATION The issue of the adequacy and efficacy of passenger safety briefings ~r~.~-nt-. D 0~ ~4 ~ ^--- There is considerable variation in the articulation and presentation of safety briefings by flight crews. Furthermore, many in the flying Dublin are rather familiar with passenger briefings and, believing that they already know the content, tend to ignore them. Yet statistics reflecting passenger response in emergency situations suggest that most passengers either do not understand the instructions or do not apply their knowledge when confronted with an emergency. 30 Although
80 this situation has been studied, there is not a sufficient scientific basis for specific policy recommendations. Empirical research results do, however, indicate some of the principal factors involved and suggest experimental approaches that might be pursued to develop a better understanding of the problems involved. The basic problem--provision of routine safety information that must be recalled under emergency conditions--involves phenomena related to a variety of research subjects, including interest and attention span, comprehension and retention, and recall under stress. A review of the vast literature on these and related topics is beyond the scope of this study, so we focus here on topics that appear to be most relevant to commercial air travel. The efficacy of alternative onboard presentations (verbal announcements, videotape presentations, and safety cards and placards) is not addressed here. A recent study by NTSB addressed such comparisons in detail; 3Q it drew from a series of theoretically unrelated empirical studies of immediate relevance to the conditions of alternative onboard announcements. FACTORS INFLUENCING PASSENGER EMERGENCY BEHAVIOR NTSB studies have focused on "maladaptive passenger behavior" in emergencies, ranging from inability to perform such emergency tasks as donning a lifevest to total inaction. The results suggested several factors that lead to such behavior: the inappropriateness or inaccuracy of information given to passengers, passenger indifference to safety information, the belief apparently held by some passengers that they are immune to injury, and the common belief that airplane accidents are not survivable and that passengers consequently have no influence on whether they will survive an accident.~° During the 1970s, McDonnell Douglas studied passenger behavior in actual emergency situations and proposed three methods to stimulate improvement: learning by trial and error, training or instruction, and clear and forceful instructions and action by the crew. McDonnell Douglas concluded that the combination of forceful cabin crew leadership with provision of passenger instruction
81 in more effective than either alone.30 That is an important finding, especially because the study examined the specific situation of passenger briefings and response in the setting of commercial aircraft. But the finding is limited, because it is not related to a more general model of information communication, comprehension, and recall. ATTENTION, COMPREHENSION, AND RECALL UNDER STRESS Industry observers have often suggested that a mild degree of anxiety increases the attention given to safety briefings and instruction cards. Too much anxiety and fear, however, often result in a "disaster syndrome" in which psychologic blocking results in inaction or inappropriate response. Berkun and others presented briefing-card information to three groups of subjects.7 Those in group 1 took off, were informed during the flight that they would have to perform an emergency ditching operation, and were then tested in flight on the briefing-card information. Those in group 2 took off, were not informed of an impending emergency, and were tested in flight on the same information. Subjects in group 3 remained on the ground, but were also tested. Time between presentation and tenting was the same for all groups. Results showed that group 1 performed significantly worse than group 2, and group 2 significantly worse than group 3. Thone results correspond to a model of the effect of emotion on the use of information--a model that relies on extensive animal and human experimental results., 6 The model predicts that, in heightened emotional states (in this case anxiety), a subject reduces the amount of attention given to "peripheral" cues and focuses on cues of most central importance. In a mild state of anxiety, for example, a person might ignore other activities in the cabin and attend to the safety announcement; this ought to result in an increase in retention and response. With greater anxiety, such as the prospect of ditching, a greater number of peripheral mental cues are ignored. perhaps even including some that are relevant for appropriate response. In other words, increasing anxiety eventually results in degeneration of response. According to this model, a course of action is facilitated or disrupted by emotion, depending on the
82 complexity of the action and on the cues attended to in the particular emotional state. The notion of facilitation or disruption of attention, comprehension, recall, and action by heightened emotion of various degrees appears to apply to many of the studies that have been conducted in the airline industry. For example, results of a McDonnell Douglas study suggested that explicit emergency evacuation instructions in a preflight briefing would not cause anxiety, but rather would reduce anxiety if properly presented. 5 However, interviews of survivors of aircraft accidents suggested that, of the four common responses to the extreme stress of emergency situations-- strengthening of resources, attacking the threat, avoiding it, or remaining inactive--the most common response by passengers during aircraft emergencies was inaction. 2 6 General psychologic research has suggested that under such conditions of high stress greater proficiency is maintained for the simplest perceptual-motor tasks. But the airline passenger must perform rather complex tasks in emergency situations--correctly donning a life preserver while seated with the seatbelt fastened and donning an oxygen mask, activating the oxygen flow, and ensuring a tight fit--and perform them properly on the first try under conditions of extreme emotional stress. The aim of passenger safety briefings is not subject to simple resolution. Presentation of information under routine conditions in such a way as to ensure recall under extreme emotional stress is a difficult task. IMPROVING PASSENGER SAFETY BRIEFINGS Although the results of studies noted above are insufficient to provide specific recommendations about how to increase the adequacy and efficacy of the provision of passenger safety information, one possible improvement is apparent. Under conditions of stress, a person is more likely to be able to perform perceptual- motor operations that have been well learned. Therefore, it would probably be most efficacious to provide passengers an opportunity to learn how to don masks and life preservers. The advisability of providing passengers ~ greater opportunity to familiarize
83 themselves with the opening of escape windows and doors is less clear. In at least one instance, passengers have opened emergency escape doors when there was an engine fire and the crew judged emergency evacuation of the aircraft to be unnecessary. Hands-on training might be impracticable, because of the variations in equipment among various aircraft. A cost-effective alternative might be to provide detailed video presentations of safety procedures in waiting lounges. It is well within the capability of current technology to store presentations describing the various aircraft used by a given airline, or even several airlines, to be viewed before passengers board a particular aircraft. Such safety information might be presented in a number of different formats. For example, it might be presented "on demand," so an to obtain a measure of the flying public's awareness and interest or it might be presented in conjunction with simple learning games, which could be used both to reinforce the information and to measure its understandability. That approach would be aimed at increasing the overall understanding of safety procedures in the flying public. The research results do not suggest an advantage associated with the presentation of all relevant information to every passenger on every flight. _ However, it ts obvious that all essential information should be available to any passenger who wants it. Video presentations in waiting lounges might have the double advantage of presenting relevant information in considerably greater detail than is commonly the case today and presenting it in a manner that is flexible enough to serve the needs of both frequent fliers and neophytes. Again, the basic elements of the problem are apparent: the difficulty in attracting and keeping passenger attention, the difficulty in communicating complicated perceptual-motor procedures, and the latent difficulty in recalling this information under conditions of extreme stress. The suggested approach does not remove any of these difficulties, but does present the possibility of developing incremental improvements that would permit gradual increases in theoretical and empirical understanding of the complex phenomena involved.
84 OVERVIEW Cabin safety procedures, equipment, and passenger information have all received considerable attention and are the subject of many federal regulations and guidelines But the regulations necessarily leave considerable discretion to individual air carriers, because of variations in the configuration of the equipment in aircraft. Therefore, in accordance with the regulations, airlines have developed equipment and procedures that they feel are appropriate for routine conditions and emergencies in air travel. This chapter has reviewed standards, regulations, and procedures that have been developed by FAA and the industry. A discussion of cabin safety would be incomplete without reference to a number of recent actions of FAA. In particular, FAA has proposed a rule concerning the use of specific materials in cargo and baggage compartments; 4 ~ promulgated a final rule requiring emergency escape-path markings that are visible when all sources of cabin lighting more than 4 it above the floor are obscured by smoke; 42 promulgated a final rule requiring air carriers to provide medical kits containing equipment and drugs for use in the treatment of injuries or medical conditions that occur during flight; 40 proposed a rule on fire protection requirements for cargo or baggage compartments that includes provision for at least two Halon extinguishers and for inspections and repairs of lavatory electric components on some aircraft; 38 proposed a rule establishing new fire test criteria for type certification of aircraft, which requires cabin interiors to correspond with the criteria, including the retrofitting of aircraft constructed since 1958~43 and proposed a rule governing the availability and performance of breathing devices to protect the crew from smoke and toxic fumes. 44 In addition to these regulatory actions, FAA is conducting research in related subjects. 2 ~ It appears advisable to review the advantages and disadvantages of a carefully designed program of passenger information aimed at developing a better understanding of passenger response to safety instructions. Consideration should be given to conducting quizzes during flight to see, for example, what proportion of passengers have retained the key
85 features of the safety briefings. Empirical research on the specific conditions of air travel can be combined with more general psychological evidence in ways that suggest an approach that ought to reveal useful scientific data while permitting incremental improvements over current practice. Although the suggestions presented in this chapter are motivated principally by a desire to improve passenger recall under the heightened stress of emergencies, they should also permit the collection of data that would illuminate the issues of attracting and keeping passenger attention and of comprehension of safety material presented. REFERENCES 1. Air Commerce Act of 1926. PL 69-254. U.S. Statutes at Large 44:568-576, 1926. 2. Airline Deregulation Act of 1978. PL95-504 U.S. Statutes at Large 92:1705-1755, 1978. 3. Airport and Airway Development Act of 1970. PL 91-258. U.S. Statutes at Large 84:219-253, 1970. 4. Airworthiness standards: Transport category airplanes. Code of FederaliRegulations, Title 14, Pt. 25. Washington, D.C.: U.S. Government Printing Office, 1985. 5. Altman, H. B., D. A. Johnson, and D. I. Blom. Passenger emergency evacuation briefing cards: Recommendations for presentation style (summary report). Vol. 2, pp. 455-474. In Survival and Flight Equipment Association. Proceedings of the Eighth Annual Symposium, Las Vegas, Nev., Sept. 28, 1970. Van Nuys, Cal.: Survival and Flight Equipment Association, 1970. 6. Bargmann, Eve, et al., Petitioners, v. J. Lynn Helms, Administrator, Federal Aviation Administration, Drew Lewis, Secretary of Transportation, Department of Transportation, Respondents. 715 F.2d. 638. U.S. Court of Appeals D.C. Circuit 230:164-169, 1983.
86 7. Berkun, M. M., H. M. Bialek, R. P. Kern, and K. Yagi. Experimental studies of psychological stress in man. Paychol. Monogr. Gen. Appl. 76(15): 1-39, 1962. 8. Briefing passengers before takeoff. Code of Federal Regulations, Title 14, Pt. 121.571. Washington, D.C.: U.S. Government Printing Office, 1985. 9. Cabin ozone concentrations. Code of Federal Regulations, Title 14, Pt. 25.832. Washington, D.C.: U.S. Government Printing Office, 1985. 10. Certification and operations: Domestic, flag and supplemental air carriers and commercial operators of large aircraft. Code of Federal Regulations, Title 14, Pt. 121. Washington, D.C.: U.S. Government Printing Office, 1985. 11. Civil Aeronautics Board Sunset Act of 1984. PL98-443. U.S. Statutes at Large 98:1703-1713, 1984. 12. Civil penalties: Federal Aviation Act of 1958. Code of Federal Regulations, Title 14, Pt. 13.15. Washington, D.C.: U.S. Government Printing Office, 1985. 13. Civil penalties: Hazardous Materials Transportation Act. Code of Federal Regulations, Title 14, Pt. 13.16. Washington, D.C.: U.S. Government Printing Office, 1985. 14. Compartment interiors. Code of Federal Regulation Title 14, Pt. 25.853. Washington, D.C.: U.S. Government Printing Office, 1985. 15. Ditching equipment. Code of Federal Regulations, Title 14, Pt. 25.1415. Washington, D.C.: U.S. Government Printing Office, 1985. 16. Easterbrook, J. A. The effect of emotion on cue utilization and the organization of behavior. Psychol. Rev. 66:183-201, 1959.
87 17. Emergency exit arrangement. Code of Federal Regulations, Title 14, Pt. 25.809. Washington, D.C.: U.S. Government Printing Office, 1985. 18. Equipment standards for oxygen dispensing units. Code of Federal Regulations, Title 14, Pt. 25.1447. Washington, D.C.: U.S. Government Printing Office, 1985. 19. European Civil Aviation Conference. Joint Requirements for TV 9~ ~9~ As_ Equipments. ECAC.CEAC Doe. No. 18. Paris: European Civil Aviation Conference, 1979. ~-~ ~ __,, ~ ~ ~ C ~. ~A.L ~ ~/V ~ &&C 20. Federal Aviation Act of 1958. PL 85-726. Statutes at Large 72:731-811, 1958. U.S . 21. Formal complaints. Code of Federal Regulations, Title 14, Pt. 13.5. Washington, D.C.: U.S. Government Printing Office, 1985. 22. Hazardous Materials Transportation Act. PL 93-633. U.S. Statutes at Large 88:2156-2173, 1974. 23. Higgins, E. A. Protective breathing: Oxygen mask use/problems, pp. 61-65. In Flight Safety Foundation, Inc. Proceedings of Cabin Safety Conference and Workshop, December 11-14, 1984. Washington, D.C.: U.S. Federal Aviation Administration, Office of Aviation Safety, 1985. 24. Inflight Occupant Protection Working Group. Inflight Occupant Protection Workshop: Summary of proceedings, pp. 167-171. In Flight Safety Foundation, Inc. Proceedings of Cabin Safety Conference and Workshop, December 11-14, 1984. DOT/FAA/ASF100-85/01. Washington, D.C.: U.S. Federal Aviation Administration, Office of Aviation Safety, 1985. 25. Investigative and enforcement procedures. Code of Federal Regulations, Title 14, Pt. 13. Washington, D.C.: U.S. Government Printing Office 1985.
88 26. Johnson, D. A. Behavioral inaction under stress conditions similar to the survivable aircraft accident, pp. 42-47. In Survival and Flight Equipment Association. Proceedings of the Ninth Annual Symposium, Las Vegan, Nev., Sept. 27, 1971. Canoga Park, Cal.: Survival and Flight Equipment Association, 1972. Legal enforcement actions. Code of Federal Regulations, Title 14, Pt. 13, Subpart C. Washington, D.C.: U.S. Government Printing Office, 1985. 28. McSweeny, T. E. FAA cabin safety activities, pp. 30-44. In Flight Safety Foundation, Inc. Proceedings of Cabin Safety Conference and Workshop, December 11-14, 1984. Washington, D.C.: U.S. Federal Aviation Administration, Office of Aviation Safety, 1985. 29. National Research Council, Committee on FAA Airworthiness Certification Procedures. Improving Aircraft Safety: FAA Certification of Commercial Passenger Aircraft. Washington, D.C.: National Academy of Sciences, 1980. 30. National Transportation Safety Board. Safety Study, Airline Passenger Safety Education: A Review of Methods Used to Present Safety Information. Washington, D.C.: National Transportation Safety Board, 1985. (draft) Onstad, C. H., and D. R. Roark, Jr. Air safety: Enforcement of the Federal Aviation Regulations, pp. 195-222. In A. Kean, Ed. Essays in Air Law. The Hague: Martinus Ni~hoff Publishers, 1982. 32. Passenger information. Code of Federal Regulations, Title 14, Pt. 121.317. Washington, D.C.. U.S. Government Printing Office, l9B5. 33. Pollard, D. W., J. A. Steen, W. J. Biron, and R. L. Cremer. Cabin Safety Subject Index. FAA-AM-84-1. Oklahoma City, Okla.: U.S. Federal Aviation Administration, Civil Aeromedical Institute, 1984.
\ 89 34. Reports of violations. Code of Federal Regulations, Title 14, Pt. 13.1. Washington, D.C.: U.S. Government Printing Office, 198S. Society of Automotive Engineers, Inc. Aerospace Standard: Heaters, Aircraft, Internal Combustion Heat Exchanger Type. AS 143. New York, N.Y.: Society of Automotive Engineers, Inc., 1943. 36. U.S. Civil Aeronautics Board. Ventilation: Final rule. Federal Register 17~5 Feb.~:1094, 1952. 37. U.S. Federal Aviation Administration. Air Carrier Operations Bulletins Consolidated Reprint. Washington, D.C.: U.S. Federal Aviation Administration, 1985. 38. U.S. Federal Aviation Administration. Airplane cabin fire protection: Final rule. Federal Register 50~29 March):12726-12733, 1985. 39. U.S. Federal Aviation Administration. Airplane cabin ozone contamination: Final rule. Federal Register 45~21 Jan.~:3880-3883, 1980. 40. U.S. Federal Aviation Administration. Emergency medical equipment: Final rule. Federal Register 51~9 Jan.~:1218-1223, 1986. 41. U.S. Federal Aviation Administration. Fire protection requirements for cargo or baggage compartments: notice of proposed rulemaking. Federal Register 49~8 Aug.~:31830-31838, 1984. 42. U.S. Federal Aviation Administration. Floor proximity emergency escape path marking: Final rule. Federal Register 49~26 Oct.~:43182-43186, 1984. 43. U.S. Federal Aviation Administration. Improved flammability standards for materials used in the interior of transport category airplane cabins: notice of proposed rulemaking. Federal Register 50~16 April):15038-15053, 1985.
go 44. U.S. Federal Aviation Administration. Protective breathing equipment: notice of proposed rulemaking. Federal Register 50~10 Oct.~:41452-41459, 198S. 45. U.S. General Accounting Office. Commercial Safety Regulations Are Avoided by Some Large Aircraft Operators. CED-79-10. Washington, D.C.: U.S. General Accounting Office, 1978. 46. U.S. General Accounting Office. Compilation and Analysis of the Federal Aviation Administration's Inspection of a Sample of Commercial Air Carriers GAO/RCED-85-157. Washington, D.C.: U.S. General Accounting Office, 1985. . Ventilation. Code of Federal Regulations, Title 14, Pt. 25.831. Washington, D.C.: U.S. Government Printing Office, 1985. 48. Ventilation. Code of Federal Regulations, Title 14, Pt. 121.219. Washington, D.C.: U.S. Government Printing Office, 1985.
