Please silence your devices. However, please open your internet browser and log onto:

Transcription

1 Please silence your devices. However, please open your internet browser and log onto:

2 Question: Ice breaker question; Would you rather be somewhere else right now?

3 CFR Associated Risks Due to Compliance

4 Background The Rules u 14 CFR u EASA-OPS u ICAO Annex 6 u IS-BAO (Not really a rule, but )

5 FAR (b)(1)(ii) u Clearly written/understood u Commonly/intentionally ignored

6 EASA-OPS u Replaced JAR-OPS and EU-OPS u Cabin alt >10,000 >30 mins u Cabin alt >13,000

7 ICAO Annex 6 u EASA-OPS mimics ICAO Annex 6. u Use of supplemental oxygen mandated by cabin altitude.

8 IS-BAO u 2015 IS-BAO Protocol changed to harmonize with ICAO Annex 6. Cabin pressure >10,000 feet > 30 mins Cabin pressure >13,000 feet

9 FAR (b)(1)(ii) Non-Compliance u Why are otherwise compliant and disciplined professional pilots choosing to ignore FAR ? u Why are the compliant pilots frustrated with the current regulation? u Why aren t the FAA and NTSB addressing this situation?

10 Safety Management u Identification of the Hazard(s) u Risk assessment u Eliminate, Mitigate, or Accept

11 FAR (b)(1)(ii) The Hazard u Hypoxia due to Depressurization u Explosive, Rapid, or Slow u Rapid Depressurization Above 41,000 ft seconds EPT

12 Risk Assessment u Severity of the Hazard u Probability of an Occurrence u Tolerability of Its Effects

13 FAR (b)(1)(ii) Severity of the Hazard u Unmitigated Depressurization Event is Categorized as Catastrophic

14 FAR (b)(1)(ii) Probability u NTSB Accident Reports u NASA ASRS Reports u AC Safety Analysis required for all systems and components. Catastrophic (critical) failure condition must be extremely improbable (1.E-9 or less)

15 FAR (b)(1)(ii) Probability u Highly Unlikely Based on an explosive or rapid decompression event

16 FAR (b)(1)(ii) Tolerability of Its Effects u Highly Unlikely/Catastrophic = Acceptable Risk

17 Hazards Caused by FAR Compliance u Fatigue u CRM Interference u Vision Interference u Oxygen Depletion u Lung, throat, sinus irritation u Unsanitary Health Risks u Untimely Wear u Quick-donning Feature Negated

18 Compliance Hazards Fatigue

19 Question: Do you feel that wearing the oxygen mask for an extended period of time adds to pilot fatigue?

20 Compliance Hazards CRM Interference u Impaired communication u Pilot Wearing Mask is Effectively Isolated Looking back on a 25 year career, this flight was one of the most challenging and dangerous flights I have ever completed, including 10 years of U.S. Navy night aircraft carrier operations.

21 Question: Do you feel that the oxygen mask interferes with CRM?

22 Compliance Hazards Vision Interference u Mask interferes with glasses u Mask blocks view of pedestal and lower instrument panel

23 Compliance Hazards Oxygen Depletion u Oxygen is consumed in NORMAL setting u Translation from psi to time/distance u Replenishment challenges at foreign locations

24 Compliance Hazards Lung, throat, sinus irritation u More time now spent breathing dry oxygen u Bronchial irritation

25 Question: Have you ever experienced any physiological symptoms after using the oxygen mask for an extended period of time?

26 Compliance Hazards Unsanitary Health Risks u Difficult to effectively clean u Hose cannot be cleaned u Stored with head bands in mask

27 Question: Are you worried about getting sick after using an oxygen mask in flight or during training?

28 Compliance Hazards Untimely Wear u Designed for emergency use u Stored by flight crew

29 Compliance Hazards Quick-donning Negated u Not easily re-stowed after routine use u Unsecured mask technique

30 Mitigation u Requires Understanding u Reduces Probability and/or Severity u Not permanent

31 Mitigation Options u Ignore FAR u Petition for Exemption u Don t Fly Above FL410 u Modify Oxygen System u Change FAR

32 Mitigation Options Ignore FAR u Poor airmanship u Normalization of deviance culture

33 Question: Do you believe that ignoring FAR is a threat to a positive safety culture?

34 Mitigation Options Petition for Exemption u Common prior to 1986 u No successful exemptions in 28 years u Only one application based on SMS risk analysis

35 Mitigation Options Don t Fly Above FL410 u Eliminates Hazards u Adds to Airspace Congestion u Higher Operating Expense u Higher Emissions

36 Question: Do you fly below FL410 because of FAR ?

37 Mitigation Options Modify Oxygen System u Fitted military style masks u Segregated emergency system

38 Question: Would you prefer a modified oxygen system over a rule change?

39 Mitigation Options Change FAR u Highly challenging option u Harmonize with ICAO Annex 6 u Possibility to include additional mitigation Training requirements Equipment requirements

40 Question: Are you in favor of changing FAR to mimic ICAO Annex 6?

41 Question: Would you accept additional mitigation, such as training or equipment requirements with a rule change?

42 HASO u NBAA High Altitude Supplemental Working Group (HASO) u

43 Question: Should we continue?

44 CFR Associated Risks Due to Compliance