NPA-OPS 44 (JAR-OPS 1) Cabin Crew Exit Training NPA-OPS 44 (JAR-OPS 1) Cabin Crew Exit Training

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1 NPA-OPS 44 (JAR-OPS 1) Cabin Crew Exit Training NPA-OPS 44 (JAR-OPS 1) Cabin Crew Exit Training CJAA/OPS DIV Page 1 of 33 29/05/2006

2 NPA-OPS 44 (JAR-OPS 1) Cabin Crew Exit Training NPA-OPS 44 NPA to JAR-OPS Part 1 (Commercial Air Transportation Aeroplanes) This NPA is comprised of:- 1. Explanatory Note 1.1. Regulatory Background 1.2. Regulatory Impact Assessment 2. Text Proposals For ease of reference, the proposals are shown in much the same format as they would appear in the JAR. Thus, Section 1 material is shown in columnar format and Section 2 reads across the page. The proposed changes to the text are shown by a combination of strikeout and bold italics. The latter indicates proposed new text (or numbering). Paragraph/s affected:- Appendix 1 to JAR-OPS Conversion and Differences Training Paragraph (c) (1) Appendix 1 to JAR-OPS Recurrent Training Paragraph (c) (1) Appendix 1 to JAR-OPS Refresher Training Paragraph (a) (3) IEM ACJ OPS /1.1010/1.1015/ Representative Training Devices Paragraph (2) (c) New Para 3 Comment Document (CRD) CJAA/OPS DIV Page 2 of 33 29/05/2006

3 1. Explanatory Note 1.1. Regulatory Background NPA-OPS 44 (JAR-OPS 1) Cabin Crew Exit Training This NPA originated from a proposal to examine the issues regarding the current text of Appendix 1 to JAR-OPS (Conversion and differences training) paragraph (c) (1), Appendix 1 to JAR-OPS (Recurrent training) paragraph (c) (1), Appendix 1 to JAR- OPS (Refresher training) paragraph (a) (3) and IEM ACJ OPS /1.1010/1.1015/ in respect of cabin crew exit training, to determine if changes are required in order to provide clarification and leave no doubt as to what is actually required. This proposal takes into account recommendations made by the United Kingdom Air Accident Investigation Branch (AAIB). Such recommendations were made in respect of unsatisfactory levels of cabin crew training for exit operation identified by the AAIB during investigations into emergency evacuations Introduction In an emergency requiring an evacuation of an aeroplane, the cabin crew are responsible for rapidly and effectively evacuating passengers through the emergency exits and down the evacuation slides, where installed. The first action to be taken by cabin crew members is to ensure that there are no external hazards that might affect the safe evacuation of passengers. The next action is to open emergency exits and to deploy the evacuation slides, where installed. This is a vital part of a cabin crew members safety responsibility and this is enforced by JAR-OPS which states that. each cabin crew member undergoes a check covering the training received in order to verify his proficiency in carrying out normal and emergency safety duties. The current text in Appendix 1 to JAR-OPS paragraph (c) (1) states that an operator shall ensure that Each cabin crew member operates and actually opens all normal and emergency exits for passenger evacuation in an aeroplane or representative training device.. Appendix 1 to JAR-OPS paragraph (c) (1) states: An operator shall ensure that, at intervals not exceeding 3 years, recurrent training also: (1) includes the operation and actual opening of all normal and emergency exits for passenger evacuation in an aeroplane or representative training device. Appendix 1 to JAR-OPS paragraph (a) (3) states The operation and actual opening of all normal and emergency exits for passenger evacuation in an aeroplane or representative training device. The associated IEM ACJ states: A representative training device may be used for the training of cabin crew as an alternative to the use of an actual aeroplane or required equipment. The IEM ACJ also states: Where practicable, exits in all modes of operation (particularly in relation to method of operation, their mass and balance and operating forces) Types of Emergency Exits and how they operate Aeroplane doors and exits differ considerably in their design and operating capabilities and characteristics. The following is a brief summary of exits and their basic operating systems: Exits without assist evacuation slides: These include floor level exits on aeroplane types which have sill heights of less than 6 foot or Type III or Type IV exits which apart from Airbus A320, Boeing 757 and Boeing 767, do not have off-wing evacuation slides. For exits that are not equipped with evacuation slides there is usually only one mode of operation and that is in the manual mode. In other words there is no difference in the operation of the exit in normal operation to that of an emergency CJAA/OPS DIV Page 3 of 33 29/05/2006

4 evacuation. NPA-OPS 44 (JAR-OPS 1) Cabin Crew Exit Training Exits without power assist means: These include some with Type I floor level exits such as the Boeing 737 and MD 80 series aeroplanes. These exits are equipped with an evacuation slide which has to be manually dragged from the slide bustle when the exit is in the armed mode with the girt bar attached to the cabin floor at the door sill. The physical effort needed to open the exit and deploy the evacuation slide will differ between aeroplane types and will very much depend on the size and weight of the evacuation slide. Exits with power assist means: An exit with a power-assist system is one which when the door handle has been operated and initial door motion has been achieved, an assist system takes over powering the door open and dragging the slide from the slide bustle. Such systems were first installed on Type A exits on wide-bodied aeroplanes in order to accommodate the much larger dual lane slides required by JAR/FAR 25. These power-assist systems are now installed on narrow-bodied aeroplane types such as the Boeing 757, Airbus A319/320/321. If the power-assist system fails then the slide can still be deployed but will again depend on the physical effort described above. More recently there has been a new development with floor level Type I exit slides being installed in an external compartment just below the exit (eg. Airbus A321 and as also proposed for A380 upper deck slides). Type IV exits: These are the smaller of the self-help exits that have a removable hatch normally operated by passengers and ejected through the exit aperture. Type IV exits are not equipped with evacuation slides. These exits are only found on narrow-bodied aeroplane, eg. Fokker F27, small commuter aeroplane and executive jets. Type IV exits are not power-assisted. Type III exits: Slightly larger than Type IV exits and usually significantly heavier but with basically the same procedure for operation. They are usually located in the middle of the aeroplane over the wing, but can also be located under the wing, eg. BAe In the case of the Airbus A319/320, Boeing 757 and Boeing 767 these exits have an integral off-wing evacuation slide installed in an exterior compartment. Since the evacuation slide is not attached to a girt bar or installed inside an internal bustle, there is no additional force required to operate the exit in the armed mode. In fact some of these exits remain in the armed mode at all times apart from maintenance checks. Conventional Type III exits are not power-assisted. Boeing new generation Type III exits: Although similar in design in terms of size and weight, the new generation Type III exits installed on Boeing /700/800 series aeroplanes have a semi-automatic operation. The single action of operating the exit handle opens the exit outwards with the hatch remaining connected to the aeroplane by the installation of an upper hinge. Type I exits: Type I exits are normally installed on narrow-bodied aeroplane, but can also be found on wide-bodied designs such as the Boeing 767 (ie. Doors 3). Type I exits are equipped with an evacuation slide when the exit sill height exceeds 6 feet. Some Type I exits are equipped with evacuation slides and power-assist systems as described above. Type A exits: Type A exits are only to be found on wide-bodied aeroplane and are required to be equipped with dual lane evacuation slides. All Type A exits are equipped with power-assist systems in order to meet the ease of operation requirements of JAR/FAR 25. This is necessary in order to accommodate the difficulty of dragging the much larger and heavier slide out of the slide bustle. Achieving door opening and slide deployment without an active power-assist system CJAA/OPS DIV Page 4 of 33 29/05/2006

5 NPA-OPS 44 (JAR-OPS 1) Cabin Crew Exit Training would be very difficult for a single crew member and would probably require the assistance of another crew member or a passenger Summary of exit types: There are basically four types of exits in respect of modes of operation, which are as follows: a) Exits which do not have evacuation slides and therefore are only operated in the manual mode. b) Exits which have evacuation slides attached by means of a girt bar and without a power-assist system. Such exits need additional physical force to open them in the armed mode. c) Exits which have evacuation slides attached by means of a girt bar but are also equipped with a power-assist system. They operate quite differently in the powerassist mode and may require additional physical force to operate if the power-assist system fails. d) Exits which have evacuation slides that are not attached by the means of a girt bar (ie. stowed in the fuselage under the exit sill). The forces to open such exits and deploy the slides should not be significantly different in the normal mode, the power-assist mode or the power-assist fail conditions Accident recommendations made to JAA The United Kingdom AAIB has made three safety recommendations in recent years regarding accidents involving JAA AOC holders, in respect of cabin crew exit training. These include the following: Recommendation : The CAA, FAA and JAA should review the requirements for public transport aircraft cabin door simulators used for crew training to require that they accurately simulate any non-linear characteristics of the associated aircraft doors and to require that full instruction is given to cabin crews regarding the door operating characteristics to be expected when operating the doors in an emergency." Recommendation : The CAA and JAA should review the requirements for flight and cabin crew training in respect of the operation of all available exits, to ensure that crew members are familiar with the operating procedures, and opening characteristics, in both the normal and emergency modes of operation. Recommendation : It is recommended that the Irish Aviation Authority and JAA review the requirements for cabin crew initial and refresher training in respect of the operation of all normal and emergency exits, to ensure that crew members become, and remain, familiar with the different operating procedures, and opening characteristics, in both normal and emergency modes of operation. The AAIB report also states: The No 2 and No 3 CCMs had difficulty opening their respective doors, R1 and R2. However, the crew members who lent assistance [positioning crew] experienced no trouble in operating these exits. At the time of the incident, whilst few of the new entrant cabin crew personnel would operate the emergency exit doors in the armed mode during Conversion and Differences training, most would not. For the latter the door opening forces which they encountered during training were considerably less than those that would be encountered in a real evacuation with an armed evacuation slide. Although their instruction was supplemented with the advice that the fully rigged door would be more resistant to opening in the real event because of the integral slide deployment, during training they would have acquired no sense of CJAA/OPS DIV Page 5 of 33 29/05/2006

6 NPA-OPS 44 (JAR-OPS 1) Cabin Crew Exit Training the forces they would normally encounter trying to open an armed door Subsequent JAA Actions In June 2002 the JAA issued Temporary Guidance Leaflet Number 31 Crew Training for Exit Operation. TGL 31 is attached to this document as Appendix 1. Note: If the changes proposed in this NPA are adopted, TGL 31 could be cancelled, although liaison with the FCSG would be necessary. The Operations Sectorial Team (OST) referred AAIB Recommendation to the Cabin Crew Steering Group in the autumn of 2004, for consideration. The resulting proposal was endorsed at OST 05-2, then reviewed by RST before being launched for public consultation 01/09/05 to 01/12/05. The CRD and final text proposals were endorsed at OST 06-2 March 06 for final RST review, prior to being submitted to the JAAC for adoption, in accordance with JAR-11. Comment received during final review at RST 06-1: The NPA should indicate that long term exemptions may need to be considered to allow reasonable time for obtaining appropriate training devices Discussion Concern has been expressed that some operators are not providing cabin crew training for exit operation in all modes of operation. Of particular concern might be the lack of practical training on door operation when the exit is in the armed mode, (ie. with the girt bar attached to the cabin floor in the area of the exit/door sill). Some aeroplane have doors with powerassist systems that will automatically power the door open dragging the slide from the slide bustle. Other aeroplanes, especially on some narrow-bodied aeroplane fleets, do not have a powerassist systems and rely only on the physical force of the cabin crew member to operate the exit operating handle and to fully open the door, dragging the evacuation slide pack out from the slide bustle and inflating the slide. Where a power-assist system is incorporated, the additional physical force may still be required by the cabin crew member if the power-assist system fails. In these cases, if the training has not replicated the physical force and effort needed to open the doors and to deploy and inflate the slide, then it could be argued that the cabin crew member has not demonstrated proficiency in door operation in the most critical mode, i.e. the actual mode required to operate the door in an emergency. The current wording of Appendix 1 to JAR-OPS (c) (1), Appendix 1 to JAR-OPS (c) (1) and Appendix 1 to JAR-OPS (a) (3) requires that each cabin crew member actually opens all normal and emergency exits for passenger evacuation. The rule does not actually specify that the exit must be opened in all modes of operation. However, it could be argued that in order to open the exit for passenger evacuation the exit must be fully available to the passenger for the purpose of evacuation. If this is accepted then it could be assumed that the exit must be opened during training in each of the operational modes that might be required to open the exit and deploy the evacuation slide. The current wording in IEM ACJ OPS /1.1010/1.1015/ Representative Training Devices, confuses the issue further since it states that whilst exit training should include the method of exit operation, exit mass and balance, and exit operating forces, this need only be achieved if practicable. An amendment to this IEM ACJ would also need to be considered. CJAA/OPS DIV Page 6 of 33 29/05/2006

7 NPA-OPS 44 (JAR-OPS 1) Cabin Crew Exit Training Conclusion In order that cabin crew are trained to effectively operate exits in an emergency the wording of Appendix 1 to JAR-OPS paragraph (c) (1), Appendix 1 to JAR-OPS paragraph (c) (1), Appendix 1 to JAR-OPS paragraph (a) (3) and the associated IEM ACJ OPS will need to be changed. Such a change will ensure that the intent of the requirement is perfectly clear and that cabin crew are trained to operate emergency exits in the normal and emergency modes of operation including the action and forces required to operate and deploy evacuation slides. The UK AAIB recommendations to the JAA strongly support the safety case for this proposed change. Whilst in the accidents mentioned above there were no passenger fatalities, the situation might have been different if the emergency scenarios had been more serious. In the last case cited by the AAIB (Recommendation ), if the fire situation had been more significant, and the positioning crew had not been on board, then the consequences to occupant survival could have been significant. CJAA/OPS DIV Page 7 of 33 29/05/2006

8 1.2. Regulatory Impact Assessment Purpose and Intended Effect NPA-OPS 44 (JAR-OPS 1) Cabin Crew Exit Training The purpose of this NPA is to update and clarify existing requirements for cabin crew exit training as specified in Appendix 1 to JAR-OPS (Conversion and differences training) paragraph (c) (1), Appendix 1 to JAR-OPS (Recurrent training) paragraph (c) (1), Appendix 1 to JAR-OPS (Refresher training) paragraph (a) (3) and IEM ACJ OPS /1.1010/ / This NPA takes into account recommendations made by the United Kingdom Air Accident Investigation Branch. Such recommendations were made in respect of unsatisfactory levels of cabin crew training for exit operation during emergency evacuations Options The options relating to JAR-OPS , JAR-OPS , JAR-OPS and the associated IEM ACJ are: a) Take no action. b) Amend JAR-OPS , JAR-OPS , JAR-OPS and the associated IEM ACJ to require training in the various modes of exit operation. To take no further action would place the JAA National Authorities and the Industry in a very difficult position if another accident were to occur, where the factors of cabin crew exit training had a detrimental affect on the successful and safe evacuation of passengers. The AAIB have now made three separate safety recommendations to the JAA resulting from three separate accidents to JAA AOC holders Impacts i. The large majority of JAA AOC holders already provide their cabin crew with exit training that incorporates different modes of operation including the actions and forces required to open the exit and deploy the evacuation slide. Such training is currently provided by the majority of AOC holders during Conversion and differences training, as well as during three-yearly Recurrent training (and Refresher training as appropriate). The majority of operators either have their own representative training devices that they use for exit training, or they use the training device of other operators. ii. There will be costs to those operators who do not currently train their cabin crew in the different modes of exit operation, and this is especially the case where perhaps no representative training devices are available. However, when taking into consideration that JAR-OPS requires verification of a crew member s proficiency in carrying out emergency safety duties, it could be argued that such a training deficit should have already been identified by National Aviation Authorities Consultation The consultation process has been conducted within the Cabin Crew Steering Group (CCSG), previously known as the Flight Crew and Cabin Crew Study Group (FCCCSG) - Subpart O. As previously stated, this issue was referred to the CCSG as a result of AAIB recommendation which was addressed to the JAA as well as the Irish Aviation Authority. The National Aviation Authorities have been involved in the drafting process of this document, as have ERA, AEA, ITF and ETF. The primary consultation was through the NPA process prescribed in JAR-11. CJAA/OPS DIV Page 8 of 33 29/05/2006

9 NPA-OPS 44 (JAR-OPS 1) Cabin Crew Exit Training Summary and Final Assessment The proposed changes to JAR-OPS , JAR-OPS , JAR-OPS and the associated IEM ACJ as defined in part 2 of the NPA, will provide clear regulation for operators who may not at this stage fully understand the intent of the current requirement in respect of cabin crew exit training. CJAA/OPS DIV Page 9 of 33 29/05/2006

10 NPA-OPS 44 (JAR-OPS 1) Cabin Crew Exit Training 2. Text Proposals Appendix 1 to JAR-OPS Conversion and Differences Training Paragraph (c) (1) (c) that: Operation of doors and exits. An operator shall ensure (1) Each cabin crew member operates and actually opens all each type or variant of normal and emergency exits for passenger evacuation in the normal and emergency modes, including failure of power assist systems where fitted. This is to include the action and forces required to operate and deploy evacuation slides. This training shall be conducted in an aeroplane or representative training device; and Appendix 1 to JAR-OPS Recurrent training Paragraph (c) (1) (c) An operator shall ensure that, at intervals not exceeding 3 years, recurrent training also includes: (1) The operation and actual opening of all normal and emergency exits for passenger evacuation Each cabin crew member operating and actually opening each type or variant of normal and emergency exit in the normal and emergency modes, including failure of power assist systems where fitted. This is to include the action and forces required to operate and deploy evacuation slides. This training shall be conducted in an aeroplane or representative training device; Appendix 1 to JAR-OPS Refresher training Paragraph (a) (3) (a) An operator shall ensure that refresher training is conducted by suitably qualified persons and, for each cabin crew member, includes at least the following: (3) The operation and actual opening of all each type or variant of normal and emergency exits in the normal and emergency modes, including failure of power assist systems where fitted. This is to include the action and forces required to operate and deploy evacuation slides. This training shall be conducted for passenger evacuation in an aeroplane or representative training device; /1/1010/1.1015/ Representative Training Devices Paragraph (2) (c) IEM ACJ OPS 2 Only those items relevant to the training and testing intended to be given, should accurately represent the aeroplane in the following particulars: (c) Where practicable, eexits in all modes of operation, (particularly in relation to method of operation, their mass and balance and operating forces) including failure of power assist systems where fitted; and 3 When determining whether an exit can be considered to be a variant of another type, the CJAA/OPS DIV Page 10 of 33 29/05/2006

11 following factors should be assessed: NPA-OPS 44 (JAR-OPS 1) Cabin Crew Exit Training a. Exit arming/disarming; b. Direction of movement of the operating handle; c. Direction of exit opening; d. Power assist mechanisms; e. Assist means, e.g. evacuation slides Consequential Editorial Changes:- JAR-OPS Initial training (See Appendix 1 to JAR-OPS ) (See IEM ACJ OPS /1.1010/1.1015/1.1020) (See ACJ OPS /1.1010/1/1015) (See Appendix 2 to ACJ OPS /1.1010/1.1015) JAR-OPS Conversion and Differences training (See Appendix 1 to JAR-OPS ) (See IEM ACJ OPS /1.1010/1.1015/1.1020) (See ACJ OPS /1.1010/1/1015) (See Appendix 2 to ACJ OPS /1.1010/1.1015) JAR-OPS Recurrent training (See Appendix 1 to JAR-OPS ) (See IEM ACJ OPS /1.1010/1.1015/1.1020) (See ACJ OPS /1.1010/1/1015) (See Appendix 2 to ACJ OPS /1.1010/1.1015) JAR-OPS Refresher training (See Appendix 1 to JAR OPS ) (See AMC OPS ) (See IEM ACJ OPS /1.1010/1.1015/1.1020) CJAA/OPS DIV Page 11 of 33 29/05/2006

12 NPA-OPS 44 (JAR-OPS 1) Cabin Crew Exit Training APPENDIX 1 JAA Administrative & Guidance Material Section Four: Operations, Part Three: Temporary Guidance Leaflet (JAR-OPS) LEAFLET NO. 31: CREW TRAINING FOR EXIT OPERATION A recently published accident report has identified differences between actual aeroplane door operation in the emergency mode with an active power assist facility and the operation of the same type of door installed in a cabin simulator. It has been recommended that cabin door simulators accurately simulate all characteristics of the associated doors and that full instructions on the specific aeroplane door operating characteristics should be provided to flight and cabin crew during training and be repeated in the Operations Manual. Differences in door operating characteristics between actual aeroplane doors and the doors installed in cabin simulators can be of critical importance during an emergency evacuation, especially if an incorrect door operation procedure is used. In the worst case scenario, the crew member may not be able to effectively open a fully functional door or exit if incorrect or inadequate procedures have been specified in the Operations Manual and are repeated during training. Consideration should be given to: a. Retrospective modification to existing cabin simulators to address these potential problems, or b. Acquisition of a cabin simulator that simulates accurately all characteristics of aeroplane door operation, and in the meantime, c. Emphasising differences between the operating characteristics of actual aeroplane doors and cabin simulator doors during training (e.g. by use of video) and in the Operations Manual. This is especially important where it is recognised that a cabin door simulator cannot, or does not, exactly replicate the actual aeroplane door operating characteristics. Operations Manuals should be reviewed to ensure that information on aeroplane door operation is fully compliant with the procedures recommended by the relevant aeroplane manufacturer. In addition, Operators should provide full instructions to their flight and cabin crew, based on information provided by the aeroplane manufacturer, regarding door operating characteristics that might be expected when operating an aeroplane door in an emergency. Reference documents: Appendix 1 to JAR-OPS (a), (a)(3)(iii)(a), (c), (c) and (a). (Section 4/Part 3 (JAR-OPS) ) CJAA/OPS DIV Page 12 of 33 29/05/2006

13 CRD to NPA-OPS 44 (Cabin Crew Exit Training)

14 Summary of NPA-OPS 44 comment phase Comment period: 01/09/2005 until 01/12/2005 Comment period extended: N/A Number of comments received: 29 CRD collated by: CJAA, Luz Mendes CRD sent for review to: Janice Fisher (CCSG Chairman) CRD sent on: 13 December 2005 Date for completion of review: 20 February 2006 Nomenclature for CRD review A = Accepted PA = Partially accepted D = Declined N = Noted CJAA/OPS DIV 14 of 33 29/05/2006

15 Comment/ Document NPA-OPS 44 (Section 1 material) General 001 Golden Air Agree with the contents of the NPA. Noted. 002 Helvetic Airw. This training may be conducted in an aeroplane or representative training device. Where an aeroplane is used, the operator shall demonstrate that the force required to open doors and exits is equivalent to the force required in a real emergency situation. The actual activation of slides may therefore be replaced by a technical device creating the same behaviour. Where no suitable method on an aeroplane or a representative training device are available, the training may at the discretion of the authority also be conducted in an other type of training device which creates similar conditions to the type being used. 003 Danish CAA Agree with the proposal. It will, however, be very difficult for some Danish operators to meet the requirements. We therefore intend to check how it will be possible for the operators to meet the requirements in practice. 004 ETF Several investigations into accidents in Europe as well as the USA have emphasized the need for systematic cabin crew exit training. The ETF recognizes, welcomes and supports the NPA 44 and the changes to Cabin Crew Exit Training in JAR-OPS Appendices 1 to , 1015, and ACJ OPS The high costs for the representative training device are beyond realistic limits if an aeroplane is operated for which such a device does not already exist on the free market. If there is no training device available, the real activation of slides on actual aircraft is not an option as well due to enormous cost for replacement of slides. Such types of aeroplanes are airline type aircraft typically built during the period 1970 till around 1985, e.g. Boeing MD80, Fokker F-100 and others. Training devices can be made available but usually at some cost. If the stance is to be that NAAs will allow alleviation, then no operator would every buy or invest in suitable training units and the overall standard of training would decline substantially. Additionally there is no requirement in the rule for activation of slides the requirement is for the appropriate door forces to be experienced. Noted. Noted. CJAA/OPS DIV 15 of 33 29/05/2006

16 Comment/ Document NPA-OPS 44 (Section 1 material) /1.1010/ In addition, the ETF appreciates that the proposed amendments will improve harmonization with the FAA rules. The ETF would however like to highlight two aspects of the exit training that should receive proper attention. Please see the attached comment forms. 010 HTF Several investigations into accidents in Europe as well as the USA have emphasized the need for systematic cabin crew exit training. HTF recognizes, welcomes and supports the NPA 44 and the changes to Cabin Crew Exit Training in JAR-OPS Appendices 1 to , 1015, and ACJ OPS /1.1010/ In addition, HTF appreciates that the proposed amendments will improve harmonization with the FAA rules. HTF would however like to highlight two aspects of the exit training that should receive proper attention. Please see our comments. 011 HTF Even if the opening of emergency exits and a speedy evacuation of the passengers represent the key task for cabin crew, the HTF would like to draw attention to a couple of accidents involving wide body aircraft which failed to depressurize. The outcome of the proposed text could be over active cabin crews, and possible injuries. HTF suggest that the JAA should consider addressing this in an ACJ revision. The above mentioned accidents include the Airbus accidents in MIA in 2000 and Djerba Airport Tunisia where cabin crew were killed during evacuation when opening exits due to overpressure in the cabin. The NTSB writes that the cabin crew in the MIA accident was forcibly ejected onto the ramp and was killed. As a consequence of these accidents, particular attention should be given when training cabin crew in wide body Noted. Whilst this is valuable information, this is both aeroplane and operator specific and therefore should not form part of rule material. This should form part of an operator s standard operating procedures and NAA s should ensure that this forms part of a training syllabus. CJAA/OPS DIV 16 of 33 29/05/2006

17 Comment/ Document NPA-OPS 44 (Section 1 material) 014 SCAA The Swedish CAA supports the proposed revision without any comments 015 Slovak CAA the SK CAA has no comments on this NPA and has express support for its adoption. 016 Transport Canada Transport Canada finds NPA-OPS 44 clear and more in line with Transport Canada's exit operation drills. Should the JAA representative be interested in viewing Canada's requirements for exit operation drills, below you can find the links for both initial and annual training. There is also below a link to Schedule A which indicates the aircraft. Even if warning lights for over pressurization are installed in the Airbus A 300 series, the training should emphasize the possible danger of over pressurization. According to the NTSB a particular problem exist when aircraft do not have pressure relief systems for the emergency exit doors. The report describes two other occurrences of injuries due to over pressurization. The incidents occurred on an ATR-72 and a CL 65 Bombardier. For reference see recommendation from UK CAA in FOD COM and NTSB Safety Recommendation of August Noted. Noted. Noted. CJAA/OPS DIV 17 of 33 29/05/2006

18 Comment/ Document NPA-OPS 44 (Section 1 material) exits which Transport Canada deems to be compatible with each other. It will be updated in the future as some of the more recent aircraft are not listed. nuals/tp12296/initial7/section3.htm nuals/tp12296/annual7/section1.htm nuals/tp12296/schedulea/menu.htm 017 SNPNC Our organization representing cabin crew from all airlines registered in France is involved in air safety matters at national, European and worldwide levels since the sixties. Noted. We long considers that there was a significant lack of realism in the way JAR OPS 1 up to now required exit training, with associated risks of errors in case of emergency. Accident investigations have emphasized on several occasions the need for systematic and realistic cabin crew exit training. Therefore, our organization welcomes and supports the amendments proposed by NPA OPS 44 to Cabin Crew Exit Training in JAR- OPS Appendices 1 to , 1015, and ACJ OPS /1.1010/ CJAA/OPS DIV 18 of 33 29/05/2006

19 Comment/ Document NPA-OPS 44 (Section 1 material) For the same reasons, we see as an additional positive step that the proposed amendments improve harmonization with the FAA rules. 018 AEA Each cabin crew member operates and actually opens each type of normal and emergency exit in all modes of operations. the normal and emergency modes, including failure of power assist systems where fitted. This is to include the action and forces or demonstrations of forces required to operate and deploy evacuation slides. This training may be conducted in an aeroplane or representative training device; 1. Clarity; replacing the normal and. where fitted by in all modes of operations. 1. The words in all modes of operation are considered to be unclear. The words normal and emergency modes clarifies the need for both modes of operation. Removing the words failure of power assist systems where fitted is not accepted. This is not covered by the previous terminology, as power assist failure could be determined as an abnormal situation. This could significantly reduce the intent of the NPA. 2. It might be impossible / unrealistic to adjust accurately the forces in all the trainers/door simulators to be exactly the same as in the aeroplanes especially in the cases where the real aeroplane door is used in the simulators. In those cases, where the simulated door is used it might be more realistic. 2. Introducing the term demonstrations of forces could allow operators to use video or other such methods. This is not the intent of the NPA. CJAA/OPS DIV 19 of 33 29/05/2006

20 Comment/ Document NPA-OPS 44 (Section 1 material) 028 NCCU Pls. See proposed text from ETF.NCCU supports this text. 3. In this kind of amendment where new requirements are set, the implementation will take some time to modify the noncompliant doors or especially when making an investment for new training device. At least one year is needed. We are also proposing some kind of grand father rights for the existing devices, if forces can be demonstrated. NCCU is of the opinion that recurrent training is of utmost importance and that cabin crew should be trained every year on how to open all exits. (Hands on training!).during normal operation it s mainly the SCC who is responsible for the opening of doors. It is therefore of utmost importance that all cabin crew is annually trained in how to operate all exits. It is the main task of the CCs in an emergency situation and all the CCs should be able to do this as a reflex action. 3. It is not the remit of the CCSG to allow a one year alleviation. This would be the responsibility of individual NAA s. The proposal to introduce grandfather rights for existing exit training devices is not appropriate as these devices do not require approval. Recurrent training does require yearly touch drills. It is not the intent or the remit of this NPA to change the rule material to require yearly hands on training. 029 DGAC France Although we fully agree with the intent of the proposal, we wonder whether the impact of the proposed amendment has been fully addressed in the case where no training devices are available does not seem to have been fully addressed, especially in the case of exits with evacuation slide. Apart from the cost of grounding the aircraft for making it available for the training (as implied in paragraph of the explanatory note), another impact of requiring actual operation of the exist on the aircraft, may be indirect negative unwanted effects (such as improper closing) of actually operating exits which are designed to be used only in case of emergency. In addition when an evacuation slide is fitted on the aircraft This is not the implication of the text in of the Explanatory Note this text merely implies that operators who are not currently compliant with the rule will need to address this shortfall. It is not the purpose of the NPA to offer solutions but to highlight the need for adequate training. CJAA/OPS DIV 20 of 33 29/05/2006

21 Comment/ Document NPA-OPS 44 (Section 1 material) such operation requires several deployments raising the risk of improper folding of the slides. From the explanatory note it does not appear whether the risk of introducing malfunctions of exits and emergency slides by operating them regularly has been properly assessed. Improper closing of exits or incorrect folding of slides is a matter for the operator and associated maintenance personnel. CJAA/OPS DIV 21 of 33 29/05/2006

22 Comment/ Document NPA-OPS 44 (Section 1 material) Appendix 1 to JAR-OPS (c )(1) 007 Boeing We suggest the following change to paragraph (c)(1) (c) Operation of doors and exits. An operator shall ensure that: (1) Each cabin crew member operates and actually opens each type of normal and emergency exit that is part of the operator s aircraft fleet in the normal and emergency modes, including failure of power assist systems where fitted. This is to include the action and forces required to operate and deploy evacuation slides. This training may be conducted in an aeroplane or representative training device; and AEA (c) Operation of doors and exits. An operator shall ensure that: (1) Each required cabin crew member operates and actually opens each type or variant of normal and emergency exit in the normal and emergency modes, including failure of power assist systems in emergency mode where fitted. This is to include the action and forces required to operate and deploy evacuation slides. This training may be conducted in an aeroplane or representative training device; and Attendants should not be required to learn to open/operate door types that are not in the operator s fleet. The training is required for the cabin crew in charge of the emergency egress that is to say the required cabin crew as defined by JAR OPS We propose to introduce the word variant for the doors type as there are very similars doors (i.e. Type A and Type 1) type with the same operating modes. A The rewording of the text in the NPA has not changed the requirements. There has never been a requirement for cabin crew to open exits on aeroplanes that are not in the operator s fleet. The intent of this NPA is to clarify the existing training requirements it does not impose anything extra. (See Appendix 1 to JAR-OPS (a) (2).) Limiting the training requirement to only required cabin crew is not in compliance with JAR-OPS All cabin crew on board an aeroplane need to meet the training requirements of Subpart O. Accepted. The NPA will be amended to include the word variant and a CJAA/OPS DIV 22 of 33 29/05/2006

23 Comment/ Document NPA-OPS 44 (Section 1 material) definition of a door/issue type variant is proposed within the ACJ OPS /1.1010/1.1015/ definition will be included in the ACJ. In order to clarify the wording of this paragraph as far as the power assistance mode is concerned, we propose to add "in emergency mode". The power assistance is only available when the door is used in emergency mode. There is no need to add additional text as the power assist system is only operational in the emergency mode. 024 Airbus Appendix 1 to JAR-OPS Conversion and Differences Training Paragraph (c) (1) (c) Operation of doors and exits. An operator shall ensure that: (1) Each cabin crew member operates and actually opens each type of normal and emergency exits for passenger evacuation in the normal and emergency modes, with all specific installations when differing throughout the aircraft, and including failure of power assist systems where fitted. This is to include the action and forces required to operate and deploy evacuation slides. This training may be conducted in an aeroplane or representative training device; and The NPA refers to types of exits. This may be understood as a reference to the definitions of exit types for large aeroplanes that are contained in JAR/FAR/CS and basically depend on size and position in relation to cabin floor level. However, on a given aircraft type, the exit operation may significantly differ between exits of the same regulatory type. These differences may be due to such factors as the exit location, the allocated escape slides/rafts, the operating systems and assist spaces. Airbus proposes to reflect this situation in the appendices to JAR- OPS-1.xxxx and the ACJ as presented in this NPA. Conversion training is both operator and aeroplane specific therefore the reference to a type of exit is for the exit installed in a particular aeroplane. The amended text in the ACJ gives guidance as to determining exit type or variant. CJAA/OPS DIV 23 of 33 29/05/2006

24 Comment/ Document NPA-OPS 44 (Section 1 material) Appendix 1 to JAR-OPS (c)(1) 005 ETF ETF suggests adding the following text to the proposed JAR-OPS Appendix 1: (The suggested text is in bold.) ( c ) ( 1) Each cabin crew member actually opens each type of normal and emergency exit in the normal and emergency modes, including failure to the power assist systems where fitted. This is to include the action and forces required to operate and deploy evacuation slides. This training may be conducted in an aeroplane or representative training device. When responsible for a pair of doors, demonstrate that he/she will proceed to the opposite door with the intention to open it. Emergency situations are dynamic and often chaotic. Accident investigations demonstrate the risk that cabin crew during an evacuation may fail to remember to open the opposite exit due to lack of proper training. There is no requirement for CCM in their daily routines to open any exits or doors. In accordance with present operators procedures a CCM may open exits or doors only every third year during recurrent training. For further information please see: UK CAA FODCOM 1/2003. Practical training in the opening in normal and emergency modes had been given to cabin crew but had concentrated on the main passenger door and overwing exits. And NTSB Recommendation A However, most recurrent training programmes do not require cabin crew to practice opening of more than one exit during drills. The NTSB is concerned that usable exits will not be opened during an evacuation because the cabin crew have not been trained to Whilst this is valuable information, this is both aeroplane and operator specific and therefore should not form part of rule material. This should form part of an operator s standard operating procedures and NAAs should ensure that this forms part of a training syllabus. The reference to FODCOM 1/2003 is not completely relevant. The FODCOM was addressing the fact that the cabin crew had opened the larger door and experienced difficulty opening the smaller galley door. They had not forgotten to open the opposite door. CJAA/OPS DIV 24 of 33 29/05/2006

25 Comment/ Document NPA-OPS 44 (Section 1 material) 008 Boeing We suggest the following change to paragraph (c)(1) (c) Operation of doors and exits. An operator shall ensure that: (1) Each cabin crew member operates and actually opens each type of normal and emergency exit that is part of the operator s aircraft fleet in the normal and emergency modes, including failure of power assist systems where fitted. This is to include the action and forces required to operate and deploy evacuation slides. This training may be conducted in an aeroplane or representative training device;.. open more than one exit. Attendants should not be required to learn to open/operate door types that are not in the operator s fleet. The rewording of the text in the NPA has not changed the requirements. There has never been a requirement for cabin crew to open exits on aeroplanes that are not in the operator s fleet. The intent of this NPA is to clarify the existing training requirements it does not impose anything extra. (See Appendix 1 to JAR-OPS (a) (2).) 011 HTF HTF suggests adding the following text to the proposed JAR-OPS Appendix 1: (The suggested text is in bold.) ( c ) ( 1) Each cabin crew member actually opens each type of normal and emergency exit in the normal and emergency modes, including failure to the power assist systems where fitted. This is to include the action and forces required to operate and deploy evacuation slides. This training may be conducted in an aeroplane or representative training device. When responsible for a pair of doors, demonstrate that he/she will proceed to the See reason below Whilst this is valuable information, this is both aeroplane and operator specific and therefore should not form part of rule material. This should form part of an operator s standard operating procedures and NAA s should ensure that this forms part of a training syllabus. The reference to FODCOM 1/2003 is not completely CJAA/OPS DIV 25 of 33 29/05/2006

26 Comment/ Document NPA-OPS 44 (Section 1 material) opposite door with the intention to open it. relevant. The FODCOM was addressing the fact that the cabin crew had opened the larger door and experienced difficulty opening the smaller galley door. They had not forgotten to open the opposite door. Emergency situations are dynamic and often chaotic. Accident investigations demonstrate the risk that cabin crew during an evacuation may fail to remember to open the opposite exit due to lack of proper training. There is no requirement for CCM in their daily routines to open any exits or doors. In accordance with present operators procedures a CCM may open exits or doors only every third year during recurrent training. For further information please see: UK CAA FODCOM 1/2003. Practical training in the opening in normal and emergency modes had been given to cabin crew but had concentrated on the main passenger door and overwing exits. And NTSB Recommendation A However, most recurrent training programmes do not require cabin crew to practice opening of more than one exit during drills. The NTSB is concerned that usable exits will not be opened during an evacuation because the cabin crew have not been trained to open more than one exit. 020 AEA (c) Operation of doors and exits. An operator shall ensure that: (1) Each required cabin crew member operates and actually opens each type or variant of normal and emergency exit in the normal and emergency modes, including failure of power assist systems in emergency mode where fitted. This is to include the action and forces required to operate and deploy evacuation slides. This training may be conducted in an aeroplane or representative training device; and The training is required for the cabin crew in charge of the emergency egress that is to say the required cabin crew as defined by JAR OPS We propose to introduce the word variant for the doors type as there are very similars doors type (i.e. Type A and Type Limiting the training requirement to only required cabin crew is not in compliance with JAR-OPS All cabin crew on board an aeroplane need to meet the training requirements of Subpart O. Accepted. The NPA will be amended to include the word variant and a CJAA/OPS DIV 26 of 33 29/05/2006

27 Comment/ Document NPA-OPS 44 (Section 1 material) 1) with the same operating modes. A definition of a door/issue type variant is proposed within the ACJ OPS /1.1010/1.1015/ In order to clarify the wording of this paragraph as far as the power assistance mode is concerned, we propose to add "in emergency mode". The power assistance is only available when the door is used in emergency mode. definition will be included in the ACJ. There is no need to add additional text as the power assist system is only operational in the emergency mode. 023 CCOO An operator shall ensure that each recurrent training also includes: Each cabin crew member actually opens each type of normal and emergency exit in the normal and emergency modes, including failure to the power assist systems where fitted. This is to include the action and forces required to operate and deploy evacuation slides. This training may be conducted in an airplane or representative training device. When responsible for a pair of doors, demonstrate that he/she will proceed to the opposite door with the intention to open it. CCOO emphasizes on the necessity for well trained cabin crew. To see a video each recurrent training on operation of doors and exits is not enough. Know how is obtained by practice, and through practice experience. Experience is very important. It is therefore very important to practice more often, also on opening the opposite door or exit, when a cabin crew member is responsible for a pair of doors. Recurrent training does require yearly touch drills. It is not the intent or the remit of this NPA to change the rule material to require yearly hands on training. Whilst this is valuable information, this is both aeroplane and operator specific and therefore should not form part of rule material. This should form part of an operator s standard operating procedures and NAA s should ensure that this forms part of a training syllabus. 025 Airbus Appendix 1 to JAR-OPS Recurrent training The NPA refers to types of exits. This may be understood as a reference to the Recurrent training is both CJAA/OPS DIV 27 of 33 29/05/2006