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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
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