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Question: Ice breaker question; Would you rather be somewhere else right now? www.pollev.com/vortex

CFR 91.211 Associated Risks Due to Compliance

Background The Rules u 14 CFR 91.211 u EASA-OPS u ICAO Annex 6 u IS-BAO (Not really a rule, but )

FAR 91.211 (b)(1)(ii) u Clearly written/understood u Commonly/intentionally ignored

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

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

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

FAR 91.211(b)(1)(ii) Non-Compliance u Why are otherwise compliant and disciplined professional pilots choosing to ignore FAR 91.211? u Why are the compliant pilots frustrated with the current regulation? u Why aren t the FAA and NTSB addressing this situation?

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

FAR 91.211(b)(1)(ii) The Hazard u Hypoxia due to Depressurization u Explosive, Rapid, or Slow u Rapid Depressurization Above 41,000 ft. 9 12 seconds EPT

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

FAR 91.211(b)(1)(ii) Severity of the Hazard u Unmitigated Depressurization Event is Categorized as Catastrophic

FAR 91.211(b)(1)(ii) Probability u NTSB Accident Reports u NASA ASRS Reports u AC 25.1309 Safety Analysis required for all systems and components. Catastrophic (critical) failure condition must be extremely improbable (1.E-9 or less)

FAR 91.211(b)(1)(ii) Probability u Highly Unlikely Based on an explosive or rapid decompression event

FAR 91.211(b)(1)(ii) Tolerability of Its Effects u Highly Unlikely/Catastrophic = Acceptable Risk

Hazards Caused by FAR 91.211 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

Compliance Hazards Fatigue

Question: Do you feel that wearing the oxygen mask for an extended period of time adds to pilot fatigue? www.pollev.com/vortex

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.

Question: Do you feel that the oxygen mask interferes with CRM? www.pollev.com/vortex

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

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

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

Question: Have you ever experienced any physiological symptoms after using the oxygen mask for an extended period of time? www.pollev.com/vortex

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

Question: Are you worried about getting sick after using an oxygen mask in flight or during training? www.pollev.com/vortex

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

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

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

Mitigation Options u Ignore FAR 91.211 u Petition for Exemption u Don t Fly Above FL410 u Modify Oxygen System u Change FAR 91.211

Mitigation Options Ignore FAR 91.211 u Poor airmanship u Normalization of deviance culture

Question: Do you believe that ignoring FAR 91.211 is a threat to a positive safety culture? www.pollev.com/vortex

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

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

Question: Do you fly below FL410 because of FAR 91.211? www.pollev.com/vortex

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

Question: Would you prefer a modified oxygen system over a rule change? www.pollev.com/vortex

Mitigation Options Change FAR 91.211 u Highly challenging option u Harmonize with ICAO Annex 6 u Possibility to include additional mitigation Training requirements Equipment requirements

Question: Are you in favor of changing FAR 91.211 to mimic ICAO Annex 6? www.pollev.com/vortex

Question: Would you accept additional mitigation, such as training or equipment requirements with a rule change? www.pollev.com/vortex

HASO u NBAA High Altitude Supplemental Working Group (HASO) u www.o2mask.org

Question: Should we continue? www.pollev.com/vortex

CFR 91.211 Associated Risks Due to Compliance