Safety Recommendation A-00-075

The FAA reviewed all of the research it has conducted on the subject of access to Type III exits and believes that the research results support the 20-inch Type III exit row width requirement that it mandated on May 4, 1992, but that the row width may be reduced to 13 inches for a triple seat passageway. For many years, based on the research, the FAA has been granting findings of an equivalent level of safety allowing reduction of the 20-inch passageway to 13 inches for a triple seat passageway. The FAA has withdrawn its January 30, 1995, notice of proposed rulemaking to revise the Type III exit passageway requirement.

The FAA indicated that in light of the consistent research results and the availability of the equivalent level of safety process, it plans no additional rulemaking action on the width of passageways to Type III exits.

When this recommendation was issued, the Safety Board indicated its concern that the research that had been used as the basis for proposed changes to the rules contained significant design flaws. Further, the Board was unaware of any other study that examined both exit hatch removal and egress speed and that compared the 20-inch exit path width with the 13-inch width. Therefore, the Safety Board issued Safety Recommendation A-00-74, recommending that the FAA conduct additional research, and Safety Recommendation A-00-75, recommending that the FAA issue a final rule on exit row width at Type III exits, based on this new research.

As noted above, the FAA conducted an extensive research program on access to Type III exits that met the intent of Safety Recommendation A-00-74. Based on its review of this research, the FAA concluded that with the equivalent level of safety process, no new rulemaking on the subject of access to Type III exits is needed. Because the need for the action in Safety Recommendation A-00-75 no longer exists, Safety Recommendation A-00-75 is classified "Closed-No Longer Applicable."

Letter Mail Controlled 2/6/2006 2:12:04 PM MC# 2060066 Marion C. Blakey, Administrator, FAA, 1/23/06 The Aviation Rulemaking Advisory Committee (ARAC) Cabin Safety Harmonization Working Group was tasked to produce a harmonized recommendation for a new regulation regarding the access to Type III exits. The ARAC working group completed its work but was unable to reach consensus on a recommendation on several key points. The ARAC working group was able to document the majority positions and minority positions on each of these key points in a report. The report has been forwarded to the FAA without a formal recommendation from ARAC.

Since the ARAC process did not produce a harmonized proposed regulation, the regulatory authorities that participated in the ARAC working group (FAA, Joint Airworthiness Authorities, and Transport Canada) have agreed to work together to agree on a consensus on access to Type III exits. Discussions among the authorities took place for over a year but failed to produce a harmonized position. The discussions on this subject have ceased for now but could start in the future. Consequently, the FAA has reviewed all the research that it has conducted on the subject of access to Type III exits.

This includes testing conducted by the FAA's Civil Aerospace Medical Institute (CAMI) in August/September 1986 and August 1991 that supported the establishment of specified minimum passageways to Type III exits (20 inches when triple seats are installed and 10 inches when double seats are installed) promulgated by Amendment 25-76. Additional testing was conducted by CAMI in September 1992 that further validated the results of the earlier testing, but also strongly supported the reduction of the 20-inch passageway requirement for triple seats to 13 inches.

Finally, the massive research effort noted in the response to this safety recommendation, which involved over 2,500 test subjects, again supported the previous research results, including the reduction of the triple seat passageway to 13 inches. As a result of the research, the FAA has been granting findings of equivalent level of safety allowing reduction of the 20-inch passageway to 13 inches. The FAA issued notice of proposed rulemaking (NPRM) 95-1 (published in the Federal Register on January 30, 1995) to revise the passageway requirement. The NPRM was subsequently withdrawn in favor of higher priority rulemaking projects.

In light of the consistent research results and the availability of the equivalent level of safety process, the FAA considers that no additional action is needed on the width of passageways to Type III exits. I believe that the FAA has satisfactorily responded to this safety recommendation, and I look forward to your response.

Pending subsequent issuance of a final rule on exit row width at Type III exits based on the research program, Safety Recommendation A-00-75 remains classified "Open--Acceptable Response."

Letter Mail Controlled 05/08/2002 1:07:59 PM MC# 2020469 The Federal Aviation Administration (FAA) completed its research on access to Type III overwing exits, and a report is scheduled to be published next month. The Aviation Rulemaking Advisory Committee (ARAC) Cabin Safety Harmonization Working Group met the week of April 8 to discuss the data generated from the research. The ARAC working group. plans to complete the harmonization effort and submit its recommendations to the FAA by the end of 2002.

The FAA reports that it completed its study of all research testing on evacuations leading from the center aisle to Type III overwing exits, and has concluded that additional testing is needed. The FAA further reports that it developed an extensive test program on this subject and has begun the testing. The FAA expects that the program will take approximately 8 to 10 months to complete. Pending issuance of a final rule on exit row width at Type III exits based on the research results, Safety Recommendation A-00-75 remains classified "Open--Acceptable Response."

The Safety Board notes that a member of its staff recently attended a meeting of the FAA's Emergency Evacuation Issues Group. At that meeting, staff from the FAA's Civil Aeromedical Institute (CAMI) reviewed an extensive proposed program of research on evacuation through Type III exits. The proposed program will conduct experiments on major issues associated with Type III exit usage. The Safety Board would appreciate receiving copies of the results of the study of completed research on Type III exits. The Board notes that until the research recommended by A-00-74 is completed, the FAA cannot take action in response to Safety Recommendation A-00-75.

Although the Board understands that the FAA may not be able to complete action on Safety Recommendation A-00-75 within 2 years, the Board also notes the history of slow progress on finalizing a rule on exit row width. The Board will consider the results of the FAA's study of completed research on Type III exits and the FAA's proposed schedule for new research and regulatory reforms. Pending notification of the research the FAA intends to sponsor, the associated regulatory developments, the schedule for these activities, and issuance of a final rule, Safety Recommendation A-00-75 is classified "Open--Acceptable Response."

Letter Mail Controlled 06/08/2001 7:19:13 PM MC# 2020481 The FAA has developed an extensive test program on evacuations leading from the center aisle to Type III overwing exits in response to Safety Recommendation A-00-74. The testing has begun and is expected to take approximately 8 to 10 months to complete. I will inform the Board of its course of action to address these recommendations after the study is completed.

Letter Mail Controlled 11/14/2000 4:39:44 PM MC# 2001688 The FAA is conducting a study in response to A-00-74 of all research testing that has been completed on evacuations leading from the center aisle to Type III overwind exits. The study will include research conducted by the FAA and Cranfield Aviation Safety Centre. It is anticipated that the study will be completed by March 31, 2001. The FAA will determine if additional research testing is needed upon completion of the study.

The FAA has tasked the Aviation Rulemaking Advisory Committee (ARAC) with harmonizing the requirements of Federal Aviation Regulations (FAR)/Joint Airworthiness Regulations (JAR) 25.813(c), which address access to Type-III exits. The ARAC is scheduled to submit a report with recommendations to the FAA in December 2000. The study described above will assist the ARAC in making its recommendations. Although the FAA expects to receive a report in December 2000, it is unable to commit to the 2-year timeframe recommended in this safety recommendation. It is likely that the report will contain multiple recommendations.

The FAA will assess these recommendations and inform the Board of a proposed schedule by March 31, 2001.