Safety Recommendation A-00-076

Safety Recommendation A-00-76 was issued because the NTSB’s safety study found that the Type III hatch is frequently much heavier and more difficult to remove than passengers expect. The NTSB also found that the way in which this hatch must be opened and stowed is not clear to passengers nor can it be easily depicted graphically. The NTSB noted that Boeing had designed a new overwing exit for its 737 series airplanes that was based on human factors principles. This new Type III exit design was hinged and opened outward, as passengers would expect. Because it moved up and out of the egress route, Boeing’s design also eliminated the problem of where to stow the exit hatch.

The FAA referred this issue to the Aviation Rulemaking Advisory Committee, which was unable to reach a consensus on its own recommendations. The FAA then entered discussions with aviation authorities in other countries but was again unable to reach a consensus.

In its current letter, the FAA stated that it had conducted a cost-benefit assessment of the recommended action. This assessment considered the benefits of the improved exit, the cost of the design changes throughout the life of the aircraft, and the cost of harmonization with non-U.S. airworthiness authorities. The assessment of the possible benefits included a decrease of between 1 and 4 seconds in the time required to prepare the exit for evacuation and a potential increase in egress effectiveness by placing the removed hatch outside the egress path.

The FAA reviewed 12 accidents in which the passengers used Type III exit doors for evacuation; this review showed that of the 40 Type III exits available for evacuation on the subject airplanes, either the passengers or crewmembers were able to open 36 exits during the accidents. With regard to the cost of the recommended action, the FAA considered the additional cost of the exit on new aircraft, as well as the additional weight and maintenance costs associated with Type III exits designed as recommended. The assessment found that the cost of an improved Type III exit is greater than the benefit.

As a result, the FAA has determined that it cannot economically justify a rule mandating the improved Type III exit, although it will encourage their installation.

The NTSB continues to believe that, in the interest of safety, the FAA should take the recommended action; however, because the FAA plans no further action, Safety Recommendation A-00-76 is classified CLOSED—UNACCEPTABLE ACTION.

Letter Mail Controlled 4/27/2009 2:48:25 PM MC# 2090265: FAA Comment. The Federal Aviation Administration agrees that a type III exit with the recommended design features would likely provide some improvement in egress performance. In our most recent response, we committed to continue our harmonization efforts with the European and Canadian airworthiness authorities and to determine whether rulemaking was warranted. The FAA has determined that we cannot economically justify a rule mandating an improved type III exit, as recommended by the Board, on newly manufactured airplanes.

This assessment considered the benefits of the improved exit features, the cost of the design changes throughout the life of the aircraft and the cost of harmonization with non-US airworthiness authorities. We researched the possible benefits of incorporating the improved exit features on newly manufactured airplanes. These benefits include a decrease of 1 to 4 seconds in the time required to prepare the exit for evacuation and the potential increase in egress effectiveness by placing the removed hatch outside the egress path. We reviewed 12 accidents where the passengers used type III exit doors for evacuation. Our review included accidents in Manchester, Los Angeles, and Little Rock.

Our investigation showed that of the 40 type III exits available for evacuation on the subject airplanes, either the passengers or crew were able to open 36 during the evacuations. The recommended exit features may have improved the possibility of opening the remaining four exits. Other studies showed little or no connection between the type III exit design and the potential lifesaving benefit. The addition of stowage requirements to the recommended type III exit doors adds considerable weight and maintenance cost to the operator. The significant cost of an improved type III exit, as the Board proposes, is greater than the benefit.

We will continue to encourage the incorporation of type III exit designs that are easy to open and intuitive to operate.

Safety Recommendation A-00-76 was issued because the Safety Board's safety study on emergency evacuation of commercial airplanes found that the Type III hatch is frequently much heavier and more difficult to remove than passengers expect. The Board also found that the way in which this hatch must be opened and stowed is not clear to passengers nor can it be easily depicted graphically. The Board noted that Boeing had designed a new overwing exit for its 737 series airplanes that was based on human factors principles. This new Type III exit design is hinged and opens outward, as passengers would expect.

Because it moves up and out of the egress route, Boeing's design also eliminates the problem of where to stow the exit hatch. The FAA referred this issue to its Aviation Rulemaking Advisory Committee (ARAC), which was unable to reach a consensus on its recommendations. The FAA then entered discussions with aviation authorities in other countries, but was again unable to reach a consensus. These discussions have ceased for now, pending completion of a benefit study sponsored by Transport Canada and the United Kingdom Civil Aviation Authority.

The FAA indicates that it agrees that action in Safety Recommendation A-00-76 would provide improvements in emergency evacuation performance, and that, based on further discussions with other aviation authorities and the results of the benefit study, the FAA may implement rulemaking to mandate the recommended change to Type III exits.

The Safety Board has previously informed the FAA that it does not believe it was necessary to refer this to the ARAC, or wait for the completion of any research. Despite previous correspondence from the Safety Board urging the FAA to take action, in the 5 1/2 years since this recommendation was issued, the FAA has not acted to mandate a Type III exit on newly manufactured aircraft that is easy and intuitive to open and that includes automatic hatch stowage out of the egress path. The Board continues to believe that the FAA should take the recommended action without further delay.

Pending timely action to mandate an improved Type III exit, Safety Recommendation A-00-76 remains classified OPEN—UNACCEPTABLE RESPONSE.

Letter Mail Controlled 2/6/2006 2:12:04 PM MC# 2060066 Marion C. Blakey, Administrator, FAA, 1/23/06 An 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 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.

Discussions among the authorities took place for over a year but failed to produce a harmonized position. The discussions have ceased for now pending completion of a benefit study sponsored by Transport Canada and the United Kingdom CAA The FAA has reviewed the research conducted on access to Type III exits. The FAA evaluated the possible benefit of Type III exits that are easy and intuitive to open and have automatic hatch stowage out of the egress path. The FAA agrees that a Type III exit with these design features would likely provide some improvement in egress performance.

The FAA will continue discussions with the European and Canadian airworthiness authorities with the goal of achieving a consensus. Based on these discussions and the results of the benefit study, the FAA will determine if additional rulemaking to mandate changes to Type III exits are warranted. The FAA will keep the Board informed of its progress on this safety recommendation

The Safety Board has previously informed the FAA that it disagrees that it is necessary to wait for completion of the ARAC research program before taking action in response to Safety Recommendation A-00-76. The Board's safety study on emergency evacuation of commercial airplanes found that the Type III hatch is frequently much heavier and more difficult to remove than passengers would expect. In addition to problems with the weight of the hatch, the Board also found that the way in which it must be opened and stowed was not clear to passengers nor easily depicted graphically.

Boeing has designed a new overwing exit for its 737 series airplanes, based on human factors principles; this new exit is hinged and opens outward, as passengers would expect. Because it moves up and out of the egress route, Boeing's design also eliminates the problem of where to stow the exit hatch.

The Safety Board continues to believe that it is not necessary to wait until the end of 2002 for the ARAC's recommendations before taking action in response to Safety Recommendation A-00-76 and that the FAA can take action now to require easy and intuitive overwing exits with automatic hatch stowage, or a similar design, on all newly manufactured aircraft with Type III exits. Pending such action, Safety Recommendation A-00-76 remains classified OPEN—UNACCEPTABLE 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 states that it intends to wait for the results of the research conducted in response to Safety Recommendation A-00-74 before determining what actions to take in response to Safety Recommendation A-00-76. The Safety Board disagrees with the FAA's plan. In the letter that transmitted this recommendation to the FAA, the Board noted that the Type III hatch is frequently much heavier and more difficult to remove than passengers expect. In addition to problems with the weight of the hatch, the recommendation letter stated the following:

The manner in which the exit is opened and the hatch is stowed is not intuitively obvious to passengers nor is it easily depicted graphically. Boeing has designed a new overwing exit for its 737 series airplanes based on human factors principles. The exit is hinged and opens outward as passengers would intuitively expect. This design also eliminates the problem of where to stow the exit hatch because it moves up and out of the egress route. In short, the design eliminates any guesswork about how the exit operates or what to do with the exit hatch once it is opened.

The Safety Board believes it unnecessary to wait for completion of the research described in response to Safety Recommendations A-00-74 and -75 before addressing the difficulties that passengers have in removing and storing Type III hatches. Further, as shown by Boeing, a superior design is already commercially available. The Board urges the FAA to take action to require such exits or a similar design on all newly manufactured aircraft with Type III exits. Pending completion of such action, Safety Recommendation A-00-76 is classified OPEN—UNACCEPTABLE 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.

Pending implementation of the requirement for Type III overwing exits on newly manufactured aircraft to be easy and intuitive to open and to have automatic hatch stowage out of the egress path, Safety Recommendation A-00-76 is classified OPEN—ACCEPTABLE RESPONSE.

Letter Mail Controlled 06/08/2001 7:19:13 PM MC# 2010481 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 has tasked the ARAC with harmonizing the requirements of FAR/JAR 25.813(c), which address access to Type III exits. The ARAC will consider automatic hatch stowage as part of the egress path designs under its current task for 14 CFR 25.813. The ARAC is scheduled to submit its report with recommendations to the FAA in December 2000. I will inform the Board of the FAA's course of action on this safety recommendation by March 31, 2001.