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NTSB · Safety Recommendation

Safety Recommendation A-14-038

Recommendation

TO THE FEDERAL AVIATION ADMINISTRATION: Once the enhanced Boeing 777 training has been developed, as requested in Safety Recommendation A-14-37, require operators and training providers to provide this training to 777 pilots.

Safety Issue and Context

This report discusses the July 6, 2013, accident involving a Boeing 777-200ER, Korean registration HL7742, operating as Asiana Airlines flight 214, which was on approach to runway 28L when it struck a seawall at San Francisco International Airport (SFO), San Francisco, California. Three of the 291 passengers were fatally injured; 40 passengers, 8 of the 12 flight attendants, and 1 of the 4 flight crewmembers received serious injuries. The other 248 passengers, 4 flight attendants, and 3 flight crewmembers received minor injuries or were not injured. The airplane was destroyed.

Safety issues relate to the need for Asiana pilots to adhere to standard operating procedures regarding callouts; reduced design complexity and enhanced training on the airplane’s autoflight system; opportunity at Asiana for new instructors to supervise trainee pilots in operational service during instructor training; guidance for Asiana pilots on use of flight directors during a visual approach; more manual flight for Asiana pilots; a context-dependent low energy alert; research that examines the injury potential from significant lateral forces in airplane crashes and the mechanism that produces high thoracic spinal injuries; evaluation of the adequacy of slide/raft inertia load certification testing; aircraft rescue and firefighting (ARFF) training for officers in command of an aircraft accident response; guidance on when to use a skin-piercing nozzle on a burning airplane fuselage; integration of the medical supply buses at SFO into the airport’s preparation drills; guidance or protocols for ensuring the safety of passengers and crew at risk of a vehicle strike during ARFF operations; requirements for ARFF staffing; improvements in SFO emergency communications; and increased Federal Aviation Administration (FAA) oversight of SFO’s emergency procedures manual.

Safety recommendations are addressed to the FAA, Asiana Airlines, Boeing, the ARFF Working Group, and the City of San Francisco.

Response History

November 4, 2024 · NTSB Correspondence · FAA

We previously pointed out that the following actions constituted an acceptable alternate solution to the training that we wanted Boeing to develop in response to Safety Recommendations A-14-37 and –39: • Boeing’s updated 777 Airplane Information Management System (AIMS) software, which includes, in the automatic autothrottle activation, additional autothrottle mode combinations that provide expanded minimum speed protection, and • Boeing’s revisions to the 777 Flight Crew Operations Manual (FCOM) and FCTM with information that will improve flight crew understanding of the new autothrottle modes and automatic activation system logic.

However, because 777 operators were not required to incorporate Boeing’s updated 777 AIMS software, we told you that a requirement was needed and would represent an acceptable alternate solution to Safety Recommendations A-14-38 and -40.

We are aware that, on March 19, 2024, you published Final Rule Airworthiness Directive (AD) 2024-04-09, “The Boeing Company Airplanes,” which requires 777 operators to incorporate Boeing’s updated AIMS software to include, in the automatic autothrottle activation, additional autothrottle mode combinations that provide expanded minimum speed protection. Consequently, Safety Recommendations A-14-38 and -40 are classified CLOSED--ACCEPTABLE ALTERNATE ACTION.

October 5, 2023 · Recipient Response · FAA

-From Kathryn B. Thomson, Deputy Administrator: The Federal Aviation Administration (FAA) published Advisory Circular (AC) 120-123, Flightpath Management (FPM), on November 21, 2022. This AC provides guidance and recommended practices for operators to implement operational procedures and training for the planning, execution, and assurance of the guidance and control of aircraft trajectory and energy under 14 CFR Parts 121 and 135

Read Recommendation

Recommendation Facts

Status
Closed - Acceptable Alternate Action
Issued
July 16, 2014
Priority
CLASS II
Recipient
FAA
Adopted
July 11, 2014
Closed
November 4, 2024
Related Investigation
DCA13MA120
Related Report
AAR-14-01
certificate holders, as well as
14 CFR Part 142
training centers, in developing operational policies, procedures, and training to support effective FPM. The AC is available at drs.faa.gov.

In addition, the FAA is considering whether it will require Boeing 777 operators to download the update to Boeing’s Airplane Information Management System software to include, in the automatic autothrottle activation, additional autothrottle mode combinations that provide expanded minimum speed protection.

I will keep the Board informed of the FAA’s progress on Safety Recommendations A-14-38 and -40 and anticipate providing an update by September 30, 2024.

June 14, 2023 · NTSB Correspondence · FAA

We note that Boeing has updated its 777 Airplane Information Management System (AIMS) software to include, in the automatic autothrottle activation, additional autothrottle mode combinations that provide expanded minimum speed protection. We also note that Boeing has revised its 777 Flight Crew Operations Manual (FCOM) to account for this change and included additional information about how the automatic autothrottle activation works. In addition, we note that Boeing’s 777 FCTM includes an expanded stall protection demonstration for when minimum speed protection is not provided.

We believe that, if it had been available on the accident aircraft, the expanded minimum speed protection that is included in Boeing’s new AIMS software would have activated during the final approach and may have prevented the accident. We also believe Boeing’s revisions to the 777 FCOM and FCTM contain information that will improve flight crew understanding of the new autothrottle modes and automatic activation system logic. These actions constitute an acceptable alternate solution to the training that we wanted Boeing to develop. Consequently, Safety Recommendations A 14-37 and -39 are classified Closed—Acceptable Alternate Action.

Because 777 operators are not required to incorporate Boeing’s updated 777 AIMS software, we believe a requirement is needed and would represent an acceptable alternate solution to Safety Recommendations A-14-38 and -40. Pending a plan for ensuring that Boeing’s new AIMS software has been incorporated into all 777 aircraft, Safety Recommendations A-14-38 and -40 are classified OPEN-- ACCEPTABLE ALTERNATE RESPONSE.

September 21, 2022 · Recipient Response · FAA

From Billy Nolen, Acting Administrator, Federal Aviation Administration: This is in further response to Safety Recommendations A-14-37 through -41, issued by the Board on July 16, 2014, and supplements our previous letters.

The Board requested in its August 4, 2021, letter that the Federal Aviation Administration (FAA) submit the relevant sections, which address these safety recommendations, of the revised 777 Flight Crew Operations Manual (FCOM) and 777 Flight Crew Training Manual (FCTM) for its review. These sections are listed below:

777-200/-230ER/-200LR/-200F/-300/-300ER FCOM (Rev 70, 12/15/2021): o Autothrottle System Controls, Page 4.10.4 o Automatic Activation, Page 4.20.10 o PFD Flight Mode Annunciations (FMAs), Page 4.10.20 o Automatic Activation, Pages 4.20.10-12 o Autothrottle Disconnect, Page 4.20.13

777 FCOM, 777-200/-300 Quick Reference Handbook (Rev 70, 12/15/2021): o Checklist Instructions, Page CI.2.4 o Autothrottle Disc, Page 4.1 o ENG EEC MODE L, R, Page 7.21 o SGL SOURCE RAD ALT, Page 10.11

777 FCTM (Rev 20, 06/30/2022): o Autothrottle Use, Page 1.39 o Initiating Takeoff Roll, Page 3.4 o Stall Protection Demonstration, Pages 7.13-14

In addition, the FAA published the draft Flight Path Management Advisory Circular (FPM AC) on February 3, 2022 (87 FR 6228). The FPM AC comment period concluded on March 7, 2022, and comments are currently being adjudicated. Once the review of comments has concluded, the FAA will begin the formal process for finalization and publication of the AC.

Once the FPM AC is published, in combination with Boeing’s updates to the 777 autothrottle software and supporting documents, the FAA will consider its actions complete. I will keep the Board informed of the FAA’s progress on Safety Recommendations A-14-37 through -41 and anticipate providing an update by September 30, 2023.

August 4, 2021 · NTSB Correspondence · FAA

You reported that Boeing has included additional modes in the 777’s automatic activation system logic, and that these changes are described in the flight crew operations manual (FCOM). We would appreciate receiving copies of the relevant sections of the revised FCOM so that we can determine whether they are responsive to these recommendations. We point out, however, that changes to the FCOM alone will not satisfy the intent of these recommendations, which is to improve flight crews’ understanding of autothrottle modes and automatic activation system logic through enhanced training.

Pending our review of the revised FCOM and a plan for requiring the recommended training, Safety Recommendations A-14-37 and -38 remain classified OPEN-- UNACCEPTABLE RESPONSE.

October 8, 2020 · Recipient Response · FAA

-From Steve Dickson, Administrator: The Federal Aviation Adminstration (FAA) has made substantial progress to improve air carrier training in flight path management (FPM) since our last update to the Board on these recommendations. As discussed below and during a teleconference between staff from the National Transporation Safety Board (NTSB) and the FAA on April 7, 2020, we believe our ongoing work to improve air carrier training in FPM, in combination with Boeing’s updates to the Boeing 777 autothrottle software and supporting documents, address these recommendations.

The FAA has identified FPM as a critical function that pilots perform. It is a top priority when it comes to flying the airplane and is viewed by the FAA as the key to prevention of loss of control inflight. The final report of the Flight Deck Automation Working Group (FltDAWG Report) included a number of findings and recommendations concerning FPM, based on a September 5, 2013, final report from the Performance-based Operations Aviation Rulemaking Committee/Commercial Safety Action Team FltDAWG (this document can be found here: https://www.faa.gov/aircraft/air_cert/design_approvals/human_factors/media/OUFPMS_Report.pdf).

The FAA is implementing many of the recommendations from the FltDAWG Report through the Air Carrier Training Aviation Rulemaking Committee (ACT ARC).

The ACT ARC is comprised of experts in human factors, training, and flight operations and serves as a key resource in the FAA’s ability to identify and address new challenges in the area of air carrier training and emerging technology. The ACT ARC, which defines “FPM” as the planning, execution, and assurance of the guidance and control of aircraft trajectory and energy, in flight or on the ground, established an FPM Workgroup, which has produced an extensive body of work to improve air carrier training in FPM, much of which targets contributing factors identified by the NTSB in the Asiana accident report.

For example, the NTSB cited (1) the flight crew’s lack of adherence to standard operating procedures (SOPs) involving selections and callouts pertaining to the autoflight system’s mode control panel and (2) the pilot flying’s faulty mental model of the airplane’s automation logic leading to his inadvertent deactivation of automatic airspeed control. The ACT ARC has developed recommendations to improve air carrier training in the areas of mode awareness, managing automated systems, pilot monitoring and its incorporation into SOPs, energy management and information management.

The FAA has published guidance based on the work of the ACT ARC and intends to publish a new advisory circular (AC) on FPM. This letter includes enclosures that describe the FPM workgroup’s scope of work, recommendations, and resulting FAA guidance (completed and planned) for air carriers.

Since the Asiana accident, Boeing made changes to the Boeing 777 Airplane Information Management System V17B software so that automatic autothrottle activation includes more autothrottle modes. The Boeing 777 Flight Crew Operations Manual (FCOM) describes these system changes as well as the autothrottle mode transition logic as requested by the Board in Safety Recommendation A-14-56, which requested that Boeing revise the 777 FCOM to include a specific statement that when the autopilot is off and both flight director switches are turned off, the autothrottle mode goes to speed (SPD) mode and maintains the mode control panel-selected speed.

In addition, the current Boeing 777 Flight Crew Training Manual (FCTM) includes content on Approach to Stall or Stall Recovery, which highlights that even though the autopilot and autothrottle are operating correctly, the airplane could fly into a condition where an approach to stall is momentarily experienced. The approach to stall or stall recovery maneuver calls for the crew to disengage the autopilot and autothrottle if the response is not acceptable, and the FCTM provides examples of unacceptable performance.

While the FCTM is not an FAA approved document, the FAA has enhanced air carrier pilot training programs by implementing new regulations, such as the Qualification, Service, and Use of Crewmembers and Aircraft Dispatchers Final Rule (79 FR 12937), that emphasize the development of pilots’ manual handling skills and add safety-critical tasks, such as stall prevention and recovery for every aircraft. This training teaches each pilot how the specific aircraft responds in these flight conditions. We believe training pilots to have the confidence to always de-automate the aircraft and recover meets the intent of these recommendations.

In summary, since our last correspondence, we have worked in partnership with the industry to improve air carrier training in FPM. While increasing aircraft automation and information automation has benefits, it also introduces vulnerabilities, as every aircraft and automation system has differing potential vulnerabilities. In addition, each air carrier has its own set of SOPs, which complicates the ability to arrive at one solution for every aircraft type. We believe it is the best use of FAA and industry resources to adopt a holistic approach to training FPM rather than to mandate training program amendments to address specific system vulnerabilities.

Each operator should have an operational FPM philosophy supported by SOPs. The policy should highlight and stress that the responsibility for FPM remains with the pilots at all times; focusing on FPM rather than simply focusing on the manipulation of automated systems.

Moreover, air carrier training, leveraging Aviation Safety Action Program and Flight Operations Quality Assurance data, should incorporate common errors and known vulnerabilities (“gotchas”) for each fleet type so that pilots are trained to expect certain scenarios and manage the workload accordingly. The FAA’s work with the ACT ARC reflects this holistic approach to training FPM, and we believe that once the FPM AC is published, in combination with Boeing’s updates to the Boeing 777 autothrottle software and supporting documents, the intent of Safety Recommendations A-14-37 through -41 will be fully addressed.

I will keep the Board informed of the FAA’s progress on these recommendations and anticipate providing an update by July 31, 2021.

December 12, 2014 · NTSB Correspondence · FAA

We do not agree with you that it is less effective to redesign or reengineer the procedures for one aircraft type, such as the Boeing 777, when every aircraft has potential vulnerabilities associated with its design and operation. We agree that every aircraft has potential vulnerabilities, that you need to address these problems, and that the scope of your action in this area may be expanded to include other aircraft types, as you deem appropriate. We issued Safety Recommendation A-14-41, discussed below, based on these concerns with all aircraft.

However, our investigation of the Asiana Airlines flight 214 accident revealed problems with the Boeing 777 that Safety Recommendations A-14-37 through -40 address.

Your letter did not discuss any actions you have either taken or planned that would require Boeing to revise the training or FCTM for the Boeing 777. Rather, you plan for Boeing 777 operators to review the facts of the Asiana Airlines flight 214 accident and determine whether their data show that they may have the same risks we identified; if they identify any such risks, you expect the operators to develop mitigations. Our investigation found deficiencies in Boeing documentation and training that apply to all operators. These deficiencies involved unclear and potentially misleading explanations of autoflight system functionality.

We do not agree that improving these materials should wait until an analysis of operational data has been completed, nor do we agree that having individual operators review their own data looking for problems will help all Boeing 777 operators, as would be achieved if Boeing were to revise the materials it provides to its customers. Accordingly, pending the FAA’s taking the actions recommended, Safety Recommendations A-14-37 and -39 are classified “Open—Unacceptable Response.”

In consideration of these issues, we have concluded that your plan for operators to review their data to determine whether they have the same risks that we found in the Asiana Airlines flight 214 accident, and to revise their training, if necessary, does not constitute an acceptable alternate response to Safety Recommendations A-14-38 or -40. We are concerned that training improvements will be unnecessarily delayed and that the “lessons learned” will be limited to a single airline’s analysis, that neither the FAA nor other Boeing 777 operators will be aware of the problems found, and that no resultant training revisions will be made.

Accordingly, pending your taking the recommended actions, Safety Recommendations A-14-38 and -40 are classified OPEN—UNACCEPTABLE RESPONSE.

We invite you to share with us any information that you may have illustrating how lessons learned by one operator was shared with all Boeing 777 operators and was incorporated into all operators’ training materials. If you can supply us with one or more examples of such an occurrence, we may reconsider whether your proposal constitutes an acceptable alternate method of addressing the recommendations.

October 9, 2014 · Recipient Response · FAA

-From Michael P. Huerta, Administrator: The Federal Aviation Administration (FAA) believes it would be less effective to simply redesign or reengineer the procedures for one aircraft type, such as the Boeing 777, when every aircraft has potential vulnerabilities associated with its design and operation. Where necessary, we will encourage carriers to amend their procedures and/or their training to mitigate the potential vulnerabilities to their operation of that aircraft.

The FAA tasked a working group under the Performance-Based Aviation Rulemaking Committee and the Commercial Aviation Safety Team on Operational Use of Flight Path Management Systems to determine the human factors associated with the use of those systems.

The working group produced a number of recommendations, which the FAA is reviewing. The FAA has also established the Air Carrier Training Aviation Rulemaking Committee (ACT ARC), which is developing additional guidance for air carriers based, in part, on the group's recommendations. The ACT ARC is currently developing additional recommendations for guidance on issues such as mode awareness and training for pilot monitoring.

The FAA will ask Boeing 777 operators to review the facts of this accident and determine whether their data shows they may have the same risks identified by the Board. If risks are identified, the operators will be expected to develop mitigations, in accordance with their safety management systems, to address those risks.