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  3. NTSB A-14-048
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NTSB · Safety Recommendation

Safety Recommendation A-14-048

Recommendation

TO THE FEDERAL AVIATION ADMINISTRATION: Once the minimum staffing level has been developed by the Aircraft Rescue and Firefighting (ARFF) Working Group, as requested in Safety Recommendation A-14-60, amend 14 Code of Federal Regulations 139.319(j) to require a minimum ARFF staffing level that would allow exterior firefighting and rapid entry into an airplane to perform interior firefighting and rescue of passengers and crewmembers.

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

You previously told us that you did not intend to establish minimum ARFF staffing levels because you believe existing regulations are sufficient. We asked you to explain how you made that determination, and you reported that ARFF services for airports can vary widely based on the airport size, type of aircraft, emergency activities, equipment, apparatus, and operating procedures. You also reported that, based on these factors and mutual-aid agreements, each airport develops its own staffing levels.

We note that you do not believe data are available to successfully pursue rulemaking to require minimum ARFF staffing levels and, therefore, you believe that the current regulations, policies, and oversight are sufficient, and the need to change current staffing regulations is not supported.

We are disappointed that you are basing your decision to not establish minimum ARFF staffing levels on research that was conducted in response to Safety Recommendation A-01-65, which we were aware of when we issued Safety Recommendation A-14-48. We also point out that, in response to Safety Recommendation A-14-60, the ARFF Working Group created a task group that conducted an applied research project to examine theories, knowledge, methods and techniques concerning the creation of a minimum staffing level.

The project consisted of a comprehensive literature review of all relevant documents and publications, as well as a research exercise that was conducted at Atlantic City International Airport. In addition, the task group, which you co-chaired, recommended establishing minimum ARFF staffing levels and performing a hazard risk analysis to determine any additional staffing needs based on each airport’s unique operations.

We continue to believe that minimum ARFF staffing levels should be established to ensure that ARFF crews arriving at the scene of an airplane have sufficient staff to begin rescue efforts for passengers and crew inside who may be unable to escape. However, because you have made it clear that you do not intend to revise section139.319 to address this concern, Safety Recommendation A-14-48 is classified CLOSED-- UNACCEPTABLE ACTION.

August 30, 2023 · Recipient Response · FAA

-From Kathryn B. Thomson, Deputy Administrator: In its June 30, 2022, letter, the Board asked the FAA how it determined that current regulations are sufficient and why the FAA will not require minimum ARFF staffing levels. In response, ARFF services for airports can vary widely based on the airport size, type of aircraft, emergency activities, equipment, apparatus, and operating procedures. Each airport develops the staffing level it feels will meet the standards for safety based on these factors and, with mutual-aid agreements, can have sufficient personnel to handle an aircraft incident or accident. We also continue to agree with what we stated in our October 7, 2014, letter to the Board:

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Recommendation Facts

Status
Closed - Unacceptable 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

In addition, independent organizations, such as the Airport Cooperative Research Program, have previously evaluated the issue of minimum ARFF staffing. Researchers failed to reach consensus on staffing. The research found no conclusive evidence suggesting that enhanced ARFF staffing standards would make a difference in the survivability of the crashes studied. We do not believe that there is data available to support establishing ARFF staffing requirements.

Without conclusive data, the FAA cannot successfully pursue rulemaking to require minimum ARFF staffing levels. Therefore, we believe that the current regulations, policies, and oversight are sufficient, and the need to change current staffing regulations is not supported.

June 30, 2022 · NTSB Correspondence · FAA

We are aware that the ARFF Working Group created a task group committee to study staffing levels for ARFF response personnel. We are also aware that the committee’s 2018 report recommended minimum ARFF staffing levels for exterior and initial interior firefighting. However, we are disappointed to learn that you do not intend to revise the regulations, as recommended.

We remain concerned that 14 CFR 139.319(j) does not require minimum ARFF staffing levels. We would like to know how you determined that existing regulations are sufficient when the task group committee, which you co-chaired, recommended minimum ARFF staffing levels. Pending our review of this information and completion of the action recommended, Safety Recommendation A-14-48 remains classified OPEN-- UNACCEPTABLE RESPONSE.

January 31, 2022 · Recipient Response · FAA

-From Steve Dickson, Administrator: The ARFF Working Group conducted a collaborative applied research endeavor with the Federal Aviation Administration (FAA) in response to Safety Recommendations A-14-47 through -49 and A-14-58, -60, and -61.

For A-14-47, the information contained in Advisory Circular (AC) 150/5210-23, ARFF Vehicle and High Reach Extendable Turret (HRET) Operation, Training and Qualifications, was complemented by the most recent edition of the FAA ARFF DVD training program. In conjunction with the ARFF Working Group, we are developing a new addendum for AC 150/5210-23 that includes an example of the hand and arm signals developed for use during HRET operations. This addendum is currently in internal coordination and is anticipated to be published by June 30, 2022.

For A-14-48, each airport develops the staffing level it feels meets the standards for safety. We believe SFO is an excellent example of how the airport fire department working through mutual aid agreements can, in fact, have sufficient personnel to handle an aircraft incident of significant magnitude. Therefore, we believe that the current regulations, policies, and oversight are sufficient, and the need to change current staffing regulations (§ 139.319) is unnecessary.

For A-14-49, the ARFF Working Group developed a training guide that provides professional level development for use by the ARFF departments. This guide can also be used by the surrounding structural fire departments when responding to mutual aid calls by the airports that they support. The FAA will continue to work with the ARFF Working Group when we next update AC 150/5210-17C, Programs for Training of Aircraft Rescue and Firefighting Personnel.

The Board assigned correlating safety recommendations to the ARFF Working Group, listed below.

Safety Recommendations assigned to FAA: A-14-47 Safety Recommendations Assigned to ARFF: A-14-58 Safety Recommendations assigned to FAA: A-14-48 Safety Recommendations Assigned to ARFF: A-14-60 Safety Recommendations assigned to FAA: A-14-49 Safety Recommendations Assigned to ARFF: A-14-61

Each group of correlating safety recommendations were completed as separate and distinct research projects, supported by a specialized committee, at the ARFF Working Group Annual Conference on September 17, 2018. Committee membership was supervised by joint chairs from the ARFF Working Group and FAA and was comprised of subject matter experts who contributed valuable knowledge and experience to satisfy each of the safety recommendations.

The Board’s letter dated October 22, 2018, addressed to the ARFF Working Group, changed the classifications for Safety Recommendations A-14-58, -60, and -61 to Closed-Acceptable Action.

The FAA believes that its work with the ARFF Working Group has been highly successful. We continue to work with the working group and address issues as they arise.

I believe that the FAA has effectively addressed Safety Recommendations A-14-48 and -49, and consider our actions complete. I will keep the Board informed of our progress with Safety Recommendation A-14-47 and anticipate providing an update by September 30, 2022.

December 12, 2014 · NTSB Correspondence · FAA

Although you regard your actions in response to this recommendation to be complete and you plan no further action, we point out that the recommended action is contingent on the ARFF Working Group’s first completing its response to Safety Recommendation A-14-60. The ARFF Working Group has informed us that they are beginning that work. We believe that it is premature to close this recommendation until after Safety Recommendation A-14-60 is closed. Accordingly, pending your taking the action recommended after the ARFF Working Group completes its action in response to Safety Recommendation A-14-60, Safety Recommendation A-14-48 is classified OPEN—UNACCEPTABLE RESPONSE.

October 9, 2014 · Recipient Response · FAA

-From Michael P. Huerta, Administrator: All major airports, such as San Francisco International (SFO), use the minimum staffing requirements of part 139. Each airport develops the staffing level that effectively meets its safety standards. We believe SFO is an excellent example of how the airport's fire department, working through mutual-aid agreements, has sufficient personnel to handle an aircraft incident of significant magnitude. Therefore, we believe that the current regulations, policies, and oversight are sufficient.

In addition, independent organizations, such as the Airport Cooperative Research Program (ACRP) have previously evaluated the issue of minimum ARFF staffing. Researchers failed to reach consensus on staffing. The research found no conclusive evidence suggesting that enhanced ARFF staffing standards would make a difference in the survivability of the crashes studied. We do not believe that there is data available to support establishing ARFF staffing requirements. You can find a copy of the ACRP report, “How Proposed ARFF Standards Would Impact Airports,” at the following link: http://onlinepubs.trb.org/onlinepubs/acrp/acrp_webdoc_007.pdf