Safety Recommendation A-22-002

-From Jack J. Pelton, CEO and Chairman of the Board: For more than 70 years, the Experimental Aircraft Association (EAA) has contributed significantly to the continual improvement of the general aviation safety record. When the NTSB approached us in 2011 with the intent to study the root causes of experimental amateur-built aircraft fatal accidents, we agreed to support the effort. We assisted the NTSB by completing survey work that resulted in the 2012 Safety Study: The Safety of Experimental Amateur-Built Aircraft. In the past 13 years, EAA has been actively working to address the recommendations designated to us in this study and additional recommendations directed to us in 2021.

We have made significant progress and are continually working to improve the experimental safety record, as demonstrated by the reduction in experimental aircraft fatal accidents. To wit, in FAA Fiscal Year 2012 there were 73 fatal accidents in experimental aircraft. In Fiscal Year 2024, there were 37 accidents. This is despite the hours flown in experimental aircraft increasing by more than 350,000 from Calendar Years 2012 to 2023. We are not resting on our laurels by any means. There is ongoing involvement with the General Aviation Joint Safety Committee (GAJSC) to find non-regulatory solutions to improving safety records in general aviation.

EAA has created, promoted, and helped to implement the usage of multiple safety improvement tools in the past five years, including the EAA Flight Test Manual 2.0, which creates a framework for flight testing a homebuilt aircraft and is now part of a formal task-based flight testing program incorporated, optionally, into homebuilt operating limitations.

Additionally, EAA has published a guide for non-builder owners of experimental aircraft, to assist prospective buyers and owners of experimental amateur-built aircraft. This non-builder, or “second owner” demographic, was identified as a significant opportunity for improvement in the 2012 NTSB safety study. There is ongoing involvement with the GAJSC to find non-regulatory solutions to improving general aviation safety records.

In this communication, we respond to the safety recommendations and provide updates on the progress to address the recommendations since they were issued:

EAA has responded to this recommendation by leveraging a range of educational content to raise awareness about the risks of carbon monoxide (CO) exposure in flight, and the critical importance of detection and prevention. A central piece in this effort is the article “Education, Not Regulation,” which directly addresses the NTSB recommendation and underscores EAA’s belief that pilot education, when paired with appropriate equipment, is the most effective means of reducing CO-related incidents.

The article outlines how CO can enter the cockpit, the symptoms of exposure, the importance of inspection of the exhaust, and the lifesaving benefits of using detectors equipped with active visual or aural alerts. Building on this foundation, the article “Building Your Airplane” encourages aircraft builders and owners to invest in higher-quality CO detectors during the construction or retrofit process, highlighting that even modest upgrades in detection equipment can be lifesaving.

EAA has also published “Coming Face to Face with a Corner Case,” a first-person account that brings attention to the very real danger of CO poisoning in general aviation. The article recounts a specific incident in which a pilot experienced in-flight symptoms of CO exposure, and walks readers through the disorientation, confusion, and eventual resolution of the event. Most importantly, it provides valuable lessons learned, reinforcing the necessity of having a working CO detector onboard.

These articles form an educational message to directly address the NTSB recommendation, and help teach pilots how to recognize, prevent, and respond to CO threats before they become emergencies. Following this recommendation, all aircraft in EAA’s operating fleet are now equipped with active electronic CO detectors. We believe that the above actions meet the requirements of this safety recommendation.

Conclusion

During the past 15 years, EAA has worked closely with the FAA and industry on many safety initiatives not only for the amateur-built community, but for all of general aviation. EAA is highly involved in the General Aviation Joint Safety Committee (GAJSC) as an industry co-chair and as a subject matter expert in various working groups. On this committee we have met and exceeded our goals for improving the safety of the general aviation community.

EAA continues to commit to improving the safety of recreational aviation activities in all of its forms, particularly experimental amateur-built aircraft. We appreciate our unique ability to work collaboratively with the National Transportation Safety Board members, as well as your staff. This relationship has allowed us to make meaningful improvements in safety. EAA will continue to foster improvements to safety in the experimental flying community.

We thank you for your interest in the safety and vitality of the amateur-built sector of aviation. We stand ready to continue to work with you, your fellow board members, and your dedicated staff now and in the future.

The National Transportation Safety Board (NTSB) is an independent federal agency charged by Congress with investigating every civil aviation accident in the United States and significant accidents in other modes of transportation—railroad, highway, marine, and pipeline. We determine the probable cause of the accidents and issue safety recommendations aimed at preventing future accidents. In addition, we carry out special studies concerning transportation safety and coordinate the resources of the federal government and other organizations to provide assistance to victims and their family members affected by major transportation disasters.

The attached letter from the NTSB Chair provides information about the NTSB’s December 20, 2021, report Require Carbon Monoxide Detectors in Certain General Aviation Aircraft, NTSB/AIR-22/01. The details of this accident investigation and the resulting safety recommendation may be found in the attached report, which can also be accessed at http://www.ntsb.gov. For more information about NTSB and our recommendation process, please see the attached one-page summary.

The NTSB is vitally interested in these recommendations because they are designed to prevent accidents and save lives. We would appreciate a response within 90 days of the date of this letter, detailing the actions you have taken or intend to take to implement these recommendations. When replying, please refer to the safety recommendation by number (for example, A-22-2). We encourage you to submit your response to ExecutiveSecretariat@ntsb.gov. If your reply exceeds 20 megabytes, including attachments, please e mail us at the same address for instructions on how to send larger documents. Please do not submit both an electronic copy and a hard copy of the same response.

All communications regarding safety recommendations will be stored by the NTSB and viewable by the public. Please do not send privileged or confidential communications in response to this recommendation. Responses marked as confidential or privileged (or similar designations) will be considered nonresponsive. If you have concerns about this protocol, please contact us at ExecutiveSecretariat@ntsb.gov.

The National Transportation Safety Board (NTSB) is an independent federal agency charged by Congress with investigating every civil aviation accident in the United States and significant accidents in other modes of transportation—railroad, highway, marine, and pipeline. We determine the probable cause of the accidents and issue safety recommendations aimed at preventing future accidents. In addition, we carry out special studies concerning transportation safety and coordinate the resources of the federal government and other organizations to assist victims and their family members affected by major transportation disasters.

The National Transportation Safety Board (NTSB) is an independent federal agency charged by Congress with investigating every civil aviation accident in the United States and significant accidents in other modes of transportation—railroad, highway, marine, and pipeline. We determine the probable cause of the accidents and issue safety recommendations aimed at preventing future accidents. In addition, we carry out special studies concerning transportation safety and coordinate the resources of the federal government and other organizations to provide assistance to victims and their family members affected by major transportation disasters.

The attached letter from the NTSB Chair provides information about the NTSB’s December 20, 2021, report Require Carbon Monoxide Detectors in Certain General Aviation Aircraft, NTSB/AIR-22/01. The details of this accident investigation and the resulting safety recommendation may be found in the attached report, which can also be accessed at http://www.ntsb.gov. For more information about NTSB and our recommendation process, please see the attached one-page summary.

The NTSB is vitally interested in these recommendations because they are designed to prevent accidents and save lives. We would appreciate a response within 90 days of the date of this letter, detailing the actions you have taken or intend to take to implement these recommendations. When replying, please refer to the safety recommendation by number (for example, A-22-2). We encourage you to submit your response to ExecutiveSecretariat@ntsb.gov. If your reply exceeds 20 megabytes, including attachments, please e mail us at the same address for instructions on how to send larger documents. Please do not submit both an electronic copy and a hard copy of the same response.

All communications regarding safety recommendations will be stored by the NTSB and viewable by the public. Please do not send privileged or confidential communications in response to this recommendation. Responses marked as confidential or privileged (or similar designations) will be considered nonresponsive. If you have concerns about this protocol, please contact us at ExecutiveSecretariat@ntsb.gov.

The National Transportation Safety Board (NTSB) is an independent federal agency charged by Congress with investigating every civil aviation accident in the United States and significant accidents in other modes of transportation—railroad, highway, marine, and pipeline. We determine the probable cause of the accidents and issue safety recommendations aimed at preventing future accidents. In addition, we carry out special studies concerning transportation safety and coordinate the resources of the federal government and other organizations to assist victims and their family members affected by major transportation disasters.