Presentation is loading. Please wait.

Presentation is loading. Please wait.

EXECUTIVE INTERIOR RULEMAKING GROUP Future Certification Requirements for Executive Interiors Presentation of Stakeholder-led Rulemaking Works Draft NPA.

Similar presentations


Presentation on theme: "EXECUTIVE INTERIOR RULEMAKING GROUP Future Certification Requirements for Executive Interiors Presentation of Stakeholder-led Rulemaking Works Draft NPA."— Presentation transcript:

1 EXECUTIVE INTERIOR RULEMAKING GROUP Future Certification Requirements for Executive Interiors Presentation of Stakeholder-led Rulemaking Works Draft NPA from RMT.0264 (MDM.066)

2 The issue with “Executive Interiors”…  CS-25 / FAR 25 are not adequate for Business Jets / Corporate Jets / VIP interiors Rulemaking Initiative Rules written for traditional cabin arrangements… 2 … are not adapted to design non-traditional interiors JMB

3  CS-25 / FAR 25 are not adequate for Business Jets / Corporate Jets / VIP interiors The certification of “Executive” or “VIP” interiors requires compliance demonstration against the applicable airworthiness code:  In EASA: JAR / CS-25  In FAA:FAR 25 This code being partially inadequate, applicants to TC or STC shall comply with additional technical requirements (Special Conditions), or show that the proposed interiors provide an equivalent level of safety for the passengers. These discussions are recorded during the certification process in documents that are generally only exchanged between the applicants and the Authorities:  In EASA: Certification Review Items (CRI)  In FAA:Issue Papers (IP) Typical Cabin Safety subjects:  Interior doors  Isolated compartments  Emergency exit access  Emergency exit deactivation…  A large administrative effort for both Applicants and Authorities is necessary for each cabin interior to document all the recurrent certification issues with CS-25 / FAR 25 Rulemaking Initiative The issue with “Executive Interiors”… 3 JMB

4  FAA / EASA Approach FAA approach  Strong request by US Industries for common / adapted airworthiness code  FAA has issued in 2009 SFAR 109 “Special Requirements for Private Use Transport Category Airplanes”  …but few applications were made against this SFAR because : o Limited to Private Use only A/C o Limited to 60 PAX max EASA approach  Strong request by EU Industries for common / adapted airworthiness code  Lack of EASA resources to include such work in Rulemaking Program  … but EASA has accepted to let EU Industries bear the rulemaking effort on an “exceptional” and “experimental” basis  Launch of Stakeholder-led Rulemaking Group on “Executive Interiors”  Launch of Stakeholder-led Rulemaking Group on “Executive Interiors” Rulemaking Initiative The issue with “Executive Interiors”… 4 JMB

5 Objective set by EASA:  The overall objectives are the reduction of recurrent CRIs and the mitigation of the diverging interpretation of safety requirements on interior designs for aeroplanes with executive interiors. This is to reduce administrative costs and to ensure a common understanding of measures with an acceptable level of safety similar to current CS-25 requirements when applied to commercial airliners and to avoid time-consuming activities on repetitive certification issues.  More specifically, the NPA shall establish Executive Interior design specifications that will amend and/or complement CS-25 by introducing new provisions and associated AMC/GM for executive interiors, taking into account the compensating factors offered by such interiors and their utilisation.  Terms of Reference (ToR) Rulemaking Initiative Preparation of the Future Requirements 5 JMB

6  Stakeholder-led Rulemaking group 9 Industry Members6 Authority Members In addition, + ~60 “second row” members amongst ~15 companies have requested to access the works of the “first row Working Group”  Airbus, Boeing Business Jets, Bombardier, Dassault Aviation, Embraer, Gulfstream Aerospace Corporation  B/E Aerospace, Cessna Aircraft Company, Continental DataGraphics, Duncan Aviation, Hawker Beechcraft Corporation, International Communications Group (ICG), Piaggio Aero lndustries S.pA, PATS Aircsaft Systems, Rockwell Catins, Inc., RUAG Rulemaking Initiative Preparation of the Future Requirements 6 JMB

7  Rulemaking Process Draft from Working Group March 2014 Start Sept 2011 We are here Rulemaking Initiative Preparation of the Future Requirements 7 3 months EASA Estimation Q months EASA Estimation Q months 3 months JMB

8  Summary: Non-Commercial and “Low Occupancy” aeroplanes for commercial operations The drafted rule therefore proposes to distinguish the products as follows: Eligibility to CS-25 Appendix X ? YESNO Is A/C limited to Non-Commercial and ≤ 150 PAX per deck Operations ? Is A/C Low Occupancy ? (maximum 19PAX or ≤1/3 rd of max TC - Total & per zone and ≤ 100 PAX per deck) YES NO Low Occupancy Requirements / Alleviations of CS-25 Appendix X Non-commercially operated Requirements / Alleviations of CS-25 Appendix X General CS-25 Requirements Group 2a corresponds to existing “natural 19” A/C (limitation as per TCDS) 2a (≤19) Group 2b addresses larger airplanes not limited to 19PAX for public operations 2b (>19) Group 1 « Private » Group 3 « Airline-like » Group 2 « Low Occupancy » Proposed Future Certification Requirements (Draft NPA) Approach of the Working Group 8 JMB

9 Proposed Future Certification Requirements (Draft NPA) Overview of the Proposed Amendments  Overview of the Proposed Amendments The proposition includes:  Amendments to CS-25 (based on Amdt 14) o Amended + New CS-25 requirements and AMCs o New Appendix X for “Non-commercially operated and Low occupancy aeroplanes” + AMCs +  Amendment to CS-Definitions o Necessary to add a definition for term “low occupancy” that will be used in CS-25 and CS-26 +  Amendment to CS-26 o Necessary to authorize use of CS-25.X.10(a) as an additional means of compliance to Part requirement (flammability requirements for interior materials). o Exempt low occupancy aeroplanes from CS – Emergency landing – Dynamic conditions. (“terminating action” from NPA with new definition for “VIP/Executive” aeroplanes) 9 JMB

10 Proposed Future Certification Requirements (Draft NPA) Overview of the Proposed Amendments  Overview of draft Amendment to : CS-Definitions New definition of “Low Occupancy Aeroplanes” Low Occupancy Aeroplane: A low occupancy aeroplane is an aeroplane whose interior is designed for a maximum authorized passenger occupancy of: o up to and including 19 passengers, or o up to and including one-third of the maximum approved passenger seating capacity of the type certificated aeroplane as indicated in the aeroplane Type Certificate Data Sheet, provided:  the maximum number of seats approved for occupancy during taxi, take-off or landing in any individual zone between pairs of emergency exits (or in any dead end zone) does also not exceed one-third of the maximum capacity allowable by CS (e) for that zone considering the maximum passenger seating capacity of the type certificated aeroplane as indicated in the aeroplane Type Certificate Data Sheet, and  the total number of passengers does not exceed 100 per deck. 10 FALCON 900: 12 PAX A319 CJ : 18 PAX JMB

11 Proposed Future Certification Requirements (Draft NPA) Overview of the Proposed Amendments Example with A319CJ (MAPSC = 145  1/3 limit = 48) 11 Total PAX = 29 (<1/3) - Fwd < 1/3 - Aft< 1/3 Fwd Area = 7 PAX Case 1 Aft Area = 22 PAX Total PAX = 42 (<1/3) - Fwd < 1/3 - Aft> 1/3 Case 2 Aft Area =35 PAX  Eligible to Appendix X  Not eligible to Appendix X if commercial operation  Overview of draft Amendment to : CS-Definitions JMB

12  Passenger Seats Distribution o Distance to Emergency Exit o Deactivation of existing Emergency Exits  Seats in Excess o Seats in Excess o Seats available for flight use only  Cabin Compartments o Interior Doors o Isolated Compartments o Installation of Shower o Installation of Cooktop  Circulation Inside Cabin During Flight o Width of Aisle o Firm Handhold  Cabin Configuration for Taxi, Take-off and Landing o Direct View o Access to Type III and IV Emergency Exit o Latching Mechanisms  Interior Furnishings Materials o Heat Release / Smoke Density o Large Glass Panels / Large Display Panels  Emergency Lighting o Emergency Exit Signs o Floor Proximity Escape Path Marking o Transverse Separation of the Fuselage  Placards and Markings o Symbolic Placards o Single Non Smoking Placard o Certification Benefit of the Briefing Card o Consensus reached o Consensus reached o Consensus reached o Consensus reached o Consensus reached o Consensus reached o Consensus reached o Consensus reached  If a majority of subjects reached a consensus… … Some group members expressed dissenting views on specific aspects o Dissenting views on extension to Group 2b (Public 19 < x ≤ ⅓TC) o Dissenting views on definition of minor obstruction o Dissenting views on extension of applicability to Group 2b. o New consensual ideas In addition, new ideas are proposed o New consensual ideas Proposed Future Certification Requirements (Draft NPA) Details of the Proposed Amendments 12  Certification Items reviewed JMB

13 4.1 - Details of the Proposed Amendments Subjects easily agreed 13 Future Certification Requirements for Executive Interiors Presentation of Stakeholder-led Rulemaking Works – Draft NPA from RMT.0264 (MDM.066) JMB

14  List of items agreed Current Situation:  EASA CRIs / FAA IPs  SFAR109 guidance Draft rule proposal:  Certification Items included in the drafted rule without appreciable change Subjects concerned:  Cabin Compartments o Interior Doors o Installation of Shower o Installation of Cooktop  Seats in Excess o Seats in Excess o Seats available for flight use only  Interior Furnishings Materials o Large Glass / Display Panels  Emergency Lighting o Emergency Exit Signs o Floor Proximity Escape Path Marking o Transverse Separation of the Fuselage  Placards and Markings o Single Non Smoking Placard  For all these subjects the working group rapidly identified a consensual position Note:  with FAA: transversal hinge door authorized Note: Alignment with FAA on test to rupture Note:  with TCAA: test with soapy floor surface not required Note: Extended to Group 3 (All A/C) Note: SFAR109 (Private) extended to Group 3 (All A/C) Note: SFAR109 (Private) extended to Group 2 (Low Occupancy)  Extensions from Group 1 (Private) to Group 2 (Low Occupancy) or 3 (Commercial) allows to address dual-use aeroplanes (iaw. ToR) Note: SFAR109 (Private) extended to Group 3 (All A/C) Proposed Future Certification Requirements (Draft NPA) Subjects agreed / clarified easily 14 JMB

15 In addition to standard certification requirements like: Rapid Decompression loads Abuse Loads Retention of item of mass … The doors between passenger compartments must: be frangible have dual means to retain it in the open position, have a means to signal to the flight crew be operable from either side In addition, the Aeroplane Flight Manual shall contain: instruction on the door operation, including its frangibility feature; instruction regarding the briefing of passengers to include the information from the AFM Supplement required above. 15  Interior Doors Current Situation:  EASA CRIs (Deviation) / FAA IPs / SFAR 109 Draft rule proposal:  Amended to authorize presence of interior doors on board as long as blocked open by maintenance action  New Rule for private use aeroplanes only Example: Proposed Future Certification Requirements (Draft NPA) Subjects agreed / clarified easily Blow-out Panel (decompression) Resist Abuse load Sensor Cockpit indicator Must be Unlocked From both side Without tool PC

16 16  Emergency Exit Signs Current Situation:  EASA CRIs (Deviation) Draft rule proposal:  Viewing Distance formula applies to lettered “EXIT” signs  Signs / lighted background may vary to maintain proportions of EN7010 Example: Proposed Future Certification Requirements (Draft NPA) Subjects agreed / clarified easily Reduced Sign size (all types) Viewing distance for lettered “EXIT” signs Signs harmonization with FAA Combination of signs for compliance with (d)(1) and (d)(2) PC

17 17  Single Non-Smoking Placard Current Situation:  EASA CRIs (deviation) Draft rule proposal:  Limited to Private or Low Occupancy: - One single no-smoking placard at each entrance - Suppression of ashtrays in lavatories Example: Proposed Future Certification Requirements (Draft NPA) Subjects agreed / clarified easily Suppressed lavatory ashtrays in non-smoking aeroplanes Single no-smoking indication For non-smoking aeroplanes From lighted non-smoking signs 1 To Permanent non-smoking placards 2 To single non-smoking placard visible when entering the A/C 3 TP

18 18  Transverse Separation of Fuselage Current Situation:  SFAR 109 – Special Requirements For Private Use Transport Category Airplanes Draft rule proposal:  Amended CS (l)(1) with percentage of inoperative electrically illuminated emergency lights dependent of the aeroplane’s size  Amended AMC to clarify how to calculate the percentage Example: Proposed Future Certification Requirements (Draft NPA) Subjects agreed / clarified easily (i) 25 %, or (ii) 33% for aeroplanes with a MAPSC of 10 to 19 passengers, or (iii) 50 % for aeroplanes with a MAPSC of 9 passengers or less TP

19 19  Shower Current Situation:  EASA CRIs (Special Condition / IM) + Certification Memo from Electrical Panel (from CRI EPS) Draft rule proposal:  CS (b) requiring: - visual and audible Return-To-Seat indication for shower occupant - visual and audible indication of deployment of the O 2 masks - Placard to prohibit use as stowage or baggage compartment - Firm handhold features inside the shower enclosure - Design to preclude anyone from becoming trapped inside Example: Proposed Future Certification Requirements (Draft NPA) Subjects agreed / clarified easily  AMC (b) with considerations to: - Leakage - Ventilation (Fresh Air) - Humid airflow - Proximity of Electrical Systems (Cert Memo) TP

20 20  Cooktops Current Situation:  SFAR 109 – Special Requirements For Private Use Transport Category Airplanes Draft rule proposal:  CS (b) + AMC for installation of Cooktops with design to minimize the risk of overheat, fire, smoke, burns, or spilled liquids Example: Proposed Future Certification Requirements (Draft NPA) Subjects agreed / clarified easily Specified design precautions 1.Minimize potential for inadvertent contact with hot surfaces 2.Restrain cookware while flight loads and turbulence 3.Placarding to prohibit use during TTOL 4.Means to address fire in the immediate vicinity of the cooktop  Placards for continuous attention + Fire detector + fire extinguisher  Or, automatic, thermally-activated fire suppression system 5.Galley Surrounding surfaces compliant with Appendix F Part III 6.Independent ventilation system protected by a flame arrester 7.Containment of spilled foods or fluids to prevent slipping hazard or structure corrosion 8.Adequate space for the user to immediately escape a hazardous cooktop condition 9.Means to shut off power to the cooktop at cooktop station and in the cockpit 10.Lid to completely enclose the cooking surface or fire blanket to completely cover the cooking surface TP

21  Large Glass Items / Large Display Panels Current Situation:  EASA CRIs (IM) / FAA IPs Draft rule proposal:  New AMC Large Glass Items  New AMC Large Display Panels Proposed Future Certification Requirements (Draft NPA) Subjects agreed / clarified easily 21 Ball Impact tests - 7J for Displays - 21J for Glass Items No loose glass (Criteria from ANSI/SAE) No toxic fumes (if gas enclosed, eg. Plasma Screens) No loose glass Cracks acceptable 300lb Large Glass Items / Display Panels must withstand : - Cabin Depressurization Loads - Abuse Loads - Crash Loads - Impacts Loads - Effect on Health in case of leakage Impacts BS Glass Items / Display Panels are considered large if: - diagonal ≥ 20 inches, - glass weight ≥ 4 kg - surface on one side ≥ 200 sq.in Harmonization with FAA for various shapes Abuse load tests Ball Impact tests

22  Seats in Excess Current Situation:  SFAR 109 – Special Requirements For Private Use Transport Category Airplanes  FAA AC Flammability Requirements For Aircraft Seat Cushions Draft rule proposal:  Rule with:- AFM limitation indicating the max approved seating capacity - Global Placard at Entrance and local placard for each non-TTOL seat - Clarification that non-TTOL seat cushions (incl. bed mattresses ) need not comply with App F Part II if in non TTOL zone only Example: Proposed Future Certification Requirements (Draft NPA) Subjects agreed / clarified easily 22 CASE 1: FULL OCCUPANCY Total PAX = 42 (<1/3) - Fwd < 1/3 - Aft > 1/3  Not eligible to Appendix X CASE 2: WITH SEATS IN EXCESS Total PAX = 42 (<1/3) - Fwd < 1/3 - Aft < 1/3  Eligible to Appendix X Placard « Not to be occupied in TTOL » + AFM limitation No required compliance to App F Part II If non TTOL area OS

23  Latching Mechanisms Current Situation:  AMC : (…) “expected wear and deterioration should be taken into account”  FAA AC : (…) Flight attendant seats that are located within a longitudinal distance equal to three rows (…) are not in compliance with § (h)(5) unless additional restraint devices (dual latching devices or equivalent) are (…). Draft rule proposal:  Rule with:- Definition of areas where to install double latch / single latch / single latch + wear & tear - Definition of wear & tear for private / low occupancy ( cycles) Example: Proposed Future Certification Requirements (Draft NPA) Subjects agreed / clarified easily 23 2m Double Latch Double Latch Extra distance If items > 4lbs are in the line of sight of Cabin Attendant Seats Simple Latch + Wear & Tear Simple Latch (no Wear and Tear) Simple Latch + Wear & Tear Flight Attendant Area Non-TTOL Area Passenger Area Flight Attendant Area OS

24 4.2 - Details of the Proposed Amendments Subjects with appreciable changes / adjustments 24 Future Certification Requirements for Executive Interiors Presentation of Stakeholder-led Rulemaking Works – Draft NPA from RMT.0264 (MDM.066) JMB

25  Distance to Exit / Exit deactivation Current Situation:  CRIs with:- Max distance on one side (30ft) but no fix limit on the other side limit (max certified = 52ft) - Max occupancy with fixed percentages / type of zones with deactivated exits - Limitation to private use Draft rule proposal:  Rule with:- Max distance on one side (30ft) and other side (45ft) - Max occupancy with slightly higher seats / type of zones with deactivated exits - Private use and Low Occupancy aeroplanes Examples: PackageEIR limitZonal limitsTotal Limit 1Private = Public Low density1/3 TC = = Public (>1/3 TC)-Not Authorized 30ft Stay out zone Extreme aft seat positions C III C Zone between 2 pairs Zonal Limit = 50% Dead-end Zone Zonal Limit = 45% PackageEIR limitZonal limitsTotal Limit 1Private-2519 (only one pair) 2Public Low density1/3 TC = (only one pair) 3Public (>1/3 TC)-Not Authorized 30ft Stay out zone Extreme aft seat positions 45ft Dead-end Zone Zonal Limit = 45% C III C Proposed Future Certification Requirements (Draft NPA) Subjects agreed / clarified with appreciable adjustments 25 OS

26  Isolated Compartments Current Situation:  EASA CRIs (Special Conditions) with difficulty to agree on a definition for isolated compartment Draft rule proposal:  An isolated compartment is defined as a cabin area (or room) where there is the possibility that a fire may grow undetected by cabin occupants.  Isolated compartments shall incorporate a smoke detection system  The AMC (b) provides guidance in assessing if a compartment is isolated or not: Proposed Future Certification Requirements (Draft NPA) Subjects agreed / clarified with appreciable adjustments 26 AH ? Variability in interpretation if isolated or not! Isolated if: Not isolated If: - Bedrooms; - Specialized rooms (Smoking rooms, Cinema rooms, Prayer rooms); - Washrooms; - Crew rest compartments, - Galley compartment - Small cabin - Baggage compartment compliant with CS ; or - No smoke tight separation, and no adjacent isolated compartment - Smoke detector is not required in lavatories per CS ; or - If the number of TTOL seats is: o between 2 and 15% of the total number of TTOL seats, or o > 10 TTOL seats

27  Isolated Compartments (Cont’d) Related Amendments:  CS (a)(9)  At least one readily accessible hand fire extinguisher must be available for use in each cabin compartment isolated from the remainder of the cabin  CS  Smoke detection in lavatory extended from > 19 PAX to > 19 PAX or 60ft in length  CS (c)(3)  There must be at least two sufficient outlets and units of dispensing equipment (…)  + corresponding AMC expanded Proposed Future Certification Requirements (Draft NPA) Subjects agreed / clarified with appreciable adjustments 27 AH

28  Firm Handhold Eligible item are above 33in from floorEligible item are above 26in from floor Today Tomorrow Current Situation:  EASA CRIs (Deviation) / FAA IPs : In wide open areas, there must be a route to enable passenger to steady themselves in moderately rough air. Eligible firm handhold item must be at least 33in high and no more than 65in apart. Draft rule proposal:  Eligible items may be considered from 26in instead of 33in (knees bended).  Distance between items is increased to 84in (allowing 1 step) Proposed Future Certification Requirements (Draft NPA) Subjects agreed / clarified with appreciable adjustments in  =65 in 26 in  =84 in BS

29  Direct View Current Situation:  CRIs with:- For Private Use: Requirement that Attendants face the cabin only - For Public Use: AMCs Draft rule proposal:  Rule with:- For Private Use: Requirement that at least half of the Attendants face the cabin - For low occupancy aeroplanes: Use of FAA AC B §10 with: o Compartment ≤ 4 PAX not concerned o Passenger calling for attention using body movements / raising hands… o Only floor level exit adjacent to required crewmember seats shall be visible Examples: Low Occupancy:  Not under Direct View (a portion of the seat must be visible) Low Occupancy:  under Direct View (passenger calling for attention) TodayTomorrow Proposed Future Certification Requirements (Draft NPA) Subjects agreed / clarified with appreciable adjustments 29 TP

30 4.3 - Details of the Proposed Amendments Subjects with dissenting views 30 Future Certification Requirements for Executive Interiors Presentation of Stakeholder-led Rulemaking Works – Draft NPA from RMT.0264 (MDM.066) JMB

31  Width of Aisles – Area of divergence # 1 Current Situation:  CS : no protrusion into the main aisle in all flight  Recent memos: protrusion authorized for non-TTOL phases for A/C ≤ 19 PAX  Private Use: protrusion authorized for non-TTOL phases (deviation CRI) Draft rule proposal:  Adopt SFAR109 + memos with extension to Group 2b, ie. Public - 19 < x < ⅓ TC Dissenting views on extension to Group 2b  Dissenting View: - Not needed for larger aeroplanes because there is more space. - FAA currently limits to FAR 135 OPS up to 19PAX - EASA recently adopted similar position in Certification Memo  Justification of the position expressed in the draft NPA: - The principle of maintaining an aisle practicable for rapid reaction in the cabin is kept (base for acceptance in SFAR 109) - Consistency with the notion of “low occupancy” - More cabin space allows difference arrangement possibilities which have its own needs. No aisle protrusion in flight is excessively constraining. Different cabin size / Similar arrangements / Same needs…  Drafted rule is currently proposed reflecting the majority position for consistency with the notion of “low occupancy” Proposed Future Certification Requirements (Draft NPA) Subjects with dissenting views 31 OS

32  Width of Aisles – Area of divergence # 2 Current Situation:  FAA memo: Criteria for less than 19 aeroplanes (commercial) time to travel with obstruction shall not exceed 3 times the time it takes without obstruction  Private Use: No criteria (EASA + FAA) Draft rule proposal:  Adopt FAA memo with extension to Group 2b, ie. Public - 19 < x < ⅓ TC + minimum allowance of 30s for small cabins Dissenting views criterion to accept obstructed aisle  Dissenting View: - Authority members: “3 times” or “30 add. Seconds” whichever is lower. - Industry members: “3 times” or “30 add. Seconds” whichever is higher.  Justification of the position expressed in the draft NPA: - Industry members : Small cabins have not much space  going around obstacles takes time  there should be a minimum 30s fix allowance - Authority members : 30s seems to big an obstruction if you can do it in 5 seconds without obstructed aisle  there should not be items likely to obstruct a cabin to that extent.  Drafted rule is requesting EASA Rulemaking Directorate Decision Proposed Future Certification Requirements (Draft NPA) Subjects with dissenting views 32 OS

33  Emergency Exit Access Current Situation:  CS : Access to Type III / Type IV: for A/C ≤ 19 PAX: Minor obstruction authorized for A/C > 19 PAX: No obstruction  EASA / FAA Memos clarifying interpretationBut: controversy on EASA position documented with arbitration letting door open to new arguments Draft rule proposal: a large agreement…  Clarification of the area not to be obstructed (40cm instead of “the width of the narrowest seat”)  Clarification that the parameter “Private” is a sufficient compensating factor  Clarification that a warning system is a mean to ensure any obstruction will be removed in TTOL Obstruction MinorMajor ≤ 19 PAX Yes if : Compensating Factors No > 19 PAX No Obstruction MinorMajor ≤ 19 PAX Yes if : Compensating Factors Yes if : Warning System > 19 PAX Yes if : Private Use Yes if : Private Use + Warning System Minor obstructions up to 19 PAX onlyMinor obstructions above 19 PAX for private use Major obstruction if a warning system is installed TodayTomorrow Proposed Future Certification Requirements (Draft NPA) Subjects with dissenting views 33 JMB

34 Dissenting view  Emergency Exit Access Draft rule proposal: … and some areas with dissenting views  Definition of “no obstruction” / “minor” / “major” obstructions  Dissenting views on allowance for “minor obstruction” if the A/C may be evacuated in 45s Deployable elements stowed in TTOL: - An item for use by cabin crew only. - An item for use by Passenger if: o Placards to stow item prior TTOL o pre-flight briefing o +: If cabin crew Warning system (crew station) If no cabin crew: Warning system (local buzzer + local light) “no obstruction”“minor obstruction” Agreed (Re)movable elements that could be in the exit door region in TTOL if not properly disposed: - Item instinctively removable while trying to access the exit (eg. divan cushion…). - Item not adversely affecting evacuation time if deployed post crash landing: o Placards / briefing that item should be stowed o Exit still practicable by 95 % percentile male o Max evacuation time in 45s Dissenting view Agreed Proposed Future Certification Requirements (Draft NPA) Subjects with dissenting views 34 JMB

35  Revision of the “19 PAX limit” for flammability requirements for materials (HR/SD) Modification of CS-26 in consistency with the notion of “low occupancy” aeroplanes Compartment interiors Operators of large aeroplanes used in commercial air transport shall comply with the following not later than [one year after the entry into force of this Regulation]: (a)All materials and equipment used in compartments occupied by the crew or passengers shall exhibit flammability characteristics compatible with minimising the effects of in-flight fires and the maintenance of survivable conditions in the cabin for a time commensurate with that needed to evacuate the aircraft.  Part 26 links flammability of materials with evacuation time  Intermediate necessary = modify CS-26 to make new draft rule acceptable  Proposal = replace “19 PAX limit” by an evacuation time criteria: 30s (Public, 19 < x ≤⅓TC) vs. 45s for Private Use A/C  Proposal = replace “19 PAX limit” by an evacuation time criteria: 30s (Public, 19 < x ≤⅓TC) vs. 45s for Private Use A/C CS Compartment interiors Compliance with Part is demonstrated by complying with CS and Appendix F or equivalent, CS (e) or equivalent and CS or equivalent or CS 25 X25.xxx or equivalent or with the following: (…) X25.xxx Interior Furnishings Materials (a)Heat Release / Smoke Density Compliance is required with the applicable provisions of CS , except that compliance with appendix F, parts IV and V to CS 25 need not be demonstrated if it can be shown by test or a combination of test and analysis under the conditions specified in appendix J to CS-25, that the maximum time for evacuation of all occupants does not exceed: (1)30 seconds, or (2)45 seconds for airplanes that are limited to private use operation only. Proposed Future Certification Requirements (Draft NPA) Subjects with dissenting views 35 TP

36  Revision of the “19 PAX limit” for flammability requirements for materials (HR/SD) Performance criteria for compliance with Part 26  It is proposed to amendment CS to include this 30s limit in order to attain one of the objective of the ToR (See CRD of ToR) = address dual-use aeroplanes  It is proposed to amendment CS to include this 30s limit in order to attain one of the objective of the ToR (See CRD of ToR) = address dual-use aeroplanes The FAA has previously found (see FAA exemption 6820) that demonstration that the occupants can escape from the airplane in 30 seconds or less provides a level an acceptable alternative to the heat release and smoke density requirements of 14 CFR (d). These airplanes provide the level of safety intended. Proposed Future Certification Requirements (Draft NPA) Subjects with dissenting views 36 See extract from FAA exemption 6820A page 8 (§ Interior Materials) Exemption No granted relief from the heat release and smoke emissions requirements of § , provided that an applicant could show that the airplane was capable of being evacuated with 30 seconds, under the conditions of part 25, appendix J. The principle behind this limitation is that the improved materials would provide enhanced evacuation capability by providing additional time to evacuate. Since this additional time is not being provided, the evacuation capability could be maintained, if the airplane could be evacuated faster than is otherwise required. The FAA arrived at the 30 second time limit by reviewing the full-scale fire test data used to establish the requirements for interior materials, and applying the increase in survival time to actual accidents, and relating that improvement to the relative evacuation performance under demonstration conditions. TP

37 4.4 - Details of the Proposed Amendments Subjects with new ideas 37 Future Certification Requirements for Executive Interiors Presentation of Stakeholder-led Rulemaking Works – Draft NPA from RMT.0264 (MDM.066) JMB

38  Exit Distribution in 19-Seat Airplanes Current Situation:  No regulation to limit distance between the two exits nor limit on distance from passenger seats to exits in 19-seat airplanes Draft rule proposal:  New requirement in CS that limits seat-to-exit distance to same 30/45 feet standard used in Deactivation of Exits proposal  Note: The group did not address the distance between the flight crew seat and emergency exits as being outside the Terms of Reference of this rulemaking task. Illustration: Proposed Future Certification Requirements (Draft NPA) New subjects proposed 38 TP Main Door / Emergency Exit Type I Emergency Exit Type III 30 feet 45 feet

39  Symbolic Placards Current Situation:  Symbolic placards not defined Draft rule proposal:  Use of GAMA Publication 15 as AMC for defining placards + list of acceptable placards Examples: Proposed Future Certification Requirements (Draft NPA) New subjects proposed 39 JS

40  Certification Benefit of the Briefing Card (1/2) Current Situation:  : The aeroplane must contain (…) The specified markings and placards (…) displayed in a conspicuous place (…)  As a result, many placards are installed locally, sometimes to the detriment of the messages Draft rule proposal:  For Private Use only: reduction of the number of placards if the instructions are provided in a briefing card prepared during certification. Examples: Today Placards for use in emergency + many placards for setting area in TTOL config. Proposed Future Certification Requirements (Draft NPA) New subjects proposed 40 OS

41 41 Tomorrow: Placards for use in emergency + detailed briefing card (stowage pockets required) Proposed Future Certification Requirements (Draft NPA) New subjects proposed  Certification Benefit of the Briefing Card (2/2) OS

42 4.5 – Summary of required insertions in Cockpit / AFM 42 Future Certification Requirements for Executive Interiors Presentation of Stakeholder-led Rulemaking Works – Draft NPA from RMT.0264 (MDM.066) JMB

43 43 Proposed Future Certification Requirements (Draft NPA) Summary of required insertions in Cockpit / AFM JMB  Insertions in the AFM  Cockpit Interfaces Limitation Section:  Private Use: Indication that the aeroplane is limited to non-commercial operations.  Seats in excess: Indication of max number of TTOL seats authorized when more seats are installed.  Briefing Card: Obligation for minimum content of briefing card if used in replacement of placards Abnormal or Emergency Procedures – Coordination between flight crew and cabin crew  Interior Doors: verification of proper door positions & instructions for their operations  Isolated Compartments: verification following smoke detection Normal Procedures – Briefing to passengers:  Interior Doors: Presence of Interior Doors & frangibility feature  Access to Exit: Explanation of the warning system and the necessary response by the passengers.  Width of Aisle: Procedures for restoring the aisle width for TTOL  Non-smoking: overall prohibition.  Firm Handhold: Recommendation to remain seated & belted. Indication:  Door Position Indication (1 light for all doors)  Indication of proper position of obstruction in front of Type III exits  Smoke Detection in Isolated Compartments (1 light for all compartments) Switch:  Cooktop: means to shut off power to the cooktop

44 5- Return of Experience on Stakeholder-led rulemaking group 44 Future Certification Requirements for Executive Interiors Presentation of Stakeholder-led Rulemaking Works – Draft NPA from RMT.0264 (MDM.066) JMB

45  Feedback from Industry Members Return of Experience on Stakeholder-led rulemaking group 45  Feedback from Authority Members Very good experience (opportunity to share experience between Industry and Authority Members) Possibility to benefit from agreed interpretations prior publication of draft NPA Involvement of the Authority Members (experts) is essential to gain reasonable insurance that the final NPA will be close to the draft submitted by the group. Consensus spirit has been prevailing However, uneven level between Industry and Authority members  doubts on EASA decision for all positions where diverging views were exposed JMB Involvement of the Authority Members (experts) is also seen as essential to gain reasonable insurance that the delivered draft NPA does not contain elements for which the Authority would be in strong opposition. Still need for resources on Rulemaking Directorate to make sure the draft NPA meets the standards set by the Agency. Still need for resources to choose between the options proposed by the group when diverging positions were presented since EASA cannot publish a NPA for which there is no full adherence to the content. This might be through a decision committee set by EASA for this purpose.

46 Questions / Answers Thank you for your attention


Download ppt "EXECUTIVE INTERIOR RULEMAKING GROUP Future Certification Requirements for Executive Interiors Presentation of Stakeholder-led Rulemaking Works Draft NPA."

Similar presentations


Ads by Google