2Pertinent DocumentsFAA memo dated May 29, 1991: Access to Emergency ExitsFAA memo dated October 15, 1991: Access to Type III Emergency ExitsTransportation Safety Board of Canada Investigation report A05Q0024 of incident on February 21, 2005FAA memo dated October 17, 2008: Policy Statement on Access to and Opening of Type III and IV Exits on Airplanes with Passenger Seating Capacities of 19 or Fewer
3FAA memo dated May 29, 1991Acknowledges difference between smaller and larger airplanesStates minimum requirementDoes not allow placarding to be used to keep exit from being unopenable
5FAA memo dated October 15, 1991 (continued) Larger Transport: Access and Openability must be maintainedSmaller Transport: Openability must be maintained
6A05Q0024 February 21, 2005 Incident Set up: Result: No passenger briefingNight landingRunway edge lights out of orderSnow covered runwayPAPI lights on Runway’s left (but to the dispatcher’s right)Result:Transportation Safety Board of Canada Aviation Incident Report A05Q0024
7Pertinent Report Statements “One of the passengers tried unsuccessfully to open the emergency door [overwing exit]. As a result of the fuselage being bent out of shape, the door was jammed in its frame.”“All the occupants left the aircraft through the main door, which proved difficult to open because the fuselage was bent out of shape.”Report’s Finding as to Risk:“The armrest of the side seat had not been removed as required and was blocking access to the emergency exit, which could have delayed the evacuation, with serious consequences.”
9ConcernThe policy memo ANM ’s Background and Relevant Past Practice section discusses A05Q0024 and restates its findings as to risk and then states “the airplane occupants exited out the main door exit, the only other exit, but not without difficulty. The main door exit was difficult to open because the fuselage was bent out of shape. One passenger who tried to open the main door exit was unable to do so. This delayed the evacuation.”The policy memo implies that for this incident the escape hatch was not utilized because the divan armrest was not positioned for TTL. It also incorrectly states that a passenger tried to open the main door exit, when in fact the report states the passenger tried to open the escape hatch which was unopenable due to fuselage deformation.