NPA-OPS 44 (JAR-OPS 1) Cabin Crew Exit Training

NPA-OPS 44

(JAR-OPS 1)

Cabin Crew Exit Training

CJAA/OPS DIV Page 1 of 33 29/05/2006 Adopted at JAAC 06-2, May 2006 NPA-OPS 44 (JAR-OPS 1) Cabin Crew Exit Training

NPA-OPS 44 NPA to JAR-OPS Part 1 (Commercial Air Transportation Aeroplanes)

This NPA is comprised of:-

1. Explanatory Note

1.1. Regulatory Background

1.2. Regulatory Impact Assessment

2. Text Proposals

For ease of reference, the proposals are shown in much the same format as they would appear in the JAR. Thus, Section 1 material is shown in columnar format and Section 2 reads across the page. The proposed changes to the text are shown by a combination of strikeout and bold italics. The latter indicates proposed new text (or numbering).

Paragraph/s affected:-

Appendix 1 to JAR-OPS 1.1010 Conversion and Differences Training Paragraph (c) (1)

Appendix 1 to JAR-OPS 1.1015 Recurrent Training Paragraph (c) (1)

Appendix 1 to JAR-OPS 1.1020 Refresher Training Paragraph (a) (3)

IEM ACJ OPS 1.1005/1.1010/1.1015/1.1020 Representative Training Devices Paragraph (2) (c) New Para 3

Comment Response Document (CRD)

CJAA/OPS DIV Page 2 of 33 29/05/2006 Adopted at JAAC 06-2, May 2006 NPA-OPS 44 (JAR-OPS 1) Cabin Crew Exit Training 1. Explanatory Note

1.1. Regulatory Background

1.1.1 This NPA originated from a proposal to examine the issues regarding the current text of Appendix 1 to JAR-OPS 1.1010 (Conversion and differences training) paragraph (c) (1), Appendix 1 to JAR-OPS 1.1015 (Recurrent training) paragraph (c) (1), Appendix 1 to JAR- OPS 1.1020 (Refresher training) paragraph (a) (3) and IEM ACJ OPS 1.1005/1.1010/1.1015/1.1020 in respect of cabin crew exit training, to determine if changes are required in order to provide clarification and leave no doubt as to what is actually required.

This proposal takes into account recommendations made by the United Kingdom Air Accident Investigation Branch (AAIB). Such recommendations were made in respect of unsatisfactory levels of cabin crew training for exit operation identified by the AAIB during investigations into emergency evacuations.

1.1.2 Introduction

In an emergency requiring an evacuation of an aeroplane, the cabin crew are responsible for rapidly and effectively evacuating passengers through the emergency exits and down the evacuation slides, where installed. The first action to be taken by cabin crew members is to ensure that there are no external hazards that might affect the safe evacuation of passengers. The next action is to open emergency exits and to deploy the evacuation slides, where installed. This is a vital part of a cabin crew members safety responsibility and this is enforced by JAR-OPS 1.1025 which states that “…. each cabin crew member undergoes a check covering the training received in order to verify his proficiency in carrying out normal and emergency safety duties.”

The current text in Appendix 1 to JAR-OPS 1.1010 paragraph (c) (1) states that an operator shall ensure that “Each cabin crew member operates and actually opens all normal and emergency exits for passenger evacuation in an aeroplane or representative training device….”. Appendix 1 to JAR-OPS 1.1015 paragraph (c) (1) states: “An operator shall ensure that, at intervals not exceeding 3 years, recurrent training also: (1) includes the operation and actual opening of all normal and emergency exits for passenger evacuation in an aeroplane or representative training device.” Appendix 1 to JAR-OPS 1.1020 paragraph (a) (3) states ‘The operation and actual opening of all normal and emergency exits for passenger evacuation in an aeroplane or representative training device’.

The associated IEM ACJ states: “A representative training device may be used for the training of cabin crew as an alternative to the use of an actual aeroplane or required equipment”. The IEM ACJ also states: “Where practicable, exits in all modes of operation (particularly in relation to method of operation, their mass and balance and operating forces)...”.

1.1.3 Types of Emergency Exits and how they operate

Aeroplane doors and exits differ considerably in their design and operating capabilities and characteristics. The following is a brief summary of exits and their basic operating systems:

• Exits without assist evacuation slides: These include floor level exits on aeroplane types which have sill heights of less than 6 foot or Type III or Type IV exits which apart from Airbus A320, Boeing 757 and Boeing 767, do not have off-wing evacuation slides. For exits that are not equipped with evacuation slides there is usually only one mode of operation and that is in the manual mode. In other words there is no difference in the operation of the exit in normal operation to that of an emergency

CJAA/OPS DIV Page 3 of 33 29/05/2006 Adopted at JAAC 06-2, May 2006 NPA-OPS 44 (JAR-OPS 1) Cabin Crew Exit Training evacuation.

• Exits without power assist means: These include some with Type I floor level exits such as the Boeing 737 and MD 80 series aeroplanes. These exits are equipped with an evacuation slide which has to be manually dragged from the slide bustle when the exit is in the armed mode with the girt bar attached to the cabin floor at the door sill. The physical effort needed to open the exit and deploy the evacuation slide will differ between aeroplane types and will very much depend on the size and weight of the evacuation slide.

• Exits with power assist means: An exit with a ‘power-assist’ system is one which when the door handle has been operated and initial door motion has been achieved, an assist system takes over powering the door open and dragging the slide from the slide bustle. Such systems were first installed on Type ‘A’ exits on wide-bodied aeroplanes in order to accommodate the much larger dual lane slides required by JAR/FAR 25. These ‘power-assist’ systems are now installed on narrow-bodied aeroplane types such as the Boeing 757, Airbus A319/320/321. If the ‘power-assist’ system fails then the slide can still be deployed but will again depend on the physical effort described above. More recently there has been a new development with floor level Type I exit slides being installed in an external compartment just below the exit (eg. Airbus A321 and as also proposed for A380 upper deck slides).

• Type IV exits: These are the smaller of the self-help exits that have a removable hatch normally operated by passengers and ejected through the exit aperture. Type IV exits are not equipped with evacuation slides. These exits are only found on narrow-bodied aeroplane, eg. Fokker F27, small commuter aeroplane and executive jets. Type IV exits are not ‘power-assisted’.

• Type III exits: Slightly larger than Type IV exits and usually significantly heavier but with basically the same procedure for operation. They are usually located in the middle of the aeroplane over the wing, but can also be located under the wing, eg. BAe 146-300. In the case of the Airbus A319/320, Boeing 757 and Boeing 767 these exits have an integral off-wing evacuation slide installed in an exterior compartment. Since the evacuation slide is not attached to a girt bar or installed inside an internal bustle, there is no additional force required to operate the exit in the armed mode. In fact some of these exits remain in the armed mode at all times apart from maintenance checks. Conventional Type III exits are not ‘power-assisted’.

• Boeing new generation Type III exits: Although similar in design in terms of size and weight, the new generation Type III exits installed on Boeing 737-600/700/800 series aeroplanes have a semi-automatic operation. The single action of operating the exit handle opens the exit outwards with the hatch remaining connected to the aeroplane by the installation of an upper hinge.

• Type I exits: Type I exits are normally installed on narrow-bodied aeroplane, but can also be found on wide-bodied designs such as the Boeing 767 (ie. Doors 3). Type I exits are equipped with an evacuation slide when the exit sill height exceeds 6 feet. Some Type I exits are equipped with evacuation slides and ‘power-assist’ systems as described above.

• Type A exits: Type ‘A’ exits are only to be found on wide-bodied aeroplane and are required to be equipped with dual lane evacuation slides. All Type ‘A’ exits are equipped with ‘power-assist’ systems in order to meet the ease of operation requirements of JAR/FAR 25. This is necessary in order to accommodate the difficulty of dragging the much larger and heavier slide out of the slide bustle. Achieving door opening and slide deployment without an active ‘power-assist’ system

CJAA/OPS DIV Page 4 of 33 29/05/2006 Adopted at JAAC 06-2, May 2006 NPA-OPS 44 (JAR-OPS 1) Cabin Crew Exit Training would be very difficult for a single crew member and would probably require the assistance of another crew member or a passenger.

1.1.4 Summary of exit types:

There are basically four types of exits in respect of modes of operation, which are as follows:

a) Exits which do not have evacuation slides and therefore are only operated in the manual mode.

b) Exits which have evacuation slides attached by means of a girt bar and without a ‘power-assist’ system. Such exits need additional physical force to open them in the armed mode.

c) Exits which have evacuation slides attached by means of a girt bar but are also equipped with a ‘power-assist’ system. They operate quite differently in the ‘power- assist’ mode and may require additional physical force to operate if the ‘power-assist’ system fails.

d) Exits which have evacuation slides that are not attached by the means of a girt bar (ie. stowed in the fuselage under the exit sill). The forces to open such exits and deploy the slides should not be significantly different in the normal mode, the ‘power-assist’ mode or the ‘power-assist’ fail conditions.

1.1.5 Accident recommendations made to JAA

The United Kingdom AAIB has made three safety recommendations in recent years regarding accidents involving JAA AOC holders, in respect of cabin crew exit training. These include the following:

• Recommendation 2000-32: “The CAA, FAA and JAA should review the requirements for public transport aircraft cabin door simulators used for crew training to require that they accurately simulate any non-linear characteristics of the associated aircraft doors and to require that full instruction is given to cabin crews regarding the door operating characteristics to be expected when operating the doors in an emergency."

• Recommendation 2002-44: “The CAA and JAA should review the requirements for flight and cabin crew training in respect of the operation of all available exits, to ensure that crew members are familiar with the operating procedures, and opening characteristics, in both the normal and emergency modes of operation.”

• Recommendation 2004-53: “It is recommended that the Irish Aviation Authority and JAA review the requirements for cabin crew initial and refresher training in respect of the operation of all normal and emergency exits, to ensure that crew members become, and remain, familiar with the different operating procedures, and opening characteristics, in both normal and emergency modes of operation.” The AAIB report also states: “The No 2 and No 3 CCMs had difficulty opening their respective doors, R1 and R2. However, the crew members who lent assistance [positioning crew] experienced no trouble in operating these exits. At the time of the incident, whilst few of the new entrant cabin crew personnel would operate the emergency exit doors in the armed mode during Conversion and Differences training, most would not. For the latter the door opening forces which they encountered during training were considerably less than those that would be encountered in a real evacuation with an armed evacuation slide. Although their instruction was supplemented with the advice that the fully rigged door would be more resistant to opening in the real event because of the integral slide deployment, during training they would have acquired no sense of

CJAA/OPS DIV Page 5 of 33 29/05/2006 Adopted at JAAC 06-2, May 2006 NPA-OPS 44 (JAR-OPS 1) Cabin Crew Exit Training the forces they would normally encounter trying to open an armed door.”

1.1.6 Subsequent JAA Actions

In June 2002 the JAA issued Temporary Guidance Leaflet Number 31 “Crew Training for Exit Operation”. TGL 31 is attached to this document as Appendix 1.

Note: If the changes proposed in this NPA are adopted, TGL 31 could be cancelled, although liaison with the FCSG would be necessary.

The Operations Sectorial Team (OST) referred AAIB Recommendation 2004-53 to the Cabin Crew Steering Group in the autumn of 2004, for consideration.

The resulting proposal was endorsed at OST 05-2, then reviewed by RST before being launched for public consultation 01/09/05 to 01/12/05. The CRD and final text proposals were endorsed at OST 06-2 March 06 for final RST review, prior to being submitted to the JAAC for adoption, in accordance with JAR-11.

Comment received during final review at RST 06-1: The NPA should indicate that long term exemptions may need to be considered to allow reasonable time for obtaining appropriate training devices.

1.1.7 Discussion

Concern has been expressed that some operators are not providing cabin crew training for exit operation in all modes of operation. Of particular concern might be the lack of practical training on door operation when the exit is in the armed mode, (ie. with the girt bar attached to the cabin floor in the area of the exit/door sill). Some aeroplane have doors with ‘power- assist’ systems that will automatically ‘power’ the door open dragging the slide from the slide bustle.

Other aeroplanes, especially on some narrow-bodied aeroplane fleets, do not have a ‘power- assist’ systems and rely only on the physical force of the cabin crew member to operate the exit operating handle and to fully open the door, dragging the evacuation slide pack out from the slide bustle and inflating the slide. Where a ‘power-assist’ system is incorporated, the additional physical force may still be required by the cabin crew member if the ‘power-assist’ system fails. In these cases, if the training has not replicated the physical force and effort needed to open the doors and to deploy and inflate the slide, then it could be argued that the cabin crew member has not demonstrated proficiency in door operation in the most critical mode, i.e. the actual mode required to operate the door in an emergency.

The current wording of Appendix 1 to JAR-OPS 1.1010 (c) (1), Appendix 1 to JAR-OPS 1.1015 (c) (1) and Appendix 1 to JAR-OPS 1.1020 (a) (3) requires that each cabin crew member actually opens all normal and emergency exits for passenger evacuation. The rule does not actually specify that the exit must be opened in all modes of operation. However, it could be argued that in order to open the exit for passenger evacuation the exit must be fully available to the passenger for the purpose of evacuation. If this is accepted then it could be assumed that the exit must be opened during training in each of the operational modes that might be required to open the exit and deploy the evacuation slide.

The current wording in IEM ACJ OPS 1.1005/1.1010/1.1015/1.1020 – ‘Representative Training Devices’, confuses the issue further since it states that whilst exit training should include the method of exit operation, exit mass and balance, and exit operating forces, this need only be achieved if ‘practicable’. An amendment to this IEM ACJ would also need to be considered.

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1.1.8 Conclusion

In order that cabin crew are trained to effectively operate exits in an emergency the wording of Appendix 1 to JAR-OPS 1.1010 paragraph (c) (1), Appendix 1 to JAR-OPS 1.1015 paragraph (c) (1), Appendix 1 to JAR-OPS 1.1020 paragraph (a) (3) and the associated IEM ACJ OPS will need to be changed. Such a change will ensure that the intent of the requirement is perfectly clear and that cabin crew are trained to operate emergency exits in the normal and emergency modes of operation including the action and forces required to operate and deploy evacuation slides.

The UK AAIB recommendations to the JAA strongly support the safety case for this proposed change. Whilst in the accidents mentioned above there were no passenger fatalities, the situation might have been different if the emergency scenarios had been more serious. In the last case cited by the AAIB (Recommendation 2004-53), if the fire situation had been more significant, and the positioning crew had not been on board, then the consequences to occupant survival could have been significant.

CJAA/OPS DIV Page 7 of 33 29/05/2006 Adopted at JAAC 06-2, May 2006 NPA-OPS 44 (JAR-OPS 1) Cabin Crew Exit Training 1.2. Regulatory Impact Assessment

1.2.1 Purpose and Intended Effect

The purpose of this NPA is to update and clarify existing requirements for cabin crew exit training as specified in Appendix 1 to JAR-OPS 1.1010 (Conversion and differences training) paragraph (c) (1), Appendix 1 to JAR-OPS 1.1015 (Recurrent training) paragraph (c) (1), Appendix 1 to JAR-OPS 1.1020 (Refresher training) paragraph (a) (3) and IEM ACJ OPS 1.1005/1.1010/ 1.1015/1.1020.

This NPA takes into account recommendations made by the United Kingdom Air Accident Investigation Branch. Such recommendations were made in respect of unsatisfactory levels of cabin crew training for exit operation during emergency evacuations.

1.2.2 Options

The options relating to JAR-OPS 1.1010, JAR-OPS 1.1015, JAR-OPS 1.1020 and the associated IEM ACJ are:

a) Take no action. b) Amend JAR-OPS 1.1010, JAR-OPS 1.1015, JAR-OPS 1.1020 and the associated IEM ACJ to require training in the various modes of exit operation.

To take no further action would place the JAA National Authorities and the Industry in a very difficult position if another accident were to occur, where the factors of cabin crew exit training had a detrimental affect on the successful and safe evacuation of passengers. The AAIB have now made three separate safety recommendations to the JAA resulting from three separate accidents to JAA AOC holders.

1.2.3 Impacts

i. The large majority of JAA AOC holders already provide their cabin crew with exit training that incorporates different modes of operation including the actions and forces required to open the exit and deploy the evacuation slide. Such training is currently provided by the majority of AOC holders during Conversion and differences training, as well as during three-yearly Recurrent training (and Refresher training as appropriate).

The majority of operators either have their own representative training devices that they use for exit training, or they use the training device of other operators. ii. There will be costs to those operators who do not currently train their cabin crew in the different modes of exit operation, and this is especially the case where perhaps no representative training devices are available. However, when taking into consideration that JAR-OPS 1.1025 requires verification of a crew member’s proficiency in carrying out emergency safety duties, it could be argued that such a training deficit should have already been identified by National Aviation Authorities.

1.2.4 Consultation

The consultation process has been conducted within the Cabin Crew Steering Group (CCSG), previously known as the Flight Crew and Cabin Crew Study Group (FCCCSG) - Subpart O. As previously stated, this issue was referred to the CCSG as a result of AAIB recommendation 2004-53 which was addressed to the JAA as well as the Irish Aviation Authority. The National Aviation Authorities have been involved in the drafting process of this document, as have ERA, AEA, ITF and ETF. The primary consultation was through the NPA process prescribed in JAR-11.

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1.2.5 Summary and Final Assessment

The proposed changes to JAR-OPS 1.1010, JAR-OPS 1.1015, JAR-OPS 1.1020 and the associated IEM ACJ as defined in part 2 of the NPA, will provide clear regulation for operators who may not at this stage fully understand the intent of the current requirement in respect of cabin crew exit training.

CJAA/OPS DIV Page 9 of 33 29/05/2006 Adopted at JAAC 06-2, May 2006 NPA-OPS 44 (JAR-OPS 1) Cabin Crew Exit Training 2. Text Proposals

Appendix 1 to JAR-OPS 1.1010 Conversion and Differences Training Paragraph (c) (1)

(c) Operation of doors and exits. An operator shall ensure that:

(1) Each cabin crew member operates and actually opens all each type or variant of normal and emergency exits for passenger evacuation in the normal and emergency modes, including failure of power assist systems where fitted. This is to include the action and forces required to operate and deploy evacuation slides. This training shall be conducted in an aeroplane or representative training device; and

Appendix 1 to JAR-OPS 1.1015 Recurrent training Paragraph (c) (1)

(c) An operator shall ensure that, at intervals not exceeding 3 years, recurrent training also includes:

(1) The operation and actual opening of all normal and emergency exits for passenger evacuation Each cabin crew member operating and actually opening each type or variant of normal and emergency exit in the normal and emergency modes, including failure of power assist systems where fitted. This is to include the action and forces required to operate and deploy evacuation slides. This training shall be conducted in an aeroplane or representative training device;

Appendix 1 to JAR-OPS 1.1020 Refresher training Paragraph (a) (3)

(a) An operator shall ensure that refresher training is conducted by suitably qualified persons and, for each cabin crew member, includes at least the following:

(3) The operation and actual opening of all each type or variant of normal and emergency exits in the normal and emergency modes, including failure of power assist systems where fitted. This is to include the action and forces required to operate and deploy evacuation slides. This training shall be conducted for passenger evacuation in an aeroplane or representative training device;

IEM ACJ OPS 1.1005/1/1010/1.1015/1.1020 Representative Training Devices Paragraph (2) (c)

2 Only those items relevant to the training and testing intended to be given, should accurately represent the aeroplane in the following particulars:

(c) Where practicable, eExits in all modes of operation, (particularly in relation to method of operation, their mass and balance and operating forces) including failure of power assist systems where fitted; and

3 When determining whether an exit can be considered to be a variant of another type, the CJAA/OPS DIV Page 10 of 33 29/05/2006 Adopted at JAAC 06-2, May 2006 NPA-OPS 44 (JAR-OPS 1) Cabin Crew Exit Training following factors should be assessed:

a. Exit arming/disarming; b. Direction of movement of the operating handle; c. Direction of exit opening; d. Power assist mechanisms; e. Assist means, e.g. evacuation slides

Consequential Editorial Changes:-

JAR-OPS 1.1005 Initial training (See Appendix 1 to JAR-OPS 1.1005) (See IEM ACJ OPS 1.1005/1.1010/1.1015/1.1020) (See ACJ OPS 1.1005/1.1010/1/1015) (See Appendix 2 to ACJ OPS 1.1005/1.1010/1.1015)

JAR-OPS 1.1010 Conversion and Differences training (See Appendix 1 to JAR-OPS 1.1010) (See IEM ACJ OPS 1.1005/1.1010/1.1015/1.1020) (See ACJ OPS 1.1005/1.1010/1/1015) (See Appendix 2 to ACJ OPS 1.1005/1.1010/1.1015)

JAR-OPS 1.1015 Recurrent training (See Appendix 1 to JAR-OPS 1.1015) (See IEM ACJ OPS 1.1005/1.1010/1.1015/1.1020) (See ACJ OPS 1.1005/1.1010/1/1015) (See Appendix 2 to ACJ OPS 1.1005/1.1010/1.1015)

JAR-OPS 1.1020 Refresher training (See Appendix 1 to JAR–OPS 1.1020) (See AMC OPS 1.1020) (See IEM ACJ OPS 1.1005/1.1010/1.1015/1.1020)

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APPENDIX 1

JAA Administrative & Guidance Material Section Four: Operations, Part Three: Temporary Guidance Leaflet (JAR-OPS)

LEAFLET NO. 31: CREW TRAINING FOR EXIT OPERATION

A recently published accident report has identified differences between actual aeroplane door operation in the emergency mode with an active ‘power assist’ facility and the operation of the same type of door installed in a cabin simulator. It has been recommended that cabin door simulators accurately simulate all characteristics of the associated doors and that full instructions on the specific aeroplane door operating characteristics should be provided to flight and cabin crew during training and be repeated in the Operations Manual.

Differences in door operating characteristics between actual aeroplane doors and the doors installed in cabin simulators can be of critical importance during an emergency evacuation, especially if an incorrect door operation procedure is used. In the worst case scenario, the crew member may not be able to effectively open a fully functional door or exit if incorrect or inadequate procedures have been specified in the Operations Manual and are repeated during training.

Consideration should be given to:

a. Retrospective modification to existing cabin simulators to address these potential problems, or

b. Acquisition of a cabin simulator that simulates accurately all characteristics of aeroplane door operation, and in the meantime,

c. Emphasising differences between the operating characteristics of actual aeroplane doors and cabin simulator doors during training (e.g. by use of video) and in the Operations Manual. This is especially important where it is recognised that a cabin door simulator cannot, or does not, exactly replicate the actual aeroplane door operating characteristics.

Operations Manuals should be reviewed to ensure that information on aeroplane door operation is fully compliant with the procedures recommended by the relevant aeroplane manufacturer. In addition, Operators should provide full instructions to their flight and cabin crew, based on information provided by the aeroplane manufacturer, regarding door operating characteristics that might be expected when operating an aeroplane door in an emergency.

Reference documents:

Appendix 1 to JAR-OPS 1.945 (a), 1.965 (a)(3)(iii)(A), 1.1010 (c), 1.1015 (c) and 1.1020 (a).

(Section 4/Part 3 (JAR-OPS) 31-1 01.06.02)

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CRD to NPA-OPS 44

(Cabin Crew Exit Training)

Summary of NPA-OPS 44 comment phase

Comment period: 01/09/2005 until 01/12/2005

Comment period extended: N/A

Number of comments received: 29

CRD collated by: CJAA, Luz Mendes

CRD sent for review to: Janice Fisher (CCSG Chairman)

CRD sent on: 13 December 2005

Date for completion of review: 20 February 2006

Nomenclature for CRD review

A = Accepted PA = Partially accepted D = Declined N = Noted

CJAA/OPS DIV 14 of 33 29/05/2006 Adopted at JAAC 06-2, May 2006 Response Noted. Declined. Training devices can be made available but usually at some cost. If the stance is to be that NAAs will allow alleviation, then no operator would every buy or invest in suitable training units and the overall standard of training would decline substantially. Additionally there is no requirement in the rule for activation of slides – the requirement is for the appropriate door forces to be experienced. Noted. Noted.

29/05/2006

text/comment Reason(s) for proposed

The high costs for the representative training device are beyond realistic limits if an aeroplane is operated for which such a device does not already exist on the free market. If there is no training device available, the real activation of slides on actual aircraft is not an option as well due to enormous cost for replacement of slides. Such types of aeroplanes are airline type aircraft typically built during the period 1970 till around 1985, e.g. Boeing MD80, Fokker F-100 and others. 33

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(Section 1 material) device are available, Comments

Comment/Response Document NPA-OPS 44 he proposal. It will, however, be Several investigations into accidents in Europe aeroplane or representative training device. Where an aeroplane is used, the operator shall demonstrate that the force required to open doors and exits is equivalent to the force required in a real emergency situation. The actual activation of slides may therefore be replaced by a technical device creating the same behaviour. Where no suitable method on an aeroplane or a representative training the training may at discretion of authority also be conducted in an other type of training device which creates similar conditions to the type being used. very difficult for some Danish operators to meet the requirements. We therefore intend to check how it will be possible for the operators to meet the requirements in practice. as well the USA have emphasized need for systematic cabin crew exit training. The ETF recognizes, welcomes and supports the NPA 44 and the changes to Cabin Crew Exit Training in JAR-OPS Appendices 1 to 1.1010, 1015, 1.1020 and ACJ OPS This training may be conducted in an Agree with the contents of NPA. Agree with t Org. Golden Air Helvetic Airw. ETF Danish CAA DIV

Number General 001 002 003 004 CJAA/OPS Adopted at JAAC 06-2, May 2006

Response Noted. Declined. Whilst this is valuable information, this is both aeroplane and operator specific and therefore should not form part of rule material. This should form part of an operator’s standard operating procedures and NAA’s should ensure that this forms part of a training syllabus. 29/05/2006

text/comment Reason(s) for proposed The above mentioned accidents include the Airbus accidents in MIA 2000 and Djerba Airport Tunisia where cabin crew were killed during evacuation when opening exits due to overpressure in the cabin. The NTSB writes that the cabin crew in the MIA accident was forcibly ejected onto the ramp and was killed. As a consequence of these accidents, particular attention should be given when training cabin crew in wide body 33

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(Section 1 material) Comments

Comment/Response Document NPA-OPS 44 rms. o f sion. i J rev C 1.1005/1.1010/1.1020. In addition, the ETF appreciates that the proposed amendments will improve harmonization with the FAA rules. The ETF would however like to highlight two aspects of the exit training that should receive proper attention. Please see the attached comment as well the USA have emphasized need for systematic cabin crew exit training. HTF recognizes, welcomes and supports the NPA 44 and the changes to Cabin Crew Exit Training in JAR-OPS Appendices 1 to 1.1010, 1015, 1.1020 and ACJ OPS 1.1005/1.1010/1.1020. In addition, HTF appreciates that the proposed amendments will improve harmonization with the FAA rules. HTF would however like to highlight two aspects of the exit training that should receive proper attention. Please see our comments. speedy evacuation of the passengers represent the key task for cabin crew, HTF would like to draw attention a couple of accidents involving wide body aircraft which failed to depressurize. The outcome of the proposed text could be over active cabin crews, and possible injuries. HTF suggest that the JAA should consider addressing this in an A Several investigations into accidents in Europe Even if the opening of emergency exits and a Org. HTF HTF DIV

Number 010 011 CJAA/OPS Adopted at JAAC 06-2, May 2006 Response Noted. Noted. Noted. for over he r t o ems f st 29/05/2006 sy

text/comment Reason(s) for proposed raft. Even if warning lights airc pressurization are installed in the Airbus A 300 series, the training should emphasize the possible danger of over pressurization. According to the NTSB a particular problem exist when aircraft do not have pressure relief emergency exit doors. The report describes two other occurrences of injuries due to over pressurization. The incidents occurred on an ATR-72 and a CL 65 Bombardier. For reference see recommendation from UK CAA in FOD COM 10 2004 and NTSB Safety Recommendation of August 2 2002. 33

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(Section 1 material) Comments

Comment/Response Document NPA-OPS 44 The Swedish CAA supports the proposed revision without any comments and has express support for its adoption. Transport Canada finds NPA-OPS 44 clear and more in line with Transport Canada's exit operation drills. Should the JAA representative be interested in viewing Canada's requirements for exit operation drills, below you can find the links for both initial and annual training. There is also below a link to Schedule A which indicates the the SK CAA has no comments on this NPA

t r o p Org. s n a r Canada T SCAA Slovak CAA DIV

6 1 Number 014 015 0 CJAA/OPS Adopted at JAAC 06-2, May 2006 Response Noted. 29/05/2006

text/comment Reason(s) for proposed

33

of 18 e/ma e/ma e/ma mmerc mmerc mmerc o o o

(Section 1 material) /CivilAviation/c /CivilAviation/c /CivilAviation/c a a a Comments c c c . . .

Comment/Response Document NPA-OPS 44 .gc .gc .gc Our organization representing cabin crew from exits which Transport Canada deems to be compatible with each other. It will be updated in the future as some of more recent aircraft are not listed. http://www.tc nuals/tp12296/initial7/section3.htm http://www.tc nuals/tp12296/annual7/section1.htm http://www.tc nuals/tp12296/scheduleA/menu.htm all airlines registered in France is involved air safety matters at national, European and worldwide levels since the sixties. We long considers that there was a significant lack of realism in the way JAR OPS 1 up to now required exit training, with associated risks of errors in case emergency. Accident investigations have emphasized on several occasions the need for systematic and realistic cabin crew exit training. Therefore, our organization welcomes and supports the amendments proposed by NPA OPS 44 to Cabin Crew Exit Training in JAR- OPS Appendices 1 to 1.1010, 1015, 1.1020 and ACJ OPS 1.1005/1.1010/1.1020. Org. SNPNC DIV

Number 017 CJAA/OPS Adopted at JAAC 06-2, May 2006 Response Declined. 1. The words ‘in all modes of operation’ are considered to be unclear. The words ‘normal and emergency modes’ clarifies the need for both modes of operation. Removing the words ‘failure of power assist systems where fitted’ is not accepted. This not covered by the previous terminology, as power assist failure could be determined as an abnormal situation. This could significantly reduce the intent of the NPA. 2. Introducing the term ‘demonstrations of forces’ could allow operators to use video or other such methods. This is not the intent of NPA. l and …. a odes of “…the norm in all m 29/05/2006

by “ text/comment . Reason(s) for proposed 1. Clarity; replacing where fitted” operations” 2. It might be impossible / unrealistic to adjust accurately the forces in all trainers/door simulators to be exactly the same as in the aeroplanes – especially the cases where real aeroplane door is used in the simulators. In those cases, where the “simulated” door is used it might be more realistic. 33

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f o

s

f n o o

i t s a e

(Section 1 material) r t d s o n m o

l l m a

e This is to include the n d i

r t i o

x the proposed amendments s e Comments

e y c c r n Comment/Response Document NPA-OPS 44 o in an aeroplane or representative f . the normal and emergency e

g d r n e a required to operate and deploy

m n e

o i d t c n For the same reasons, we see as an additional positive step that improve harmonization with the FAA rules. Each cabin crew member operates and actually opens each type of normal a operations modes, including failure of power assist systems where fitted. forces evacuation slides. This training may be conducted training device; a Org.

A E A DIV

8 1 Number 0 CJAA/OPS Adopted at JAAC 06-2, May 2006

but to NPA to lutions o text merely implies Response 3. It is not the remit of CCSG to allow a one year alleviation. This would be the responsibility of individual NAA’s. The proposal to introduce ‘grandfather’ rights for existing exit training devices is not appropriate as these devices do not require approval. Declined. Recurrent training does require yearly ‘touch drills’. It is not the intent or the remit of this change the rule material to require yearly ‘hands on’ training. Declined. This is not the implication of text in 1.2.3 of the Explanatory Note – this that operators who are not currently compliant with the rule will need to address this shortfall. It is not the purpose of the NPA to offer s highlight the need for adequate training. 29/05/2006

text/comment Reason(s) for proposed 3. In this kind of amendment where new requirements are set, the implementation will take some time to modify the non- compliant doors or especially when making an investment for new training device. At least one year is needed. We are also proposing some kind of grand father rights for the existing devices, if forces can be demonstrated. NCCU is of the opinion that recurrent training is of utmost importance and that cabin crew should be trained every year on how to open all exits. (Hands training!).During normal operation it’s mainly the SCC who is responsible for opening of doors. It is therefore utmost importance that all cabin crew is annually trained in how to operate all exits. It is the main task of the CCs in an emergency situation and all the CCs should be able to do this as a reflex action. Apart from the cost of grounding aircraft for making it available the training (as implied in paragraph 1.2.3 of the explanatory note), another impact of requiring actual operation of the exist on the aircraft, may be indirect negative unwanted effects (such as improper closing) of actually operating exits which are designed to be used only in case of emergency. In addition when an evacuation slide is fitted on the aircraft 33

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(Section 1 material) Comments

Comment/Response Document NPA-OPS 44 oposed text from ETF.NCCU r p e e S . hough we fully agree with the intent of s t l l supports this text. proposal, we wonder whether the impact of proposed amendment has been fully addressed in the case where no training devices are available does not seem to have been fully addressed, especially in the case of exits with evacuation slide. P A

e c n a r F

Org. C A G NCCU D DIV

9 2 Number 028 0 CJAA/OPS Adopted at JAAC 06-2, May 2006 Response Improper closing of exits or incorrect folding of slides is a matter for the operator and associated maintenance personnel. 29/05/2006

text/comment Reason(s) for proposed such operation requires several deployments raising the risk of improper folding of the slides. From the explanatory note it does not appear whether the risk of introducing malfunctions of exits and emergency slides by operating them regularly has been properly assessed. 33

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(Section 1 material) Comments

Comment/Response Document NPA-OPS 44 Org. DIV

Number CJAA/OPS Adopted at JAAC 06-2, May 2006 ting arify the exis l to c Response NPA is Declined. The rewording of the text in NPA has not changed the requirements. There has never been a requirement for cabin crew to open exits on aeroplanes that are not in the operator’s fleet. The intent of this training requirements – it does not impose anything extra. (See Appendix 1 to JAR-OPS 1.1010 (a) (2).) Declined. Limiting the training requirement to only ‘required’ cabin crew is not in compliance with JAR-OPS 1.988. All cabin crew on board an aeroplane need to meet the training requirements of Subpart O. Accepted. The NPA will be amended to include the word ‘variant’ and a 29/05/2006

text/comment Reason(s) for proposed Attendants should not be required to learn to open/operate door types that are not in the operator’s fleet. The training is required for the cabin crew in charge of the emergency egress that is to say the required cabin crew as defined by JAR OPS 1.990. We propose to introduce the word variant for the doors type as there are very similars doors (i.e. Type A and 1) type with the same operating modes. A 33

of 22 y be a l and of a where ergency ber operates riant a m (Section 1 material) e of norm

mode or v This training m l and em

a This is to include the

. d e cabin crew member operates t Comments t i that is part of the operator’s in emergency an aeroplane or representative in the norm Comment/Response Document NPA-OPS 44 ems required st (1) Each cabin crew m s where f sy em ergency exit odes, including failure of power assist We suggest the following change to paragraph (c)(1) (c) Operation of doors and exits. An operator shall ensure that: and actually opens each type em aircraft fleet m syst action and forces required to operate deploy evacuation slides. conducted in training device; and ... (c) Operation of doors and exits. An operator shall ensure that: (1) Each and actually opens each type normal and emergency exit in the emergency modes, including failure of power assist fitted. This is to include the action and forces required to operate and deploy evacuation slides. This training may be conducted in an aeroplane or representative training device; and Org. Boeing AEA DIV

Number Appendix 1 to JAR-OPS 1.1010 (c )(1) 007 019 CJAA/OPS Adopted at JAAC 06-2, May 2006 Response

. Declined. Conversion training is both operator and aeroplane specific therefore the reference to a type of exit is for the installed in a particular aeroplane. The amended text in the ACJ gives guidance as to determining exit type or variant. definition will be included in the ACJ Declined. There is no need to add additional text as the power assist system is only operational in the emergency mode.

This . of exits proposes to reflect to types 29/05/2006

text/comment Reason(s) for proposed The NPA refers may be understood as a reference to the definitions of exit types for large aeroplanes that are contained in JAR/FAR/CS 25.807 and basically depend on size and position in relation to cabin floor level. However, on a given aircraft type, the exit operation may significantly differ between exits of the same regulatory type. These differences may be due to such factors as the exit location, the allocated escape slides/rafts, the operating systems and assist spaces. Airbus this situation in the appendices to JAR- OPS-1.xxxx and the ACJ as presented in this NPA. definition of a door/issue type variant is proposed within the ACJ OPS 1.1005/1.1010/1.1015/1.1020. In order to clarify the wording of this paragraph as far the power assistance mode is concerned, we propose to add "in emergency mode". The power assistance is only available when the door used in emergency mode. 33

of 23 en differing h (Section 1 material)

Comments

Comment/Response Document NPA-OPS 44 ersion and Differences Training Appendix 1 to JAR-OPS 1.1010 Conv th all specific installations w i including failure of power assist systems where fitted. This is to include the action and forces required to operate and deploy evacuation slides. This training may be conducted in an aeroplane or representative training device; and… throughout the aircraft, and Paragraph (c) (1) (c) Operation of doors and exits. An operator shall ensure that: (1) Each cabin crew member operates and actually opens each type of normal and emergency exits for passenger evacuation in the normal and emergency modes, w

Org. s u b r i A DIV

4 2 Number 0 CJAA/OPS Adopted at JAAC 06-2, May 2006 that was training specific FODCOM a completely procedures ensure FODCOM this is both not the fact that this is valuable Response to open the opposite opening the smaller rule material. This door and experienced of Declined. Whilst information, aeroplane and operator and therefore should not form part should form part of an operator’s standard operating and NAAs should this forms part of syllabus. The reference to 1/2003 is relevant. The addressing cabin crew had opened the larger difficulty galley door. They had not forgotten door. 29/05/2006

text/comment to open the opposite exit due

Reason(s) for proposed to lack of proper training. There is no requirement for CCM in their daily routines to open any exits or doors. In accordance with present operators’ procedures a CCM may open exits or doors only every third year during recurrent training. For further information please see: UK CAA FODCOM 1/2003….“Practical training in the opening normal and emergency modes had been given to cabin crew but had concentrated on the main passenger door and overwing exits.” And NTSB Recommendation A-92-71 “However, most recurrent training programmes do not require cabin crew to practice opening of more than one exit during drills. The NTSB is concerned that usable exits will not be opened during an evacuation because the cabin crew have not been trained to Emergency situations are dynamic and often chaotic. Accident investigations demonstrate the risk that cabin crew during an evacuation may fail to remember 33

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(Section 1 material) ill proceed to the th the intention to open it. i Comments

Comment/Response Document NPA-OPS 44 ETF suggests adding the following text to proposed JAR-OPS 1.1015 Appendix 1: (The suggested text is in bold.) ( c ) 1) Each cabin crew member actually opens each type of normal and emergency exit in the normal and emergency modes, including failure to the power assist systems where fitted. This is to include the action and forces required to operate and deploy evacuation slides. This training may be conducted in an aeroplane or representative training device. When responsible for a pair of doors, demonstrate that he/she w opposite door w Org.

F T E DIV

5 0 Number Appendix 1 to JAR-OPS 1.1015 (c)(1) 0 CJAA/OPS Adopted at JAAC 06-2, May 2006 of the cabin training specific existing a procedures the are not in the this is both that anything extra. (See this is valuable Response rule material. This to open exits on of NAA’s should ensure that impose Declined. The rewording of the text in NPA has not changed the requirements. There has never been a requirement for crew aeroplanes operator’s fleet. The intent this NPA is to clarify training requirements – it does not Appendix 1 to JAR-OPS 1.1010 (a) (2).) Declined. Whilst information, aeroplane and operator and therefore should not form part should form part of an operator’s standard operating and this forms part of syllabus. The reference to FODCOM 1/2003 is not completely

not be required to 29/05/2006

should text/comment to open/operate door types that Reason(s) for proposed Attendants learn are not in the operator’s fleet. open more than one exit.” See reason below 33

of 25 y be a ergency l and a (Section 1 material) ill proceed to the ber operates and l and em a m e

Comments that is part of the operator’s

Comment/Response Document NPA-OPS 44 in the norm in an aeroplane or representative

s where fitted. This is to include the suggests adding the following text to

ergency exit F odes, including failure of power assist T We suggest the following change to paragraph training device; .. m system action and forces required to operate deploy evacuation slides. This training m conducted (c)(1) (c) Operation of doors and exits. An operator shall ensure that: (1) Each cabin crew m actually opens each type of norm em H proposed JAR-OPS 1.1015 Appendix 1: (The suggested text is in bold.) ( c ) 1) Each cabin crew member actually opens each type of normal and emergency exit in the normal and emergency modes, including failure to the power assist systems where fitted. This is to include the action and forces required to operate and deploy evacuation slides. This training may be conducted in an aeroplane or representative training device. When responsible for a pair of doors, demonstrate that he/she w aircraft fleet Org.

F T H Boeing DIV

1 1 Number 008 0 CJAA/OPS Adopted at JAAC 06-2, May 2006

centrated on the than one exit during Response uation may fail to remember ained to open more than relevant. The FODCOM was addressing the fact that cabin crew had opened the larger door and experienced difficulty opening the smaller galley door. They had not forgotten to open the opposite door. Declined. Limiting the training requirement to only ‘required’ cabin crew is not in compliance with JAR-OPS 1.988. All cabin crew on board an aeroplane need to meet the training requirements of Subpart O. Accepted. The NPA will be amended to include the word ‘variant’ and a xits or doors. In accordance with 29/05/2006

text/comment e the risk that cabin crew during an evac Reason(s) for proposed on because the cabin crew have not been tr The training is required for the cabin crew in charge of the emergency egress that is to say the required cabin crew as defined by JAR OPS 1.990. We propose to introduce the word variant for the doors type as there are very similars doors type (i.e. Type A and 33

of 26 ammes do not require cabin crew to practice opening of more of mal and emergency modes had been given to cabin crew but con where riant a (Section 1 material) no requirement for CCM in their daily routines to open any e s only every third year during recurrent training. mode or v th the intention to open it. cabin crew member operates i Comments doors and exits. An operator

in emergency f chaotic. Accident investigations demonstrat

Comment/Response Document NPA-OPS 44 o n o ems i t required e exits will not be opened during an evacuati st a r e sy p O ) c opposite door w ( shall ensure that: (1) Each and actually opens each type normal and emergency exit in the emergency modes, including failure of power assist fitted. This is to include the action and forces required to operate and deploy evacuation slides. This training may be conducted in an aeroplane or representative training device; and Org. AEA DIV

drills. The NTSB is concerned that usabl one exit.” main passenger door and overwing exits.” And NTSB Recommendation A-92-71 “However, most recurrent training progr Number Emergency situations are dynamic and often present operators’ procedures a CCM may open exits or door For further information please see: UK CAA FODCOM 1/2003….“Practical training in the opening nor 020 CJAA/OPS Adopted at JAAC 06-2, May 2006 to open the opposite exit due lack of proper training. There is training specific NPA to a procedures this is both this is valuable Response rule material. This of NAA’s should ensure that

. definition will be included in the ACJ Declined. There is no need to add additional text as the power assist system is only operational in the emergency mode. Declined. Recurrent training does require yearly ‘touch drills’. It is not the intent or the remit of this change the rule material to require yearly ‘hands on’ training. Declined. Whilst information, aeroplane and operator and therefore should not form part should form part of an operator’s standard operating and this forms part of syllabus. Declined. Recurrent training is both

This . of exits to types 29/05/2006

text/comment Reason(s) for proposed 1) with the same operating modes. A definition of a door/issue type variant is proposed within the ACJ OPS 1.1005/1.1010/1.1015/1.1020. In order to clarify the wording of this paragraph as far the power assistance mode is concerned, we propose to add "in emergency mode". The power assistance is only available when the door used in emergency mode. CCOO emphasizes on the necessity for well trained cabin crew. To see a video each recurrent training on operation of doors and exits is not enough. Know how is obtained by practice, and through practice experience. Experience is very important. It is therefore very important to practice more often, also on opening the opposite door or exit, when a cabin crew member is responsible for a pair of doors. The NPA refers may be understood as a reference to the 33

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(Section 1 material) When ill proceed to the each recurrent Each cabin crew th the intention to open it. i Comments Recurrent training Comment/Response Document NPA-OPS 44 An operator shall ensure that training also includes: member actually opens each type of normal and emergency exit in the normal emergency modes, including failure to the power assist systems where fitted. This is to include the action and forces required to operate and deploy evacuation slides. This training may be conducted in an airplane or representative training device. responsible for a pair of doors, demonstrate that he/she w opposite door w Appendix 1 to JAR-OPS 1.1015

Org. s O u O b r C i C A DIV

3 5 2 2 Number 0 0 CJAA/OPS Adopted at JAAC 06-2, May 2006 Response operator and aeroplane specific therefore the reference to a type of exit is for the installed in a particular aeroplane. The amended text in the ACJ gives guidance as to determining exit type or variant. proposes to reflect 29/05/2006

text/comment Reason(s) for proposed definitions of exit types for large aeroplanes that are contained in JAR/FAR/CS 25.807 and basically depend on size and position in relation to cabin floor level. However, on a given aircraft type, the exit operation may significantly differ between exits of the same regulatory type. These differences may be due to such factors as the exit location, the allocated escape slides/rafts, the operating systems and assist spaces. Airbus this situation in the appendices to JAR- OPS-1.xxxx and the ACJ as presented in this NPA. 33

of 28 en differing h (Section 1 material)

Comments

Comment/Response Document NPA-OPS 44 th all specific installations w i Paragraph (c) (1) (c) An operator shall ensure that, at intervals not exceeding 3 years, recurrent training also includes: (1) The operation and actual opening of all normal and emergency exits for passenger evacuation. Each cabin crew member operates and actually opens each type of normal and emergency exit in the emergency modes, w throughout the aircraft, and including failure of power assist systems where fitted. This is to include the action and forces required to operate and deploy evacuation slides. This training may be conducted in an aeroplane or representative training device; … Org. DIV

Number CJAA/OPS Adopted at JAAC 06-2, May 2006 Response Declined. The rewording of the text in NPA has not changed the requirements. There has never been a requirement for cabin crew to open exits on aeroplanes that are not in the operator’s fleet. The intent of this NPA is to clarify the existing training requirements – it does not impose anything extra. (See Appendix 1 to JAR-OPS 1.1010 (a) (2).) Declined. Limiting the training requirement to only ‘required’ cabin crew is not in compliance with JAR-OPS 1.988. All cabin crew on board an aeroplane need to meet the training requirements of Subpart O. Accepted. The NPA will be amended to include the word ‘variant’ and a definition will be included in the text/comment Reason(s) for proposed

Attendants should not be required to learn to open/operate door types that are not in the operator’s fleet. The training is required for the cabin crew in charge of the emergency egress that is to say the required cabin crew as defined by JAR OPS 1.990. We propose to introduce the word variant for the doors type as there is very similar doors (i.e. Type A and Type 1) with the same operating in 29 of 33 29/05/2006 33 of 29

(Section 2 material) in emergency in emergency required cabin crew Comments Comment/Response Document NPA-OPS 44 of normal and emergency exit operator shall ensure that refresher where fitted. This is to include the action uggest the following change to paragraph or variant (a) An operator shall ensure that refresher training is conducted by suitable qualified persons and, for each cabin crew member, includes at least the following: ... of each type normal and emergency exit that is part of the operator’s aircraft fleet (3) The operation and actual opening the normal and emergency modes, including failure of power assist systems where fitted. This is to include the action and forces required to operate and deploy evacuation slides. This training may be conducted in an aeroplane or representative training device; ... (a)(3) and forces required to operate deploy evacuation slides. This training may be conducted in an aeroplane or representative training device; (a) An An (a) in the normal and emergency modes, including systems power assist of failure mode training is conducted by suitable qualified persons and, for each member, includes at least the following: (3) The operation and actual opening of each type We s We Org. Boeing AEA

Number Appendix 1 to JAR-OPS 1.1020 (a)(3) 009 021 DIV CJAA/OPS Adopted at JAAC 06-2, May 2006 Response ACJ. Declined. There is no need to add additional text, as the power is only system assist operational in the emergency mode. Declined. Refresher training is both operator and aeroplane specific therefore the reference to a type of exit is for the installed in a particular aeroplane. The amended text in the ACJ gives guidance as to determining exit type or variant. text/comment Reason(s) for proposed

modes. A definition of a door/issue type variant will be proposed within the ACJ OPS 1.1005/1.1010/1.1015/1.1020. In order to clarify the wording of this paragraph as far the power assistance mode is concerned, we propose to add "in emergency mode". The power assistance is only available when the door is used in emergency mode. The NPA refers to types of exits. This may be understood as a reference to the definitions of exit types for large aeroplanes that are contained in JAR/FAR/CS 25.807 and basically depend on size and position in relation to cabin floor level. However, on a given aircraft type, the exit operation may significantly differ between exits of the same regulatory type. These differences may be due to such factors as the exit location, allocated escape slides/rafts, the operating systems and assist spaces. Airbus proposes to reflect this situation in the appendices to JAR-OPS-1.xxxx and the ACJ as presented in this NPA. 30 of 33 29/05/2006 33 of 30

(Section 2 material) Comments Comment/Response Document NPA-OPS 44 Refresher training Appendix 1 to JAR-OPS 1.1020 Paragraph (a) (3) (a) An operator shall ensure that refresher training is conducted by suitable qualified persons and, for each cabin crewmember, includes at least the following: (3) The operation and actual opening of all each type of normal and emergency exits in the normal and emergency modes, with all specific installations when differing throughout the aircraft, and including failure of power assist systems where fitted. This is to include the action and forces required to operate and deploy evacuation slides. This training may be conducted for passenger evacuation in an aeroplane or representative training device;… Org. Airbus

Number 026 DIV CJAA/OPS Adopted at JAAC 06-2, May 2006 Response Declined. Whilst this is valuable information, this is both specific aeroplane and operator and therefore should not form part of rule material. This should form part of an operator’s procedures standard operating and NAA’s should ensure that training a this forms part of syllabus. text/comment Reason(s) for proposed

The above mentioned accidents include the Airbus accidents in MIA 2000 and Djerba Airport Tunisia where cabin crew were killed during evacuation when opening exits due to overpressure in the cabin. The NTSB writes that the cabin crew in the MIA accident was forcibly ejected onto the ramp and was killed. As a consequence of these accidents, particular attention should be given when training cabin crew in wide body aircraft. Even if warning lights for over pressurization are installed in the Airbus A 300 series, the training should emphasize the possible danger of over pressurization. According to the NTSB a particular problem exist when aircraft do not have the for systems pressure relief emergency exit doors. The report describes two other occurrences of injuries due to over pressurization. The incidents occurred on an ATR-72 and a CL 65 Bombardier. For reference see recommendation from UK CAA in FOD COM 10 2004 and NTSB Safety Recommendation of August 2 2002. 31 of 33 29/05/2006 33 of 31

(Section 2 material) Comments Comment/Response Document NPA-OPS 44 Even if the opening of emergency exits and a speedy evacuation of the passengers represent the key task for cabin crew, ETF would like to draw attention a couple of accidents involving wide body aircraft which failed to depressurize. The outcome of the proposed text could be over active cabin crews, and possible injuries. The ETF suggest that the JAA should consider addressing this in an ACJ revision. Org. ETF

Number ACJ OPS (IEM) 1.1005/1.1010/1.1015/1.1020 006 DIV CJAA/OPS Adopted at JAAC 06-2, May 2006 Response Accepted. The NPA will be amended to include the word ‘variant’ and a definition will be included in the ACJ. Declined. Training devices can be made available but usually at some cost. If the stance is to be that NAA’s will allow alleviation, then no operator would every buy or invest in suitable training units and the overall standard of training would decline substantially. Declined. Training is both operator and aeroplane specific therefore the reference to a type of exit is for the exit installed in a particular aeroplane. The amended text in the ACJ gives guidance as to determining exit type or variant. proposes to reflect text/comment Reason(s) for proposed

Some doors/exit are very similar (i.e. Type A and Type 1 doors) it seems reasonnable to use a Type A simulator cover also the use of type 1 door (unsing the same operating procedures). Lack of training devices in this country make this impracticable and costly The NPA refers to types of exits. This may be understood as a reference to the definitions of exit types for large aeroplanes that are contained in JAR/FAR/CS 25.807 and basically depend on size and position in relation to cabin floor level. However, on a given aircraft type, the exit operation may significantly differ between exits of the same regulatory type. These differences may be due to such factors as the exit location, the allocated escape slides/rafts, the operating systems and assist spaces. Airbus this situation in the appendices to JAR- OPS-1.xxxx and the ACJ as presented in this NPA. 32 of 33 29/05/2006 33 of 32

(Section 2 material) (particularly (particularly

a door/exit with similar Comments Comment/Response Document NPA-OPS 44 including failure of power assist add the text paragraph (20 ( c ) oposed to add the ACJ Variant definition To To IEM ACJ OPS 1.1005/1/1010/1.1015/1.1020 Training Devices Representative Paragraph (2) (c) Only those items relevant to the training and testing intended to be given, should accurately represent the aeroplane in following particulars: (c) Exits in all modes of operation For new aircraft introduction and where no aircraft devices are located in a country, operators may seek a dispensation from the local authority to conduct normal operation of doors on an aircraft but with video or other means to demonstrate the effect of a slide deployment and power assist failure as agreed with the authority. in relation to method of operation, their mass and balance operating forces), with all specific installations (e.g. assist spaces, slide/raft installation) when of exit across the differing for one type aircraft ) systems where fitted; and … Pr : Door/exit variant is operating modes and interface than the reference door/exit. The variant may be smaller than the reference door/exit used for training. Org. Airbus Flybe AEA

Number 022 027 013 DIV CJAA/OPS Adopted at JAAC 06-2, May 2006 Response text/comment Reason(s) for proposed

33 of 33 29/05/2006 33 of 33

(Section 2 material) Comments Comment/Response Document NPA-OPS 44 Org.

Number DIV CJAA/OPS Adopted at JAAC 06-2, May 2006