34th CSSG Köln, September 20071 EASA Rulemaking Group CS 25.040 Type III exits INDEX 1.- EVENTS 2.- CS 25- 040 COMPOSITION 3.- CS 25- 040 MEETINGS PROCEDURES

34th CSSG Köln, September 2007

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EASA Rulemaking Group CS 25.040

Type III exits

INDEX

1.- EVENTS

2.- CS 25- 040 COMPOSITION 3.- CS 25- 040 MEETINGS PROCEDURES AND REFERENCE DOCUMENTATION

4.- PARAMETERS RAISED BY THE GROUP

5.- WORK SCHEDULE

6.- GROUP DISSAGREEMENTS

7.-FINAL RULE CS 25.813 ( c ) AND AMC

8.-JAR 26 RETROFIT DISCUSSION


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EASA Rulemaking Group CS 25.040 Type III Exits

Accidents (Manchester, 1985, Los Angeles, 1991 ), indicated a need to further improve the access to and operation of the Type III exits.

As a result of harmonisation activity between the FAA and the JAA regulatory changes were proposed to JAR/FAR 25.813 (c) by the Cabin Safety Harmonisation Working Group (CSHWG).

Rulemaking activity is included in the EASA ´s rulemaking programme for 2005. The purpose of the EASA NPA´s is to propose an amendment to CS 25.813 (c) to improve safety standards.

New AMC modifying the existing AMC 25.813 and introducing guidance on Seat position in relation to passageway configuration.

1.- EVENTS


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INDUSTRY

Marie-Laure WAWRZYNIEC AIRBUSJean-François PETIT AIRBUS (S.A.S.)Harald MERENSKY LUFTHANSA AG (AEA) Stewart LOFT THOMSON FLY (IACA)Josef MAURER CSA CZECH AIRLINES (ETF)

NAA NATIONAL AIRWORTHINESS AUTHORITIES

Michael MARKUS AUSTROCONTROLCarmela TRIPALDI ENAC Enrique NIN DGAC Spain

EASAPeter CHITTENDEN EASA (Chairman)Ray CHERRY Group SecretaryJan NOVAK EASA Focal Point

OBSERVERSJeff GARDLIN FAAClaude LEWIS Transport Canada Gary WEISS Boeing

2.- CS 25- 040 COMPOSITION


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MEETINGS HELD DURING 2006

MEETING 1 28th March 2006 MEETING 2 30th May 2006MEETING 3 8th September 2006MEETING 4 13th November 2006

MEETINGS HELD DURING 2007

MEETING 5 23th January 2007

3.- CS 25- 040 MEETINGS PROCEDURES AND REFERENCE DOCUMENTATION


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GROUP WORKING PROCEDURES Rulemaking procedures doc. nº 25-040-007

Rulemaking process doc. nº 25-040-008

Determination of the membership doc. nº 25-040-005

Terms of reference doc. nº 25-040-003

DOCUMENTS DELIVERED:

Dissenting Positions Document

RIA Draft Iss.4

NPA Nº 2007-XX . Draft 5



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Main Reference Documentation (1)

NPA 25D-270A Draft Improved Operation of and Access to Type III Exits FAA ARAC Cabin Safety Harmonization Working Group Report



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Reference Documentation (2)



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Parameter Variables Agreement

Positions

Passageway WidthDimension

Dimension of unobstructed passageway

yes 10” two seats, 13” three seats, OSR configuration

Passageway Height Dimension Overhead bins height

Not an issue for exit operation yes Adequately controlled by actual regulations

Passageway WidthProjection

Oversized exitsProjected opening

yes Projected opening should be taken as its actual size or the minimun required

Passageway WidthOSR

outboard seat removed yes OSR configuration was acceptable which is in line with the JAA NPA.

Passageway AccesibilityMonuments close to exits

Implications in passageways functionality.

yes This configuration would be acceptable but further consideration would need to be given to an acceptable access width. This issue would be addressed in the NPA.


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Positions

Passageway Conditions for unobstructed measurement Stowable items allowed to intrude

Other deployable items:Tray TablesVideo monitors etc. in “Economy style”Footrest

yes Stowable items, features that can be deployed by passengers, should be allowed to intrude only during flight.

Text to be developed to ensure that deployable items (Tray Tables, Video monitors etc. in “Economy style” Footrest) do not cause an impediment to an evacuation.

Passageway Conditions for unobstructed measurement Post Crash Deform.

Post Crash Deform. yes Deformation into the required passageway are acceptable until 3 inch ( 16 g crash condition )

Same values required in AC 25 .562-1B

Passageway Dual pairs of Type III exits

IAPA considers that the type III exit should not be allowed in future new aircraft designs. Regulations should only allow doors as type I or larger.

yes FAR25 Amendment 88 was discussed. This amendment removed the previous prohibition of Type III exits on aircraft with a seating configurations greater than 299 (which remains in CS25). This would constitute a separate activity


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Positions

Required vs Actual exit dimension Exit opening yes Oversized exit is to be addressed in the rule or the Advisory Material, as minimum required.

Hatch Operation Conditions under which inward opening hatch must be “unobstructed”

Fwd seat reclineTray TablesVideo MonitorsPost Crash Deform

yes All variables should be at worst possible position, for distance equal to seat width from exit.

Offset / Encroachment (position of the passageway relative to the exit aperture)

Position of passageway relative to exit aperture(offset of center line caused by rear seat encroachment)

yes Aft side of passageway should not be forward of required exit Center Line ( if oversized door is in place)

Breakforward/Stiffness of seats fore/aft of passageway

Amount by which seat backs may be moved for/aft by pax trying to bypass provided exit access.

yes Ability for Pax to climb over seats for/aft of exit passageway should be minimised Seats needs to be considered to determine break forward stiffness values.


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Positions

Foot Entrapment Gaps, holes which may trap feet of pax treading on outboard seat

yes Outboard seat should have no holes/gaps greater than 1 inch

Hatch Operation ADH (Automatically Disposable Hatch)Is a Type III disposed of automatically such that it does not present evacuation

AOH (Automatically Opening Hatch)

yes ADH , automatic disposal agreed :

Consensus in introduce the requirement in aircraft greater than a certain number of seats. TBD:-41 or 60 pass. discriminant or- aeroplanes enabling 4 abreast seating configuration or more.

Definitions ADH and AOH required

Definitions JAA CSSG perhaps could provide opinions expressed in their past meetings.

Placards Placing of operation instruction placards in clear view of passenger seated in exit row

yes Requirement for placards is reasonable


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Positions

Passageway Conditions for unobstructed measurement Intrusions

Forward seat recline And leg rest

no The Group were divided

Design Position

The required access must be maintained with the footrest extended and the seats reclined at their worst position as allowed by design (for instance automatic devices for placing the seats in the take-off and landing position).

FAA and CAA Canada regulations : no seat recline or footrest protrusion is allowed into the passageway to the exit.

Operation Position

There must be a means available to the crew, to ensure that the seats are in and remain in the approved Take-off and Landing position.The passageway must be kept clear during taxi, take off and landing, except that during flight the forward seat may recline into the passageway by 3 inches. One means to ensure this may be by a cabin crew lockout device.



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5.- WORK SCHEDULE


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The space reserved for an unobstructed passageway might be utilised, without compromising safety, for recline of seatbacks and/or the deployment of foot rests or other convenience items, under the control of passengers.

Area of Disagreement

There is disagreement regarding acceptable method for guaranteeing that such items will be moved out of the required passageway prior to the critical flight phases.

Methods proposed:

1.- “Procedural Process” A check procedure to stow items under passenger control in the vicinity of Type III exits, must be performed by cabin crew. A device, out of easy passenger reach and which when operated would prevent operation of the items in question, might be proposed in addition.

2.- “Design Solution” The passageway configuration must be ensured by the design. Deployment of items into the passageway in flight may be acceptable by the provision of devices to automatically restore them to a safe condition should passengers fail to do this.



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EASA Rulemaking Directorate final decision

EASA concluded that it cannot give a credit to the “Procedural Process solution” involving Cabin Crew actions.

The design alone without supporting actions by Cabin Crew must assure that the minimum required Type III exit unobstructed passageway is available in the critical phases of flight.

Acceptability of “Procedural Process” solution involving Cabin Crew actions is however not ruled out forever and this option can be further explored in the future during individual aircraft type certification projects. CS 25-40

The group is therefore requested to implement in the NPA proposal for CS-25 the “Design Solution”



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Final texts included in NPA 2007-XX Draft 5 circulated to the group on July 2007

• CS 25.813 Emergency exit access, and ease of operation

• AMC 25.813 ( To be defined if AMC to 25.807 and AMC 25.813 is necessary or it could be removed.)



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CS 25.813 Emergency exit access, and ease of operation(See AMC to 25.807 and 25.813)

(c ) The following must be provided for each Type III or Type IV exit -

(1) There must be access from the nearest aisle to each exit. In addition, for each Type III exit in an aeroplane that has a passenger-seating configuration of 20 or more and which has only seats installed immediately to the forward and aft of the exit-

(i) Except as provided in paragraph (c)(1)(ii) of this section, the access must be provided by an unobstructed passageway that is at least 10 inches in width for interior arrangements in which the adjacent seat rows on the exit side of the aisle contain two seats, or 13 inches in width for interior arrangements in which those rows contain three seats. The width of the passageway must be measured with adjacent seats adjusted to their most adverse positions. At least 10 inches of the required passageway width must be within the required projected opening width of the exit. (See AMC 25.813 (c))

Passageway configuration



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CS 25.813 Emergency exit access, and ease of operation(See AMC to 25.807 and 25.813)

(ii) In lieu of one 10- or 13-inch passageway, there may be two passageways, between seat rows only, that must be at least 6 inches in width and lead to an unobstructed space adjacent to each exit. Adjacent exits must not share a common passageway.

The width of the passageways must be measured with adjacent seats adjusted to their most adverse positions. The unobstructed space adjacent to the exit must extend vertically from the floor to the ceiling (or to the bottom of upper side wall stowage bins), inboard from the exit for a distance not less than the width of the narrowest passenger seat installed on the aeroplane, and from the forward edge of the forward passageway to the aft edge of the aft passageway. The exit opening must be totally within the fore and aft bounds of the unobstructed space. (See AMC 25.813 (c)).

Passageway projectionOSR



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CS 25.813 Emergency exit access, and ease of operation

(2) For each Type III exit which has a fixed bulkhead / wall installed adjacent to its forward and/or aft edge, access must be provided by an unobstructed passageway that is at least 20 inches in width.

The width of the passageway must be measured with any adjacent seats, or other movable features, adjusted to their most adverse positions.

The position of this passageway relative to the exit must be demonstrated to provide a level of safety equivalent to the arrangements defined in paragraph (c) (i) above.

Monuments



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(3) In addition to the access -

(i) For aeroplanes that have a passenger seating configuration of 20 or more, the projected opening of the exit provided must unobstructed and there must be no interference in opening the exit by seats, berths, or other protrusions (including seat backs in their most adverse positions) for a distance from that exit not less than the width of the narrowest passenger seat installed on the aeroplane.

(ii) For aeroplanes that have a passenger-seating configuration of 19 or fewer, there may be minor obstructions in this region, if there are compensating factors to maintain the effectiveness of the exit.

Passageway projection



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(4) For each Type III exit there must be placards that are readable by each person seated adjacent to and facing a passageway to the exit, in their normal field of view; and one adjacent to or on the exit.

(i) Is installed on or next to the exit , readable by each person seated adjacent to exit

(ii) Accurately state or illustrate the proper method of opening the exit, including the correct use of controls, handles, handholds etc.

(iii) If the exit is a removable hatch, state the weight of the hatch and indicate an appropriate location to

place the hatch after removal.

Placards



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(5) For each Type IV exit there must be a placard that –

(i) Is installed on or next to the exit, readable by each person seated adjacent to the exit.

(ii) Accurately states or illustrates the proper method of opening the exit, including the correct use of controls, handles, handholds etc.

(iii) If the exit is a removable hatch, states the weight of the hatch and indicates an appropriate location to place the hatch after removal.

Placards



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(6) For aeroplanes with a passenger seating configuration of TBD , 41- 60 or more, 4 seat abreast ?, each Type III exit must be designed in such a manner that, when operated to the fully open position, the hatch / door is automatically disposed so that it can neither reduce the size of the exit opening, the passageway(s) leading to the exit, or the unobstructed space specified in sub-paragraph (c)(1)(ii) of this paragraph, to below the required minimum dimensions.

In the fully open position the hatch/door must also not obstruct in any way egress from the exit via the escape route specified in CS25.810(c). (See AMC 25.813(c)).

TBD:

- 41 or 60 pass. discriminant or-aeroplanes enabling 4 abreast seating configuration or more.

Hatch operation



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AMC Automatic Disposal of Hatch/Door

The intent of requiring “automatic” disposal of a Type III hatch/door on aircraft with passenger seating configurations TBD is to remove the risk of passenger confusion, difficulty or error once the initial opening handle movement has been initiated.In this context, “automatic” is intended to convey the requirement that a Type III exit should be as simple, instinctive and easy to operate as intended by the design, as any other type of exit.

Markings, controls and kinematics of the design should be so that with minimal instruction (i.e. from a study of the placards required by CS25.813(c)(3)) a naïve subject, with the ranges of size and strength found in the 5th percentile female to the 95th percentile male, would be expected to be able to swiftly and correctly operate the exit to its fully open and secured position.In this regard, the exit hatch/door must move from its closed to fully open position in one simple and continuous operator motion, e.g. avoiding discontinuities in required force/direction on the handle(s). It is to be noted that the requirements of CS 25.809, which defines emergency exit operating characteristics,

testing requirements etc. is applicable to all exit types, including Type III and IV.

Hatch operation



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(7) The seat back of each seat bounding the passageway leading to each Type III or Type IV exit must be restricted in its movement to prevent evacuees from folding down seat backs to climb over in the course of evacuating.

Each seat back forward and aft surface must remain in an essentially upright position, i.e. not exceeding 20 degrees rearward and 10 degrees forward from a plane through the seat reference point normal to the floor and normal to the direction in which the occupant faces.

The seat back must be capable of maintaining this essentially upright position under loads of up to 668 N (150 lbf) applied horizontally, in the most critical combination of position and direction.

AMC Post Crash Seat Deformation

The requirement for an “unobstructed” passageway is not intended to preclude some deformation of seat structure into the required minimum passageway dimension due to emergency landing dynamic loading.

Seat permanent deformation of up to 3 inches (as recorded in the tests required by CS25.562) into the minimum passageway dimensions defined in CS25.813(c) is acceptable, provided no part of the seat intrudes into the minimum required projected opening of the exit.

Crashworthiness&

Passageway projection



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(8) The design of all seats and bulkheads / partitions bounding the passageways leading to each Type III or Type IV exit must be free from coat hooks and any other protrusions, which could impede evacuation.

Monuments & evacuation conditions



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(9) The design and arrangement of all seats bordering and facing a passageway to each Type III or Type IV exit, both with and without the bottom cushion in place, must be free from any gap, which might entrap a foot or other part of a person standing or kneeling on a seat or moving on or along the seat row.

Entrapment



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10) The latch design of deployable features (such as tables, video monitors, telephones, leg/foot rest) mounted on seats or bulkheads/partitions bordering and facing a passageway to a Type III or Type IV exit, must be such that inadvertent release by evacuating passengers will not occur.

The latch design of deployable features must also be such that cabin crew can easily check that the items are fully latched in the stowed position.

Placards indicating that each such item must be stowed for taxi, take-off and landing must be installed in the normal field of view of, and be readable by, each person seated in each seat bordering and facing a passageway to a Type III or Type IV exit. (See AMC 25.813(c)).

AMC Deployable Features

Features mounted on seats, bulkheads or other cabin features, under passenger control and which deploy into the required minimum passageway, may be accepted as not contravening the “unobstructed” requirements of CS25.813(c) provided;

Passageway Intrusions



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AMC Deployable FeaturesCS25.813(c) continuation

1.- They are easily and instinctively pushed out of the passageway by escapees in the event that they remain deployed prior to an evacuation. This may include, but not be limited to, items such as handsets, footrests, tray tables, in-armrest video monitors. Or

2.- They can only be released by permanently pushing a button/control for several seconds. This may include, for instance, a situation such as a business/first class seat with an electrically actuated leg-rest/foot-rest extending across the minimum required passageway.

Although this is, on the face of it, in direct contradiction to the text of CS25.813(c)(1)(i), it is accepted that such a deliberate, flagrant and obvious action on the part of a passenger is most unlikely and would be in any case most probably be discovered by a cabin attendant, even if seated at their assigned seat during taxi, take-off or landing. However, in such a case, the requirements of CS25.813(c)(2) must still be met in full, i.e. the operation of the exit may not be

compromised by the seat in any position.

Designs intending to use the principles of 1. or 2. above will be assessed on their individual merits.

It must be noted that none of the above reduces the requirement to design latching means that will prevent inadvertent release by evacuating passengers.

It is not accepted that Cabin Crew actions prior to taxi, take-off and landing are employed as the means to prevent later passenger actions to deploy features into the minimum required passageway.

Features may still be unsafe, even if they do not deploy into a defined minimum 10 or 13 inch passageway (as applicable). In the case where a wider passageway than the minimum is provided, it cannot be assumed that escaping passengers will constrain themselves to passing along one side or the centre.

Features which deploy into the actual passageway provided (in vertical projection from floor level to the upper ceiling/over head bin constraint) must be assessed in the same way as if they deployed into the minimum passageway, i.e. they must be accepted on one of the bases in 1. or 2. above.

Passageway Intrusions



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(11) Movable class dividers (including curtains and suspended solid panels) must not be installed above or along seat rows bordering a passageway to a Type III or Type IV exit.

Monuments



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(12) All seats bordering the passageway to a Type III or Type IV exit must be designed such that any baggage stowage provisions (such as under seat stowage) would prevent baggage items entering the passageway under the

inertia forces of CS25.561(b)(3).

Crashworthiness



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CS 25.813 ITEM CS 25.813 ( c)SUBPARAGRAPH

STANDARDS TO BE UPDATED OTHER SYSTEM REDESIGN( NO: ATA 25, ATA 12 MARKINGS)

CERTIFICATION STANDARDS

CS 25

OPERATIONAL REQUIREMENTS JAR 26

PASSAGEWAY CONFIGURATION

(1) (i) EASA NPA JAA NPA 25D.270 MINOR MOD

OSROutboard Seat Removed

(1) (ii) EASA NPA JAA NPA 25D.270 MINOR MOD

ACCESS THROUGH BULKHEADS

(2) EASA NPA JAA NPA 25D.270 MINOR MOD

PASSAGEWAY CONFIGURATION

(3)(i) (ii)

EASA NPA JAA NPA 25D.270 MINOR MOD

PLACARDS (4)(i) (ii) (iii)


PLACARDS (5)(i) (ii) (iii)


HATCH OPERATION (6) EASA NPA. Some details referring discriminant TBD

TO BE REVIEW ATA 50 STRUCTUREATA 29 HYDRAULIC POWERATA 24 ELECTRICAL POWERATA 52 DOORS

CRASHWORTHINESS (7) EASA NPA JAA NPA 25D.270 ATA 50 STRUCTURE



PASSAGEWAY ENTRAPMENT (9) EASA NPA JAA NPA 25D.270 MINOR MOD

DEPLOYABLE FEATURES (10) EASA NPA JAA NPA 25D.270 MINOR MOD



CRASHWORTHINESS (12) EASA NPA JAA NPA 25D.270 ATA 50

8.-JAR 26 RETROFIT DISCUSSION


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Thanks very much

Documents

34th CSSG Köln, September 20071 EASA Rulemaking Group CS 25.040 Type III exits INDEX 1.- EVENTS 2.- CS 25- 040 COMPOSITION 3.- CS 25- 040 MEETINGS PROCEDURES