EurECCA’s opinion on the recently published EASA draft SIB relating to the Minimum Cabin Crew for Twin Aisle Aeroplanes.
As the ORO 100 is always prevailing over any SIB that EASA may issue, EurECCA does not see in which way the EASA Safety Information Bulletin (SIB) N°2014-29 issued on the 24th October 2014 or this new draft SIB changes the way in which the minimum required cabin crew will be establisched.
The ORO CC 100 is quite clear regarding the establishment of the number of cabin crew members by the aircraft certification process, allowing the operators to fly with unattended floor level emergency exits.
Besides this fact, all arguments now under analysis by EASA, such as Design Organization approval over the operator cabin lay out, or any disconnections between the operational and airworthiness regulations, (e.g. direct visibility of the emergency on the opposite side may not be assured due to more complex arrangements of the interior components in the door areas), are not strong enough to impose any improvement in the main and actual rule.
This new SIB still allows airlines to have the choice between applying ORO 100 or following the EASA SIB’s recomendation, as this draft SIB is NOT mandatory, nor was the previous SIB no2014-29. Airlines have a choice and in practice operations with only the minimum number of required cabin crew members on board do occur. TAP Portugal for example follows the ORO CC 100 rule and reduced her A340 and A330 cabin crew to 6, where as others, like Iberia have upgraded the minimum required cabin crew in A340 and A330 aircrafts to 8.
EurECCA strongly supports the recommendations of EASA in their recent draft SIB on minimum required cabin crew on twin aisle aeroplanes. One cabin crew per floor exit on twin Aisles Aeroplanes is a must to enhance cabin and passenger safety. The control of passengers in an evacuation situation cannot be assured if floor level exits are unattended by cabin crewmembers. Flying twin aisle aeroplanes with unattended floor level emergency exits creates situations where emergency exits will be operated by passengers when it should not be, or not operated by cabin crew when it should be, will be a risk to passenger safety.
EurECCA emphasises the need for harmonisation of safety rules and is asking for a revision of ORO 100 on this topic in order to have the same mandatory rules applied by all airlines.
In the Notification of a Proposal to issue a Certification Memorandum (Large Aeroplane Evacuation Certification Requirements – Cabin Crew Members Assumed to be On Board, CM-CS-088 issue 01) which should be read in conjunction with the above mentioned draft SIB, EASA considers the required cabin crew for single aisle aeroplanes with Type III exits in case of a seating capacity of 50 seats or fewer. The factors weighed are both safety and economic (p.8 of 12).
EurECCA is of the opinion that considerations regarding safety of passengers in aviation should be based on safety factors only.
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