Transportation Safety
Improvements
Federal Issues
Aviation
Improve Audio and Data Recorders/Require Video Recorders
Importance
In order to rapidly, effectively, and efficiently determine the factors related to an aircraft accident, the Safety Board’s investigators must have as much information as possible. Automatic information recording devices, such as CVRs and flight data recorders (FDRs) have proven to be very useful in gathering pure factual information. The fact that this information is recorded immediately prior to and during the accident sequence often gives investigators the ability to quickly determine and correct a problem. This knowledge results in the development of timely, more precise safety recommendations that are likely to reduce future similar accidents.
The lack of valuable cockpit information available during the investigations of several aircraft accidents, including the crash of USAir flight 427, a Boeing 737 at Aliquippa, Pennsylvania, on September 8, 1994; the crash of USAir flight 105, a Boeing 737, on September 8, 1989, in Kansas City, Missouri; the crash of ValuJet flight 592 in the Florida Everglades shortly after takeoff from Miami International Airport on May 11, 1996; the SilkAir flight 185 crash on December 19, 1997; the crash of Swissair flight 111 on September 2, 1998; and the crash of EgyptAir flight 990 on October 31, 1999, prompted the Safety Board to issue several recommendations addressing specific improvements to CVRs and FDRs that are essential to accident investigation data collection and analysis.
Summary of Action
On February 28, 2005, the FAA published an NPRM, “Revisions to Cockpit Voice Recorder and Digital Flight Data Recorder Rules.” The NPRM proposed to increase the duration of CVR and FDR recordings, increase the sampling rate of certain FDR parameters, require physical separation of the FDR and CVR, require improved reliability of the CVR and FDR power sources, and require the recording of data-link communications. On April 29, 2005, the Safety Board provided comments to the docket for this NPRM. The Board stated that the NPRM contains positive actions that are responsive to several of its recommendations. However, several other Board recommendations were not addressed by the proposed rulemaking. Among these unaddressed recommendations are several on the Most Wanted List, including the use of forward- and aft-mounted combination voice and data recorders. The NPRM also does not address the Board’s image recorder recommendations. The NPRM comment period closed June 28, 2005. Although the FAA expected to publish a final rule, it has not yet done so.
2-Hour CVR
The FAA’s NPRM proposes to require that all CVRs record a minimum of 2 hours of audio information. The NPRM requires all newly manufactured aircraft to be equipped with a 2-hour CVR within 2 years of the rule date, and a 4-year phase-in to retrofit the existing fleet.
The NPRM proposes a requirement for the installation of a 10-minute independent power source for the CVR that will engage when electrical power to the CVR is lost. However, this requirement will apply only to newly manufactured aircraft. The Board believes that a 4-year retrofit similar to that being considered for the 30-minute-to-2-hour CVR conversion should also be applied to RIPS. The benefits gained from a CVR independent power supply will vastly outweigh the additional cost.
The Safety Board takes exception to the FAA’s NPRM, which states, “After a careful analysis of the benefits of having two systems, the FAA is unable to justify the excessive cost that would be incurred in the installation of two complete systems.” Although Safety Recommendations A-99-17 and A-00-31 specify two combined (CVR/FDR) recording systems, the intent of these recommendations was to have two redundant recorders—not to require two flight data acquisition units and two sets of cockpit microphones. The Board believes that the FAA’s cost estimates are unnecessarily inflated. The Board also disagrees with the NPRM that “in the case of an accident so catastrophic that neither recorder survives [meaning the currently required, aft-mounted recorders], a second set of recorders located in the front of the aircraft would probably not survive either.” In fact, there are a number of catastrophic accidents that could have resulted in a forward-mounted recorder surviving despite the aft-mounted recorder’s being lost to fire or impact. Embraer is currently delivering its model EMB-170/190 to U.S. operators with forward- and aft-mounted combined CVR/FDRs, and Boeing is considering a similar design for its new 787 aircraft.
The NPRM is consistent with the Board’s recommendation that the FDR and CVR be on separate generator buses with the highest reliable power so that any single electrical failure does not disable both. However, the proposed change applies only to newly manufactured aircraft, even though the recommendation was aimed at existing aircraft as well. The Board believes that any retrofit requirement will have minimal economic impact.
Video Recording
Small Aircraft
An image recording system would provide critical information to investigators about the actions inside the cockpit immediately before and during an accident on aircraft not required to have a CVR or FDR. Such systems, estimated to cost less than $8,000 installed, typically consist of a camera and microphone located in the cockpit to continuously record cockpit instrumentation, the outside viewing area, engine sounds, radio communications, and ambient cockpit sounds. As with conventional CVRs and FDRs, data from such a system is stored in a crash-protected unit to ensure survivability. Public Law 106-424, signed November 1, 2000, provides for withholding from public disclosure voice and video recorder information for all modes of transportation.
In March 2003, the European Organization for Civil Aviation Equipment (EUROCAE) issued ED-112, “MOPS [Minimum Operational Performance Specification] for Crash Protected Airborne Recorder Systems.” Amendment 2 to this document was issued by EUROCAE in September 2003. On July 28, 2006, the FAA issued TSO C176, “Aircraft Cockpit Image Recorder Systems” which incorporates ED-112.
The FAA has previously stated that no rulemaking is underway to mandate the installation of TSO-approved video equipment on aircraft operated under Part 135 that do not currently have flight recorders. Several years ago, the FAA collected data from a proof-of-concept test to determine whether an image recording system could be used to collect specific parametric data and other flight information. As part of the test, several image recording systems were installed on an FAA aircraft that was flown in various operational and environmental conditions. The FAA continues to evaluate data recorded on those flights. The FAA previously indicated that it would use the results of this analysis along with other required considerations to determine whether rulemaking for this recommendation is warranted. Although the report was expected to be completed by December 2006, it still has not been published or released.
Large AircraftThe Safety Board asked for the installation of cockpit image recorders in large transport aircraft to provide information that would supplement existing CVR and FDR data in accident investigations. This kind of additional information would have been extremely valuable in a number of important accident investigations, including ValuJet 592 near Miami; Silk Air 185 in Indonesia; Swissair 111 near Peggy’s Cove, Nova Scotia; and EgyptAir 990. The Radio Technical Commission for Aeronautics’ Future Flight Data Collection Committee (FFDCC) considered the issue of video recording and concluded that this methodology would provide useful information to accident investigation, and that it was technologically feasible. The Committee did note concerns about the protection from disclosure outside of accident investigation, particularly for international flights. The Board’s last reauthorization extended the protections that have long been in place for CVRs to image recorders.
In years past, the FAA has informed Congress that the FFDCC did not present information that was of such a compelling nature to convince the FAA of the necessity of installing image recording systems in aircraft operated under Parts 121, 125, or 135. The FAA has no rulemaking underway to mandate the installation of cockpit image systems as described in the safety recommendations. The FAA indicated to Congress that if the Board requires additional flight data information to investigate an accident or incident, the FAA would likely propose a performance-based requirement, stipulating that this flight data must be captured. Industry would be allowed to respond to the requirement in the manner it found most appropriate. The FAA believes that it is not prudent to mandate, as the Board recommends for a cockpit imaging system, that any electrical system have circuit protection that is not accessible to the flight crew. The FAA’s belief is based on the concern that in the event of an in-flight electrical fire, the crew must be able to cut off power to all electrical equipment quickly.
Action Remaining
In addition to adopting the 2-hour CVR requirement in the NPRM, require the retrofit of existing aircraft CVR systems with RIPS, and require that for existing aircraft, the FDR and CVR be on separate generator buses with the highest reliable power, so that any single electrical failure does not disable both. Require the installation of video recording systems in small and large aircraft.
Safety Recommendations
A-99-16 (FAA)
Issued March 9, 1999
Added to the Most Wanted List: 1999
Status: Open—Unacceptable Response
Require retrofit after January 1, 2005, of all cockpit voice recorders (CVRs) on all airplanes required to carry both a CVR and an FDR with a CVR that (a) meets Technical Standard Order (TSO) C123a, (b) is capable of recording the last 2 hours of audio, and (c) is fitted with an independent power source that is located with the digital CVR and that automatically engages and provides 10 minutes of operation whenever aircraft power to the recorder ceases, either by normal shutdown or by a loss of power to the bus. (Source: A safety recommendation letter dated March 9, 1999, based on the lack of complete cockpit and flight data in the September 2, 1998, crash of Swissair flight 111 into the waters near Peggy’s Cove, Nova Scotia)
A-99-17 (FAA)
Issued March 9, 1999
Added to the Most Wanted List: 1999
Status: Open—Unacceptable Response
Require all aircraft manufactured after January 1, 2003, that must carry both a cockpit voice recorder (CVR) and a digital flight data recorder (DFDR) to be equipped with two combination (CVR/DFDR) recording systems. One system should be located as close to the cockpit as practicable and the other as far aft as practicable. Both recording systems should be capable of recording all mandatory data parameters covering the previous 25 hours of operation and all cockpit audio including controller–pilot data link messages for the previous 2 hours of operation. The system located near the cockpit should be provided with an independent power source that is located with the combination recorder, and that automatically engages and provides 10 minutes of operation whenever normal aircraft power ceases, either by normal shutdown or by a loss of power to the bus. The aft system should be powered by the bus that provides the maximum reliability for operation without jeopardizing service to essential or emergency loads, whereas the system near the cockpit should be powered by the bus that provides the second highest reliability for operation without jeopardizing service to essential or emergency loads. (Source: A safety recommendation letter dated March 9, 1999, based on the lack of complete cockpit and flight data in the September 2, 1998, crash of Swissair flight 111 into the waters near Peggy’s Cove, Nova Scotia)
A-99-18 (FAA)
Issued March 9, 1999
Added to the Most Wanted List: 1999
Status: Open—Unacceptable Response
Amend Title 14 CFR Parts 25.1457 (cockpit voice recorders) and 25.1459 (flight data recorders) to require that CVRs, FDRs, and redundant combination flight recorders be powered from separate generator buses with the highest reliability. (Source: A safety recommendation letter dated March 9, 1999, based on the lack of complete cockpit and flight data in the September 2, 1998, crash of Swissair flight 111 into the waters near Peggy’s Cove, Nova Scotia)
A-00-30 (FAA)
Issued April 11, 2000
Added to the Most Wanted List: 2002
Status: Open—Unacceptable Response
Require that all aircraft operated under title 14 CFR Part 121, 125, or 135 and currently required to be equipped with a cockpit voice recorder (CVR) and digital flight data recorder (DFDR) be retrofitted by January 1, 2005, with a crash-protected cockpit image recording system. The cockpit image recorder system should have a 2-hour recording duration, as a minimum, and be capable of recording, in color, a view of the entire cockpit including each control position and each action (such as display selections or system activations) taken by people in the cockpit. The recording of these video images should be at a frame rate and resolution sufficient for capturing such actions. The cockpit image recorder should be mounted in the aft portion of the aircraft for maximum survivability and should be equipped with an independent auxiliary power supply that automatically engages and provides 10 minutes of operation whenever aircraft power to the cockpit image recorder and associated cockpit camera system ceases, either by normal shutdown or by a loss of power to the bus. The circuit breaker for the cockpit image recorder system, as well as the circuit breakers for the CVR and the DFDR, should not be accessible to the flight crew during flight. (Source: A safety recommendation letter dated April 11, 2000, prompted by the lack of valuable cockpit information during the investigations of several aircraft incidents and accidents, including USAir flight 105 on September 8, 1989 [NTSB/AAR-90-04]; ValuJet flight 592 on May 11, 1996 [NTSB/AAR-97-06]; SilkAir flight 185 on December 19, 1997; Swissair flight 111 on September 2, 1998; and EgyptAir flight 990 on October 31, 1999 [NTSB/AAB-02-01])
A-00-31 (FAA)
Issued April 11, 2000
Added to the Most Wanted List: 2002
Status: Open—Unacceptable Response
Require that all aircraft manufactured after January 1, 2003, operated under Title 14 CFR Part 121, 125, or 135 and required to be equipped with a cockpit voice recorder (CVR) and digital flight data recorder (DFDR) also be equipped with two crash-protected cockpit image recording systems. The cockpit image recorder systems should have a 2-hour recording duration, as a minimum, and be capable of recording, in color, a view of the entire cockpit including each control position and each action (such as display selections or system activations) taken by people in the cockpit. The recording of these video images should be at a frame rate and resolution sufficient for capturing such actions. One recorder should be located as close to the cockpit as practicable and the other as far aft as practicable. These recorders should be equipped with independent auxiliary power supplies that automatically engage and provide 10 minutes of operation whenever aircraft power to the cockpit image recorders and associated cockpit camera systems ceases, either by normal shutdown or by a loss of power to the bus. The circuit breaker for the cockpit image recorder systems, as well as the circuit breakers for the CVRs and the DFDRs, should not be accessible to the flight crew during flight. (Source: A safety recommendation letter dated April 11, 2000, prompted by the lack of valuable cockpit information during the investigations of several aircraft incidents and accidents, including USAir flight 105 on September 8, 1989 [NTSB/AAR-90-04], ValuJet flight 592 on May 11, 1996 [NTSB/AAR-97-06], SilkAir flight 185 on December 19, 1997, Swissair flight 111 on September 2, 1998, and EgyptAir flight 990 on October 31, 1999 [NTSB/AAB-02-01])
A-03-64 (FAA)
Issued December 22, 2003
Added to the Most Wanted List: 2004
Status: Open—Unacceptable Response
Require all turbine-powered nonexperimental, nonrestricted-category aircraft that are manufactured prior to January 1, 2007, that are not equipped with a cockpit voice recorder, and that are operating under 14 Code of Federal Regulations Parts 91, 135, and 121 to be retrofitted with a crash-protected image recording system by January 1, 2007. (Source: A safety recommendation letter dated December 22, 2003, based on several aircraft accidents, including the October 25, 2002, crash of a Raytheon (Beechcraft) King Air A100 near Eveleth, Minnesota. NTSB/AAR03/03.)
November 2007
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