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Safety Recommendation Details

Safety Recommendation A-10-085
Details
Synopsis: On January 15, 2009, about 1527 eastern standard time,1 US Airways flight 1549, an Airbus Industrie A320-214, N106US, experienced an almost total loss of thrust in both engines after encountering a flock of birds and was subsequently ditched on the Hudson River about 8.5 miles from LaGuardia Airport (LGA), New York City, New York. The flight was en route to Charlotte Douglas International Airport (CLT), Charlotte, North Carolina, and had departed LGA about 2 minutes before the in-flight event occurred. The 150 passengers, including a lap-held child, and 5 crewmembers evacuated the airplane via the forward and overwing exits. One flight attendant and four passengers received serious injuries, and the airplane was substantially damaged. The scheduled, domestic passenger flight was operating under the provisions of 14 Code of Federal Regulations (CFR) Part 121 on an instrument flight rules flight plan. Visual meteorological conditions prevailed at the time of the accident.
Recommendation: TO THE FEDERAL AVIATION ADMINISTRATION: Revise the life vest performance standards contained in Technical Standard Order-C13f to ensure that they result in a life vest that passengers can quickly and correctly don.
Original recommendation transmittal letter: PDF
Overall Status: Closed - Acceptable Action
Mode: Aviation
Location: Weehawken, NJ, United States
Is Reiterated: No
Is Hazmat: No
Is NPRM: No
Accident #: DCA09MA026
Accident Reports: Loss of Thrust in Both Engines, US Airways Flight 1549 Airbus Industrie A320-214, N106US
Report #: AAR-10-03
Accident Date: 1/15/2009
Issue Date: 5/21/2010
Date Closed: 1/19/2018
Addressee(s) and Addressee Status: FAA (Closed - Acceptable Action)
Keyword(s): Water Survival

Safety Recommendation History
From: NTSB
To: FAA
Date: 1/19/2018
Response: e note that, on February 3, 2017, you published TSO C13g, “Life Preservers,” which is consistent with the updated inflation requirements provided in Society of Automotive Engineers International Aerospace Standard 1354, “Individual Inflatable Life Preserver.” The revised TSO includes improved performance and inspection criteria for life preservers that are donned multiple times a day, as well as contains requirements to prevent the inflation cylinder from backing out and to use a visual indicator to make inflation system inspection easier. The TSO also includes new requirements to make it easier to understand the donning instructions on the life preserver, to operate the retention mechanism, and to open the life preserver packages. Further, the TSO includes testing that simulates the reduced dexterity that a person may experience during an emergency in a cold and wet environment. We believe that the revised TSO satisfies the intent of Safety Recommendations A-07-29 and A-10-85, which are classified CLOSED--ACCEPTABLE ACTION.

From: FAA
To: NTSB
Date: 6/19/2017
Response: -From Michael P. Huerta, Administrator: On February 3. 2017, the Federal Aviation Administration (FAA) published a revision to Technical Standard Order (TSO)-C 13L Life Preservers. which includes the new requirements found in SAE International Aerospace Standard (AS) 1354. Individual Inflatable Life Preserver. TSO-C I 3g includes numerous enhancements to the previous donning requirements found in TSO-CI 3f. Enhancements include new requirements for comprehensibility of the donning instructions on the life preserver, operation of the retention mechanism. and ease or package opening. Add iti onall y, TSO-C13g includes testing that simulates the reduced dex teri ty of chilled hands that may occur during an emergency in a cold and wet environment. The guidance can be found at the following Web site: http://rgl.faa.gov/Regulatoryand_Guidance_Library/rgTSO.nsf/0/99/7ab70f'2d9a99886256da400653444/$FTLE/C 13f.pdf. In our letter dated May 23, 20 16, we noted we were revising Advisory Circular 121-24. Passenger Safety lnfom1at ion Briefing and Briefing Cards. which is expected to be published by December 2017. In its July 29, 20 16, response, the Board included completion of this AC as part of a condition for closure of this recommendation. We note this AC is a related but separate activity that is beyond the scope of this recommendation as originally written. Based on completion of the TSO, I believe that the FAA has effectively addressed this safety recommendation and consider our actions complete.

From: NTSB
To: FAA
Date: 7/29/2016
Response: We issued this recommendation based on our finding from the US Airways flight 1549 accident investigation that only 4 of 33 passengers who retrieved a life vest (all of which were TSO 13f-compliant) were able to correctly don them. We note that, to address this recommendation, you have been working with the SAE International Aerospace Council S9 Cabin Safety Provisions (SAE S9) Committee to address donning requirements in Aerospace Standard (AS) 1354, “Individual Inflatable Life Preservers,” and that you plan to revise TSO C13f after AS 1354 is revised. We further note that, to support the SAE S9 Committee, your Civil Aerospace Medical Institute (CAMI) conducted a study of donning test parameters and examined the relationship between pre-flight briefings and successful life-preserver donning. In December 2014, you published a report titled “Inflatable Emergency Equipment 1: Evaluation of Individual Inflatable Aviation Life Preserver Donning Test.” describing the results of CAMI’s research. Based on that research, the SAE S9 Committee is currently making further revisions to AS 1354. Finally, we note that, to address the study findings regarding the relationship between pre-flight briefings and successful life-preserver donning, you plan to revise advisory circular (AC) 121-24, “Passenger Safety Information Briefing and Briefing Card.” In response to your previous letter of October 8, 2014, we replied that, although we were encouraged that you planned to revise the TSO and were making progress, the length of time it was taking to complete the recommended actions was excessive. We generally expect the actions we recommend to be completed within 3 to 5 years after we issue a recommendation. Safety Recommendation A-10-85 is now over 6 years old, and we do not believe the revised TSO will be issued this year. Consequently, pending issuance of the revisions to AS 1354, their incorporation into TSO C13f, and issuance of revisions to AC 121-24, Safety Recommendation A-10-85 remains classified OPEN—UNACCEPTABLE RESPONSE.

From: FAA
To: NTSB
Date: 5/23/2016
Response: -From Michael P. Huerta, Administrator: The Federal Aviation Administration (FAA) is planning to revise Technical Standard Order (TSO)-C13f to address the donning issue. As previously noted, the FAA is also working with the SAE International Aerospace Council S9 Cabin Safety Provisions (SAE S9) Committee, to address donning requirements in Aerospace Standard (AS) 1354. Individual Inflatable Life Preservers. To support this activity, the FAA Civil Aerospace Medical Institute (CAMI) conducted a study of donning test parameters and examined the relationship between the pre-flight briefing and successful life preserver donning. The CAMI report, In the table Emergency Equipment 1: Evaluation oflndividuallnl1atable Aviation Life Preserver Donnings Tests was published in December 2014. This report is available at the following Web site: https://www.faa.gov/dataresearch/research/medhumanfacs/oamtechreports/2010s/media/201414.pdf. Based on the recommendations contained in the CAMI report, the SAE S9 committee enhanced the standard. Enhancements include an added comprehensibility requirement for the life preserver markings, changes to how the life preserver is packaged, and requirements for package testing. We anticipate the revision to AS 1354 to be completed in 2016. at which time we will revise TSO-C 13f to include the new requirements. Additionally, regarding pre-flight safety briefings and fostering passenger awareness, the FAA Flight Standards Service is working on a revision of Advisory Circular 121-24, Passenger Safety Information Briefing and Briefing Card. I will keep the Board informed on the progress of this safety recommendation and provide an update by March 31, 2017.

From: NTSB
To: FAA
Date: 12/12/2014
Response: We note that you continue to work with the SAE International Aerospace Council, S9 Cabin Safety Provisions Committee, to include standards for PFDs in Aerospace Standard (AS) 1354 that will ensure proper inflation and quick and correct donning by passengers. Although we are disappointed to learn that the issuance of AS 1354 has been delayed, we continue to believe that your efforts thus far are positive steps toward implementing both of these safety recommendations. You previously indicated that, once AS 1354 were finalized, you would revise TSO C13f as recommended in Safety Recommendation A-07-29 and would consider revising it as recommended in Safety Recommendation A-10-85. Although we are encouraged that you are making progress, the length of time it is taking to complete the recommended actions is excessively long. We encourage your timely issuance of the revised TSO as recommended; in the meantime, Safety Recommendation A 07-29 and A-10-85 are classified OPEN—UNACCEPTABLE RESPONSE.

From: FAA
To: NTSB
Date: 10/8/2014
Response: -From Michael P. Huerta, Administrator: The Federal Aviation Administration (FAA) continues to work with the SAE International Aerospace Council, S9 Cabin Safety Provisions (SAE S9) Committee, to include requirements to address life preserver donning and the inflation issue in Aerospace Standard (AS) 1354, Individual Inflatable Life Preservers. In April 2014, the FAA met with the SAE S9 Committee and Civil Aerospace Medical Institute (CAMI) researchers to discuss preliminary findings from the CAMI study of donning test parameters and the relationship between the pre-flight briefing and successful life preserver donning. In addition, the FAA is working to improve the performance and inspection criteria for life preservers that are donned multiple times a day, such as in an air-tour environment. For example, the current draft of AS 1354 contains proposed requirements that would require the life preserver to incorporate a means to prevent the inflation cylinder from backing out, and a visual indicator that allows for easy inspection of the inflation system. Due to the SAE S9 Committee's current consideration of these findings and CAMI's anticipated report publication date of September 2014, SAE S9 is delaying the issuance of AS 1354 until December 2015. Once the SAE AS 1354 standard is finalized, Technical Standard Order-C 13f will be revised to include the new requirements. I will keep the Board informed on the progress of these safety recommendations and provide an update by February 2016.

From: NTSB
To: FAA
Date: 3/21/2014
Response: We continue to disagree with your position that TSO 13f, “Life Preservers,” is stringent enough to ensure that only those life preserver designs that can be consistently and correctly donned in a timely manner are able to meet it. We believe that our finding from the US Airways flight 1549 accident, in which only 4 of 33 passengers who retrieved the life vests (all of which were TSO 13f compliant) were able to correctly don them, shows that current standards are not effective. For some reason, TSO 13f–compliant life vests could not be correctly donned by the overwhelming majority of passengers in an actual emergency when the vests were needed. We do not understand the comment in your current letter that the donning test in TSO 13f provides a baseline level of equipment performance, and that this baseline may differ from actual life preserver usage in a particular accident where conditions vary from the TSO test conditions. You stated that the donning test procedure in TSO 13f is conducted to determine life preserver usability in a representative environment for a planned water landing; it is not intended to represent a forced landing on water. We are not aware of any significant differences related to donning a life preserver correctly that would exist between a planned water landing and a forced water landing. Although we understand that there are differences between a standards test that establishes a baseline, and actual accident conditions, we also believe that devices that comply with the standards but are not used correctly by over 88% of passengers in actual conditions demonstrate evidence of an ineffective standard. Showing compliance with TSO 13f donning standards places a burden on life preserver manufacturers with little to no associated safety benefit. We note that you continue to work with the SAE S9 Cabin Safety Provisions Committee, which is currently developing SAE Aerospace Standard (AS) 1354, “Individual Inflatable Life Preservers,” to include in AS 1354 enhancements to the donning test for life preservers. Before publication of AS 1354, the S9 Committee determined that additional testing was required to assist in the development of new life preserver test requirements. In support of this need, the Civil Aerospace Medical Institute (CAMI) is studying life preserver donning test parameters. Your letter stated that, as part of this research, CAMI plans to evaluate the relationship between the pre-flight briefing and the effectiveness of donning the life preserver. We caution that any action in response to this recommendation that depends on a pre flight safety briefing will need to address not only (1) the contents of the briefing, but also (2) the considerable body of cabin safety research documenting that passengers do not typically pay attention to the briefings and (3) the poor retention by passengers of the needed information provided in these briefings. In addition to research results available in the scientific literature about this problem, on July 14, 2000, we issued Safety Recommendation A-00-86 in our safety study “Emergency Evacuation of Commercial Airplanes,” SS-00/01, which found that the current practice regarding pre-flight safety briefings did not adequately convey safety information to passengers. A-00-86 Conduct research and explore creative and effective methods that use state-of-the-art technology to convey safety information to passengers. The presented information should include a demonstration of all emergency evacuation procedures, such as how to open the emergency exits and exit the aircraft, including how to use the slides. Earlier correspondence concerning Safety Recommendation A-00-86 stated that the FAA did not believe additional research was needed to address this issue, and that current state of-the-art technology was effective and already being used in the aviation industry. In response, on May 5, 2004, we classified Safety Recommendation A 00 86 “Closed?Unacceptable Action.” We caution that, in order to satisfy Safety Recommendation A 10 85, your reply will need to include documentation that the briefings will be effective in normal airline operations. You have previously indicated that, when you issue AS 1354, you will consider revising TSO 13f. In the meantime, pending revisions to that TSO that result in a design for a life vest that passengers can don quickly and correctly, Safety Recommendation A-10-85 remains classified OPEN—ACCEPTABLE RESPONSE.

From: FAA
To: NTSB
Date: 12/20/2013
Response: -From Michael P. Huerta, Administrator: The Board stated in its October 1, 2012, letter that any performance standard for life preservers must be stringent enough to ensure that only those designs that can be consistently and correctly donned in a timely manner are able to meet it. Although the Federal Aviation Administration (FAA) concurs with this assessment, we maintain that the current test requirements in Technical Standard Order (TSO)-C 13f are effective in this regard. In our letter dated August 2, 2012, we indicated that we continued our work with the SAE S9 Cabin Safety Provisions Committee to update and improve the life preserver standard. We noted that the SAE S9 Committee expected to publish Aerospace Standard (AS) 1354, Individual Inflatable Life Preserves, by the end of2012. Although AS 1354 has not yet been published, the Committee continues its work on this issue. Before publication of AS 1354, the Committee determined that additional testing was required to assist in the development of potential new test requirements that may enhance life preserver donning performance. To support this process, the FAA Civil Aerospace Medical Institute (CAMI) is studying donning test parameters that could enhance the assessment of donning perf01mance. As part of this research activity, CAMI plans to evaluate the relationship between the pre-flight briefing and the effectiveness of donning the life preserver. We intend to complete the research and publish the results by March 2014. Regarding the differences between the TSO-C 13f donning requirements and the donning performance identified in the US Airways flight 1549 accident findings, we note that the donning test in TSO-C 13f provides a baseline level of equipment performance. This baseline may differ from actual life preserver usage in a particular accident where conditions vary from the TSO test conditions. More specifically, the donning test procedure in TSO-C13f is conducted to determine life preserver usability in a representative environment for a planned water landing; it is not intended to represent a forced landing on water. Establishing a requirement that addresses modeling passenger decision-making in any specific accident is beyond the scope of the donning test. We will keep the Board informed of the FAA's progress and provide an update by October 2014.

From: FAA
To: NTSB
Date: 12/13/2013
Response: The Board stated in its October I, 2012, letter that any performance standard for life preservers must be stringent enough to ensure that only those designs that can be consistently and correctly donned in a timely manner are able to meet it. Although the Federal Aviation Administration (FAA) concurs with this assessment, we maintain that the current test requirements in Technical Standard Order (TSO)-C 13f are effective in this regard. In our letter dated August 2, 2012, we indicated that we continued our work with the SAE S9 Cabin Safety Provisions Committee to update and improve the life preserver standard. We noted that the SAE S9 Committee expected to publish Aerospace Standard (AS) 1354, Individual Inflatable Life Preserves, by the end of2012. Although AS 1354 has not yet been published, the Committee continues its work on this issue. Before publication of AS 1354, the Committee determined that additional testing was required to assist in the development of potential new test requirements that may enhance life preserver donning performance. To support this process, the FAA Civil Aerospace Medical Institute (CAMI) is studying donning test parameters that could enhance the assessment of donning perf01mance. As part of this research activity, CAMI plans to evaluate the relationship between the pre-flight briefing and the effectiveness of donning the life preserver. We intend to complete the research and publish the results by March 2014. Regarding the differences between the TSO-C 13f donning requirements and the donning performance identified in the US Airways flight 1549 accident findings, we note that the donning test in TSO-C 13f provides a baseline level of equipment performance. This baseline may differ from actual life preserver usage in a particular accident where conditions vary from the TSO test conditions. More specifically, the donning test procedure in TSO-C13f is conducted to determine life preserver usability in a representative environment for a planned water landing; it is not intended to represent a forced landing on water. Establishing a requirement that addresses modeling passenger decision-making in any specific accident is beyond the scope of the donning test. We will keep the Board informed of the FAA's progress and provide an update by October 2014.

From: NTSB
To: FAA
Date: 10/1/2012
Response: The NTSB agrees that a specific design requirement is best addressed by the designers, so long as their designs pass the donning performance tests; however, we disagree with the FAA’s position that there is insufficient evidence to suggest that the waist strap design problems alone prevented the timely donning of life vests in the US Airways flight 1549 accident. Although TSO C13f requires successful, time-limited donning by a representative population sample unfamiliar with the equipment, with specific requirements for age and gender, the findings of our accident investigation show that the TSO is not effective. Regardless of the reason, only 4 out of 33 passengers who retrieved the life vests were able to correctly don them. This is in contrast to the performance standard specified in C13f that “It must be demonstrated… that at least 75% of the total number of test subjects and at least 60% of the test subjects in each age group… can don the life preserver within 25 seconds unassisted, starting with the life preserver in its storage package.” For some reason, TSO C13f–compliant life vests could not be correctly donned by the overwhelming majority of passengers in an actual emergency, when they were needed. We acknowledge that it is not appropriate for a performance standard to prohibit a particular design (such as a life vest with a waist strap), but for the performance standard to be effective, it must be able to distinguish between designs that can be donned quickly and correctly and those that cannot. We believe that the findings of the US Airways flight 1549 accident investigation, as well as the 1983 study of life vest donning conducted at the FAA’s Civil Aerospace Medical Institute both confirm that incorrect use of the waist strap is a common cause of incorrect donning. As a result, we believe that any performance standard must be sufficiently stringent to ensure that only those designs that can be consistently and corrected donned in a timely manner are able to meet it. We note that the FAA continues to work with the Society of Automotive Engineers (SAE) S9 Cabin Safety Provisions Committee, which is currently developing SAE Aerospace Standard (AS) 1354, “Individual Inflatable Life Preservers,” to include in AS 1354 enhancements to the donning test for life preservers. The FAA has previously indicated that when AS 1354 is issued, the agency will consider revising TSO C13. Accordingly, pending revisions to the TSO that result in a design for a life vest that passengers can don quickly and correctly, Safety Recommendation A-10-85 remains classified OPEN—ACCEPTABLE RESPONSE.

From: FAA
To: NTSB
Date: 8/2/2012
Response: -From Michael P. Huerta, Acting Administrator: According to its letter dated December 16, 2011, the Board believes that the life preserver standard should focus on a representative test subject sample being able to easily and correctly don the life preserver, rather than specific design issues that are best addressed by designers and manufacturers. The Federal Aviation Administration (FAA) believes the current FAA Technical Standard Order (TSO)-CI3f, Life Preservers, has appropriate donning performance standards. The current standard does require successful, time-limited donning by a representative population sample unfamiliar with the equipment, with specific requirements for age and gender. The Board also indicated that any acceptable revision must include a provision for either eliminating the waist strap or greatly simplifying the procedure for securing it. However, we maintain that a specific design requirement is best addressed by the designers, assuming their design passes the donning performance tests specified by TSO-C 13f. Furthermore, the FAA believes there is insufficient evidence to suggest the waist strap design problems alone are the overriding issue in US Airways Flight 1549. Nevertheless, we continue to work with the SAE S9 Cabin Safety Provisions Committee to develop SAE Aerospace Standard (AS) 1354, Individual Inflatable Life Preservers, to include other life preserver safety enhancing standards. In April 2012, we met again with the SAE S9 Committee and discussed potential requirements that may enhance the donning test for life preservers. However, we have not reached a decision on this issue and additional discussions are necessary. The SAE S9 Committee is working towards publishing AS 1354 by the end of2012. I will keep the Board informed of the FAA's progress on this safety recommendation and provide an update by July 2013.

From: NTSB
To: FAA
Date: 12/16/2011
Response: Since we received the FAA’s previous letter, staffs from the FAA and the NTSB have discussed the specific difficulties encountered by passengers on US Airways flight 1549 when they attempted to don life vests. As described in our final report on this accident and in the letter that transmitted this recommendation to the FAA, of the estimated 33 passengers in the US Air 1549 accident who had reported eventually obtaining a life vest, only 4 confirmed that they had been able to complete the donning process by securing the waist strap without assistance. Most passengers who obtained life vests either had difficulty attempting to secure the strap or chose not to secure it at all, for a variety of reasons. From the information available in the post-accident interviews, it was not possible to ascertain why some passengers with a life vest did not connect the waist strap. We point out that this is not a new finding. Research on the donning of life vests conducted by the FAA’s Civil Aerospace Medical Institute (CAMI) almost 30 years ago, in 1983, indicated that the life vests’ waist straps were the major obstacle to correct donning and that users failed to tighten the straps, did not fasten them correctly, or did not fasten them at all. Although the FAA agrees that passengers must be able to don their life preservers quickly and correctly, it has not explained why the current test requirements in TSO-C13f are inadequate for meeting that objective. The FAA indicates that it plans to issue a revision to the TSO, which will use a new SAE International Aerospace Standard, SAE AS 1354, as its performance requirement. The FAA is currently meeting and working with the responsible SAE committee to discuss potential new requirements related to donning. The NTSB is concerned that the FAA’s effort to identify a design problem with the waist strap indicates that the FAA believes a design standard is appropriate for life vest donning requirements. We disagree; rather, we believe there should be a performance requirement, based on a representative sample of the population being able to don a life vest quickly and correctly. We note that the CAMI study identified a type of life vest that was easily and quickly donned and that did not rely on a waist strap. We believe that the FAA standards should focus on the ease of correctly donning a life vest, rather than reasons for why one is not quickly donned, which is a design issue best addressed by designers and manufacturers of life vests. The NTSB reiterates the point that we made in our March 17, 2011, letter regarding this recommendation: that the FAA’s plan to ask the SAE committee responsible for AS 1354 to revise the standards is constructive and responsive. However, in order to satisfy this recommendation, any revisions must focus on either eliminating the need for the waist strap or greatly simplifying the procedure for securing it. Accordingly, pending revisions to the TSO that result in a design for a life vest that passengers can don quickly and correctly without the challenges associated with the waist strap, Safety Recommendation A-10-85 remains classified OPEN—ACCEPTABLE RESPONSE.

From: FAA
To: NTSB
Date: 9/7/2011
Response: CC# 201100344: - From J. Randolph Babbitt, Administrator: Our previous letter to the Board, dated September 23, 2010, stated that the Federal Aviation Administration would contact the Board to obtain better clarity as to what specific difficulties were encountered when the passengers attempted to don life vests. We have contacted the Board and received additional information regarding the issues encountered by passengers. The additional information indicated that passengers who obtained a life vest were able to place the life vest properly over their head and chest. However, many of the passengers did not connect the waist strap and therefore, did not fully don the device. From the information available in the post accident interviews, it is still difficult to ascertain why all passengers with a life vest did not connect the waist straps. Of the 29 passengers that had partially donned a life vest, two individuals specifically mentioned that they struggled with the buckle on the strap. The remaining passengers were not specific as to why they did not attach the waist strap or if they even attempted to attach it at all. We agree that passengers must be able to don their life preservers quickly and correctly, but it is not clear that the current test requirements in Technical Standard Order (TSO)-CI3f are inadequate for meeting that objective. However, we are currently planning to publish a revision to TSO-C13, which will rely on a new Aerospace Standard (SAE AS 1354) as its performance requirement. In April 2011, we met with the SAE committee responsible for AS 1354 to discuss potential requirements that could enhance the donning characteristics of life vests for the next revision to TSO-C13. However, we have not reached a decision on this issue and additional discussions are necessary. In summary, we agree that it is desirable for life preserver donning to occur as rapidly as possible. We will provide the Board with an update on possible changes to TSO-C13 donning requirements, and the expected impact of those changes on passenger safety. I will keep the Board informed of our progress on this safety recommendation and provide an update by July 31, 2012.

From: NTSB
To: FAA
Date: 3/17/2011
Response: In the letter that transmitted this recommendation to the FAA, we stated that, of the estimated 33 passengers in the US Air 1549 accident who had reported eventually obtaining a life vest, only 4 confirmed that they had been able to complete the donning process by securing the waist strap themselves. Most passengers who had life vests either struggled with the strap or chose not to secure it at all, for a variety of reasons (emphasis added). Research on the donning of life vests conducted by the FAA's Civil Aerospace Medical Institute (CAMI) in 1983 indicated that the life vests' waist straps were the major obstacle to correct donning and that users failed to tighten the straps, did not fasten them correctly, or did not fasten them at all. In its current letter, the FAA indicated that TSO-C13f contains a performance requirement for life vests to be donned within 25 seconds for 75 percent of the participants in a test, with the testing performed with participants from diverse gender and age groups who have never previously been involved in life preserver testing. The FAA believes that life preservers that meet the requirements in TSO-C13f have been designed to be donned quickly and correctly. The FAA plans to publish a revision to TSO-C13 that will rely on a new revision to SAE Aerospace Standard (AS) 1354 as its performance requirement. Currently, the FAA is discussing with the SAE committee responsible for AS 1354 possible improvements to life preserver donning requirements. The FAA's letter also acknowledged the NTSB's finding that, in the US Air 1549 accident, of the approximately 33 life vests that had been retrieved, only 4 had been successfully donned. The FAA indicated that it was unclear how many passengers had attempted to don a life vest after retrieval but had been unsuccessful, and the FAA requested a meeting to discuss the issues involved. This meeting is currently being arranged between FAA and NTSB technical staff. The NTSB emphasizes that problems with securing the waist strap on TSO C13d-eompliant life vests appear to be a major impediment to passengers properly and promptly donning life vests, as was the case in the US Air 1549 accident. The NTSB further believes that, although the revisions in TSO C13f constitute significant improvements, they do not adequately address the issue of securing the waist strap. The FAA's plan to ask the SAE committee responsible for AS 1354 to revise the standards is constructive and responsive, but in order to satisfy this recommendation, any revisions must include a focus on eliminating the need for the waist strap or greatly simplifying the procedure for securing it. Accordingly, pending revisions to the TSO that result in a design for a life vest that passengers can don quickly and correctly without challenges associated with the waist strap, Safety Recommendation A-10-85 is classified OPEN – ACCEPTABLE RESPONSE.

From: FAA
To: NTSB
Date: 9/23/2010
Response: CC# 201000368: - From J. Randolph Babbitt, Administrator: TSO-C13fcontains a performance requirement for life vests to be donned within 25 seconds for 75 percent of the participants in a test. It requires testing to be performed with participants from diverse gender and age groups who have never previously been involved in life preserver testing. We believe this requirement provides a safety improvement over the previous TSO-Cl3d requirement for a single life preserver to be donned within 15 seconds by a single adult, because the previous test failed to account for variability in human performance. The Board's report indicated that only 4 passengers successfully donned life vests even though approximately 33 life vests were retrieved from the aircraft. From the information provided, it is unclear how many passengers attempted to don a life vest after retrieval and were unsuccessful. We would like to discuss this situation with the Board to gain additional clarification about difficulties these passengers encountered when attempting to don their life vests. We agree that passengers must be able to don their life preserver quickly and correctly, but it is not clear that the current test requirement in TSO-C13f is inadequate for meeting that objective. We are currently planning to publish a revision to TSO-C13 which will rely on a new Aerospace Standard (SAE AS 1354) as its performance requirement. We will contact the SAE committee responsible for AS 1354 and discuss possible improvements to life preserver donning requirements relative to the overall performance requirements for TSO-C13 life preservers. In summary, we agree that it is desirable for life preserver donning to occur as rapidly as possible. We will provide the Board with an update on possible changes to TSO-C13 donning requirements, and the expected impact of those changes on passenger safety.