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Safety Recommendation Details

Safety Recommendation A-87-013
Details
Synopsis: ABOUT 2050 ON MARCH 13, 1986, SIMMONS AIRLINES FLIGHT 1746, AN EMBRAER BANDEIRANTE, EMB-110P1, OPERATING AS A REGULARLY SCHEDULED FLIGHT, DEPARTED THE DETROIT METROPOLITAN AIRPORT EN ROUTE TO SAULT STE. MARIE, MICHIGAN, WITH A STOP IN ALPENA, MICHIGAN. THE ENROUTE PORTION OF THE FLIGHT TO ALPENA WAS UNEVENTFUL. HOWEVER, DUE TO THE PREVAILING INSTRUMENT METEOROLOGICAL CONDITIONS, THE CREW WAS UNABLE TO COMPLETE THE INSTRUMENT LANDING SYSTEM (ILS) APPROACH AND LAND AND THEY DECLARED A MISSED APPROACH AT 2142. AT 2153, THE FLIGHT WAS CLEARED FOR A SECOND ILS APPROACH TO ALPENA. AT 2156, THE CREW ACKNOWLEDGED THAT RADAR SERVICES WERE BEING TERMINATED. THIS WAS THE LAST TRANSMISSION FROM THE AIRPLANE. ABOUT 2215, A MOTORIST REPORTED THAT THE AIRPLANE HAD CRASHED. THE AIRPLANE WAS FOUND IN A WOODED AREA ABOUT 300 FEET TO THE LEFT OF THE EXTENDED CENTERLINE, AND 1 1/2 MILES SHORT OF THE THRESHOLD OF RUNWAY 1 AT ALPENA. THE AIRPLANE WAS DESTROYED AND TWO OF THE SEVEN PASSENGERS AND ONE OF THE TWO CREWMEMBERS ON BOARD WERE KILLED.
Recommendation: THE NTSB RECOMMENDS THAT THE FEDERAL AVIATION ADMINISTRATION: REEXAMINE 14 CFR 91.11(A)(1) IN THE LIGHT OF RECENT FINDINGS ON THE EFFECTS OF ALCOHOL CONSUMPTION ON PILOT PERFORMANCE, AND CARRY OUT THE RESEARCH NEEDED TO ESTABLISH THE MINIMUM AMOUNT OF TIME, FOLLOWING ALCOHOL CONSUMPTION, REQUIRED BY PILOTS TO PERFORM THEIR DUTIES WITHOUT IMPAIRMENT.
Original recommendation transmittal letter: PDF
Overall Status: Closed - Unacceptable Action
Mode: Aviation
Location: ALPENA, MI, United States
Is Reiterated: No
Is Hazmat: No
Is NPRM: No
Accident #: DCA86AA021
Accident Reports: Simmons Airlines, Flight 1746, Embraer Bandeirante, EMB-110P1, N1356P
Report #: AAR-87-02
Accident Date: 3/13/1986
Issue Date: 3/17/1987
Date Closed: 3/17/1988
Addressee(s) and Addressee Status: FAA (Closed - Unacceptable Action)
Keyword(s):

Safety Recommendation History
From: NTSB
To: FAA
Date: 3/17/1988
Response: The Safety Board is concerned that the FAA has declined to reevaluate its rule regarding the minimum amount of time following alcohol consumption required by pilots to perform their duties without impairment. The Safety Board believes that the zero alcohol concept should become the measure for impairment and, therefore, that the rules on time between alcohol consumption and duty performance need to be reviewed. Further, we believe that the "hang-over" effect of alcohol on human performance must be considered as an important factor in determining the proper required time between consumption of alcohol and non-impaired operation of an airplane. Based on the strong position taken by the FAA in refusing to reevaluate its rules, this safety recommendation has been classified as "Closed--Unacceptable Action." Enclosed for your information, is a copy of a recent letter sent to Secretary Burnley further outlining the Safety Board's position on this issue.

From: FAA
To: NTSB
Date: 12/3/1987
Response: THE FAA DOES NOT PLAN TO BEGIN ANOTHER EVALUATION OF THE ADEQUACY OF 14 CFR 91.11. THE REQUIREMENTS OF THAT REGULATION PROVIDE THAT NO PERSON MAY ACT OR ATTEMPT TO ACT AS A CREWMEMBER OF A CIVIL AIRCRAFT WHILE HAVING A BLOOD ALCOHOL CONCENTRATION OF .04 PERCENT OR HIGHER. IT ALSO PROVIDES THAT NO PERSON MAY ACT OR ATTEMPT TO ACT AS A CREWMEMBER OF A CIVIL AIRCRAFT "WITHIN 8 HOURS AFTER THE CONSUMPTION OF ANY ALCOHOLIC BEVERAGE" OR WHILE UNDER THE INFLUENCE OF ALCOHOL. THEREFORE, 14 CFR 91.11 PREVENTS CREWMEMBERS FROM ESCAPING FAA ENFORCEMENT ACTION IF THEY ARE SUSPECTED OF ALCOHOL ABUSE OF ANY KIND REGARDLESS OF THE BAC MEASUREMENT.

From: NTSB
To: FAA
Date: 8/3/1987
Response: The Board believes that recent research indicates that "hang-over" effects may be more subtle than an individual could detect while the effect on flying performance could be substantial. It may be possible for a pilot's performance to be impaired without him realizing that he is under the influence of alcohol even though his last drink was taken considerably prior to 8 hours before flight. Therefore, it appears evident that the FAA should carefully examine the more recent findings on alcohol's effects on performance and then evaluate the adequacy of the current regulations. Pending further correspondence, Safety Recommendation A-87-13 has been classified as "Open--Unacceptable Action."

From: FAA
To: NTSB
Date: 6/2/1987
Response: RULES RELATING TO THE CONSUMPTION OF ALCOHOLIC BEVERAGES IN CONNECTION WITH AIRCRAFT OPERATIONS ARE SET FORTH IN 14 CFR 91.11 OF THE FARS. THIS SECTION PROVIDES THAT NO PERSON MAY ACT AS A CREWMEMBER OF A CIVIL AIRCRAFT WITHIN 8 HOURS AFTER THE CONSUMPTION OF ANY ALCOHOLIC BEVERAGE OR WHILE UNDER THE INFLUENCE OF ALCOHOL. ADDITIONALLY, A VALUE OF 40 MILLIGRAMS PERCENT BY WEIGHT OF ALCOHOL IN THE BLOOD, BASED ON EXTENSIVE STUDY RESEARCH, WAS INCORPORATED INTO THE REGULATION, ALONG WITH THE 8-HOUR RULE AND THE WORDS "UNDER THE INFLUENCE" BECAUSE, DURING THE PROMULGATION OF 14 CFR 91.11, SEVERAL COMMENTORS CORRECTLY NOTED THAT IT IS POSSIBLE TO HAVE A BLOOD ALCOHOL LEVEL HIGHER THAN .04 PERCENT MORE THAT 8 HOURS AFTER CONCUMING AN ALCOHOLIC BEVERAGE. I BELIEVE PRESENT MEASURES ARE SUFFICIENT TO IDENTIFY AND DETER CREW MEMBERS FROM PERFORMING DUTIES WHILE UNDER THE INFLUENCE OF ALCOHOL, AND NO FURTHER ACTION IS PLANNED ON THIS RECOMMENDATION.