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Safety Recommendation Details

Safety Recommendation A-15-003
Details
Synopsis: The NTSB has long been concerned about rapid recovery of recorded information to guide investigations, help determine accident causes, and develop recommendations to prevent recurrences. To focus attention on this issue, the NTSB convened its Emerging Flight Data and Locator Technology Forum on October 7, 2014, in Washington, D.C. Forum discussions among government, industry, and investigative experts helped identify the following safety issues: • Need for improved technologies to locate aircraft wreckage and flight recorders following an accident in a remote location or over water • Need for timely recovery of critical flight data following an accident in a remote location or over water This letter presents recommendations to address these safety issues and discusses open recommendations regarding cockpit image recorders and the need to protect flight recorder systems against intentional or inadvertent deactivation.
Recommendation: TO THE FEDERAL AVIATION ADMINISTRATION: Require that all newly manufactured aircraft used in extended overwater operations and operating under Title 14 Code of Federal Regulations (1) Part 121 or (2) Part 135 that are required to have a cockpit voice recorder and a flight data recorder, be equipped with a means to recover, at a minimum, mandatory flight data parameters; the means of recovery should not require underwater retrieval. Data should be captured from a triggering event until the end of the flight and for as long a time period before the triggering event as possible.
Original recommendation transmittal letter: PDF
Overall Status: Open - Acceptable Response
Mode: Aviation
Location: Washington, DC
Is Reiterated: No
Is Hazmat: No
Is NPRM: No
Accident #: DCA14SS009
Accident Reports:
Report #: None
Accident Date: 10/7/2014
Issue Date: 1/22/2015
Date Closed:
Addressee(s) and Addressee Status: FAA (Open - Acceptable Response)
Keyword(s):

Safety Recommendation History
From: NTSB
To: FAA
Date: 12/13/2018
Response: We note that ICAO has completed its update to the Annex 6 SARPs; however, the amended SARPs reference a manual that ICAO had not yet written at the time that the Annex 6 change was published. We further note that the referenced manual (Document 10054), which will provide guidance on recovering flight data without the need for underwater retrieval, is not yet finished. Finally, we note that, after the reference manual has been published, you will consider mandating requirements based on the ICAO SARPs and guidance. Pending your issuing a requirement based on the ICAO SARPs and guidance, Safety Recommendation A-15-3 remains classified OPEN--ACCEPTABLE RESPONSE.

From: FAA
To: NTSB
Date: 9/21/2018
Response: -From Daniel K. Elwell, Acting Administrator: Efforts at ICAO to update Annex 6 Standards and Recommended Practices (SARPs) are complete. However, the amended SARPs reference a manual that ICAO had not yet written at the time of the Annex 6 change publication. Work is still ongoing to publish the referenced manual (Document I 0054), which will provide guidance on the recovery of flight data without the need for underwater retrieval. We anticipate completing this work by December 2019. Once complete, the FAA will assess the feasibility of mandating requirements based on ICAO SARPs and guidance.

From: NTSB
To: FAA
Date: 1/6/2017
Response: We note that, because of a number of concerns summarized in your letter, you are not yet in a position to pursue the recommended rulemaking. We further note that this recommendation is being addressed by work that you are doing with ICAO, and that, in the interest of harmonizing with ICAO standards, you plan to develop associated policy after the related ICAO guidance has been developed. Pending completion of the guidance by ICAO, your adopting similar guidance that addresses this recommendation, and a requirement based on the guidance after it is issued, Safety Recommendation A 15 3 remains classified OPEN—ACCEPTABLE RESPONSE.

From: FAA
To: NTSB
Date: 9/13/2016
Response: -From Michael P. Huerta, Administrator: At this time, the FAA is not in a position to pursue rulemaking on this issue. Informal industry feedback indicates there are too many open issues regarding safety (e.g. unintended deployment of a flight recorder), data security (e.g., streamed data can be intercepted), integrity (e.g., streamed data may not meet mandatory requirements due to connectivity issues resulting in data dropouts, etc.), chain of custody (e.g. deployable flight recorder data downloaded and read by unauthorized entities). and ownership (e.g., who owns the data and how to obtain the data). This issue also ties very closely with work that we are doing with ICAO, and we do not believe it to be effective to produce rulemaking that may not be in conformance with ICAO standards. ICAO has published SARPs in Annex 6 that state aircraft·· ... shall be equipped with a means approved by the State of the Operator, to recover flight recorder data and make it available in a timely manner." A Note to those SARPs says ... Guidance on approving the means to make flight recorder data available in a timely manner is contained in the Manual on Location of Aircraft in Distress and Flight Recorder Data Recovery (Doc I 0054). In the interest of assuring harmonization with ICAO standards. the FAA will not develop policy until the ICAO guidance has been developed. I will keep the Board informed of the FAA's progress on this recommendation and provide an update by May 31, 2017.

From: NTSB
To: FAA
Date: 11/19/2015
Response: We are aware that some misunderstandings have arisen over Safety Recommendation A 15 3; specifically, the belief that this recommendation calls for three recorders. We wish to clarify that there are several possible solutions that would satisfy the NTSB’s recommended action that the FAA require mandatory flight data parameters to be recoverable other than by underwater retrieval. Among these options is a requirement for a single combination recorder and a single deployable recorder. Another option that would satisfy Safety Recommendation A-15-3 is a triggered flight data transmission combined with the existing requirements for recorders. The International Civil Aviation Organization (ICAO) Air Navigation Commission recently proposed revisions to the carriage requirements of flight recorders that are currently being reviewed by States that are signatories to ICAO. Although these actions are not yet complete and you are participating in ICAO’s activities, we believe that the FAA should be more proactive, particularly in the United States, to encourage these efforts, such as by forming a US industry group to consider technologies that would address our recommendations, and by encouraging voluntary implementation of an alternative method of data recovery for those aircraft capable of such technology. Pending your completion of the recommended actions, Safety Recommendations A 15 1, -3, and -4 are classified OPEN—ACCEPTABLE RESPONSE.

From: FAA
To: NTSB
Date: 4/22/2015
Response: -From Michael P. Huerta, Administrator: These recommendations have created a lot of discussions and activities within the avionics community and multiple policy offices within the Federal Aviation Administration (FAA). The International Civil Aviation Organization has tasked the Flight Recorder Working Group with the issue of tracking aircraft in remote locations and over water. The FAA is a member of this working group. Once the working group has reviewed the concerns raised at the Emerging Flight Data and Locator Technology Forum, it will determine the best feasible course of action. We will provide an updated response by June 2016.