sea-plane, thoughts and comments, common sense replies

[bushwhacker]

Event 1
On 29 November 2009, a Seair Seaplanes Ltd. de Havilland DHC-2 (Beaver) was departing Lyall Harbour, Saturna Island, en route to the Vancouver International Airport, British Columbia. After an unsuccessful attempt at taking off downwind, the pilot took off into the wind towards the island. The aircraft became airborne, but remained below the surrounding terrain. The aircraft turned left, then descended and collided with the water. The pilot and one passenger survived with serious injuries. The other six occupants drowned inside the aircraft.
Safety Issues
Over the last 20 years, some 70% of fatalities in aircraft that crashed and sank in water were from drowning. Many TSB investigations found that the occupants were conscious and able to move around the cabin before they drowned. In fact, 50% of people who survive a crash cannot exit the aircraft and drown.
In this accident, 2 occupants were able to escape from the aircraft, but neither managed to retrieve a life vest. The investigation has shown that those inside a sinking aircraft either do not have enough time to locate and don a life vest or overlook doing so. Of those who do not survive following escape, 86% drown.
TSB Recommendations
A11-05 - The Department of Transport require that all new and existing commercial seaplanes be fitted with regular and emergency exits that allow rapid egress following a survivable collision with water.
A11-06 - The Department of Transport require that occupants of commercial seaplanes wear a device that provides personal flotation following emergency egress.
Transport Canada Response to Recommendations A11-05 and A11-06
Transport Canada (TC) has over the years taken steps to address floatplane safety through safety promotion and awareness campaigns, as well as regulatory actions. TC will run an updated floatplane safety campaign during the summer of 2011.
TC issued Civil Aviation Safety Alert (CASA) on June 6, 2011, with its focus on commercial and private float plane operators and pilots, recommending the following best practices in relation to floatplane safety:
Upper body restraints to be used by front seat occupants;
Briefing passengers on the proper usage of floatation devices during emergency egress;
Underwater emergency egress training for flight crew; and
Aircraft safety design improvements facilitating egress.
In July 2011, TC will hold a focus group with selected members of industry to determine the most effective means of addressing the recommendations related to rapid egress and the mandatory use of personal floatation devices. The conclusion of the focus group will be presented to the Canadian Aviation Regulation Advisory Council (CARAC) by the spring of 2012 as the basis for amendments to the rules and any proposed rule changes will be consulted expeditiously. TC will also expedite the implementation of proposed regulatory amendments which have already been consulted, which will provide for increased flexibility in the possible types of Personal Flotation Devices.
Purpose
The primary purpose of this meeting is to review TSB Accident Report A09PO397 Recommendations A11-05 and A11-06, assess the issues and to propose appropriate actions, either regulatory or non regulatory for consideration by Transport Canada management. The Focus Group will also review current best practices for floatplanes, to determine the actions necessary to ensure Canadian operations are conducted in accordance with current international safety standards.
SCOPE
The members will:

Review present industry standards and best practices in respect to floatplane safety.
Review the TSB Accident Report A09PO397 Recommendations A11-05 and A11-06 and supporting documentation.
Through risk analysis, determine what action is appropriate for Transport Canada; e.g., to develop or modify regulations, standards, and guidance material with regard to the TSB Recommendations; and,
Review and consider other regulatory authorities in an effort to adopt and harmonize regulations and best practices with those authorities, where appropriate.
Document recommendations with adequate justification to be submitted to the Director, Standards.
Review the TSB Accident Report A09PO397 and other similar accident findings as to Cause and Contributing Factors as an initial step in conducting a comprehensive safety review of Canadian floatplane safety.
Deliverables
The group will develop a set of recommendations, in the form of a report with supporting rationale, with respect to:
Addressing the TSB Recommendations A11-05 and A11-06 to be completed by September 9th, 2011.
Provide an overview and suggested actions, as appropriate, for identified areas of safety concerns for Canadian floatplane operations.
APPROACH

The WG deliverables, however, should be compatible with the Government of Canada’s policy on regulations as described in the Cabinet Directive on Streamlining Regulations. The CDSR identifies the following key principles:
Protect and advance the public interest in health, safety and security, the quality of the environment, and the social and economic well-being of Canadians, as expressed by Parliament in legislation;
Promote a fair and competitive market economy that encourages entrepreneurship, investment, and innovation;
Make decisions based on evidence and the best available knowledge and science in Canada and worldwide, while recognizing that the application of precaution may be necessary when there is an absence of full scientific certainty and a risk of serious or irreversible harm;
Create accessible, understandable, and responsive regulation through inclusiveness, transparency, accountability, and public scrutiny;
Advance the efficiency and effectiveness of regulation by ascertaining that the benefits of regulation justify the costs, by focusing human and financial resources where they can do the most good, and by demonstrating tangible results for Canadians; and
Require timeliness, policy coherence, and minimal duplication throughout the regulatory process by consulting, coordinating, and cooperating across the federal government, with other governments in Canada and abroad, and with businesses and Canadians.

The deliverables should also be compatible with the Transport Canada Civil Aviation policy of making decisions based on a risk-based approach. Accordingly, the Focus Group should use a risk based approach while conducting its business. Where a risk assessment has been completed, whether by the International Civil Aviation Organization, another authority or stakeholder entity, it should be validated for acceptance by the Focus Group.
MEMBERSHIP
Membership will consist of Transport Canada Inspectors, and invited industry representatives, including operators involved with floatplane operations, Floatplane Associations and Aircraft manufactures.

Operators and interested parties may select their own representatives from their organizations. Members should be individuals with specialized technical knowledge in the subject matter. Members may be supported by technical advisors if deemed necessary.

Members and advisers may be requested to provide supporting data to justify recommendations and should have data available during meetings.

The participation and involvement of aviation industry stakeholders, including aircraft manufacturers and air operators, will contribute to the success of this initiative.

Group Leader:
The Group Leader will be Debbie Warren, Regional Manager, System Safety, Transport Canada, Vancouver, 604-666-9520 (email) deborah.warren@tc.gc.ca


Group Facilitator
A Risk Management facilitator will be assigned to the process.
REPORTING
The Group will report to the Director of Standards, Civil Aviation

Members are responsible to report all decisions reached, unresolved issues, and planned action back to their respective organizations.

On issues where there is no consensus, all views will be properly recorded to allow the Group Leader to make recommendations to the Director, Standards on those issues. Final Reports will include specific recommendations, the rationale upon which those recommendations are based and, where required, details of any dissenting points of view when consensus is not reached.
CARAC CONSULTATION
The Group will make recommendations to the Director of Standards concerning the disposition of TSB Recommendations A11-05 and A11-06. Any recommendation leading to a rule change will be consulted through the appropriate CARAC process.
TIMING
Work will commence once the Terms of Reference are approved and the membership defined. A single meeting five days will be held in Vancouver during the week of August 22nd to complete the analysis and recommendations. Resulting recommendations will be submitted to CARAC for approval.
BUDGET
Costs incurred by the organizations outside of Transport Canada Civil Aviation are expected to be borne by those organizations.

Costs incurred by TCCA representatives are expected to be borne by their respective offices.



ADMINISTRATIVE
Transport Canada Civil Aviation Standards Branch will be responsible for providing meeting facilities and secretarial support.


Approved by:


Original signed by Jacqueline Booth July 20th, 2011
________________________________________________ __________
Jacqueline Booth Date
A/Director, Standards
Civil Aviation
Attachment: Excerpt from TSB Report A090PO3972
3.0 Conclusions

3.1 Findings as to Causes and Contributing Factors
The combined effects of the atmospheric conditions and bank angle increased the load factor, causing an aerodynamic stall.
Due to the absence of a functioning stall warning system, in addition to the benign stalling characteristics of the Beaver, the pilot was not warned of the impending stall.
Because the aircraft was loaded in a manner that exceeded the aft CG limit, full stall recovery was compromised.
The altitude from which recovery was attempted was insufficient to arrest descent, causing the aircraft to strike the water.
Impact damage jammed 2 of the 4 doors, restricting egress from the sinking aircraft.
The pilot's seat failed and he was unrestrained, contributing to the seriousness of his injuries and limiting his ability to assist passengers.
3.2 Findings as to Risk
There is a risk that pilots will inadvertently stall aircraft if the stall warning system is unserviceable or if the audio warnings have been modified to reduce noise levels.
Pilots who do not undergo underwater egress training are at greater risk of not escaping submerged aircraft.
The lack of alternate emergency exits, such as jettisonable windows, increases the risk that passengers and pilots will be unable to escape a submerged aircraft due to structural damage to primary exits following an impact with the water.
If passengers are not provided with explicit safety briefings on how to egress the aircraft when submerged, there is increased risk that they will be unable to escape following an impact with the water.
Passengers and pilots not wearing some type of flotation device prior to an impact with the water are at increased risk of drowning once they have escaped the aircraft.

[System Message]

Page 142 The Immortal Beaver states. "Converting a military machine involves, among other changes, removing its ejection doors, doors whose hinge pins can be pulled for quick exits."
Why would they remove a safety feature like this and then make it even harder for a fat man to get out by wearing a life preserver. This idea can only anger the passengers and will cause arguments between a pilot who can not break regulations he does not agree with, and passengers that consider it hazardous to wear it in the aircraft.

[North Shore]

I think that the removal of the quick release doors was/is a mistake.

I'm not sure that the majority of passengers are sufficiently well-informed or knowledgeable enough to make judgements about the safety (or not) of wearing lifejackets of some sort in an aeroplane. That's why there's a regulator to decide for them. If that's the rule, then any argument should be decided with the following statement "Them's the rules. Wear a life jacket or we don't go."

[System Message]

Passengers on a float plane are more knowledgable as an individual than the regulator that may have just signed the bill to get it off their desk. Your unairconditioned CL215 may be very hot over a fire but that same regulator can make you wear an arctic water survival suit because they heard a swimmer can be dead in four minutes.

[North Shore]

Passengers on a float plane are more knowledgable as an individual than the regulator

You think? Judging by the asinine questions asked of me by passengers over the course of my career, I really wonder. By extension, should we then have airworthiness standards, or licences for pilots? After all, the pax are better qualified to assess their safety than some bureaucrat at his desk trying to get rid of paperwork..


If there was a rash of drowning/hypothermia incidents linked to CL215 accidents, and enough evidence was amassed to come to the conclusion that arctic survival suits would be helpful, then, yes, I'd wear one. That's not the case though. You are making it seem like 'the regulator' just woke up one morning, and with a stroke of a pen decided that pax should have to wear lifejackets because he felt like it that day. A lot of thought and discussion has gone into this.

ps. We've got air conditioning - and it's verra niiice!

[System Message]

Good for the airconditioning. I always thought that was a nasty place to be in the heat and smoke. Some descretion needs to be left to the individual, and that individual needs to be prudent of the conditions. The rubber suit is prudent over cold water but not for Canadian summers. These regulations often ignore the individual situation. Foatation devices need to be regulated to be in reach of everyone but removing the descretion of that individual will cause problems such as the pilot who does not have time for that shit and just insults the passenger with 'Them's the rules'. Personally I ask passengers not to wear nylon on my flights yet I don't want an inspector to grab my underwear to check the label.

[Cranium]

They need to come up with something a bit more specific:
The problem with a regular life jacket is it may hold you at the top of the cabin (or whatever happens to be the top at the time), preventing you from being able to go down to reach the door.

The inflatable vests with the cartridge work - I've seen pilots wear theirs permanently. They're light and small - you just have to tell the passenger not to pull the cord until they're out of the airplane.

There are advantages - the problem is they're not cheap.

[robertsailor1]

The inflatable vests are cheap if you compare them with anything else aviation

[Rowdy]

The inflatable life vests are a great thing and I believe that something should obviously be done to the extent of mandating them in commercial seaplane ops.

I still think 4 point harnesses should be mandatory in the front seats of ALL floatplanes as well. Those vests will do you NO good whatsoever if you're unconcious in the front seat of that beaver/206/185/Otter etc.

Hows the pop out window program coming along? I'd like to actually see one demonstrated in person.

[TG]

I did the egress course in Halifax a couple of years ago.

They drilled us to keep our eyes closed, open our respective exit door, grab a frame with one hand, unbuckle with the other and then pull yourself out. All in that order.
I have hard time imagining a rooky passenger keeping his coolness doing all this in an upside down/flooded cabin after an impact.
And poping his life vest when finally outside (not while still inside)


To stay on topic, you will also get out with whatever you are wearing at the moment.

[cdnpilot77]

There are advantages - the problem is they're not cheap.

I assume you are talking about a mustang type jacket? The airline style overhead inflatable jackets that come in a pouch are only about $60 each.

[Cranium]

No, I'm talking about the ones that are worn all the time - something like this:

http://www.stearnsflotation.com/33-Gram ... 07C17.aspx

The problems with the ones in the pouch are that people either forget to grab one, can't get it out of the pouch on time, or pull the cord while still in the aircraft and get trapped.

[200hr Wonder]

No, I'm talking about the ones that are worn all the time - something like this:

http://www.stearnsflotation.com/33-Gram ... 07C17.aspx

The problems with the ones in the pouch are that people either forget to grab one, can't get it out of the pouch on time, or pull the cord while still in the aircraft and get trapped.

Cranium that vest should NEVER be worn in a plane. It is an auto inflation type. You go in and get wet and it goes poof. Bad news.

The thing about life vests/no life vests is this:

There are two ways to die in a float plane crash generally speaking, 1. you are trapped inside 2. exposure outside.

What traps people inside? Unconsciousness, inability to open the exit and egress and panic. Any one who can open the exit and exit is probably staying calm enough to not pull the cord on the life vest. People who panic and pull the cord I hate to say it probably would not make it with or without a life vest. So you get the lucky few who do egress and make it to the surface. The fact is without a flotation device most people will turn hypothermic and drop like a stone in less than 30 minutes with the coastal water temperatures in Canada. For a very large part of Canada and a large part of the year it is significantly less than that. The chances of being rescued by then are slim. You need a jacket to have any chance of survival.

I think with all the studies done we can say would a constant wear jacket in a float plane save more lives than it takes? Yes 100% I can say I believe that to be true. Will some people yank the cord and get trapped? Most likely but to be perfectly honest I do not put that type of person's odds of egress that high to begin with. Though as a float pilot always a good idea to wear a smallish strait knife in that situation so you can pop a jacket if need be.

[Beefitarian]

Is it time to introduce the idea of a bottle of breathing air on board to the discussion yet? You know for extra take off weight and complications.

[Cranium]

Oops. Didn't read the product description - I just found one that looked like the right thing. That one would be worse than nothing if you went upside down.

[sueonkent]

Some planes are inherently difficult to exit in an emergency due to design faults , such as the cessna 206 with flaps extended ,restricting rear doors opening .Most accidents are associated with t/off and landing scenarios.Flaps are extended restricting use of rear exit doors.Isnt there a better design or modification to remedy this.?