0 U.S. Deportment of Transportation Federal Aviation Administration Advisory Circular Subject: Emergency Evacuation Date: 03/12/12 AC No: 25.803-1A Demonstrations Initiated By: ANM-115
1. Purpose. This advisory circular (AC) provides guidance on means, but not the only means, of compliance with Title 14, Code of Federal Regulations (14 CFR) part 25 concerning: (1) conduct of full-scale emergency evacuation demonstrations, and (2) use of analysis and tests in lieu of conducting an actual demonstration. Throughout this AC, any reference to a full-scale demonstration, unless further qualified, means an evacuation demonstration in which a full complement of passengers and the requisite number of crewmembers evacuate an airplane using assist means, if installed, under the conditions specified in part 25, appendix J. References to “appendix J” means 14 CFR part 25, appendix J. Additionally, any reference to an analysis, which is to be used to satisfy the emergency evacuation requirements of part 25, means a formal analysis document supported by data from tests or demonstrations. Terms such as “shall” and “must” are used only in the sense of ensuring applicability of this particular means of compliance when the acceptable means of compliance described herein is used.
2. Applicability.
a. The guidance provided in this document is directed to airplane manufacturers, modifiers, foreign regulatory authorities, and Federal Aviation Administration (FAA) transport airplane type certification engineers, and their designees.
b. This material is neither mandatory nor regulatory in nature and does not constitute a regulation. It describes acceptable means, but not the only means, for demonstrating compliance with the applicable regulations. The FAA will consider other means of demonstrating compliance that an applicant may elect to present. While these guidelines are not mandatory, they are derived from extensive FAA and industry experience in determining compliance with the relevant regulations. On the other hand, if we become aware of circumstances that convince us that following this AC would not result in compliance with the applicable regulations, we will not be bound by the terms of this AC, and we may require additional substantiation or design changes as a basis for finding compliance.
c. This material does not change, create any additional, authorize changes in, or permit deviations from, regulatory requirements.
3. Cancellation. Advisory Circular 25.803-1, Emergency Evacuation Demonstrations, dated November 13, 1989, is canceled.
4. Related Requirements.
a. Section 25.803, Emergency evacuation, as amended through Amendment 25-117.
b. Appendix J to part 25 - Emergency Evacuation, as amended through Amendment
25-117.
c. Section 121.291, Demonstration of emergency evacuation procedures, as amended through Amendment 121-233.
5. Background.
a. The requirements for emergency evacuation demonstrations were first established in 14 CFR part 121 (§ 121.291) by Amendment 121-2, effective March 3, 1965. Operators were required to conduct full-scale evacuation demonstrations within a time limit of two minutes using 50 percent of the exits. The purpose of the demonstration was to validate the crewmembers' abilities to execute the established emergency evacuation procedures and to ensure realistic assignment of functions to the crew. A full-scale demonstration was required upon:
(1) initial introduction of a type and model of airplane into passenger-carrying operation,
(2) an increase in passenger seating capacity of five percent or greater, or
(3) a major change in the cabin interior that would affect emergency evacuation.
b. The requirement for the airplane manufacturer to conduct an evacuation demonstration for airplanes having a seating capacity of more than 44 passengers was established in § 25.803 by Amendment 25-15, effective October 24, 1967. The time limit for the manufacturer's demonstration was established at 90 seconds, and the part 121 time limit was reduced to 90 seconds. It was considered that the manufacturer's demonstration would show the basic capability of a new airplane and, as before, the part 121 demonstration was intended to account for crew training and adequate crew procedures. Therefore, the demonstration conditions were somewhat different.
With the addition of the requirement for a full-scale demonstration in part 25, § 25.803(d) allowed for analysis in lieu of demonstration under certain conditions. Section 25.803(d) stated that the demonstration need not be repeated for a change in the interior arrangement or a passenger capacity change of not more than five percent, or both, if it could be substantiated by 2
analysis that the passengers could be evacuated in 90 seconds. At that time, analysis was used for decreases in passenger capacity when an airplane was reduced in size. Generally, the analysis was based on a full-scale demonstration for the larger airplane. Analyses were also used for increases of less than five percent.
c. Since Amendment 25-15, numerous full-scale demonstrations have been conducted by airplane manufacturers to satisfy both type certification and operational requirements. These demonstrations provided data on evacuation rates, escape system performance, and the behavior of evacuees (passengers and crewmembers who evacuate the airplane) during the demonstration.
d. By Amendments 25-46 and 121-149, effective December 1, 1978, § 25.803 was revised to allow a means other than actual demonstration to substantiate the evacuation capability of the airplane and to replace the existing part 25 demonstration conditions with conditions that would satisfy both part 25 and part 121 so one demonstration could serve both requirements. Part 25 was changed to match the conditions in part 121.
Amendment 25-46 removed the five percent limitation on analysis from § 25.803(d). It was proposed in Notice 75-26, that analysis or a combination of analysis and tests be used to show evacuation capability. Amendment 25-46 dropped the provision which allowed analysis alone and required a combination of analysis and tests to assure approvals would be based on sufficient test data. The possibility was considered that sufficient data may not be available in the case of a completely new airplane model or a model which had major changes or a considerably larger passenger capacity than a previously approved model. Thus, the requirement that the Administrator find the data used in the analysis acceptable was intended to preclude approvals which might be based on insufficient test data to support the proposed analysis.
e. Amendment 121-176, effective January 18, 1982, allowed a part 121 certificate holder to use the results of a part 25 demonstration or the part 121 demonstration of another operator to show compliance with § 121.291. This amendment also eliminated the five percent limit from part 121 because the manufacturer would have already shown compliance with § 25.803 and the partial demonstration required by § 121.291 would show that the air carrier's procedures, training program and maintenance program are adequate.
f. The conduct of emergency evacuation demonstrations and the use of analysis in lieu of a full-scale demonstration were discussed at the Public Technical Conference held by the FAA in September 1985, in Seattle, Washington. These items were later discussed in detail at working group meetings. As a result of a paragraph by paragraph review of § 25.803(c), the FAA concluded that it was necessary to formalize its policy on how to conduct an evacuation demonstration and to clarify items of concern expressed by the group members. Most of the guidance presented in the original version of this AC, and much of the guidance in this revised version, is consolidated from existing FAA policy or the consensus of the working group. In 3
those areas where no consensus could be reached, for example the use of analysis in lieu of full-scale demonstration, the FAA decided how best to implement the regulations.
g. Amendment 25-72 to part 25 revised § 25.803 by moving the conditions under which an emergency evacuation demonstration was to be conducted from § 25.803(c) to a new appendix J to part 25. Additionally, other sections of part 25 were relocated to group requirements more logically.
h. Amendment 25-79 revised appendix J by revising the age/gender mix to be used when conducting an emergency evacuation demonstration, by prohibiting flightcrew assistance, and by allowing the use of stands or ramps for descending from overwing exits only when the airplane is not equipped with an off-wing descent means.
i. Amendment 121-233 revised § 121.291 to require demonstrations conducted after September 27, 1993, be in accordance with paragraph (a) of appendix D to part 121 or with the § 25.803 in effect on or after that date.
j. Amendment 25-117 revised appendix J by including provisions to reduce the potential for injuries to participants. This included a provision for pre-deployed escape slides, a low level of ambient lighting in the test facility, and briefing of test passengers on the safety precautions taken for the demonstration. None of these new provisions are mandatory.
k. The FAA established the Aviation Rulemaking Advisory Committee (ARAC) on January 22, 1991, to provide advice and recommendations to the FAA concerning the full range of the FAA's safety-related rulemaking activity. The ARAC, in turn, established a Performance Standards Working Group to study the rules involving emergency evacuation to see if they could be restated in terms of performance standards. A second task was given to the group to recommend revisions to the existing emergency evacuation demonstration requirements and compliance methods to eliminate or minimize injury for participants (persons performing the roles of either passengers or crewmembers in an evacuation demonstration). In January 1993, the working group forwarded a report, "Emergency Evacuation Requirements and Compliance Methods that Would Eliminate or Minimize the Potential for Injury to Full Scale Evacuation Demonstration Participants," to the ARAC. The ARAC accepted the report and forwarded it to the FAA. Many of the recommendations for revising the compliance methods associated with the demonstration have been incorporated into this AC.
6. Objective of the Rule.
a. A full-scale demonstration is conducted to assess the evacuation capability of the airplane and, when compliance with paragraph g of appendix J regarding compliance with § 121.291 is requested, to also demonstrate the effectiveness of crew training and emergency 4
procedures. Appendix J to part 25 specifies the conditions for conduct of the evacuation demonstration.
b. The objective of any analysis allowed by § 25.803(c) is to substantiate that the airplane can be evacuated within 90 seconds under the conditions specified in appendix J without actually conducting the demonstration. The use of analysis can eliminate the need to conduct a full-scale demonstrations where adequate knowledge is already available from previous full-scale demonstrations or other tests. A decrease in the number of full-scale demonstrations will reduce the number of participants subjected to possible injury.
7. Determination of Whether Analysis or a Full-scale Demonstration is Required for a New Airplane Type or a New Configuration of an Existing Airplane Type.
a. Each new airplane type and each change in airplane design of an existing airplane type that may have an effect on the emergency evacuation capability of the airplane should be evaluated by the applicant for its impact on compliance with § 25.803, either by conducting a full-scale demonstration or, if appropriate, by submitting the results of a combination of tests and analysis.
b. The following are examples of design changes that may have an effect on evacuation capability and therefore should be evaluated:
(1) A change in type, number, or location of exits.
(2) An increase in passenger capacity above that listed on the type certificate data sheet.
(3) Changes in passenger distribution within the cabin area that would increase the number of passengers expected to use an exit pair to a number greater than the exit rating of the exit pair.
(4) Classifying an exit as an "excess" exit in accordance with the requirements of § 25.807(h).
(5) Installation of escape slides or other assist means not previously approved for that model airplane.
(6) Changes to the passenger cabin configuration that reduce the passengers' access to any emergency exit below the access that was provided in the certification demonstration.
Examples of such changes include partitions, galleys, etc., that restrict the flow of passengers merging from an aisle and cross aisle; the crew's ability to determine which exits are operable; or the crew's ability to balance the passenger flow among the active exits.
(7) Changes to the flight attendant seating locations.
c. If compliance with § 121.291 is sought per paragraph g of appendix J of part 25, then any change that affects the duties of the flight attendant(s) must be evaluated. Any change to flight attendant training must be clearly specified because such changes are likely to become mandatory training for all U.S. operators of the airplane type in question.
d. The determination whether a demonstration or formal analysis is required is made by the FAA. As noted above, reducing the number of full-scale demonstrations will reduce the number of demonstration participants subjected to potential injury, particularly during the phase of the demonstration when evacuees are transitioning from the airplane to the ground. For this reason the FAA will consider proposals for analysis for all new and modified airplanes. The analysis, however, must be supported by appropriate testing. Such tests may include, but are not limited to, the following:
(1) Tests to determine the evacuation rates for all new exit/assist means combinations under appendix J conditions.
(2) Tests to determine the time necessary to open exits and have assist means ready to receive evacuees.
(3) Tests to determine that flight attendant training and procedures are adequate to assist passengers in expeditiously exiting the airplane. This may include a full-scale test in which the evacuees exit onto platforms or ramps rather than onto airplane-installed assist means.
(4) Tests to determine the impact of revised passageways, including their orientation to the exit, or relocated cross aisles, which may merge passengers from one aisle into passengers in another aisle at a different point than was previously demonstrated.
(5) Tests to determine the impact of revised, brighter or dimmer, emergency lighting inside or outside of the airplane.
(6) Tests to determine that the relocation of flight attendant seated positions has not adversely impacted the flight attendants’ abilities to manage the evacuation.
(7) Tests to determine that, on airplanes with more than one occupied deck, communications and, if necessary, transiting between decks is adequate.
e. If the FAA decision is to allow analysis, the applicant must indicate the source(s) of the data for the analysis and have these sources available to the FAA during any evaluation of the analysis.
8. Guidance For Demonstrating Compliance With § 25.803(c) and Appendix J Using an Actual Demonstration.
a. Section 25.803(c) and appendix J. The following is intended to provide uniform standards for conducting demonstrations in order to make demonstration results as directly comparable to each other as is practical.
(1) Upon determination that an actual demonstration will be required, the applicant should prepare a plan that outlines such details as time and place for the demonstration, demonstration vehicle configuration, and crew training program. This plan should be submitted to the FAA as soon as possible to allow the FAA time to review, request any necessary changes, and approve the plan, as well as arrange for participation of the appropriate FAA organizations.
(2) The phrase "The maximum capacity... for which certification is requested," refers to the airplane model presented for certification.
(3) All passengers and crewmembers used in the demonstration must be evacuated to the ground or to an off-wing ramp (if applicable) within 90 seconds to constitute a successful demonstration. Seats, including restraint systems, adequate for purposes of the demonstration, must be provided for all passengers. (For example, a 5-place seat assembly may be used to seat 6 passengers, if the 6 passengers can be accommodated and 6 restraint systems are installed and used.) The limits of § 25.807(g) or (i) may not be exceeded. Partial credit, equal to or less than the number of evacuees on the ground at 90 seconds, may be granted by the FAA if all passengers and crewmembers used in the demonstration have not been evacuated by that time.
For example, if an airplane is equipped with four pairs of Type A exits, the maximum seating configuration allowed by § 25.807(g) provides for 440 passengers. If certification is requested for 440 passengers plus crewmembers, that number of passengers and crewmembers must be provided seating in the airplane and they must evacuate the airplane in 90 seconds for a successful demonstration. If, in the demonstration, only 420 passengers evacuate the airplane within the 90 second time limit, the FAA may allow some credit (up to a maximum seating capacity of 420 passengers). The actual credit will depend on many factors, including the number of crewmembers that evacuate within 90 seconds, with the primary focus on the reasons that the demonstration failed. This determination is made only after submittal of test documentation by the applicant, including video or film from inside and outside the airplane, that shows that approval of the reduced capacity is warranted. Such decisions must be coordinated with the Transport Standards Staff.
(4) Federal Aviation Administration observers should be stationed inside the airplane at expected critical locations, and outside the airplane at each exit to be used. Airplanes which do not have space for adequate onboard observation should provide interior video coverage to compensate for the absence of official witnesses.
(5) The airplane should be configured with the minimum aisle, crossaisle, and passageway clearances expected to be type certificated. (Configuration changes reducing clearances below those demonstrated may require substantiation.) This may require combining features of more than one interior configuration. The airplane interior need not be representative of a specific operational configuration for the purposes of the demonstration. For example, galleys and other furnishings may be simulated by mockups; seats need not have a Technical Standard Order (TSO) authorization, etc. The interior configuration should be FAA-approved, as a demonstration configuration, prior to the demonstration, and should be described in sufficient detail to allow an FAA conformity inspection.
(6) The phrase "including the number of crewmembers required by the operating rule" refers to the minimum number of flight crewmembers listed in the Airplane Flight Manual (AFM) and the minimum number of flight attendants required by § 121.391 for the passenger seating capacity to be demonstrated. The observer seats need not be occupied for the demonstration. If the minimum number of flight attendants required for the specific passenger capacity requested results in a more favorable flight attendant to passenger ratio than would a lower passenger capacity, both arrangements should be substantiated for compliance with the 90 second requirement. If it is obvious which arrangement is more critical, then other arrangements could be addressed through analysis following a successful demonstration. If it is not obvious which arrangement is more critical, the applicant may wish to propose conducting the demonstration with one fewer flight attendant than would be required. For example, a passenger capacity of 201 requires 5 flight attendants, whereas a capacity of 199 requires only 4. In this case, the change in passengers is only about 1 percent, but the number of flight attendants is reduced by 20 percent. So, while a lower capacity, the latter arrangement is arguably more critical.
(7) If the evacuation demonstration fails, the demonstration should not be repeated until the applicant has identified the cause(s) and instituted corrective measures. The FAA should be informed of the cause(s) of the failed demonstration and the corrective action(s) taken by the applicant, before the demonstration is repeated. In accordance with the regulations, different groups of passengers and crewmembers must be used in any repeat demonstrations.
(8) Participants in the demonstration should be encouraged to wear long sleeve shirts, full length pants and low heel shoes in order to reduce the occurrence and severity of injury. If emergency escape slides are used in the demonstration, gloves should be distributed to the participants in order to reduce abrasions to the hands caused by contact with the slide surfaces.
(9) Flight attendants are a critical element in the conduct of a safe, efficient, evacuation. These crewmembers initiate the evacuation, direct the evacuation process at usable exits, direct passengers away from unusable exits, and provide passenger management within the cabin, all with the safety of the participants as a foremost consideration. Flight attendants should be cautioned about the "demonstration" nature of the evacuation and the importance of 8
minimizing the potential for injury by using passenger management techniques that are consistent with airline training programs.
(10) Thorough internal and external video documentation may be beneficial for acquiring data, explaining anomalies, or identifying causes of failed demonstrations, and is highly recommended.
(11) The test director should have a means to abort the demonstration in the event a safety hazard develops. A test abort signal system is recommended.
b. Paragraph c of appendix J.
(1) If the airplane is equipped with an off-wing assist means, e.g., an emergency escape slide, it must be used during the demonstration in lieu of stands or ramps.
(2) Safety personnel stationed outside the airplane to help in preventing injury should not position any assist means (e.g., slide or ramp) following its deployment or otherwise interfere or assist in the evacuation process except as necessary to prevent injury to a participant.
NOTE: If it is determined that intervention by safety personnel significantly accelerated completion of the demonstration, this may
invalidate the demonstration. However, in the event that the demonstration is deemed valid, the FAA may still assess time penalties (i.e., add to the total evacuation time at any specific exit) to compensate for the assistance of ground personnel.
(3) Safety personnel stationed on the wing of an airplane equipped with removable exit hatches may accept the hatches if they are passed out of the exit opening. The hatches must be at least halfway out of the airplane before the safety personnel may assist. The safety personnel may not encourage, by word or gesture, the person in the cabin to hand the exit hatch to them.
c. Paragraph e of appendix J. The emergency assist means used in the demonstration should be of the type intended to be part of the airplane type design. If the assist means is a slide, the slide certification program should have progressed to the point where the system is reliable and can be expected to perform safely during the demonstration. Any changes to the assist means after the demonstration should be assessed for their possible effect on the outcome of the demonstration.
d. Paragraph g of appendix J.
(1) Evacuation demonstrations conducted to meet the requirements of § 25.803(c) only, for example, to demonstrate the evacuation capability of the airplane, need not use regularly 9
scheduled crewmembers (see sub-paragraph 7.e for a definition of regularly scheduled crewmembers). Therefore, there would be no crew training requirements specific to the operating rules, i.e., part 121, for the demonstration.
NOTE: Airplanes which have been shown to meet § 25.803(c) only, may
need to have a full-scale emergency evacuation demonstration conducted which satisfies § 121.291 before being allowed into part 121 operations.
(2) Evacuation demonstrations intended to meet the requirements of § 25.803(c) and § 121.291(a)(1) should use regularly scheduled line flight attendants. These demonstrations are conducted to demonstrate both the evacuation capability of the airplane and the effectiveness of the flight attendants' emergency training program and evacuation procedures.
NOTE: These procedures, once successfully demonstrated, should not be
revised in service without due consideration of the possible impact on the
emergency evacuation capability of the airplane.
(3) Flight attendants should be seated with their restraints fastened at cabin locations consistent with § 121.391 at the start of the demonstration. Each flight attendant should be sitting in a normal position without either hand resting on the seat restraint release mechanism.
(4) The normal demonstration start signal is the interruption of ground power to the airplane, as evidenced by the extinguishing of normal cabin lighting. This is the signal for flight attendants to begin the demonstration.
(5) Following the demonstration start signal, the flightcrew should delay evacuating the flightdeck by a time equivalent to that required to accomplish appropriate emergency procedures.
(6) Crewmembers in excess of the number required for the demonstration should be available so that the FAA can select the crew that will participate in the demonstration.
Crewmembers that are not selected may be considered by the FAA for participation in any subsequent demonstrations that may be conducted.
e. Paragraph g of appendix J. In order to be considered a "regularly scheduled line crew," the flight attendants should meet the following requirements:
(1) The flight attendants should be trained in specific duties related to an emergency evacuation in accordance with an FAA-approved training program (for evacuation demonstration purposes). This training program need not be a complete flight attendant training program but should be an emergency evacuation training program similar in content and duration to the emergency evacuation portion of training programs approved under part 121. Reference paragraph r of appendix J.
(2) If the flight attendants to be used for the demonstration have been previously trained under an operator's FAA-approved program, additional training may be given when the airplane model or layout to be demonstrated differs from the one used by that operator. Training in exit operation and passenger management is especially important for a demonstration of a new model airplane. This training should be similar in content and duration to the training received by a flight attendant when an operator adds a new model airplane to their operating certificate. The flight attendants should not be trained for specific demonstration conditions, except that specific training should be given which relates to the safety of the participants prior to and during the demonstration. This specific safety training should relate to initiating and recognizing the signal for emergency termination of the demonstration and emergencies related to the demonstration site. The FAA should be provided with documentation describing all special training that was given in preparation for the demonstration.
(3) If the demonstration is not successful and flight attendant procedures are changed in order to successfully conduct a repeat demonstration, the changes in procedures should be fully documented and added to the training program.
(4) The flight attendant training required for a successful demonstration should be the basis for the training program of all operators utilizing the demonstration for compliance with § 121.291(a)(1).
(5) The flight attendants to be used in the demonstration should not be instructors, supervisory personnel, safety representatives from worker organizations, or anyone else who may be expected to have knowledge of evacuation demonstrations beyond that of an average flight attendant.
(6) Flight attendants from more than one operator may be used in the demonstration.
f. Paragraph h of appendix J. The term "normal health” means that participants should be free of medical conditions or physical limitations that could affect the demonstration results or increase the chance of injury to themselves or others.
g. Paragraph h of appendix J. An alternative age/gender distribution may be utilized, provided the applicant can present justification that the overall evacuation capability of the proposed distribution is no faster than the overall evacuation capability of the group specified in the regulation. Age/gender distributions defined in previous versions of appendix J (or in § 25.803 itself) are acceptable for airplanes with the respective earlier certification basis.
h. Paragraph h(4) of appendix J. The life size dolls should be of appropriate size and weight to simulate children approximately two years old.
i. Paragraph h(5) of appendix J. In addition to those persons prohibited by the regulation, persons involved in the design or type certification of escape systems, development of emergency evacuation crew training, or those who have previously conducted evacuation demonstrations should not be used as passengers for the demonstration.
j. Paragraph i of appendix J. Passenger seating for the demonstration should be random.
One method for ensuring this is to allow passengers to select their own seats. Employees of the applicant are not allowed to sit next to exits. Federal Aviation Administration observers may, at their discretion, relocate passengers.
k. Paragraph k of appendix J. Simulated carry-on luggage in the form of small suitcases, gym bags, airplane flight bags, briefcases, etc., filled with clothes or newspaper, that will fit under a passenger seat, should be placed in the main aisle(s) with approximately one bag per seat row for each aisle. Also, some bags should be placed in the cross aisles and passageways, at approximately the same spacing as in the main aisle(s). Additionally, pillows and blankets should be scattered in the main aisle(s), approximately one pillow or blanket for every two rows.
In order to maintain a more typical preflight scenario, the bags, etc., should be distributed after the safety briefing takes place.
l. Paragraph l of appendix J.
(1) Neither the crew nor passengers should hear or otherwise receive any indication that the demonstration is about to begin. The first indication to participants should be the extinguishing of the normal cabin lighting.
(2) If safety devices or any other equipment external to the airplane could indicate to the test participants which exits are to be used in the demonstration, passengers and crew should enter the airplane through a tunnel or other means that will prevent them from seeing that indication. Similarly, exterior windows should be obscured from the outside to prevent both viewing of the outside conditions and any ground lighting from shining into the airplane.
(3) Placement of video cameras inside the airplane should not indicate which exits are to be used in the demonstration. This may require installation of cameras at all exits.
(4) Mechanical methods of exit deactivation which are not perceptible to crew or passengers prior to attempting to operate the exit should be used. The applicant should ensure that the deactivation means can withstand the high forces which may be applied by crewmembers or passengers, since inadvertent opening of a deactivated exit will likely invalidate the demonstration.
(5) If one or more of the exits must be mechanically deactivated after the airplane has been boarded, care should be taken to prevent the crew from becoming aware of the deactivation 12