Seaplane Safety for 14 CFR Part 91 Operators AC 91-69A Date: 11/19/99
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SEAPLANE SAFETY FOR 14 CFR PART 91 OPERATORS
FOREWORD This Advisory Circular (AC) contains recommendations and revised information for the safe operation of seaplanes operated under Title 14 of the Code of Federal Regulations (14 CFR) part 91. This AC is intended to be operational advisory material and has been produced in a size and format that makes it easily added to pilot flight manuals or carried in flight cases. This AC does not change agency regulations and does not authorize deviation from regulatory requirements.
/s/ L. Nicholas Lacey Director, Flight Standards Service
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CONTENTS Paragraph Page
1. Purpose 1
2. Cancellation 1
3. Related CFR Sections 1
4. Definitions 1
5. Related Reading Material 1
6. Background 2
7. Seaplane Preflight 3
8. Passenger Briefings 5
9. Use of Seatbelts and Shoulder Harnesses in Seaplanes 8
10. Escape/Egress in the Event of an Upset in the Water 8
11. Water Survival 10
12. Flotation Gear for Seaplanes 12
13. Summary 15 Appendix 1. Sample Passenger Preflight Briefing Checklist (2 pages) Appendix 2. Index (1 page)
Par 1 Page 1 SEAPLANE SAFETY FOR 14 CFR PART 91 OPERATORS
1. PURPOSE.
a. This Advisory Circular (AC) provides revised information to Title 14 of the Code of Federal Regulations (14 CFR) part 91 seaplane operators regarding seaplane preflight, oral briefings for seaplane passengers, the use of safety belts and shoulder harnesses in seaplanes, escape/egress after capsizing, water survival, and flotation gear for seaplane occupants. This AC generally covers seaplanes engaged in not-for-hire operations. Most for-hire seaplane operations are subject to 14 CFR part 135, as well as part 91.
b. The Federal Aviation Administration (FAA) recommends that seaplane operators engaged in not-for-hire operations equip their aircraft with FAA or U.S.
Coast Guard (USCG)-approved inflatable personal flotation devices (PFD).
(1) For-hire operators must use FAA-approved inflatable PFD's. A PFD should be worn by each occupant while on the seaplane.
(2) The FAA also recommends that the pilot in command (PIC) brief passengers on the location and use of flotation gear and the location and operation of each normal and emergency exit.
2. CANCELLATION. Advisory Circular 91-69, Seaplane Safety For FAR Part 91 Operators, dated March 13, 1992, is canceled.
3. RELATED CFR SECTIONS. Sections of 14 CFR part 91 that are related to the information in this AC are sections 91.105, 91.107, 91.115, and 91.205.
Title 49 CFR part 175, section 175.310, contains information regarding the transportation of flammable liquid fuel in small, passenger-carrying aircraft.
4. DEFINITIONS. In this AC, seaplane refers to an airplane on floats (amphibious or nonamphibious) or a flying boat (water-only or amphibious).
5. RELATED READING MATERIAL. Readers may find additional information related to the subject of this AC listed below.
a. Current editions of the following AC's may be obtained at no cost by sending a written request to U.S. Department of Transportation, Subsequent Distribution Office, Ardmore East Business Center, 3341 Q 75th Avenue, Landover, MD 20785:
(1) AC 120-47, Survival Equipment for Use in Overwater Operations.
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(2) AC 121-24, Passenger Safety Information Briefing and Briefing Cards.
(3) AC 150/5210-13, Water Rescue Plans, Facilities, and Equipment.
b. Current editions of the publications below may be purchased from:
New Orders, Superintendent of Documents, P.O. Box 371954, Pittsburgh, PA 15250-7954.
(1) FAA-H-8083-3, Airplane Flying Handbook.
(2) COMDTINST M16672.2B, Navigation Rules, International- Inland.
(3) Aeronautical Information Manual: Official Guide to Basic Flight Information and Air Traffic Control Procedures.
6. BACKGROUND.
a. For-Hire Operations. For-hire operations are subject to additional regulatory requirements, even if they are permitted to be conducted only under part 91. While most for-hire operations will be covered by both part 91 and part 135, some operations may be permitted to operate only under part 91 pursuant to an exception provided in 14 CFR part 119, section 119.1(e). In any event, section 91.205(b)(12) also applies to an aircraft operating in a for-hire capacity when it is over water and beyond power-off gliding distance from shore. Each person operating a civil aircraft for-hire must provide at least one pyrotechnic signaling device and have FAA-approved flotation gear readily available to each occupant (section 91.205(b)(12)). Aircraft operations subject to part 135 also require a preflight briefing on the use of flotation gear and exiting the aircraft in an emergency (section 135.117(a)(4)). As indicated above, the FAA recommends that seaplane operators engaged in not-for-hire operations under part 91 also conduct such preflight briefings.
b. Status of Seaplanes as Vessels. USCG's Navigation Rules, International-Inland, provides the following definition: “The word ‘vessel’ includes every description of water craft, including nondispl acement craft and seaplanes, used or capable of being used as a means of transportation on water.” Therefore, a seaplane is a vessel once it lands on the water and, as such, is required to comply with the USCG navigation rules applicable to vessels. Adherence to section 91.115 should ensure compliance with the USCG rules.
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7. SEAPLANE PREFLIGHT. All PIC's, including those operating within the territorial waters of the U.S. coast, are responsible for taking preflight action consistent with section 91.103. Additionally, in order to comply with the requirements in section 91.7 (Civil aircraft airworthiness), the PIC is responsible for determining whether the aircraft is in a condition for safe flight. One means of assuring compliance with section 91.7 is for the PIC to make sure a thorough preflight inspection of the aircraft is conducted. With some exceptions, the preflight inspection of a seaplane is similar to that for a landplane. The major difference is checking the floats or hull. The airplane flight manual (AFM), pilot’s operating handbook (POH), or manufacturer’s recommendations will contain procedures for doing this in addition to the usual preflight actions, such as fuel sumping, fuel quantity, engine oil quantity, control checks, etc.
a. Some operators haul seaplanes out of the water for dry land storage on a trailer or raft, making preflight more convenient for the pilot. However, the pilot should not conduct an abbreviated inspection just b ecause a seaplane is preflighted while in the water.
b. The pilot should first note how the seaplane rides in the water. If the stern of the floats or hull is very low in the water, i.e., float stern submerged or, in a flying boat, tail in the water, the seaplane could be loaded incorrectly, or there could be a leak in a float compartment or in the hull. This is why manufacturers recommend that floats and hulls be inspected and bilge-pumped before each flight.
(1) The pilot should first inspect floats and hulls for obvious or apparent defects or damage, such as dents, cracks, deep scratches, loose rivets, corrosion, separation of seams, punctures, and general condition of the skin. This might also be a good time to inspect the fuselage for damage. Ensure that the airframe/float combination and attachments are approved for use on the seaplane.
(2) Because of the rigidity of float installations, the pilot s hould check fittings, wire or tubular bracing, and adj acent structures for cracks, defective welds, proper attachment, alignment, and safety wires and nuts.
(3) Pilots should check all hinge points for wear and corrosion, particularly if the seaplane operates on salt water.
(4) The pilot should inspect the water rudders, if installed, and their cables and springs for free and proper movement. Special attention should be paid to the area where cables go over pulleys, and the pilot should inspect the cable for fraying.
(5) The pilot should pump out each bilge or compartment of a float or the hull to remove water. A small amount of water, e.g., a cupful, is not unusual and can occur from condensation or normal seepage. (If the bilge pumps out no water, it is more likely that the pump itself, or the tube leading to the bilge, is defective.) All
Par 7Page 4 water should be removed before flight by pumping or with a sponge b ecause the water may critically affect the seaplane’s weight and its center of gravity. Finding an excessive amount of water should cue the pilot to look for the source of the leak. If drain plugs and inspection plates are installed, the pilot should use a systematic method (refer to manufacturer’s recommendations) to remove the plugs and plates and examine the compartments thoroughly. Of course, it is equally important to reinstall the plugs and plates systematically before a water takeoff.
(a) Some floats are equipped with a bilge funnel which does not require the removal of a cover to pump the bilge. However, if the funnel becomes disconnected from the hose that goes to the bottom of the float, the pump will not pump any water, and there may still be water in the float. The answer is to be suspicious if no water emerges when bilging after the seaplane has spent an extended time on the water or in storage.
(b) Floats stored in freezing climates should be inspected particularly closely because water in the floats expands upon fr eezing. Frozen water in compartment seams can cause severe leakage problems. Many operators who store the floats off the airplane for a season put them away upside down with compartment covers off to allow drainage. It might also be a good idea to look for any creatures that might have made a home in the floats.
(6) The pilot should ensure that nothing is stored in compartments of floats not approved for storage. For those floats approved for storage of items, the pilot must ensure that the contents and their placement allow the seaplane to remain within its weight and balance limitations. Another consideration is that floats are certificated to continue to float after two compartments per float have been flooded.
The potential for capsizing or sinking is increased where compartments are at their limit for storage and other compartments become filled with water after accident damage. Pilots should be aware that float compartments have no ventilation. It is extremely dangerous and illegal to carry a container of fuel anywhere fuel vapors could accumulate. Title 49 CFR section 175.310 specifies the manner in which fuel must be transported by air. It permits limited amounts of flammable liquid fuel to be carried on board airplanes for use in remote areas, provided it is carried in closed metal containers that meet the specifications prescribed in section 175.310.
NOTE: Pilots transporting flammable liquids under this section must assure that their operation is not-for-hire; otherwise, they would be required to complete the training specified in 49 CFR sections 172.700-704.
(7) Pilots should be careful when carrying external cargo and should follow the manufacturer’s recommendations regarding such carriage. If the manufacturer does not permit it, then the pilot should not either. B ecause of their bulk or size, certain items may not be able to be loaded in the cabin of small aircraft.
Floats, because of their size, make a useful platform for carrying items that are too
Par 7 Page 5 large to fit into the cabin. However, certain precautions must be taken to ensure safety of flight. Items must be placed to ensure compliance with weight and balance limitations. The weight should be equally distributed on both floats, items should be aft of the propeller arc, and the weight of any external cargo should be included during the weight and balance calculations. Finally, external loads must be properly secured to the aircraft in a manner that does not block the emergency exits.
8. PASSENGER BRIEFINGS.
a. Background. From the standpoint of passenger survival in seaplanes, an upset or capsizing from accidental water contact--whether it is a float or a wingtip or an encounter with a large wave or landing gear down on amphibious floats--is the most critical type of occurrence. This is because of the lack of time to prepare for evacuation and the likelihood of major cabin structural damage from impact with the water. During such a crisis, the pilot may be too busy coping with the problem to give instructions beyond the order to evacuate. Furthermore, if the pilot becomes incapacitated in an emergency, it is important for the passengers to know what to do and how to do it without additional prompting from the pilot. Since seaplanes tend to come to rest inverted in water accidents or incidents but can remain afloat for long periods if the floats are not breached, the FAA cannot stress enough the importance of a thorough preflight passenger briefing, even when one is not required .
(Although this AC suggests topics to cover in such a preflight briefing, the pilot should also consult the POH or AFM for any special evacuation procedures.)
Evacuation of a seaplane creates a few problems not associated with a landplane;
therefore, passengers need to know the location and operation of normal and emergency exits, flotation gear, seatbelts, and shoulder harnesses, etc. The PIC is directly responsible for and is the final authority for the safe operation of an aircraft.
Being “directly responsible” may also include responsibility for passengers carried in that aircraft in the event of an accident or incident.
b. Presentation. The pilot should present the pretakeoff oral briefing preferably before engine start so passengers can easily hear it and easily see the actual or simulated demonstrations. Pilots should speak clearly and distinctly and physically point out and explain the operation of both normal and emergency exits and any safety equipment on board. Whenever possible, pilots should demonstrate the use of safety equipment and both normal and emergency exits. When a demonstration is impractical, such as demonstrating the actual inflation of flotation gear, the pilot should simulate the actions involved as closely as possible. The FAA Aviation Safety Program has produced an excellent series of videotapes including one that addresses passenger briefings for seaplane operators. Please contact the Aviation Safety Program Manager at your local Flight Standards District Office (FSDO) to view a copy of this videotape.
c. Pretakeoff Briefing. Before each takeoff, the pilot s hould orally brief all passengers on each of the following:
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(1) When, where, and under what conditions passengers may smoke and when smoking materials must be extinguished.
(2) How to fasten, tighten, and unfasten the safety belt and shoulder harness (if installed) without looking at the mechanism, and how to stow the loose end of the seatbelt so that the loose end does not hinder opening the seatbelt in the event of capsizing.
(3) How to recognize, by feel, seatbelt rollover and that the buckle, in this condition, must be righted so it can be opened.
(4) How to operate seats, forward and backward, to enhance egress.
(5) That the seat back should be upright for takeoff and landing.
(6) The location of each normal and emergency exit.
(7) The operation of each normal and emergency exit by explanation and demonstration, if practical.
(8) To leave carry-on items behind in the event of an evacuation in the water.
(9) To establish “situational awareness.” During the preflight briefing, the pilot should help passengers establish a definite frame of reference, such as left hand on the left knee or left armrest or right hand toward the direction of the exit.
Once they have established situational awareness, passengers can use a “hand-overhand” technique to make their way to an exit when the pilot gives the evacuation order; e.g., “Exit through the left rear door,” or “Exit right side.” Using positional and situational awareness and the “hand-over-hand” technique decreases the possibility of becoming disoriented. The pilot should stress the point that whether a passenger is upright or inverted, left and right are still the same; i.e., if the exit is on the passenger’s right while upright, it will still be on the passenger’s right if inverted.
The pilot should also be sure to make all directional references to the passenger’s right or left, not the pilot’s. Pilots should advise passengers if the door handle on the inside of the airplane will work in reverse when they are upside down and that, when the door is closed and locked as in flight, the door may not be able to be opened from the outside.
(10) The following various aspects of flotation gear:
(a) If using flotation cushions, the pilot should brief on the type, location, and how to use in the water, including a physical demonstration, if possible;
e.g., how to insert arms through the straps and rest the torso on the cushion once in the water and not to wear the cushion on one’s back.
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(b) If using some form of PFD, the pilot should brief on the type, location, and use of the available PFD, including a demonstration of how to don the device and a simulated demonstration of how to inflate an inflatable device either by carbon dioxide (CO 2) or by oral or manual methods after entering the water. The pilot must emphasize that an inflatable PFD should NOT be inflated until clear of the wreckage after exiting the aircraft since these devices can easily get hung up on wreckage, block an exit, or pr event a passenger from exiting an inverted seaplane. An inflated PFD that becomes damaged because of punctures caused by contact with the wreckage or snagged on debris, may be rendered useless.
NOTE: The FAA suggests that operators consider establishing a policy where all occupants wear an inflatable PFD anytime the seaplane operates on or near the water.
(11) The use and operation of any fire extinguishers on board, location of survival gear--including the Emergency Locator Transmitter (ELT) and pyrotechnic signaling device (flares)--an appropriate brace position, and the proper location for carry-on items.
(12) Seaplanes are dangerous at both ends. Exercise extreme caution when around the propeller and the elevator. Serious injuries, amputations, and death have resulted from propeller strikes and the horizontal stabilizer when unwary passengers attempt to help in the launching or docking of a seaplane. The elevator balance weight on many seaplanes is an effective finger guillotine. In the preflight briefing pilots should instruct passengers not to assist unless specifically requested to do so by the pilot . If the pilot anticipates needing passenger assistance, the pilot should provide specific instructions on the passenger’s duties, including a pr ecaution about avoiding the spinning propeller, and how to properly handle the horizontal stabilizer.
d. Passengers Needing Assistance. The pilot should individually brief a passenger who may need assistance in exiting. The briefing should include all of the above information and who will be assisting the passenger to exit. If the passenger is accompanied by an attendant, the pilot s hould brief both the passenger and the attendant on the above information, including the most appropriate route to an exit, when to move toward the exit, and the most appropriate manner of assisting the passenger.
e. Prelanding Briefing. At a minimum before each landing, the pilot should ensure that all passengers have been briefed to fasten seatbelts and shoulder harnesses (if installed), place seat backs in the upright position, and stow carry-on items.
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9. USE OF SEATBELTS AND SHOULDER HARNESSES IN SEAPLANES.
a. Seaplanes are subject to the seatbelt and shoulder harness requirements of section 91.107. Unfortunately, takeoff and landing are the phases of flight where improper pilot technique or water or wind conditions could result in a capsized seaplane. The shock of entering cold water and being inverted while strapped into a seat can cause panic in passengers. That is why the preflight briefing on seatbelt operations is very important. The FAA is aware that some operators have passengers leave seatbelts unfastened or loosened during any type of water taxiing to position for takeoff or after landing. Both of these practices are prohibited under FAA regulations.
b. Pilots are reminded that section 91.105(a) requires them to keep their seatbelt fastened during takeoff, landing, and while en route when at the crewmember station unless an absence is necessary to perform duties in connection with the operation of the aircraft. Section 91.105(b) requires pilots to keep their shoulder harness, if installed, fastened during takeoff and landing. However, section 91.107(a)(3) provides that the person pushing off the seaplane from the dock and the person mooring the seaplane are excepted from the requirement to be seated in an approved seat and secured with a seatbelt.
10. ESCAPE/EGRESS IN THE EVENT OF AN UPSET IN THE WATER.
a. Accident History. A review of past seaplane accidents on the water indicates that the pilots and passengers in inverted aircraft often survived the impact but were unable to evacuate the aircraft under water and subsequently drowned. In some cases, passengers were unable to unfasten their seatbelts, and, consequently, their bodies were discovered with little or no impact injuries still strapped to the seats. In other cases, passengers were able to get out of their seatbelts but were unable to find an exit and/or open the exit because of impact damage or ambient water pressure. Those who did survive generally spoke of the extreme disorientation and that they did not exit in what may be considered a normal procedure; i.e., they did whatever they had to in order to get out of the aircraft.
(1) Opening a door under water can be extremely difficult, and some operators adopt the practice of water taxiing with one door open at all times to permit easier egress. However, operators should check the POH or AFM for evacuation procedures since, in the event of capsizing, this practice could lead to the cockpit and cabin flooding sooner and sinking the seaplane faster.
(2) In many cases, pilots exited relatively easily through a smashed cockpit windshield or the cockpit door and seemed to have less difficulty evacuating the seaplane because of their familiarity with it. Passengers, on the other hand, often do not have a thorough knowledge of their surroundings. Investigations of evacuations of air carrier aircraft have shown that passengers tend to want to exit through the door where they entered. It is likely this would hold true even for a small
Par 10 Page 9 seaplane because where the passenger entered might be the only familiar frame of reference in an emergency.
(3) In some of the accidents where pilots survived and passengers did not, investigation revealed that pilots had met the requirements of section 91.107 but did not go beyond that; i.e., did not brief passengers on how to exit in an emergency, on the location, donning, and inflation of a PFD, and on the procedures for an underwater exit of the aircraft. There were accidents where the pilot was injured or killed and could not assist passengers in an underwater evacuation. Therefore, a comprehensive preflight briefing, although not a regulatory requirement, can provide critical information to passengers so that they can help themselves. T he information in that preflight briefing could make the difference between a successful evacuation and being trapped inside a submerged seaplane.
b. Evacuation. The pilot should never take for granted that people already know how to exit the seaplane. After an accident, and especially while submerged inverted in water, the passengers are likely to panic, but they will usually defer to what the pilot instructs. In their eyes, the pilot knows what to do.
(1) The pilot should keep commands simple and concise, since it is likely that passengers will cease to listen much bey ond the initial order to evacuate.
Passengers respond to very short instructions, i.e., “stop,” “leave it,” and “come here.” Pilots should issue commands and make decisions in a positive, confident, and expeditious manner.
(2) Being upside down can cause orientation problems. Once the turbulence of the upset has subsided, even though the pilot may have briefed passengers on situational awareness before takeoff, the pilot may still need to help passengers establish positive situational awareness so that they can determine left from right.
(3) Maneuvering while holding flotation devices can also be disorienting because it occupies the hands, making swimming or treading water difficult. This adds to the argument for wearing an inflatable PFD. However, it is important to remember not to inflate the PFD until after exiting the seaplane. It is virtually impossible to swim downward to an exit (from an inverted position) with an inflated PFD. Any preflight briefing on the use of inflatable PFD's should include this vital point.
(4) Impact forces may jam normal or emergency exits and prevent them from operating. Pilots should be prepared to, and have briefed passengers to be prepared to, break out or kick out windows in order to escape. In many instances, this may be the only option for evacuation and everyone on board should plan to use this technique if necessary.