Comments Tilt In Favor Of High-Load Airline Seats

Air Safety Week,  Oct 10, 2005  

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Air Transport Association (ATA):

"Passenger seats meeting improved survivability standards ('16 G compatible seats') now make up the largest segment of U.S. aircraft seats as a result of retrofits and new aircraft introductions. Many airlines have voluntarily invested in 16 G compatible seats in anticipation of a rule setting forth final specifications, with the understanding that 16 G compatible seats would be accepted under the new rule. In addition, more than 67,000 passenger seats ? approximately 12 percent of the fleet ? meet all of the criteria in FAR 25.562."

Airbus:

"The relatively high costs of $285.7 million or 55 percent of the overall undiscounted total costs of the SNPRM for the upgrading of cabin attendant seats questions the need for replacement."

Boeing:

"The FAA is proposing an overwhelming investment in seating upgrades at a time when the entire commercial transport aviation industry is struggling to survive. This proposed regulation is not consistent with the Safer Skies industry-government partnership intended to direct safety investment where it has the most leverage.

"The cost/benefit analysis supporting the 16 G Seat Retrofit Rule must be re-examined. There are fundamental, fatal flaws in both the analysis of benefits and the analysis of costs. ...

"Finally, if the FAA finds it necessary to implement a regulation for retrofit of seat upgrades, current FAA policies for the certification of passenger and flight attendant seats will make this effort cumbersome and costly."

Takeo Kawakita:

(Takeo Kawakita is chairman of the organizing committee for IREI Air Safety, a voluntary group of bereaved families from the 1985 crash of a B747 at Uenomura, Japan, which killed 520 and severely injured four).

"Torao Imanaru, a dentist who examined the bodies, wrote in the report issued by the Gunma Prefecture Dentists Association, 'The bodies of stewardesses seemed to be less damaged thanks to their rear facing seats. Passengers' bodies were cut by lap belt of forward facing seats.' ... While it is well known by the public that aircraft crashes give disastrous damage to the people on board, it is almost not known that there exists such a technical safety discrimination between the passengers and cabin attendants. ...

"After the bereaved families from the JAL123 crash knew that the passengers had mainly died of fatal injuries at head and abdomen caused by the interaction with seats, IREI Air Safety earnestly demanded that JCAB [Japan Civil Aeronautics Board] take the lead in developing passenger seats that will give safer protection to the occupant ... Responding to our request, JCAB decided to run a 3-year project ... to develop two kinds of safer seat, rear- facing seat and seat with shoulder harness. The team [comprised] of various companies in aircraft industry succeeded in developing two new kinds of model that passed the dynamic tests using dummy. The seats were [also] tested by actual use in freighter and were proved to be usable. Presently, the above new prototype models have never been used in actual airline passenger aircraft."

Fran?ois Braun:

(Fran?ois Braun is an independent consultant to the Directorate General for Transport of the European Commission):

"[It] is suggested that the scope of FAR 25.562 be recognized as applicable to the specific case of [a] passenger's seat equipped with three point shoulder harnesses, as it is described for the cabin attendant's seats."

National Air Disaster Alliance/Foundation (NADA/F):

"If the directive from the Airport and Airway Safety and Capacity Expansion Act of 1987 had been promptly implemented, hundreds of people would be alive today. The technology and financial resources for improved seats in airplanes have been available for many years, and it is inexcusable to delay all or part of this rulemaking any longer. ...

"We recommend that any consideration for cost benefit analysis be put aside, as the airlines have demonstrated that cost benefit analysis was not a reason for the delays of 15 years. Airlines have quickly retrofitted passenger seats for marketing reasons to give passengers increased leg room, or re- configure seats per class of service, and we believe saving lives is more important than marketing."

International Brotherhood of Teamsters, Airline Division:

"In the 16 years since passage of the [Airport and Airway Safety and Capacity Expansion] Act, and the intervening 15 years since the initial rule was proposed, advances in technology, testing standards, and the introduction of new materials, cause the original and supplemental notices to be antiquated when measured against the benchmark established by Congress. During this same intervening period (1988-2003), the automotive industry has implemented 18 occupant safety regulations issued by the National Highway Transportation Safety Administration (NHTSA). The FAA's failure to act more expeditiously and in concert with the intent of the law is disappointing. ...