Business jet accident shows the value of exceeding regulatory requirements for flight attendants.
By Wayne Rosenkrans
AeroSafety World, October 2007
(Expanded version of article)
Some operators of corporate, charter and private flights in business jets use flight attendants to perform safety and service duties when this is not required by aviation regulations.1 Other operators say that a flight attendant would not be appropriate in the context of their overall safety strategy — and they instead train passengers to cope with cabin emergencies or depend entirely on the flight crew. Making someone responsible only for service-related duties in the cabin, however, falls short of the best safety practices currently recommended.
Deciding whether to voluntarily implement a three-person crew deserves a careful assessment of risks, costs and benefits, but there is no reason for any operator to begin with a blank sheet of paper. Extensive resources are available, from the regulatory requirements applicable to commuter and charter operations in business aircraft that have 19 or more passenger seats and cabin crew requirements for airlines to industry-developed standards and information included in accident reports. Some operators delegate preparation of a safety case to a consultant and/or hire a cabin safety specialist to launch a cabin safety and service initiative.
Circumstances of the February 2005 runway overrun at Teterboro, New Jersey, U.S., by a chartered Bombardier Challenger 600 brought into sharp focus the value of a flight attendant in corporate/charter operations (ASW, 3/07, pp. 30–36).2 The aircraft was destroyed by crash forces and postcrash fire after colliding with vehicles on a freeway and a warehouse. The flight crew received serious injuries. The nine passengers, including one “cabin aide” — a customer service representative provided by the operator — received minor injuries.
This accident has raised interest in the current rewriting of U.S. Federal Aviation Regulations (FARs) Part 135, Commuter and On-Demand Operations and Rules Governing Persons Onboard Such Aircraft, and in advanced cabin safety practices like those the European Aviation Safety Agency (EASA) embedded in January 2007 interim rules applicable to specified commercial flight operations.3
One of the U.S. National Transportation Safety Board (NTSB) findings said, “The cabin aide did not perform a seat belt compliance check before the accident flight, which resulted in two passengers being unrestrained during the accident sequence.” Another said, “The cabin aide’s training did not adequately prepare her to perform the duties with which she was tasked, including opening the main cabin door during emergencies.” One of the accident report’s four safety recommendations focused on the risk of passenger confusion about any cabin aide’s role and qualifications.4
A separate survival factors report also cited confusion about who was responsible for the preflight passenger safety briefing; the cabin aide’s misreporting to the flight crew that the cabin was secure for takeoff; the beverage service conducted during takeoff with glasses and ceramic/china cups; the cabin aide’s unfamiliarity with evacuation procedures and the emergency operating mode of the main cabin door; and the cabin aide’s departure from the aircraft and accident scene before accounting for everyone on board.5
The passengers told investigators that when the airplane came to rest, the cabin was dark and they did not realize immediately that it was burning. They assumed that the cabin aide was a flight attendant trained to conduct an evacuation, but initially they could not find her, they heard no evacuation commands and they heard no answer when they asked her how to open the main cabin door.
By comparison, an EASA rule to prevent such scenarios says, “An operator shall ensure that all cabin crewmembers wear the operator’s cabin crew uniform and are clearly identifiable to the passengers as a cabin crewmember. Other personnel such as medical staff, security staff, child minders, escorts, technical staff, entertainers [and] interpreters who undertake tasks in the cabin shall not wear a uniform which might identify them to passengers as a cabin crewmember, unless they comply with [regulatory requirements for cabin crew safety training].”
Comprehensive investigations of flight attendants’ actions in corporate/charter accidents have been atypical for the NTSB but now will be more likely, whether future accidents are assigned to a regional office or to a “go team” sent from headquarters. “This was the accident that really highlighted the issues of — what they called — cabin aide training,” said Nora Marshall, chief, NTSB Survival Factors Division. “We were concerned when we heard that passengers were thrown out of their seats and were unable to locate seat belts on the divan. We asked our regional investigators to notify us if they find those problems in future accidents because we would like to investigate and document that type of information. Seat belt usage is one of the building blocks of crashworthiness; it is essential and a fundamental of occupant protection in an accident. The NTSB believes that if there is someone on board the aircraft who could be perceived as a trained crewmember, that person should have proper training. The NTSB did not ask for cabin attendants to be required, it said that if on board, they should be trained and effective for emergencies.”
Several of the passengers — because of differences compared with flying on their own company’s Challenger — had been surprised to be greeted by a person who the NTSB found was “dressed in a crewmember-appearing uniform,” served them beverages and occupied the cockpit jump seat for takeoff but did not conduct a pre-takeoff safety briefing.6
“The passengers assumed — as most people would — that this person was a flight attendant, someone that you would see in a Part 121 airline operation, which in this case she was not,” said Jason Fedok, the NTSB survival factors investigator for this accident. “When there is a cabin aide on board, flight crews may be tempted to delegate some of their safety-related responsibilities — such as the safety briefing — to this ‘crewmember’ when, in fact, he or she may only be a caterer or server with absolutely no safety training.”
By documenting survival factors involving corporate flight attendants, flight training organizations and other industry groups should be able to improve their operations even before the U.S. Federal Aviation Administration (FAA) decides whether to introduce a new requirement, Marshall said. “We made the strongest safety recommendations that the evidence supported, but that does not mean that these were the only lessons,” she said.
One lesson derived from the Challenger pilots’ difficulty in extricating themselves from the cockpit, was that “the pilots are not always available — this time it actually was a passenger who got the door open in an environment that they needed to get out of,” Fedok said.
The NTSB has watched the airline industry, over a period of decades, shift the balance of in-flight service from a “hostess mentality” of focusing on passenger comfort issues to currently putting safety first as safety professionals. “The same evolution needs to happen in the corporate/charter world,” Marshall said. “We would like to see operators — without sacrificing the quality of their current cabin service — consider safety as their most important service, as vital as any other part of the flight. I tell corporate operators, ‘You can have beautiful service and a lovely cabin, but if you have an emergency and cannot provide safety, you are not serving your customers.’ Corporate/charter passengers expect an extremely high level of professional service during normal operations, and they also should expect an equivalent high level of professionalism during any kind of emergency situation. Their lives may depend on it.”
Not As Expected
Flight Safety Foundation safety auditors discourage the use of cabin aides for one main reason. “You cannot tell passengers that the person serving them is less than fully qualified — that would only confuse them,” says Darol Holsman, FSF manager, safety audits. The same principle applies to substituting in this role any pilot or maintenance technician who has not cross-trained as a flight attendant.
Holsman said that he has been “disappointed” lately by some corporations’ reluctance — in spite of FSF efforts — to voluntarily integrate a flight attendant into the crew complement of cabin-class business jets for the sake of passenger safety. Corporate/charter operators typically consider a flight attendant only if they fly something like a Challenger 600, 601, 604 or Global Express; a Gulfstream GIV/4 or GV/450/550; or a Dassault Falcon 50, 2000 or 900, he said. Assigning flight technicians — maintenance technicians cross-trained as flight attendants — appears to have declined because of the difficulty finding enough maintenance technicians, he said.
The FSF audit team has promoted hands-on cabin emergency training for frequent-flier corporate executives, especially when a flight attendant cannot be assigned. “Passengers taking hands-on training should be good leaders who are willing to take care of the people traveling with them and to make sure that everyone gets off the airplane without smoke inhalation or injury from the evacuation,” Holsman said. “What is lacking in that approach, however, is any guarantee that those who receive training have the discipline in an emergency to get people off the airplane in a hurry. You have that confidence with a flight attendant’s training, experience and background. More than 90 percent of pilots we interview have a high level of confidence that the flight attendant could evacuate the passengers during an emergency.”
As a best practice, the FSF audit team recommends that flight attendants pass a medical assessment every 24 months to the standards of an FAA second-class medical certificate or better.
Refreshing ICAO SARPs
A proposal to modernize International Civil Aviation Organization (ICAO) standards and recommended practices (SARPs) relevant to business aviation would require operators to make a decision about using flight attendants but would not change the existing requirement for a flight attendant only in airplanes with 19 or more passenger seats (ASW, 5/07, pp. 25–26). Indications from states’ comments on this element of the proposed amendment to ICAO Annex 6 — Operation of Aircraft, Part II, International General Aviation — Aeroplanes suggest no difficulties in gaining acceptance, said Peter Ingleton, director, ICAO liaison, of the International Business Aviation Council (IBAC). The proposed applicability date of the overall amendment is November 2008.
As IBAC and the International Aircraft Owners and Pilots Association developed the amendment proposal, which was subsequently reviewed by the ICAO Secretariat and the Air Navigation Commission, they “looked very carefully at mirroring existing cabin crew–related SARPs from Annex 6, Part I, International Air Transport – Aeroplanes, where feasible,” Ingleton said.7
IBAC’s voluntary code of best practice, the International Standard for Business Aircraft Operations (IS-BAO), says, “The minimum number of cabin crewmembers shall be in accordance with national requirements” and operators “shall ensure that each cabin crewmember has fulfilled the requirement of the operator’s ground and flight training program [with initial and annual training covering aircraft type training, safety procedures training, emergency procedures training initially and every two years, first aid training and aircraft-surface contamination training].” In addition to specifying functions or actions to be covered in emergency procedures training by all aircraft crewmembers, IS-BAO recommends “particularly for aircraft without [flight] attendants, that passengers that fly frequently receive emergency procedures training.”
Flight attendant training already is a major part of the U.S. National Business Aviation Association (NBAA) Standards of Excellence in Business Aviation (SEBA) program, which encourages continuing education within the business aviation community. Adhering to SEBA, a flight attendant typically would begin a career as a corporate cabin crewmember at the first level, then progress to successively higher levels as a senior corporate cabin crewmember, lead corporate cabin crewmember and manager/supervisor corporate cabin crewmember. It establishes a set of common expectations between flight attendants and aviation department pilot-managers, says Jay Evans, director, operations, and staff committee liaison to the NBAA Flight Attendants Committee. “It gives the individual flight attendants and the person who employs them an understanding of what the professional qualifications should look like [at each level].”
The NBAA has promoted the voluntary use of flight attendants by awarding a total of 261 scholarships since 2000, identifying training organizations and attracting flight attendants to business aviation. Flight attendants also have been strongly encouraged to complete the NBAA certified aviation manager program.
Endorsement of professional training of flight attendants has permeated NBAA activities, Evans said. “The NBAA Management Guide also emphasizes that a flight attendant is aboard for safety — ensuring that the flight crew is briefed properly, exits are managed properly, emergency equipment is prepared, and the passengers briefed and ready to go,” he said. “In so many instances, we know that a properly trained flight attendant responded properly and saved lives. Being there and handling the situation made a difference.”
Voluntarily implementing a three-person crew in a cabin-class business jet can begin with just one manager’s commitment to the value of having a flight attendant and the belief that this will contribute to the level of safety, says Doug Schwartz, manager, Global Aviation Services at ConocoPhillips. “Some aviation department managers devote very little time to considering this practice; others see this as a high priority, devoting a considerable amount of time, and they are willing to argue for it with their own management,” Schwartz said.
His company takes the position that within the logistical confines of the size of the airplane, the minimum crew for a business jet with a flat floor and wide cabin is two pilots and a flight attendant. Logistics come into play because in some airplane types, there is no room in a full cabin for a flight attendant to walk back and forth or even to stand up, he said.
This is not unlike the process of deciding whether to voluntarily carry an automated external defibrillator (AED) on every airplane. “It is a crazy irony that managers see huge value in the AED but do not want a flight attendant aboard to operate it,” Schwartz said. They typically expect the pilot monitoring to go to the cabin to operate the AED. “But I ask them, ‘Is that where you want your pilots — administering first aid to a passenger rather than flying the airplane? If you have the resources for an AED program, why would you hesitate to use a flight attendant?’”
The commitment to using a flight attendant should extend to cabin safety policies, procedures and training. Unlike the airlines, the decision about whether a flight attendant flies only on certain flights or on all flights is left to the discretion of the operator. The criteria typically include how many passengers are in the airplane, low long the flight will be, whether it will be over water/international and whether it will include hot meals, Schwartz said.8
An aviation department manager typically must be able to explain to senior corporate executives why the company should use flight attendants and how the new function will be managed. “If you use flight attendants, how do you recruit them?” he said. “What characteristics and qualifications are required? Do you network or outsource? Full-time or part-time people? Do you have different qualifications for full-time and part-time people? In any case, if you use a flight attendant, how does the flight attendant fit into the crew? Is he/she just an additional person in the back of the airplane or an integral part of the crew? Procedurally, how do the pilots and flight attendant communicate and interrelate? What kind of briefing do the pilots conduct for the flight attendant?”
This commitment also implies a mindset that, just like the pilots, the flight attendant is a necessity regardless of regulations. “The philosophy is not two pilots and a flight attendant, it is a minimum crew of two pilots and a flight attendant,” Schwartz said. “If cabin safety is going to be an integral part of flight operations, the interactions between the flight attendant and pilots need to be just as well scripted as between the flight crewmembers.”
Judith Reif, president and contract flight attendant for JR Flight Services and a member of the NBAA Flight Attendants Committee, argues that business aviation operators’ crewing decisions should be based on safety issues, not arbitrary factors.
“Flying domestically, some operators feel that a flight attendant is not needed and that the pilots can attend to the passenger needs,” Reif said. “Anything could go wrong at any moment, however. We are an asset to the pilots, and we can be their eyes and ears in the cabin.”
Except for breaks on long flights, pilots need to be in the cockpit. “Once a pilot steps out of the cockpit, the flight is a single-pilot operation, which becomes a safety issue,” Reif said.
Because few regulatory requirements govern the work of so many of the flight attendants in business aviation, some training organizations aim to empower them with more aviation education than in the past. This contrasts sharply with the old idea that trainers should focus on procedural competency rather than understanding, says Colette Hilliary, program manager for cabin safety and flight attendant training, FlightSafety International.
A strong focus on crew resource management, understanding dynamic variables and informed decision making under the stress of an emergency situation or outside the normal scope of responsibility constitute the new model. “We have always trained on classes of fires and different extinguishers,” Hilliary said. “Now we are focusing on what happens if the flight attendant must use an extinguisher other than the recommended type for the class of fire encountered. It is important to know what to expect and how to counter that reaction.”
Other examples are familiarization with the general operation of aircraft radios; hands-on operation of a quick-donning oxygen mask; operation of jumpseat adjustment and harness release for extrication of an incapacitated pilot; and vigilance looking for hazards outside the airplane during ground operations, especially while taxiing and while in the hangar. Some operators also train their corporate flight attendants to shut down the aircraft engines and/or auxiliary power unit in an emergency.
Medically approved mixed-gas training equipment — an alternative to the hyperbaric chamber — also has been installed inside the cabin trainer to provide corporate flight attendants an optional training enhancement to experience their individual symptoms of hypoxia. This training has been highly effective, she said.
Among her recent insights into current practices of corporate/charter operators, Hilliary has learned that operators increasingly ask contract flight attendants to present documents that validate their currency. “I have seen an increasing number of contract flight attendants who are keeping up their basic qualifications and maintaining their currency on an annual basis,” she said. Another insight is that more of the corporate/charter pilots taking recurrent crew emergency training tell their instructors, ‘We have a flight attendant now.’”
In the context of airline layoffs and increased awareness of corporate aviation, she also has seen more people in corporate flight attendant training who have an FAA certificate of demonstrated proficiency, which must be issued through an airline or Part 135 operator.9 “We have a lot of contract trainees who inquire whether they will be issued an FAA flight attendant certificate” after completing a course, Hilliary said. More chief pilots and directors of aviation also are inquiring whether the contract flight attendant has this FAA certificate, which has parallels with the standardization of professional pilot training, she said.
Because of increased FAA surveillance of the operational control of charter flights, such as under FAA Notice 8000.355, Inspector Guidance for Part 142 Training Centers, operator responsibility for ensuring training — including Part 135 flight attendant training — has come to the forefront in 2007. Operators are expected to be diligent in identifying all personnel who need training before flying charter trips, for example. “We have trained FAA inspectors for the past 10 years with respect to emergency and survival equipment,” Hilliary said. “The course also includes proving runs, evacuation demonstrations and training requirements. In October 2007, we will offer a segment of that course to the industry along with modules that focus on adhering to the guidelines of this notice.”
The current standard in business jet flight operations is flight attendant training specifically designed for corporate/charter flights, says Doug Mykol, N.D., president and CEO of AirCare Solutions Group, which includes FACTS Training. The solution has become advanced full-motion simulators for flight attendants with representative galleys, actual exit-opening mechanisms, standard emergency equipment, smoke and fire simulation, and realistic sounds, Mykol said.
Training organizations also have been advocates for wider use of flight attendants in business aviation. “My estimate is that 60 to 70 percent of the cabin-class business jets have a third crewmember on every flight,” Mykol said. “Our position is that anytime operators have a stand-up cabin — whether six or 14 passengers — they really should have a trained third crewmember. We find that everybody is happier, the safety mindset is in the forefront, workloads are shared between all three crewmembers, there is another set of eyes as backup for pilots, and flight operations are smoother as long as the flight attendant is treated as a crewmember and not as just a host or hostess.”
The FACTS checklist for flight attendants has been accepted by regulators as documentation of competence using aircraft-specific safety equipment, Mykol said. “After training, they know where everything is, how to release brackets, how to use the on-board emergency equipment — and it all goes into their training file,” he added.
Realistic Safety Briefings
In her experience, most passengers flying on corporate/charter aircraft have shown respect for the duties and responsibilities of the flight attendant, said Mary Lou Gallagher, owner of Beyond & Above Corporate Flight Attendant Training. “Whether a CEO or a nurse, they will follow any emergency procedure that the flight attendant directs them to do,” Gallagher said.
Yet behind the scenes at some Part 135 operators, confusion about regulations concerning a required flight attendant sometimes arises. “Operators do not realize that if required for a Part 135 flight with 19 or more seats, even a trained and current flight attendant cannot operate without the aircraft-specific indoctrination training described in the flight operations manual accepted by the FAA,” she said.
Passenger safety briefings before every takeoff and landing are no less important in corporate/charter operations than in airline operations, Gallagher said. “The owner may not want to hear about the location of the emergency equipment, but a flight attendant does not know what any passenger knows about the plane — such as whether there is a life raft on board and its location.”
Since the Challenger overrun at Teterboro, a greater number of cabin aides have completed the company’s corporate flight attendant course — typically at their own expense as freelance contractors. The extent of this training often was not appreciated beforehand by the cabin aides or their employers. “By the end, we will have put them through a ditching in which they had to put on a life vest, jump in the water, inflate the raft and get into the raft,” Gallagher said. “They are excited then because they feel very confident about using all the equipment on board.”
Demand for wider voluntary use of flight attendants could depend somewhat on passenger awareness. “Because there has been an explosion of people buying their own aircraft, and other people managing these aircraft, I do not think the people sitting in the back are as educated as they should be about who actually is in the cabin and their credentials,” she said. They are still assuming they know, Gallagher said.
- FARs Part 135.107 — similar to regulations in many countries — requires that an airplane with a passenger seating configuration of more than 19 passengers have a flight attendant in commuter and on-demand operations. There is no equivalent for corporate or private aircraft that operate under Part 91. Relatively few operators are believed to have a flight attendant aboard smaller jets and turboprop airplanes whether used or corporate, charter or private flights.
- NTSB. Runway Overrun and Collision, Platinum Jet Management, LLC, Bombardier Challenger CL-600-1A11, N370V, Teterboro, New Jersey, February 2, 2005. Accident Report NTSB/AAR-06/04, Oct. 31, 2006.
- European Union OPS Regulation 1899/2006 Subpart O Cabin Crew OPS 1.989 and 1.990. The regulations specify the maximum number of different aircraft types and variants that a contract cabin crewmember may fly in commercial operations. Other rules specify details such as cabin crewmember record-keeping of flight, duty and rest time; initial and recurrent training course content; conversion and differences training; refresher training after a six-month absence from flying duties; medical fitness assessments; crew resource management training; and the minimum hours and number of familiarization flights before flying as the only cabin crewmember.
- Safety recommendation A-06-69 says, “Require that any cabin personnel on board … Part 135 flights who could be perceived by passengers as equivalent to a qualified flight attendant receive basic [FAA-]approved safety training in at least the following areas: preflight safety briefing and safety checks; emergency exit operation; and emergency equipment usage. This training should be documented and recorded by the Part 135 certificate holder.” In January 2007, the FAA said, “The FAA is reviewing all current regulations and the recommendations of the Part 125/135 Aviation Rulemaking Committee (ARC) to identify possible method(s) of requiring that cabin personnel provided by the certificate holder, who could be perceived by passengers as equivalent to a qualified flight attendant, are appropriately trained in the identified safety areas.” Initial plans to address the issue with a Safety Alert for Operators and a notice to FAA personnel were revised, and in September 2007, the NTSB recommended that such guidance await revisions to Part 135, called the FAA’s efforts “responsive” and classified these steps as an “open acceptable” response.
- NTSB. “Survival Factors Group Chairman’s Factual Report.” Accident no. DCA05MA031. Aug. 26, 2005. The cabin aide involved in the accident received “informal” initial safety training lasting about an hour from another cabin aide, who had been trained by a third cabin aide who had completed a six-day corporate flight attendant training course, the report said. None of the cabin aides was required by any regulation to have flight attendant safety training for their employer’s type of operation.
- FSF Editorial Staff. “Assigning Seats to Flight Attendants Requires Care in Business Aircraft.” Cabin Crew Safety Volume 38 (May–June 2003).
- The amendment in part says, “The requirement for cabin crew for each type of airplane shall be determined by the operator, based on seating capacity or the number of passengers carried, in order to effect a safe and expeditious evacuation of the airplane, and the necessary functions to be performed in an emergency or a situation requiring emergency evacuation. The operator shall assign these functions for each type of airplane.” It also says, “An operator shall ensure that a training program is completed by all persons before being assigned as a cabin crewmember.” A related recommendation says, “An operator should establish and maintain a cabin crew training program that is designed to ensure that persons who receive training acquire the competency to perform their assigned duties and includes or makes reference to a syllabus for the training program in the company operations manual.” Other SARPs would cover maintaining a flight attendant’s consciousness during loss of pressurization and, in specified airplanes, providing a harness-equipped, forward or rearward-facing seat for the flight attendant to be ready for an emergency evacuation.
- Sheehan, John J. “The Case for Flight Attendants.” Journal of Business Aviation Safety. NBAA, Volume 21 (2006). Sheehan, president of Professional Aviation, safety auditor and consultant, said that other criteria include case-by-case discretion of the aviation department manager or chief pilot, transportation of customers and undefined special circumstances.
- FAA. “Flight Attendant Certification.” Flight Standards Information Bulletin for Air Transportation no. FSAT 04-07, Dec. 10, 2004.