Call me persistent, call me stubborn, call me crazy–what started as a small test and evaluation of aviation life rafts nearly 20 years ago for The Aviation Consumer has finally resulted in a new and vastly improved SAE Aerospace Standard for aviation life rafts, AS1356. This new standard addresses many of the serious deficiencies that I uncovered in a series of three groundbreaking life raft evaluations, as well as subsequent tests.
Over a decade and a half ago I first got involved in the SAE International Aerospace Council, Aircraft Division, S9 Cabin Safety Provisions Committee and S9A Safety Equipment and Survival Systems Sub-Committee. These committees develop standards, procedures and recommended practices for related systems on transport category aircraft, some of which, such as this life raft standard, are also applicable to General Aviation. The SAE aerospace documents generated by these committees form the basis for many new, revised and updated TSOs (Technical Standard Orders), ACs (Advisory Circulars), and FARs (Federal Air Regulations) issued by the FAA. I am the only consumer and General Aviation advocate that sits on these committees.
One of my prime motivations to joining these committees was those disappointing early evaluations of aviation life rafts. Since the FAA was already moving towards using SAE standards to develop new and updated TSOs (the standards to which aviation devices must be certified), it seemed like a unique opportunity to help change things for the better. The then Aerospace Recommended Practice ARP1356 for Life Rafts came up for review in 1999 and at the request of the FAA, S9 undertook the task of converting it to an Aerospace Standard that the FAA could use as the basis to update TSO C70a, the existing life raft TSO.
Thirteen years later, AS1356 – Life Rafts has finally been published. It is not a record for time taken to update a standard, but it is up near there. I’d love to tell you we are now done, but this is only the first step. Next the FAA has to review the AS and write a revised TSO C70b that incorporates this AS. That process is itself fraught with potholes. The FAA can simply accept AS1356 as written, or it can add requirements that may go beyond those in the AS and/or it can roll back some of the advances we have incorporated. It is likely that the new TSO will only apply to new life raft certifications and old designs will continue to be manufactured in accordance with prior, less stringent approvals.
Then, once the FAA has initially developed the revised TSO, they will publish a Notice of Proposed Rulemaking (NPRM) giving everyone, including the public, a crack at the proposal (more on that later, as well). Submitted comments, pro and con, will then need to be dealt with by the FAA and may result in further revision to the TSO before the final version is published. On rare occasions a further NPRM is published, if the changes are significant. This process could take anywhere from a year or more. I wouldn’t bet on an easy and quick rulemaking process.
AS1356 was developed through a collaborative process that is typical of standards development by the many standard setting organizations that exist. Ideally, all the interested parties from industry, government and, in this case, end users, work together to arrive at a consensus, which generally means that everyone has to compromise to some degree. The end result is equal parts liked and disliked, but all have bought into the final version.
The original draft of AS1356 by myself and Tom Anderson of Goodrich, those many years ago, was a compilation of the lessons learned from the groundbreaking Equipped To Survive life raft tests and evaluations and Tom’s decades of experience in the life raft business and as an FAA Designated Engineering Representative at Goodrich. We’d seen the good, the bad and the ugly, and this was a unique opportunity to aim towards the best. In the end, I think the result is pretty damn good, if not the very best it might have been, but that it the nature of this process and by and large it works.
While AS1356 doesn’t go as far as I would have liked in some respects, this new standard is a huge step forward compared to the existing inadequate TSO C70a, which is hopelessly outdated. Using TSO C70a and ARP1356 as a start, no section was left untouched and all were improved, many dramatically.
With only a few problematic exceptions, the new requirements are now performance based, meaning that how the designers and engineers attain the required performance is not mandated, just the end result. Performance based standards don’t tell you what to build or how to build it, they just lay out what level of performance, in terms of a testable goal, needs to be met. This allows for more innovation as new technologies are developed and we are no longer saddled with decades-old mandated technology. Not every single part of the standard could be so specified, there are still a few areas where testing would be so difficult or expensive that mandates are still included, but the vast majority are performance based.
We also strove to ensure a level playing field for all manufacturers and to protect end users by closing obvious loopholes and spelling out previously vague or ill-defined requirements. These flaws allowed life rafts to be approved in the past that really did not meet the existing TSO without straining credulity and some gave a particular manufacturer an advantage over others. It has to be understood that the FAA does not have much, if any, technical expertise in life raft design and manufacturing. So, when approving a TSO, in the past it has been relatively easy for a persuasive sales engineer to convince the FAA representative(s) involved that a particularly inventive interpretation was valid. Some other manufacturer may not be so “lucky.” Hopefully, there will be far fewer opportunities for that to occur with AS1356. This helps ensure that the end user who is depending upon this life raft to save their life is really getting the minimum level of lifesaving performance they should expect and nobody is penalized in the market.
In a number of instances we compromised by adopting somewhat less stringent standards for large life rafts used in transport category aircraft compared to smaller life rafts used in General Aviation aircraft. This was rationalized by the fact that these smaller life rafts are subject to potentially more adverse conditions for longer periods of time due to the diverse nature of General Aviation flying and because the larger life rafts used in transport category aircraft generally have trained crews and their size alone compensates for some otherwise more problematic issues. I didn’t always agree with some of these compromises, but as indicated, that is often the price paid for moving things forward and we worked hard to hold the line where it counted the most. Generally, I believe that we succeeded. This standard is somewhat unique in that it covers life rafts ranging from one- and two-persons to over 50 persons. There are, indeed, some practical differences between the aircraft on which they are carried and the likely circumstances of use in an emergency.
You’re probably wondering where the link is to the new AS1356. Well, that is another ongoing frustration. If you want to review it, which you ought to be able to do freely in order to understand and comment upon it, as is your right, you have to pay SAE $66. SAE does make its standards available for you to review at a very few selected libraries and document repositories, but it does not generally make them easily and readily accessible to the public, absent some extraordinary action.
In any case, as the NPRM process moves forward I will be publishing my extensive comments submitted to FAA so that anyone interested will be better able to understand the document and why these changes are critical of improving aviation safety.
Thirteen years is a damn long time and a lot of travel to committee meetings held all over the U.S. I estimate that it has taken somewhere around $30,000 to fund my participation in S9 over these past 13 years! While this standard was not the sole reason I participate in SAE S9, it has been one of the driving forces. ETS doesn’t get financial support from industry or the government for these activities. I am the only advocate representing you, the GA pilot or airline passenger, at these meetings. Please consider making a contribution to support my work on your behalf.