Jump to Content
Mode Aviation
Reference No. AR201400115
Date reported 12 December 2014
Concern title A change in procedure relating to the charging of the emergency floor strip lighting
Concern summary

The concern related to a procedural change which the reporter felt would reduce the safety in the cabin if an emergency occurred and the cabin had to be evacuated.

Industry / Operation affected Aviation: Air transport
Concern subject type Aviation: Flight crew

Reporter's concern

The reporter expressed a safety concern regarding the change of procedure in relation to the charging of the emergency floor strip lighting prior to the first flight of the day.

The reporter advised that [location] does not have engineering coverage for the first flight of the day resulting in the flight crew having to prepare the aircraft. This is normally the first officer’s duty, but they are often required to assist the captain in planning the flight resulting in the departure being delayed, as the photo luminescent floor strip lighting has not had sufficient time to be fully charged.

The Boeing flight crew operating manual (FCOM) specifies that the floor strip lighting must be charged prior to the first flight of the day.

Recently, the operator’s pilots were informed of a procedural change to charge the floor strip lighting the night before the flight, instead of charging the lights prior to departure.

The Boeing FCOM does not allow for this procedure and the operator’s operations manual instructs pilots to refer to the FCOM if a conflict occurs.

Reporter comment: It is possible that if this –procedural is adhered to, an aircraft may depart without the floor strip lighting being fully charged. A safe passenger evacuation under these circumstances would be compromised in low light/smoke etc.

Operator's response (Operator 1)

In the interest of continual improvement and increased safety, we welcome all feedback on our flying operations. In relation to the complaint raised in the REPCON, this issue is known to our management team and has been raised within industrial forums. The matter relates to a reduction in sign on time for the crew. We appreciate the opportunity to respond to REPCON AR201400115 with regards to concerns raised about Photo Luminescent Emergency Lighting (PLEL) at this specific location.

The Flight Crew Operations Manual (FCOM) produced by Boeing is a pilot’s reference manual which is in part a shortened version of the Flight Manual. It contains information for the pilot relevant to the operation of the aircraft, but lacks the details offered in the Flight Manual.

The section relating to the PLEL system is generic because the system is an option and is available from more than one manufacturer. Hence, the limited amount of information and how generic in nature the pilot instructions are. The FCOM gives a brief description on operation and a statement relating to charging before the first flight of the day. I have copied the text from this manual below.

Photo luminescent floor proximity lighting

Photo luminescent floor proximity lighting is located on both sides of the aisle on the floor.

These strips glow to direct passengers to the emergency exits. These photo luminescent floor emergency lighting strips are charged by the ceiling lighting. The CEILING lighting control is located on the forward attendant panel. Prior to boarding passengers for the first flight of the day, the ceiling lighting must be set to the bright position, with overhead bin doors closed, for at least 30 minutes. Two external overwing escape path lights, one each located above and aft of the wing, provide illumination to the emergency escape paths on the wings and the ground below the wing trailing edge. The tailcone escape path lights, located at the top of the tailcone EXIT, provide illumination on the slide and the ground contacted area.

NOTOP [number] Photo Luminescent Emergency Lighting

Pilots are issued NOTOP’s to advise them of changes in procedure from time to time. NOTOP [number] was distributed because of a change in aircraft scheduling that required modifications to engineering support which affected the process of charging the PLEL system. The change relates to engineering staff recharging the PLEL system at the end of shift rather than the aircrew, this aligns the charging of the system with the daily inspection and enhanced engineering shift coverage.

Aircrew were asked to facilitate this process by closing the cabin overhead baggage lockers and ensuring that the cabin lights were on high prior to leaving the aircraft on the last flight of the day. Engineering would then charge the lights whilst carrying out the terminating checks. The new procedure complies with the requirements of the FCOM and ensures a safe charge is given to the PLEL system.

The charging requirements from the Aircraft Maintenance Manual (AMM) are listed below.

The Aircraft Maintenance Manual has a table for charging of the photo luminescent escape path lighting which shows as follows:-

 First Flight Charge Times REPCON AR201400115


Supplementary Type Certificate (STC)

STC’s are supplements approved by the aircraft manufacturer (Boeing) and attached to the flight manual giving the operator specific instructions on how to operate the system.

The related STC states that if the aircraft is operating in daylight the charging of this system isn’t required. We haven’t adopted this procedure because it’s not in the FCOM and it was decided that this would be confusing to our flight crew, hence the engineering solution.

A Non-technical objection (NTO) has been sought from Boeing to align the FCOM with the STC. A response from Boeing is anticipated shortly.


The last flight of the day arrives in [location] at [time] local time. If the engineers commence the charge of 45 min immediately, the tables from the AMM indicate that the system is capable of 14 hours before discharging. This allows the aircraft to remain in service through to 11:15 local time. Subsequent operation of the aircraft with the interior lighting ‘ON’ will cover the remaining requirements.

This procedure has been introduced to ensure that at a minimum the lights have a cumulative charge of 45 mins prior to the first flight of the day as stated in the FCOM.

The procedures described are tangible evidence of our commitment to the safety of our aircraft and the crew who operate them.

Regulator's response (Regulator 1)

CASA has reviewed the REPCON and the issue appears to be related to the planning of the maintenance required to charge the emergency lighting system rather than the ability of the pilot to carry out the maintenance without distraction. For aircraft used in regular public transport the pilot would not be permitted to carry out the maintenance as it is not listed as pilot maintenance in Manual of Standards Part 42. However, this should not be an issue if the maintenance is planned appropriately the system can be charged the night before, and this information should be recorded in the maintenance records to allow the pilot to easily identify how long they have until the aircraft must be dispatched before the system requires maintenance (charging) again.

From the report there appeared to have been an inadequate allowance for pilot pre-flight duties in the rostered flight duty period (FDP). The FDP did not appear to provide sufficient time before the first flight for foreseeable contingencies, such as those that required the first officer to assist with flight planning. In order to address this inadequate time allocation, it seems as though the requirement to charge the floor lighting has been re-scheduled to occur at the end of the previous flight and not the commencement of the first flight of the day. From the information provided it does not appear that there are clear maintenance/airworthiness and crew procedures in place to make sure the charge cycles adequately covers the rotation of the aircraft for the day. In addition, it appears that there may be further issues in relation to duty times and provision of adequate preparation time at the aircraft especially for the first flight of the day. Such a change should be managed in the organisation's change management process (managed via the safety management system) that should be applied in this case.

CASA is following this matter up with the operator to ensure the procedures adopted are in accordance with regulatory safety requirements. Should any deficiencies be identified appropriate action will be taken.

ATSB comment

The ATSB has been advised by the operator that this procedure has been withdrawn.

Share this page Comment
Last update 15 May 2015