The reporter has raised a safety concern regarding the lack of a safety briefing when seated at the left side overwing exit and the unavailability of a 'safety on board' card.
The reporter states that on a recent flight on (aircraft registration), upon scanning their boarding pass at the gate, a ground staff member notified them that they were sitting at an overwing exit and asked if they would be willing to assist in the event of an emergency - to which the reporter agreed.
The reporter advises that during boarding, there was no overwing exit brief provided by the cabin crew member allocated to the overwing exit. After hearing the passenger safety briefing over the PA and mention of the 'safety on board' card, the reporter states it was apparent that there was no safety card available for the passengers in the overwing exit seats in the seat pockets / stowage in the rear of the seats in front.
The reporter asked the cabin crew member allocated to the right overwing exit about the overwing briefing and also about the safety card and was advised that an overwing briefing was not required due to it being a 'crewed' exit, and that the safety cards for seats D and E were located in a stowage on the sidewall in the row behind, next to seat F - obscured by the passenger seated in that location.
The reporter expressed further concern regarding the apparent dismissive attitude from the cabin crew member to provide safety information when requested.
[Operator] takes every measure to ensure the safety of its aircraft, crew and passengers whilst onboard, and we appreciate any concerns that are raised to ensure we are providing the safest possible service.
The aircraft [model] is equipped with ‘full door’ exits as per the diagram below (provided to the ATSB), and as such does not have ‘overwing exits’ mentioned by the reporter. Each of these exits are controlled and operated by crew and are not required to be operated by passengers in the event of an emergency.
[Operator] appreciates that the reporter was asked to assist crew in the event of an emergency, however this was for the purpose of utilising ‘able bodied passengers’ (ABP’s) should they be required to assist the egress of passengers in such an event. The reporter may have been expecting an emergency exit briefing, as is required for aircraft with passenger operated ‘overwing exits’, however this is not necessary on this aircraft type as all doors are crew operated.
[Operator] would also like to highlight that all passengers are provided with a safety on board card as per [Operator's] policy. For this aircraft configuration the passenger safety on board cards are located in a side pocket of the fuselage wall indicated by orange arrows in the diagram.
[Operator] appreciates that this is not the common ‘seat back’ location; however, is necessary given that the space is too large between the passenger’s seat and the seatback of the passenger in front for seatback storage. Additionally, standard procedures ensure that additional safety on board cards are carried in the event that one is damaged or missing. It is an [Operator] requirement that cabin crew pre-flight checks ensure that all passengers are provided with a safety on board card, as required by CASR 121.280(1).
In light of the review of the briefing requirements contained within the exposition of the Operator's manual, CASA believes that the matter does not require any further action. [Operator's] response addresses the concerns of the REPCON by successfully outlining procedures and policy for the aircraft type that does not require the briefing of a passenger at exits that are primarily operated by cabin crew and only requires a passenger to be abled bodied.
In regard to the safety card location [Operator] has outlined within the REPCON that the cards are available to all passengers stowed within a side pocket of the fuselage.
The ATSB sought further clarification from the Regulator:
The ATSB notes that in regard to the safety cards, the procedure for ensuring passengers all have access to one does not appear to have been addressed. Photographs taken by the reporter show that safety cards for the exit row are located in a row behind the passengers and further obscured by passengers seated in the row behind. Without any briefing from the crew as to where to find the safety card, and no ability for the passenger to access them, the reporter would like some clarity on how CASA is satisfied that safety cards are available to all passengers.
Regulator's further response:
CASA provides legislation which outlines within Division 1 of Chapter 8 of the Part 121 Manual of Standards of what must be included within a safety briefing card. To this part there is no non-compliance with what we find in the passenger’s information within the REPCON and Operator’s response.
CASA provides further guidance material (GM 121.280 Safety briefing card) ensuring the card is available to each passenger and Advisory Circulars (AC 121-04 passenger safety information) which contain information for the operator’s consideration.
It is important to note that Guidance material (GM) is non-binding material issued by CASA which helps to illustrate the meaning of a requirement or specification and is used to support the interpretation of CASR.
[Operator] has provided evidence within the REPCON response on 'how' they, as the operator, ensure the card is available through pre-flight checks of cards and supplemental cards if one is found not available.
The operator further advised the ATSB that they had been in contact with the Regulator and it is their view that as the subject safety briefing cards are not emergency exit briefing cards, their in-flight announcement (excerpt provided to the ATSB) stating that the safety briefing cards are located in the seat pocket satisfies the 'where to find it' requirement of CASR 121.280. The operator advised that CASR 121.280 does not require to state the direction/bearing or distance to the seat pocket from the seat.