The reporter has raised a safety concern in relation to the emergency exit row seating policy on board the Part 121 operator's [aircraft type].
The reporter advised they travelled from [Location 1] to [Location 2] on [flight number] on [date]. The reporter observed that the flight was not full and that the emergency exit row was not occupied despite a number of able-bodied passengers occupying other seats in the cabin. The reporter further advised, in the case of a water ditching emergency, the only exits recommended on the emergency information card are the [wing] exits. The reporter queried the flight attendant about the procedures should an emergency ditching take place and was informed that it was company policy to have the exit rows unoccupied if possible.
The reporter is concerned that in the event of an emergency, should the flight attendant be incapacitated, or indeed in the rush to evacuate the aircraft the flight attendant cannot reach the emergency exits, that this may compromise the safe operation of the emergency exits. Further, passengers are not provided with a safety briefing or training in the operation of the emergency exits.
The reporter finally queries the [operator]'s rationale behind the seating policy including whether a relevant risk assessment has been conducted.
Thank you for providing [Operator] an opportunity to respond to a safety concern raised under the ATSB confidential reporting system.
[Operator] is committed to upholding the highest levels of safety and compliance within our operations and we take all safety concerns raised seriously. Our subject matter experts have now reviewed the emergency exit row seating policy concern highlighted by the reporter and we provide the following response.
[Operator] is an Australian registered operator with an Air Operators Certificate approved by the Civil Aviation Safety Authority of Australia. The [Location 1] to [Location 2] sector is operated under our CASR Part 119 Instrument of Approval, as a CASR Part 121 operation on our [aircraft type] series aircraft.
The [aircraft type] series is configured to a single class, [xx] seat layout, as shown in the seat map (supplied to the ATSB and CASA). On [date], the aircraft was not operating to full passenger capacity.
Emergency exit row seating is a 'value added' option available for purchase to the travelling public, on this particular sector, there had been no passengers who opted to purchase this option on this flight.
In respect to ditching procedure concerns raised in this report, [Operator] has clearly prescribed, trained and risk assessed procedures for a prepared or an unprepared ditching, with or without able-bodied passengers (ABPs) seated at usable emergency exits.
While no airline can reasonably account for every possible emergency scenario, these procedures are constantly being risk assessed and reviewed as part of continued safe operations and industry best practise.
I can confirm that [Operator] complies with all Civil Aviation Safety Regulations in respect to emergency exits and evacuation procedures for this type of aircraft, of particular reference, CASR 121.270 and CASR 121.630.
On behalf of [Operator], we would like to thank the reporter and encourage further feedback either formally or informally via our customer care team. The safety discussions raised herein have driven a timely review of our related [aircraft type] risk assessments and affirmed our position on this matter.
Thank you for the opportunity to review this REPCON. CASA has reviewed the report and the operator’s response and confirm the operator’s procedure complies with relevant regulatory requirements.
CASA provides guidance to operators regarding exit row seating, with the strong encouragement that having at least one suitable person seated at unstaffed exit rows or at an exit where one crew member is responsible for a pair of exits during critical phases of flight, will aid in the timely and safe exit of passengers during an emergency evacuation and reduce the possibility of injuries and loss of life. Examples of this include:
AMC 121.270 (p63) states that an operator establishes procedures for assigning passengers into emergency exit row seats such that:
- a passenger occupies an exit row seat on each side (not staffed by a cabin crew member) during taxiing, take-off, and landing unless this would be impracticable due to a low number of passengers or it might negatively impact the mass and balance limitations
- if procedures cannot be reasonably implemented at the time of passenger check-in, there are alternative procedures established to ensure that appropriate seat allocations are made on board.
Multi-part AC121-10 (p8) states that:
- having at least one suitable person seated at unstaffed exit rows or at an exit where one crew member is responsible for a pair of exits during critical phases of flight, will aid in the timely and safe exit of passengers during an emergency evacuation and reduce the possibility of injuries and loss of life.
Procedures related to specific operators, and their unique operating environments, are evidenced through an operator's Safety Management System, and consideration of risk associated with an emergency evacuation. This is regularly reviewed by CASA as part of our regulatory oversight of all operators.