A Safety Study of Survivability in Seaplane Accidents
Personal Flotation Devices
In view of the continuing vulnerability of the occupants of seaplanes in accidents on the water to drowning, and since nearly four-fifths of fatal seaplane accidents which terminated in the water occurred during the take-off or the approach and landing phase, the Board, having considered advances in permanent wear, damage resistant, inflatable life-jackets, recommends that:
The Department of Transport require that all occupants of seaplanes wear a personal flotation device during the standing, taxiing, take-off, and approach and landing phases of flight. A94-07
Transport Canada's Response:
Transport Canada Aviation (TCA) has identified a requirement to update the Life Saving Equipment Order, (A.N.O., Series II, No.8) and to improve life preservers currently in use.
During consultation with industry, operators of floatplanes and amphibians pointed out that life preservers are not rugged enough for everyday wear, are unsuitable for frequent donning and doffing and are expensive. Continuing research and development is being conducted by TCA to improve life preserver design. In addition, TCA will present the proposal to make the wearing of such devices a regulatory requirement to the Work Group of the Canadian Aviation Regulation Advisory Council (CARAC) which is currently developing recommendations pertaining to Life Saving Equipment requirements. The Work Group will be asked to assess the safety implications of the proposal.
There is a widespread concern in the aviation industry regarding additional risks inherent in the wearing of the life vests during the standing, taxiing, take-off and landing phases of flight. It is claimed that marine cushions that are in wide-spread supplementary use are more likely to aid in water accidents.
TCA will not legislate that all occupants of seaplanes wear a personal flotation device during the standing, taxiing, take-off, and approach and landing phases of flight until clear safety benefits can be quantified. The revised legislation will require the life preservers to be within was reach of each seated passenger. This will increase their availability to all the occupants in the seaplane.
Personal Restraint Systems
Although the majority of fatal seaplane accidents in the water involve drowning, approximately one-tenth of these victims were incapacitated from non-fatal impact forces. The availability and use of personal restraint systems could have facilitated a successful egress for many of these victims.
The amendment to ANO Series II, No. 225, which would require the fitment of seat-belts and shoulder harnesses and their use by flight crews on board small commercial fixed wing aircraft, has not been promulgated. Consequently, a significant proportion of Canadian seaplanes (most of which were manufactured before 1978) continue to operate without shoulder harnesses available--even for the flight crew. Given that the 1990 Sypher: Mueller study26 estimated that the front seats of aeroplanes could be retrofitted with shoulder harnesses for approximately $2,000, the Board does not understand TC's apparent reluctance to require retrofit.
In view of the vulnerability of seaplane pilots to drowning following non-fatal accident impact forces, the Board recommends that:
The Department of Transport require the fitment of lap belts and shoulder harnesses in seaplanes and require their use by all pilots during take-offs and landings before the 1995 seaplane season begins. A94-08
Transport Canada's Response:
The new Canadian Aviation Regulations (CARs) will address the requirement to install seat belts and shoulder harnesses in aircraft. Some of the relevant text in section 605.24 of the proposed Canadian Aviation Regulations General Operating and Flight Rules stipulates the following as a minimum requirements to which all Canadian aircraft will have to conform, among other things:
- no person shall operate an aeroplane, other than a small aeroplane manufactured before July 18, 1978, unless each front seat or, if the aeroplane has a flight deck, each seat on the flight deck is equipped with a safety-belt that includes a shoulder harness;
no person shall operate a small aeroplane manufactured after December 12, 1986, the initial type certificate of which provides for not more than nine passenger seats, excluding any pilot seats, unless each forward or aft-facing seat is equipped with a safety-belt that includes a shoulder harness;
- no person shall operate a rotorcraft manufactured after September 16, 1992, the initial type certificate of which specifies that the rotorcraft is certified as belonging to the normal or transport category, unless each seat is equipped with a safety-belt that includes a shoulder harness.
Canadian commercially registered aircraft will have to conform to these regulations as a minimum requirement. Section 602.116 paragraph (a) of the proposed Canadian Aviation Regulations General Operating and Flight Rules states:
"No person shall operate an aircraft unless; the crew members are seated at their stations with their safety-belts fastened during take-off and landing, and at any other time the pilot-in-command so directs;...."
The accident record seriously draws into question the attitude of some seaplane pilots towards basic safety measures. Even when shoulder harnesses were fitted in the aircraft, two-thirds of the accident pilots were not using them; some of them did not even secure the lap belt. Only half of the accident passengers who had shoulder harnesses available wore them--perhaps a reflection of the example set by their pilots. Similarly, despite the availability of life jackets on many of the accident aircraft, apparently few occupants wore them, or had a personal flotation device sufficiently close to use.
The Board recognizes that more stringent regulations alone will not alter current behaviour patterns which exacerbate the fatality rate. Furthermore, enforcement of regulations pertaining to seaplane operations in Canada presents a formidable challenge on a day-to-day basis. Nevertheless, in view of the continuing disregard of basic safety provisions by many pilots and operators in seaplane operations, the Board recommends that:
The Department of Transport implement a national safety awareness program, promoting the use of personal restraint systems and personal flotation devices in seaplane operations as soon as practicable; and (A94-09)
The Department of Transport investigate options for imposing strong sanctions on owners and operators who flagrantly disregard the basic tenets of safety in seaplane operations, and make public its findings within one year of the receipt of these recommendations. A94-10
Transport Canada's Response A94-09:
Transport Canada Aviation (TCA) concurs with the intent of this recommendation. A National Safety Awareness Program which focuses on the use of personal restraint systems and personal flotation devices will be developed.
This program will build on current initiatives under way in the Ontario and Pacific Regions which are aimed at ad dressing safety in seaplane operations.
Transport Canada Response A94-10:
Transport Canada Aviation (TCA) concurs with the current of this recommendation. It is TCA's current policy to take strong enforcement action against any operator who flagrantly violates the aviation safety rules. In addition, the Legislation and Compliance Branch publishes annual statistics on national compliance activities. Regional Compliance Offices pay particular attention to seaplane operations every year in their annual surveillance activities.
The authorities to impose strong sanctions for violations of the aviation safety rules are provided in the Aeronautics Act and the Criminal Code. These authorities must be exercised equitably and fairly in respect to all operators, regardless of the nature and location of their business.
To target any specific member of the aviation community for higher sanctions or penalties, may be considered contrary to the intend and spirit of the Charter of Rights.
Many of the occupants of the accident aircraft were not experienced in seaplane operations. Often they were fare-paying passengers who were unfamiliar with the aircraft, its personal restraint systems, its life-support equipment, emergency egress routes, etc. These passengers could have benefited from a pre-flight briefing prior to the take-off or landing on water. The provision of such safety briefings was recommended in the 1988 CASB study;27 but regrettably, the recommendation has not been satisfactorily implemented.
In order to improve the survival of passengers in the event of a seaplane accident, the Board recommends that:
The Department of Transport establish and promote specific pre-flight briefing requirements for passengers for commercial seaplane operations from or to water. A94-11
Transport Canada's Response:
Amendments to regulations are being made requiring safety briefings for all passengers on commercial air carrier operations.
The Life-Saving Equipment Order (A.N.O., Series II, No.8) requires the carriage of life preservers on all aircraft taking off from or landing on water for each person on board. The Order also requires the passengers to be informed of the location and method of use of the life-saving equipment carried for their use.
Proposed amendments to the Order Respecting Air Carrier Using Large Aeroplanes, (A.N.O., Series VII, No.2), the Order Respecting Air Carriers Using Small Aeroplanes, (A.N.O., Series VII, No.3), and the Order Respecting Rotorcraft Transport Operations, (A.N.O., Series VII, No.6), were published in the Canada Gazette, Part 1 on April 23, 1994. Comments have been received and the Canada Gazette, Part 2 is being prepared for publishing. The proposed amendments will require the provisions of "standard safety briefings" on all commercial flights and among the briefings required are those to be delivered before each take-off. One of the requirements of the pre-flight safety briefing is the location and use of life preservers including a demonstration of their location, and use of life preservers including a demonstration of their location, method of donning and inflation for aircraft being operated in accordance with the Life-Saving Equipment Order.
Again, the Board recognizes the difficulty of enforcing such a requirement. Whereas a TC inspector cannot be omni-present, perhaps the fare-paying passengers themselves can be better informed regarding seaplane safety and encouraged to report unsafe practices to TC; e.g. inadequacy of passenger briefing, non-availability of personal restraint systems and personal flotation devices, excessive or improperly secured cargo, etc. Therefore, the Board recommends that:
The Department of Transport provide all commercial seaplane operators with safety information brochures, including procedures for reporting unsafe operating practices, to be made available to all fare-paying passengers. A94-12
Transport Canada's Response:
Transport Canada Aviation (TCA) concurs with the intent of this recommendation. The Department currently publishes two brochures, TP 5584 Flying With Floats, and TP 7087E A Safety Guide for Aircraft Charter Passengers, which in a generic sense provide safety-related information to seaplane passengers. Notwithstanding, TCA will publish a new safety information brochure, to be carried on all commercial seaplanes, which will specifically address the concerns of Recommendation A94-12.
TCA will ensure the dissemination of this brochure and the requirement to make it available to passengers, to all commercial seaplane operators though an Air Carrier Circular.
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