Cabin Configuration and Evacuation Certification
Date: October 6, 2019
Seat pitch continues to shrink in aircraft cabin as airlines try to squeeze as much revenue out of each flight as possible. At the same time, passengers are on average significantly larger in body mass, electronics include charging cords and can be projectiles. More passengers are in the cabin than ever before with more baggage. Meanwhile, Flight Attendant staffing is at FAA minimums based on standards set only for aircraft evacuation, not current day duties and responsibilities of aviation’s first responders. And Flight Attendants are left to manage the frustrations of passengers jammed into ever-shrinking space. This is not an issue the market will fix. Safety needs to provide a bottom line.
Some problems with shrinking seat pitch and seat size:
- Questions about safe evacuation
- Increase passenger angst leads to air rage and passenger disruptions
- More passengers, more bags and conflict over bag storage
- Difficult to provide safe passage for passengers with disabilities
Flier’s Rights, a passenger rights group, recently filed a petition with the FAA to call for rule making that would set a minimum seat pitch which airlines could not decrease. The FAA refused to move forward with rule making. The response (attached) from the FAA, in summary, was that seat pitch has no impact on passenger evacuation and that seats are designed for safe collapse with seat pitch as low as 27”. Without a science-based approach and stakeholder involvement, it is clear that this FAA is not prepared to provide minimum seat pitch standards that will help conditions in the cabin, and may in fact further harm conditions.
Last year legislation was introduced in both the House and Senate (House/Senate attached) to address cabin seat pitch. The legislation is referred to as the SEAT Act (attached). There were three key components in the bill:
- “establishing minimum standards for space for passengers on passenger aircraft, including the size, width, and pitch of seats, the amount of leg room, and the width of aisles on such aircraft for the safety and health of passengers”
- requiring each air carrier to prominently display on the website of the air carrier” the seat size, pitch, amount of leg room, and width of aisles.
- Stakeholder involvement and science-based approach – “the Administrator shall consult with the Occupational Safety and Health Administration, the Centers for Disease Control and Prevention, passenger advocacy organizations, physicians, and ergonomic engineers.”
This SEAT Act language was attached to the FAA Reauthorization bill prior to the House and Senate Conference. In the conference process, however, items 2 and 3 of the SEAT Act were removed. The final stripped-down seat pitch language is in Section 577 (attached).
The good news is that the FAA Reauthorization Bill also contains a provision (Section 377 attached) to require the FAA conduct “a study on evacuation certification of transport-category aircraft used in air transportation” and to report back to Congress within one year. This provision includes consultation with the NTSB and all stakeholders including our unions.
Congressman DeFazio said in a floor speech before the FAA Reauthorization Act of 2018 was passed that the FAA should not move forward with Section 577 until completing Section 377 on evacuation certification standards. Congressman Steve Cohen (one of the original lawmakers to introduce the SEAT Act) also encouraged the evacuation study to be used as the basis for setting seat pitch.
T&I Committee Ranking Member Peter DeFazio:
“We have to see whether or not we can actually meet the standard of evacuating a plane in 90 seconds as budget carriers and others cram more and more seats in that are narrower and narrower, less and less pitch. Can we still meet those standards? We are going to find out whether we can or not. A provision later in the bill inserted by another of my colleagues, Steve Cohen, will require the FAA, particularly if instructed by this study, to set minimum pitch width and length requirements for passenger seats.”
Congressman Steve Cohen stated:
“Americans have become larger. Seats have become smaller. They have become more dangerous. There needs to be a study on the width and the pitch of seats to make sure that they are safe to be evacuated within the approximate 90 seconds they are supposed to be able to evacuate a plane.”
If the FAA moves forward on the seat pitch provision without first doing the Evac Certification standards (science-based) they’ve already signaled they will determine 27” is safe. The airlines were successful in stripping out two important provisions of the SEAT Act that our union supported. We cannot allow the FAA to determine minimum seat pitch and size absent science and stakeholder input. The resulting effect could be lowering the bar from the already questionable conditions of today’s aircraft cabin configuration. We can’t let that happen. We won’t.
