

Demand that the FAA reinstall emergency oxygen systems in airliner lavatories


Demand that the FAA reinstall emergency oxygen systems in airliner lavatories
The Issue
In March, 2011 the FAA issued an airworthiness directive mandating that all civil airliners remove or discharge emergency chemical oxygen generators from lavatories.
The FAA enforced the AD before publically issuing it, stating that prior notice and opportunity for comments was 'contrary to the public interest', simply citing that the emergency oxygen generators 'presented a hazard to flight safety' and the AD 'removed that hazard'.
http://edocket.access.gpo.gov/2011/pdf/2011-5292.pdf
http://www.airsafenews.com/2011/03/faa-orders-removal-of-lavatory-oxygen.html
Emergency oxygen equipment is required to be provided to all aircraft occupants on all pressurized aircraft that operate at high altitudes.
FAR Part 91 Section 211 (b) Pressurized cabin aircraft
(1) No person may operate a civil aircraft of US registry with a pressurized cabin;
(i) At flight altitudes above flight level 250 unless at least a 10 minute supply of supplemental oxygen is available for each occupant of the aircraft for use in the event that a descent is necessitated by loss of cabin pressurization;
http://en.wikipedia.org/wiki/Time_of_useful_consciousness
Part of the FAAs justification for removal of the lavatory emergency oxygen was that 'decompressions are rare', but recently Southwest flight 812 suffered a rapid decompression, highlighting the very reason why emergency oxygen systems must be carried aboard civil airliners.
http://en.wikipedia.org/wiki/Southwest_Airlines_Flight_812
The FAA's reasons are supposedly security related, and yet the European aviation authorities have chosen not to adopt the same AD.
http://online.wsj.com/article/SB10001424052748704261504576205340082506086.html
The fact is, all US registered airliners which have adopted AD 2011-04-09 are currently in violation of FAR 91 Section 211 and are therefore not airworthy under the FAA’s own airworthiness regulations.
The minimal risk posed by the heat generated from emergency oxygen generators is taken into account in their installation design, however the risk is exaggerated by incidents such as the Valujet 592 crash which was attributed to a fire accelerated by spare chemical oxygen generators being illegally ferried in the cargo hold, not the lavatory.
Chemical oxygen generators, when installed correctly, offer no greater flammability risk than the galley ovens.
http://en.wikipedia.org/wiki/ValuJet_Flight_592
Without supplemental oxygen during a depressurization an individual will begin to suffer from hypoxia, fainting, and eventually even brain damage or death.
If you believe that the risk of terrorism justifies the waiver of airworthiness standards, then don't sign this petition. If however you believe that pressurized cabin airliners should comply with mandatory emergency backup oxygen rules for all occupants onboard an airliner, then please sign this petition urging Randy Babbitt to repeal this paranoid AD or initiate action to correct it.
The hope is that, as in Europe, the FAA will see sense and re-install these life-critical systems as they were before, or substitute them with another oxygen supply other than the suspect chemical generators.
Thank you for reading.

The Issue
In March, 2011 the FAA issued an airworthiness directive mandating that all civil airliners remove or discharge emergency chemical oxygen generators from lavatories.
The FAA enforced the AD before publically issuing it, stating that prior notice and opportunity for comments was 'contrary to the public interest', simply citing that the emergency oxygen generators 'presented a hazard to flight safety' and the AD 'removed that hazard'.
http://edocket.access.gpo.gov/2011/pdf/2011-5292.pdf
http://www.airsafenews.com/2011/03/faa-orders-removal-of-lavatory-oxygen.html
Emergency oxygen equipment is required to be provided to all aircraft occupants on all pressurized aircraft that operate at high altitudes.
FAR Part 91 Section 211 (b) Pressurized cabin aircraft
(1) No person may operate a civil aircraft of US registry with a pressurized cabin;
(i) At flight altitudes above flight level 250 unless at least a 10 minute supply of supplemental oxygen is available for each occupant of the aircraft for use in the event that a descent is necessitated by loss of cabin pressurization;
http://en.wikipedia.org/wiki/Time_of_useful_consciousness
Part of the FAAs justification for removal of the lavatory emergency oxygen was that 'decompressions are rare', but recently Southwest flight 812 suffered a rapid decompression, highlighting the very reason why emergency oxygen systems must be carried aboard civil airliners.
http://en.wikipedia.org/wiki/Southwest_Airlines_Flight_812
The FAA's reasons are supposedly security related, and yet the European aviation authorities have chosen not to adopt the same AD.
http://online.wsj.com/article/SB10001424052748704261504576205340082506086.html
The fact is, all US registered airliners which have adopted AD 2011-04-09 are currently in violation of FAR 91 Section 211 and are therefore not airworthy under the FAA’s own airworthiness regulations.
The minimal risk posed by the heat generated from emergency oxygen generators is taken into account in their installation design, however the risk is exaggerated by incidents such as the Valujet 592 crash which was attributed to a fire accelerated by spare chemical oxygen generators being illegally ferried in the cargo hold, not the lavatory.
Chemical oxygen generators, when installed correctly, offer no greater flammability risk than the galley ovens.
http://en.wikipedia.org/wiki/ValuJet_Flight_592
Without supplemental oxygen during a depressurization an individual will begin to suffer from hypoxia, fainting, and eventually even brain damage or death.
If you believe that the risk of terrorism justifies the waiver of airworthiness standards, then don't sign this petition. If however you believe that pressurized cabin airliners should comply with mandatory emergency backup oxygen rules for all occupants onboard an airliner, then please sign this petition urging Randy Babbitt to repeal this paranoid AD or initiate action to correct it.
The hope is that, as in Europe, the FAA will see sense and re-install these life-critical systems as they were before, or substitute them with another oxygen supply other than the suspect chemical generators.
Thank you for reading.

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Petition created on April 14, 2011