Petition Closed
Petitioning Administrator, FAA Randy Babbitt

Demand that the FAA reinstall emergency oxygen systems in airliner lavatories

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.

Letter to
Administrator, FAA Randy Babbitt
The issue of AD 2011-04-09 mandating the discharge or removal of all chemical oxygen generators from pressurized passenger airliners has placed all aircraft which complied with it in violation of FAR Part 91 Section 211;

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;

Please note 'each occupant'. An 'occupant' includes somebody occupying the aircraft lavatory.
Regardless of security concerns which may have motivated this AD, because it has been arbitrarily issued without opportunity for comments, this places every single US registered airliner which has complied with it in violation of FAR part 91, section 211, and all these aircraft are therefore not airworthy under the Federal Airworthiness Regulations.

Other civil regulatory authorities which have followed suit under direction from the FAA, including those in Brazil and Canada, are also in violation of the same rule.

You, as the FAA administrator, have the authority to either repeal this dangerous airworthiness directive or initiate follow-up corrective action to have either chemical oxygen generators or compressed oxygen tanks safely re-installed in every US registered civil airliner.
The action you take will set the precedent for other regulatory agencies to follow.

Please resolve the lavatory emergency oxygen problem and return the affected civil airliners to airworthy flight status.

Thank you.