Record of Communication between the Federal Aviation Administration ( FAA ) and the European Aviation Safety Agency ( EASA ) on Revised Class B and N ew Class F C argo C ompartment Rule

Date s of Communications : Februa ry 3, 11, 12, 27 and 28, 2014.
September 11 and 26, 20 14.
November 24 and 25, 2014.
Participants : Peter Chittenden, EASA Manager Cabin Safety Expert
Patrick Louchez, EASA Cabin Safety Expert

Thomas Ohnimus , EASA Senior Expert for Cabin Safety
Stephen Happenny, FAA Senior Aerospace Engineer/Safety Engineer , Environmental Control Systems & Fire Protection Systems

Mr. Happenny conducted discussions with the EASA representatives listed above, via e

- mail and tele phone , during th e time period provided above

. The discussions were conducted to confirm harmonization of the purpose and effect of the FAA proposed rules and guidance material with that of the corresponding EASA regulations ( i.e., Certification Specifications for Large Aeroplanes (CS

- 25) 25.851, 25.85 5, and 25.857) and regulatory guidance ( i.e., Acceptable Means of Compliance ( AMC ) 25.851(a)(2) , (b) , and (c) )

. The discussion s addressed the following issues:

1. A ccessibility of a Class F cargo compartment :

Mr. Happenny contacted EASA to confirm that the purpose and effect of our rule for Class F cargo compartments was the same as EASA ’s , since we included additional phrases in our rule text that are not in EASA’s corresponding rule. O ne of the phrase s (“located on the main deck”) is in EASA’s means of com pliance for their corresponding rule and one is not (“accessible in flight”). The discussion s confirmed that the purpose and effect is the same

— to ensure that Class F cargo compartments are only placed on the main deck

— and including th at restriction within our rule accomplished the same effect as EASA’s current interpretation of their regulations and their associated AMC , which are of a more mandatory nature than the FAA’s advisory circulars

. In discussing “accessible in flight , ” EASA provided an example of

a certification project that they approved in which a Class F cargo compartment was not accessible in flight. After further discussion , the FAA concluded that requiring accessibility in flight was overly restrictive , and unneces sary to restrict Class F cargo compartments to the main deck and achieve harmonization

.2. R eferences to industry standards/requirements within advisory circulars ( AC ) 25.851

- X and AC 25.857

- X , which do not appear in AMC 25.851(a)(2) , AMC 25.851(b) , and AMC 25.851(c) :

In the discussion s , Mr. Happenny explained that after EASA created the ir regulatory requirements and guidelines ( CS

- 25 , Amendment 4 , December 2007 ) , industry developed additional standards and guidelines that provide useful information and assist in demonstrating compliance to the FAA regulatory requirements. For example, SAE Aerospace Standard (AS) 6453 specifies the design and performance criteria an d testing methods of fire containment covers (FCCs) for carriage of cargo on the main deck of transport category airplanes. In response, FAA developed Technical Standard Order (TSO) TSO

- C203C , which includes additional requirements for FCCs. While the curr ent EASA regulatory requirements and guidance in their AMCs lack these reference s, EASA agreed that including these details in the FAA rule and guidance material was appropriate in the harmonization effort.

3. R egulatory text differences between EASA CS 25.85 1(b) and FAA 25.851(b) :

Mr. Happenny discussed with EASA the FAA’s omission of the word “anywhere” from the first sentence of § 25.851(b) (2) : The capacity of each required built

- in fire extinguishing system must be adequate for any fire likely to occur anywhere in the compartment where used, considering the volume of the compartment and the ventilation rate.

Mr. Happenny explained that this word was redundant and unnecessary because , if the capacity of a built

- in fire extinguishing system must be adequa te “for any fire likely to occur in the compartment” ( the existing rules ) , it must already be adequate for a fire likely to occur “anywhere” in the compartment. However, in its rule, the FAA use d the term “anywhere” in an additional sentence that is not in EASA’s corresponding rule:
For purposes of this paragraph, a system is adequate if there is sufficient quantity of agent to extinguish the fire or suppress the fire anywhere baggage or cargo is placed within the cargo compartment for the duration required to land and evacuate the airplane.

Mr. Happenny explained to his counterparts that to ensure enforceability, the FAA included that clarifying sentence in the rule text. The FAA and EASA reached a consensus that, while these changes differ from the EASA rule, the purpose and effect of the EASA rule is met by the FAA rule, so the FAA rule is still harmonized with its EAS A corresponding rule.

4. T he 52

- inch reach discussed in AC 25.857

- X:

EASA had adopted the Cargo Standards Harmonization Working Group recommendation that included an estimate of the size of a Class B cargo compartment that would meet theintent that a crewmember be able to reach any part of the compartment in the event of a fire

. This estimate was based on the approximate reach of a 95th percentile male and that the outline of any compartment, viewed from above, should fit within a vertical cylinder of radius 52 inches (132 cm) measured from the centerline of the access door or hatch. T his 52

- inch radius also included consideration of the effective controlled distance from the discharge of a hand fire extingui sher to the burning item

. In the discussions listed at the beginning of this record, Mr. Happenny explained the FAA’s position that the use of a 95 th percentile male is not realistic because many crewmembers, including flight attendants , are female and have a smaller reach. A 50 th percentile female has a reach of 28 .96 inches (~74 cm ), and the FAA believed that this is a reasonable value to use. However, the FAA consider s the effective controlled distance from the discharge of a hand fire e xtinguisher to the burning item to be on average about 23 inches. The consensus reached by Mr. Happenny and his counterparts was that regardless of w hether the 52

- inch reach wa s based on a 95 th percentile male or a 50 th percentile female , the effective reach of 52 inch es is consider ed to be nominally correct when consideration is given for variations in effective control of the discharge of a hand fire extinguisher , service experience of Class B cargo compartment s, and the benefits of harmonization

.
5. Non

- significant differences in the advisory material provided in AC 25.851

- X and AC 25.857

- X and EASA’s AMC 25.851(a)(2) , AMC 25.851(b) , AMC 25.851(c) :

Mr. Happenny discussed with EASA the differences between the FAA’s proposed ACs on this subject and EASA’s AMCs. T he ACs will be very similar to the AMCs , but will include additional information on the use of non

- halon fire extinguishing/suppression agents , agent simulants in lieu of discharging halon during certification tests , fire resistant u nit l oad d evices (ULDs) in C las s F cargo compartments , and f ire c ontainment c overs (FCC) on ULDs and/or bulk cargo pallets in C lass F cargo compartments. The consensu s between Mr. Happenny and his EASA counterparts was that th is additional information does not create any regulatory differences and reflect s developments in industry standards and the results of testing.