Southern AeroMedical Institute SAMI 

1698 W. Hibiscus Blvd 

; 1 

Melbourne, Florida 32901 

Phone: 321-676-3200 

www.sami-aeromedical.com 

Contact: Dr. Paul Buza drbuza@gmail.com 

HAE Exemption Request 

Request for Exemption Ruling 61.31 (g) (2) 

Purpose for the Relief Request/Equal Level of Safety 

We are seeking relief from 14 CFR Part 61, 61.31 (g) (2) which requires, in pertinent part, High Altitude 

Endorsement (HAE) training be conducted in a " pressurized aircraft, or in a flight simulator or flight 

training device that is representative of a pressurized aircraft". Due to the unique configuration of our 

Garmin simulation ( which represents the TBM 850 cockpit) with Zodiac Aerospace oxygen masks within 

the high altitude chamber some aspects of the simulator are difficult to incorporate. However, it is our 

contention that the fundamental principles of the requirement to use a pressurized aircraft, flight 

simulator or flight training device that is representative of a pressurized aircraft for HAE training remain 

intact with minor variations to accommodate the unique and beneficial physiological training afforded 

by the high altitude chamber. In addition to the "type specific" protocols that must be accomplished for 

cabin depressurization emergency procedures is the added benefit of a true reduction in cabin pressure 

to also teach the signs and symptoms of hypoxia as it relates to their instruments and mask systems. 

Hence, this HAE exemption maintains current standards while enhancing pilot skills to demonstrate their 

procedures in a true hypoxic environment. 

The primary purpose to seek this relief is to further enhance and reinforce the training objective as to 

the dangers of cabin depressurization. By utilizing a type specific trainer that is matched with a true 

reduction in cabin pressure achieves a model that would occur during a real emergency. Current HAE 

training is conducted in normal sea level environments where oxygen levels are normal and only a 

simulation of decompression/low oxygen environment is possible. In an actual decompression event the 

pilots will perform their emergency procedures in the low oxygen environment. This exemption seeks to 

further augment the existing training by demonstrating proficiency "at altitude" as well as at sea level. 

By learning the physiological effects of hypoxia which is "highly recommended" by the FAA (Advisory 

C:ircular AC 61-107 (B), paragraph 2-7) while engaged in mandatory type specific HAE training maintains 

and augments further the fundamental principles of the high altitude endorsement which is to be 

"representative of the aircraft". The simulation device set-up is such that the pilot will demonstrate 

proficiency in mask donning followed by proper communications and emergency descent procedures. 

Our set-up meets the intent of the rule and, consequently, an equal level of safety. The addition of 

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exposure and practice in a low oxygen environment increases pilot knowledge on his or her specific 

signs and symptoms of hypoxia, and ultimately increasing safety. 

Benefit to the Public 

Fatalities associated with cabin depressurization remains problematic within the industry. The primary 

benefit to the public is the enhancement of pilot training to improve aviation safety. The provision of 

type specific HAE training with the high altitude chamber improves the current training standards to 

further enhance learning of the dangers of hypoxia and the need for early intervention and utilization of 

the high altitude emergency protocols. The additional emphasis of "slow onset hypoxia" training in 

addition to the rapid or explosive models adds training benefit to the "insidious" nature of a slow cabin 

depressurization. Review of fatal accidents associated with cabin depressurization since 1999 finds that 

most were related to "slow onset hypoxia" and hence the need to further augment training to address 

this issue. Enhancing pilot training leads to reduced risks of incidents and accident to the flying public. 

The exemption would also allow easier access to the pilot community to achieve their training in a 

timely and cost efficient manner. The pilot would not only be able to satisfy the mandatory HAE 

requirement but simultaneously receive the high altitude chamber certificate (TKG1) as well. Although 

strongly recommended the majority of the pilot community has not undergone high altitude chamber 

training . This exemption accomplishes both training modalities in a single session thereby increasing the 

number of pilots who can access this training in a timely and cost effective manner. We now have a new 

generation of pilots in training that have not had the benefit of hypoxia training compared to prior 

generations. Such training would provide not only an equal level of safety, but an enhanced level of 

safety to the current HAE standards with the added safety benefit of true physiological training. This 

added safety benefit is a benefit to the public. 

Summary and Additional Comments (TKG3) 

Primary Objective 

The primary object is to comply with the existing HAE requirements with the seamless integration of 

physiological training to achieve an enhanced "representation of the aircraft". Further integration of the 

"Scenario Based Physiological Training" module (Appendix 1) within the course requirements further 

enhances the HAE training as to the dangers of incapacitation from a cabin depressurization. 

Introduction 

The Southern AeroMedical Institute (SAMI) has acquired a Garmin 1000 simulation device (which 

represents the TBM 850 cockpit) with Zodiac Aerospace quick don mask system for the purpose to 

provide the High Altitude Endorsement (HAE) (Appendix 2).Given our location in central Florida where 

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there are a large number of commercial pilots in training which will allow easier access to obtain the 

HAE training. SAM I seeks the capability to offer HAE certification by utilizing the successful integration of 

the 3 panel Garmin 1000 simulation device with Zodiac Aerospace quick don masks within a high 

altitude chamber to achieve a model that is "representative of the aircraft". Traditional altitude 

chamber training is not mandatory but "highly recommended" (Appendix 3). This exemption seeks to 

fuse both models of the HAE training along with the strongly recommended altitude chamber program 

into a single module that represents a more precise training environment. Scenario based principles are 

also included to recreate an accurate depressurization event that is "representative of the aircraft". 

Given the challenge to accomplish such a representation there are some limitations to the simulation 

device in keeping with HAE requirements. Hence, the need for the exemption. However, pilots training 

on the Garmin1000/Zodiac Mask systems will experience a true reduction in cabin pressure while 

demonstrating proficiency that is required for the HAE emergency protocols. 

Scenario Based Training 

Further incorporated into this module is the FAA FITS accepted "Scenario Based Physiological Training" 

module which we authored in 2008 and have currently provided this training to 2800 pilots. Our 

objective is to integrate these principles seamlessly with the fundamental principles of the HAE 

requirement. The trainee must engage in a flight plan (Appendix 4) whereby a simulated and "true" 

decompression occurs. Several scenarios are provided to match the flight profiles most encountered by 

the pilot depending upon their experience and type of aircraft that they fly. An example would be an 

experienced Phenom 300 pilot who flies out of Aspen and the scenario is a failure of pressurization on 

ascent while solving an ACAS alert related to the right engine. While achieving simulated cruise altitude 

with the Garmin simulation device an unbeknownst new way point is instructed by ATC. The altitude in 

the chamber is matched to the simulated flight plan and the scenario includes a "failure of 

pressurization on the ascent". Here the pilot begins to experience the signs and symptoms of hypoxia at 

which point the alerts and alarms are engaged. The pilot at this point demonstrates his proficiency 

consistent with the HAE requirements. Another example would be a TBM 900 at cruise altitude of 31K 

near Teterboro with very heavy traffic and inclement weather. Given the different scenarios the 

fundamental premise of the HAE training is to achieve an accurate representation of a true physiological 

decompression while engaging the Garmin 1000 which is representative of the TBM-850 aircraft. This 

module allows for creativity to create custom scenarios that closely match the pilot's flying profile. 

Another example is CRM based training where the crew members fly together and train as a crew. Here 

the crew member not only learns his or her unique hypoxia profile but can also recognize hypoxia with 

the corresponding crew member further increasing situational awareness. There is even training for 

"companions" in general aviation that flies together such as spouses. Proficiency is demonstrated by 

donning of the mask followed by proper communications and emergency descent procedures. Our 

current configuration meets this requirement. 

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The Importance of Trapped Gas Phenomenon 

Learning the importance of trapped gases can only be accomplished within a high altitude chamber. As 

the cabin altitude rises the volume of a gas expands. Here the pilots learn that during a cabin 

depressurization that he or she will note frequent ear popping, abdominal bloating and cooling of the 

cabin temperature even before the first symptom of hypoxia ensues. This valuable teaching point in and 

of itself increases situational awareness as to the reduction in cabin pressure resulting in earlier 

intervention before fixation ensues. Another valuable teaching point related to trapped gas phenomena 

is where the pilot learns the importance of middle ear equalization during his emergency descent not 

only for his crew but passengers as well. Middle ear equalization with the mask on is taught while 

performing an emergency descent in keeping with HAE training. 

Flight Performance Video 

Video recording of the flight performance allows detailed analysis of the HAE training experience 

(Appendix 5). The subtle changes associated with hypoxia such as entering an incorrect heading or 

waypoint clearly shows the mental impairment of the pilot who otherwise feels in control. This can be 

easily seen on the PFD/MFD displays. For example, a heading of 270 issued by ATC but resulting in the 

pilot entering 280 can be easily seen. Other changes include the slowing of speech and reaction times 

while engaging the flight plan. The video serves as a powerful teaching tool during the post-flight 

debriefing and can also be used for recurrent training. 

The Importance of Recognizing Fixation 

One of the primary objectives is to teach the dangers of fixation which is associated with hypoxia. The 

slower the onset of hypoxia the greater the fixation. While engaging the scenario based flight plan with 

"live"ATC communications (Appendix 6) the pilot must demonstrate proficiency of his aircraft and 

maintain situational awareness at all times. He or she also learns how the neurocognitive impairment 

develops in an insidious manner making the interaction with the Garmin 1000 difficult. This is an 

essential teaching point as many pilots will begin to fixate and not be aware of the mistakes that are 

being made. At that point a cabin depressurization alarm is activated whereby the pilot must don his 

quick don mask with 1 hand in 5 seconds followed by an emergency descent in communication with 

ATC. 

Oxygen Saturation Awareness 

Incorporated within the Scenario Based Training is physiological monitoring of the pilot's oxygen 

saturation profile. Worn on the wrist in a non-cumbersome fashion the oxygen saturation profiles are 

collected for each pilot. This data is uploaded and a report is provided to the pilot as part of the training 

(Appendix 7). This emphasizes how low the oxygen availability is during a decompression. As important, 

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it also emphasizes how quickly oxygen saturations normalized once the mask has been donned. On 

average the oxygen saturation will normalize in 1 minute. If a pilot continues to appear hypoxic after 1 

minute during the emergency descent the crew should check to make sure the mask is properly fitted. 

Corporate and Pilot Response to the Program 

The feedback from experienced corporate pilots has been remarkable. Already accustomed to the HAE 

requirement and many who have been trained at FAA and Air Force Chamber programs appreciate the 

realistic scenario of this program. The "walk away" message accomplished with the current curriculum is 

how insidious hypoxia can be and hence the need for improved situational awareness and the 

importance of early donning of the oxygen mask in the event of a cabin depressurization. Due to the 

positive feedback from the pilots the corporate response has also been encouraging. As a result, Daher 

Socata has made the training available with the purchase of each new aircraft. The formal 

announcement was made July 20, 2015 at Oshkosh: http:Uwww.aopa.org/News-and-Yideo/AIINews/2015/July/20/Daher-offering-high-altitude-training?WT.mc id=150723speciai&WT.mc sect=osh 

Additional support by Embraer, Piper Meridian, Eclipse, Cessna 421, Twin Commanders (TKG4) and 

others have supported the development of this program. 

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Appendix 1 FAA FITS Scenario Based Physiological Training 

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Appendix 2 Garmin 1000 Simulator/Zodiac Aerospace Eros Series 10 Masks 

Appendix 3 High Altitude Chamber Aircraft Configuration 

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Appendix 4 Flight Plan 

Appendix 5 Performance Review Video 

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Appendix 6 Scenario Based Flight Plan With 11Uve ATC11 

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ATC SCRIPT: HYPOXIC G-1000 SIMULATION 

-Aircraft should be addressed by their individual call signs if they are known. 

-Plan on communications being made every minute unless otherwise specified. 

-Numbers in brackets represent the aircrafts anticipated simulation altitude. (not chamber 

altitude.) 

TBM 1 Miami center, Fly heading 090, climb and maintain 9000 ft [ 5000 ft; ] 

TBM 1 Left heading 360, Altimeter 31.87 [7000 ft; ] 

TBM 1 Left heading 270, climb and maintain 13, 000 ft [9000 ft;] 

TBM 1 Left heading 260 [11,000 ft;] 

TBM 1 Right heading 190, climb and maintain Flight levell90 [13,000 ft] 

TBM 1 Left heading 180[15,000 ft;] 

TBM 1 Indent (immediately after their response) 

TBM 1 Right heading 260 [17 ,000 ft;] 

Pilots are expected to reset altimeter setting upon crossing FL 180 

TBM 1, Right heading 280 Squawk 3428 [19,000 ft;] 

TBM 1 say altitude and heading (if they did not reset altimeter) 

TBM 1 check altitude (if they don't realize that they forgot to reset altimeter) 

TBM 1 check altimeter setting (if they still don't realize that they forgot to reset altimeter) 

TBM 1 Left heading 210, climb and maintain Flight level 210 

TBM 1 Right heading 280, descend and maintain Flight level200 

TBM 1, restricted airspace activated north of QUAZR, proceed immediately direct to 

ALLSO descend and Maintain FL 180. (Commence Symptom check) 

The following commentary can be interjected between above communication. 

Cessna 738FC Miami center, descend and maintain 9000 ft, proceed direct to YEHAW. 

Bombardier l right heading 220 

Embraer 2 ident 

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Appendix 7 Oxygen Saturation Awareness 

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