No more O2 mask--if you act now

[densoo]

This was sent out by ALPA last week:

ALPA’s Aeromedical Committee, in conjunction with FedEx Express, submitted a petition for exemption to the Federal Aviation Administration on October 13, 2009, seeking relief from the requirement for one pilot to don an oxygen mask above FL250 whenever the other pilot leaves the flight deck.

Subsequent to numerous discussions between ALPA and the FAA on this subject, the agency published a petition for exemption on March 4, 2010, in the Federal Register. The exemption requests that the pilot at the controls place the mask in his or her lap while the other pilot is absent.

ALPA made this request in light of the potential spread of communicable diseases by use of these masks, given that the equipment is not cleaned in accordance with U.S. Health & Human Services Department mask-sanitation standards. Pilots wanting to don the masks anytime above FL250 in accordance with current federal aviation regulations would not be restricted from doing so.

The FAA is asking for information regarding a number of issues raised by this petition. The Aeromedical Committee is in the process of developing a response to the petition to meet the FAA’s comment deadline of March 24, 2010.

If you want to get rid of this requirement to wear the O2 mask please submit your comments!

To make it as easy as possible, I've navigated through the FAA comment site and this link is the page for submitting a comment for this specific proposal. No identifying information needs to submitted (left side). All you have to do is submit a comment in the block on the right side.

http://www.regulations.gov/search/Regs/home.html#submitComment?R=0900006480a41a09

Also, here is a proposed comment. You can just copy it and paste it right into the commment block and hit submit. It fits (barely). Or write your own. But take action. This is a chance to get rid of this requirement!

If you have other good reasons to get rid of this requirement, please post them here and we can also post those comments to the FAA site, en masse.

TO: FAA

While I agree with the proposal to allow pilots to place the oxygen mask on the lap during the absence of the other pilot in order to prevent the spread of H1N1, I also urge you to adopt this proposed rule for two other safety reasons:

1. An aircraft in flight is most vulnerable to terrorist activity when the flight deck door is opened for one pilot to exit to take care of physiological needs. Very specific procedures are in place for this transition. However, the threat is always there that a flight deck breach could occur. In the event the flight deck were breached by an intruder, an oxygen mask around the head is no more than a lasso that the intruder could grab to immobilize and harm the only remaining pilot. The risk of this happening is small, but if it were to happen it would be catastrophic. Wearing the mask is an unnecessary hazard. I urge the FAA to not require pilots to wrap the oxygen mask around their head so that they might not be unnecessarily vulnerable to this threat.

2. Continuous ATC radio contact is essential to the safe conduct of aircraft. Lost comm continues to be an problem with busy frequencies and equipment issues. The communication capability of the oxygen mask was designed for emergencies and is more than adequate for that purpose. However, one pilot momentarily leaving the flight deck for physiological reasons is not an emergency. Wearing the oxygen mask during the time of the other pilot's absence often results in missed radio calls, misunderstood clearances, and with no second pilot present, the loss of CRM capability to catch the mistake.

Using the quick don oxygen mask for a non-emergency is unsanitary but it isn't the most compelling reason not to wear it. Vulnerability to terrorist attack and lost comm problems are also issues that have not been addressed and must be resolved. I urge you to adopt not only the temporary suspension of this FAR, but to make it permanent.

A Concerned Pilot

 

[i fly boxes]

so let me get this straight, rather than use a sanitary wipe and wipe down the mask before you use it, you would rather jeopardize up to 400 people on board if there is a rapid decompression. Especially the guys that fly in the high 30's low 40's?

 

[b707guy]

I wonder which management pilot got picked off for, um, 'non-compliance'?

Three-seat airplanes, the rule is overkill. Unfortunately, they are getting more rare every day. Two-seat airplanes, a bit more valid. Still feel that 25k is a bit low for the requirement, though, either way.

This may have more to do with my own personal comfort of "who's been infecting this mask and with what before I got to it?", regardless of how effectively I wipe it down with sanitizer.

 

[TWA Dude]

Precautions only make sense if the threat is substantial. The threat of a rapid or explosive decompression occurring just when a pilot is using the lav is so small putting on the mask is just unnecessary. And as every airline pilot already knows, compliance with the mask-on FAR is probably less than 25%. (I do it, of course!)

Time for this reg to change.

 

[Scope out RJ's]

Precautions only make sense if the threat is substantial. The threat of a rapid or explosive decompression occurring just when a pilot is using the lav is so small putting on the mask is just unnecessary. And as every airline pilot already knows, compliance with the mask-on FAR is probably less than 25%. (I do it, of course!)

Time for this reg to change.

I agree. It was a stupid rule/reg anyway!

 

[Dan Roman]

so let me get this straight, rather than use a sanitary wipe and wipe down the mask before you use it, you would rather jeopardize up to 400 people on board if there is a rapid decompression. Especially the guys that fly in the high 30's low 40's?

I'm wondering why not wearing a mask with one pilot gone is any safer than not wearing a mask with two pilots. In other words, how does having two pilots grabbing for their mask in the event of a rapid decompression make them less likely to become incapacitated than one guy having to.

 

[flypdx]

Read the last sentence...

 

[Fubijaakr]

Additionally, if you have a "box mask" as on a 737 or 757, the mask is not certified as quick donning if it is removed from the box. Just a fun fact...

 

[BoilerUP]

Additionally, if you have a "box mask" as on a 737 or 757, the mask is not certified as quick donning if it is removed from the box. Just a fun fact...

My thoughts as well...most masks are quick-dons and absolutely NOTHING will be gained from having the mask in your lap vs. in its holder, if you needed to get it on RIGHT NOW.

A single pilot flying a jet Part 91 has to wear a mask above FL350...this altitude makes MUCH more sense for a dual-crew airliner with a crewmember out of the cockpit vs. putting a mask in the lap above FL250.

 

[densoo]

so let me get this straight, rather than use a sanitary wipe and wipe down the mask before you use it, you would rather jeopardize up to 400 people on board if there is a rapid decompression. Especially the guys that fly in the high 30's low 40's?

Exactly. Why would the FAA approve this if it were simply because pilots are too lazy to wipe down the mask (like that would do any good in sterilizing the mask).

The FAA could care less about pilots or whether they are inconvienced. The current rest/fatigue rules and the the failure to lift a finger to get Crew Pass nearly nine years after 9/11 are a pretty good examples of this. So they aren't going to be swayed by "hey, I might get H1N1" even if this could be stretched into a public health threat.

That is why I recommend the two other--and much more compelling--comments be sent. Because....

First, if an intruder gains access to the flight deck, the remaining pilot will be helpless if the intruder grabs the hose of the mask and pulls it down. Ever seen a fight when one of the people are wearing a hoodie sweatshirt? One guy just grabs the hoodie near the forehead and pulls down hard. The guy is pretty much disabled at that point. Every time we put on an O2 mask and that door is opened, we are just that vulnerable.

Second, the latest focus of the FAA is to stay in radio communication. The Minneapolis incident brought this to the forefront. The FAA recently put out an instruction to ATC to file a report if they are out of communication with a plane for more than five minutes. One pilot group was briefed of this recently and instructed to file an ASAP report if they lost comm with ATC for any reason. The O2 mask increases the chances of missing normal communications.

Intruder threat and lost comm, in this age of security awareness, are legitimate reasons to change this rule. And they are threats that the FAA might actually agree with--and finally change this rule!

Go to the site and submit your comments. Please!

http://www.regulations.gov/search/Regs/home.html#submitComment?R=0900006480a41a09

 

[densoo]

Precautions only make sense if the threat is substantial. The threat of a rapid or explosive decompression occurring just when a pilot is using the lav is so small putting on the mask is just unnecessary. Time for this reg to change.

I think the FAA agreed with you on this. The FAA had actually published a rulemaking in December of 2005 that changed the required altitude to have the mask on from above FL250 to above FL350. They were so sure this was a no-brainer that they published it as "a direct final" rule (skipping the customary "proposal" comment period. Here it is:

SUMMARY: In this direct final rule, the FAA is amending its regulation on the use of pilot supplemental oxygen. The amendment changes the flight level at which the remaining pilot at the controls of the airplane must put on and use his oxygen mask if the other pilot at any time leaves his control station of the airplane. This amendment revises that altitude to "above flight level 350" from "above flight level 250." It will also eliminate the needless use of oxygen that is not otherwise required to provide for safety in air carrier operations. This will reduce needless expenditures to replace oxygen equipment that is subject to excessive wear and tear.

DATES: Effective January 9, 2006.

In accordance with Sec. 11.13, the FAA is issuing this rule as a direct final with request for comment because we do not expect to receive any adverse comments, and thus, an NPRM is unnecessary. However, to be certain that we are correct, we set the comment period to end before the effective date. If the FAA receives any adverse comment or notice, then the final rule is withdrawn before it becomes effective. The FAA may then issue an NPRM.

The FAA anticipates that this regulation will not result in adverse or negative comment and therefore is issuing it as a direct final rule. This final rule reduces the restrictiveness of a requirement as it applies to air carriers conducting operations under part 121. The reduction in the requirement will not affect the safety of these operations because of the improvement of oxygen equipment. As a result, the FAA has determined that this amendment is a relieving change that has no adverse effect on public safety.

http://rgl.faa.gov/Regulatory_and_G...64a7136de336f3e7862570d700784f73!OpenDocument

Boy, were they surprised. The NTSB essentially humiliated the FAA by going public with a "what the heck were you thinking" and "gee, you sure are stupid" comment. They could have handled in quietly but it seems they wanted to make a point. The FAA immediately withdrew the rule. Here's their removal comment:
　

"On November 10, 2005, the Federal Aviation Administration (FAA) published a direct final rule to amend its regulation on the use of pilot supplemental oxygen with an effective date of January 9, 2006. The FAA received an adverse comment from the National Transportation Safety Board stating that the FAA relied on time of useful consciousness data that did not represent actual pilot performance under realistic decompression conditions. In accordance with Sec. 11.31, which states if the FAA receives an adverse comment it will notify the public by publishing a document in the Federal Register, the FAA is using this notice to withdraw this direct final rule in whole."
　
http://rgl.faa.gov/Regulatory_and_G...c6432c5f14e19330862570f3006ba317!OpenDocument

　
Personally, I think the FAA had done a post-9/11 risk analysis of the intruder in the cockpit scenario and decided that it was, in fact, a signficant risk. This rulemaking change balanced the new risk (intruder) with the old (decompression) and found a safe compromise: change the altitude to FL350.

Too bad common sense did not prevail. Please, go to the link and post your comment. We can get this changed!

http://www.regulations.gov/search/Regs/home.html#submitComment?R=0900006480a41a09

 

[ableone]

so let me get this straight, rather than use a sanitary wipe and wipe down the mask before you use it, you would rather jeopardize up to 400 people on board if there is a rapid decompression. Especially the guys that fly in the high 30's low 40's?

Those sanitary wipes might make you feel better but they don't kill germs and viruses.

 

[Dash8don]

I can hear the FAA's response now, "we're not going remove the requirement for the other pilot to wear the mask but we are going to require that each pilot is issued their own mask to prevent the spread of disease." Of course, the company is going to treat this like headsets and guess who is going to have to foot the bill?

 

[DrewBlows]

H1N1 is much more prevalent than rapid decompression...

 

[NWA-AirGuard]

The Air Force's rule is the pilot in the seat has the mask on when above FL350 with the other pilot is out of the seat. So I think the FAA was trying to match that.

 

[BrickTop]

You guys a such a bunch of whining a$$ little girls. Grow a set, be smart and put the F*&ing mask on. Germs are everywhere and in far worse places you touch daily than an aircraft oxygen mask.

 

[FlyinGuy]

I thought all you were required to do is pretend to put the mask on while the other dude was leaving the cockpit. Once he dings to come back in you were suppose to put it back on.

I must be confused!!!

 

[densoo]

You guys a such a bunch of whining a$$ little girls. Grow a set, be smart and put the F*&ing mask on. Germs are everywhere and in far worse places you touch daily than an aircraft oxygen mask.

It isn't about the germs. That's a lame reason to change the rule.

However unlikely, it is about an intruder gaining access and grabbing a device that is cinched onto my head like an alien facehugger.

This is a pilot preparing to fight off a cockpit intruder by himself: http://www.bert-san.com/wp-content/uploads/2008/11/1979_alien_012.jpg

Submit your comments at this link. Let's just get this rule changed!!

 

[densoo]

I thought all you were required to do is pretend to put the mask on while the other dude was leaving the cockpit. Once he dings to come back in you were suppose to put it back on.

I must be confused!!!

When a fed is in the jumpseat that's not gonna work. I know a captain who got his license suspended for six months for that.

If the first time you've put it on and worn it for the entire time the other pilot is out is when a fed is in the jumpseat, it's going to be obvious. Do you know how to configure the comm panel to talk through the mask to talk to the pilot who is ringing from behind the door to get back in? You can't use the handset or the phone set because you'd have to take the mask off to do that.

If you don't know how to do that then you don't want to be figuring it out with a fed watching you trying to figure out what the heck you're doing while you're trying to figure out what the heck you're doing. It'll be obvious you've never done it before.

And just about that time, ATC calls to give you a new clearance....

This is a pilot configured to talk to ATC and to the pilot wanting to get back into the cockpit: http://www.bert-san.com/wp-content/uploads/2008/11/1979_alien_012.jpg

Let's just get this rule changed!! Submit your comments here:

http://www.regulations.gov/search/Regs/home.html#submitComment?R=0900006480a41a09

 

[dougdrvr]

Actually, they should require all pilots that fly above 25,000' to go through an altitude chamber check every 5 years or so.

Do any of these 'shake and bake" schools require this of the "children of the magenta line"?