Quick LinksStriking the captain seat's headrest Fatigue-related risks Affecting 100s of 787s in the US
While the Federal Aviation Administration (FAA) has finalized an airworthiness directive (AD) to address a safety concern related to the Boeing 787's captain seat and decompression panels potentially striking the seat's headrest, at least three airlines have raised concerns that the directive will, instead, introduce fatigue-related safety risks.
Striking the captain seat's headrest
On February 6, the FAA issued a notice of proposed rulemaking (NPRM) to address a risk related to the 787-8, 787-9, and 787-10s' captain seat's headrest potentially being struck by the flight deck door decompression panel during a flight deck or below the flight deck rapid decompression event.
According to the FAA, the associated risk occurs when the captain's seat is in a particular position, and as a result, the United States regulator proposed to require operators to replace the affected seats' assembly on certain 787s.
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"The FAA is issuing this AD to address the possibility that the decompression panel could strike the captain's head or face. The unsafe condition, if not addressed, could result in serious or potentially fatal injury to the captain after a flight deck or below the flight deck rapid decompression event."
The FAA issued its final rule AD on October 8, with an effective date of November 12. While the Air Line Pilots Association, International (ALPA) and United Airlines supported the NPRM without change, some airlines voiced their concerns about the directive.
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13 Fatigue-related risks
The two network carriers of Air France-KLM, British Airways, and an individual commented on the NPRM and requested the FAA to allow modifications to the Boeing Flight Crew Operations Manual (FCOM) to comply with the directive.
Air France asked for an alternative method of compliance (AMOC) that would include marking limits on the flight deck based on existing Boeing FCOM instructions while also adding procedures - that the manufacturer is currently developing - into the airplane flight manual (AFM).
"Air France stated that the seat modification makes it impossible for pilots to achieve effective rest and may force the operator to add a third pilot on the operated routes or change the Boeing 787 fleet network, which can cause significant costs."
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KLM requested that an alternative to the directive would require operators to include instructions similar to those that are outlined in the current Boeing FCOM, along with AFM revisions, which would result in a placard limiting seat recline and providing information to aid the correct seat position.
"[KLM] stated that the seat modification limits seat recline to the point that it reduces the ability for pilots to have a controlled rest, which can negatively affect flight safety."
As such, the Dutch carrier said that limiting seat reclining and providing information about the correct seat position would result in the same level of safety as replacing the seat's assembly.
British Airways commented that the AD allows installing later-approved part numbers and claimed that those parts will be a seat with a placarding solution proposed by Boeing that will essentially revert the part number back to the original one.
"British Airways requested that the proposed AD be revised to allow for the Boeing proposal using a placard as a means of compliance."
The London Heathrow Airport (LHR)-based airline stated that the new, mechanically limiting seat assembly would be more restrictive, resulting in pilots being unable to rest properly, which, in turn, would increase fatigue-related operational risks.
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"British Airways suggested the increased risk due to pilot fatigue outweighs the low risk of a flight deck decompression while the pilot's seat is in the most rearward and tilted position."
The sole individual requested an AMOC-type approach that would enable airlines to enhance procedural compliance with existing Boeing FCOM procedures, flight deck markings, and crew awareness training.
In addition, they requested a longer-term approach to the decompression panel, which would allow Boeing to develop a permanent solution to the door panel, nulling the need for the current directive.
"The individual stated that the risk analysis appears to be exaggerated given the likelihood of a decompression event occurring with a taller pilot without an alternative crew member available to safely continue flight, which the commenter stated is not likely given in-service experience of modern jet aircraft."
They added that the seat recline was restricted more than what would be required for 99.9% of pilots to avoid being hit by the decompression panel. The mechanical limiter does not account for the seat's fore/aft position and assumes the worst-case scenario with a pilot that was in the 0.01%.
"The FAA does not agree with the commenters' requests. The FAA evaluated fleet data and determined through risk analysis that the risk to flight crew is unacceptable and that delaying this action would be inappropriate."
In addition, the FAA said that the flight deck door decompression panel might strike a 787 captain, no matter their height because the headrest is in the panel's path when the seat is in the aft track position with a full recline and full seat pan tilt.
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The US regulator stated that none of the commentators provided enough data to support their arguments, adding that while the AD does allow the installation of later-approved parts to comply, these parts are unequal to a placard solution.
The FAA concluded that using a placard to limit seat recline was not the same as a later-approved part.
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2 Affecting 100s of 787s in the US
According to the FAA's estimates, the directive would affect 155 787 aircraft registered in the US. Estimating the compliance costs, the FAA said that the replacement of the captain's seat assembly would take three hours ($85 per work hour), and with part-related expenses being $1,335, airlines should spend up to $1,590 to comply with the AD.
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However, British Airways also requested the compliance time - within three years after Boeing's Requirements Bulletin (RB) publishing date of June 13, 2023, or three years after the issuance of the aircraft's airworthiness certificate, whichever occurs later - to be extended.
The British carrier argued that it has relied on subcontractors to modify the seats, with limited additional seats to use while replacements are being provided, and the supplier might not have the capacity to ramp up the conversion rate.
Furthermore, British Airways noted that Boeing does not have enough of the newer seat model in stock to support a fleet-wide campaign within the three-year compliance time.
The FAA rejected the request, saying that the compliance time was appropriate to maintain an adequate level of safety.
Boeing's RB, B787-81205-SB250294-00, outlined that the bulletin applied to all 787 aircraft with line numbers (LN) ranging from six to 1141, with certain airframes being exempt from the RB. In total, over 1,000 787s fall within that range, with Boeing having delivered 1,146 aircraft of the type as of September 30.
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The latest directive was unrelated to the AD that the FAA issued following the rapid descent on a LATAM Airlines 787-9, registered as CC-BGG, on March 11.
Addressing that safety issue, the FAA mandated operators to check both pilots' seats for missing or cracked rocker switch caps and for cracked or nonfunctional switch cover assemblies, a rocker switch cap pull test, marking of the seats, and applicable on-condition actions.
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