There was no requirement for operators of passenger transport flights in aircraft with six or less seats to provide passengers with a verbal briefing, or written briefing material, on the brace position for an emergency landing or ditching, even for aircraft without upper torso restraints fitted to all passenger seats.
The ATSB notes that for air transport operations in small aeroplanes that operators will either be required to provide information about the brace position in the safety briefing card (if the aeroplane has more than 2 rows of seats) or the safety briefing (for other aeroplanes). Although ideally all air transport operations in small aeroplanes would have been required to include information about the brace position in the safety briefing, the ATSB is satisfied that the safety action taken has reduced the risk of the safety issue.
Issue finalisation date: 29 June 2021
On 10 April 2018, the Civil Aviation Safety Authority (CASA) issued ‘Cabin safety bulletin 6 – Brace positions’. The purpose of the bulletin was to ‘…highlight to operators the importance of assuming an appropriate brace position and provide guidance associated with recommended brace-for-impact positions for both passengers and crew’. The bulletin was stated as applying to all Australian air operators. It emphasised the importance of using a brace position, and it provided detailed guidance information on appropriate brace positions for different situations.
On 10 October 2018, the CASA issued ‘Cabin safety bulletin 12 - General aviation passenger briefings’.[1] The purpose of the bulletin was to ‘…provide guidance on how to conduct a briefing to increase passenger situational awareness and enhance any response to an emergency or abnormal event within the passenger-carrying environment’.
The background section stated:
Survivors of aircraft accidents have provided anecdotal evidence as to the importance of their recollection of information concerning the correct operation of aircraft equipment such as exits, the location of emergency equipment and how to adopt the brace position for impact. Adequately briefed passengers, who understand how to help themselves, will assist in the quick and successful evacuation of an aircraft.
The bulletin provided guidance for briefings of small aeroplanes, helicopters and hot air balloons. For small aeroplanes, the bulletin included the following information.
Pre-flight briefing
▸Seat belt fastening, tightening, releasing procedures.
▸Importance of using a shoulder harness where fitted.
▸Location and operation of doors and emergency exits.
▸Location and operation of emergency equipment such as the emergency locator transmitter, survival kit, first-aid kit, fire extinguisher and any other safety equipment.
▸Location and use of life jackets, including fitment and when to inflate.
▸No smoking.
▸Oxygen-dispensing equipment.
▸Brace position.
▸Remain in the seat unless given permission to move.
▸Do not distract the pilot during take-off, manoeuvring or landing.
In the event of an emergency
Actions and precautions to take in the event of an emergency:
▸follow instructions
▸do not distract the pilot
▸check that any loose equipment in the cabin is secured
▸adopt brace position…
General guidance for pre-flight briefings on all aircraft types also referred to briefing the brace position, although specific guidance for helicopters did not mention the brace position.
[1] The full bulletin, and other CASA cabin safety bulletins, is available on the CASA website at www.casa.gov.au/aircraft/standard-page/cabin-safety-bulletin.
Civil Aviation Safety Regulation (CASR) Part 135, applicable to air transport operations (including passenger charter operations) in small aeroplanes, was issued in December 2018. CASR 135.280 stated that the operator and the pilot in command were required to provide passengers with a safety briefing, instructions or demonstrations in accordance with the requirements prescribed by the Part 135 Manual of Standards (MOS).
In December 2018, the Civil Aviation Safety Authority (CASA
)issued a draft MOS. With regard to safety briefings, the draft MOS stated that, among many other things, safety briefings must include information about ‘…when, and how, to assume the brace position’. The MOS stated that the safety briefing could be given orally, by audio presentation, by video presentation or a combination of these methods.
CASR 135 also required operators of aeroplanes with more than two rows of seats to ensure a safety briefing card was available for each passenger. The draft MOS stated that the safety briefing card needed to provide the same information as was required for a safety briefing (including when and how to assume the brace position).
In August 2019, in response to the draft ATSB report, CASA stated that the MOS was still under development.
The Part 135 Manual of Standards (MOS) was issued on 11 December 2020. It stated that when a safety briefing card was required to be carried (that is, for aeroplanes with more than 2 rows of seats), then the card was required to included information about 'how to assume the brace position, including the position for passengers with infants'.
The MOS also stated that when a safety briefing card was not required to be carried, then the safety briefing was required to include 'when, and how, to assume the brace position, including the position for passengers with infants'.
Similar requirements were introduced at the same time for air transport operations in helicopters under CASR Part 133 and the Part 133 MOS. In effect, safety briefings were required for all operations to included 'when, and how, to assume the brace position, including the position for passengers with infants'. In addition, safety briefing cards were required for helicopters with a maximum operational passenger seat configuration of more than 2, and the safety briefing card was required to include 'how to assume the brace position, including the position for passengers with infants'.