Cessna 206 aircraft that feature a rear double cargo door do not meet the aircraft certification basis for the design of cabin exits. Wing flap extensions beyond 10° will block the forward portion of the rear double cargo door, significantly hampering emergency egress. This has previously resulted in fatalities.
The ATSB notes and disagrees with the view of the Civil Aviation Safety Authority (CASA). CASA states that as the certifying state considers the Cessna 206 meets the certification standard and believes the design is safe, then they consider the aircraft meets the certification standard and the design is safe.
The ATSB disagrees and considers that the use of the cabin door as an emergency exit does not meet the certification requirements around emergency exits as the emergency exit is blocked by flap extension and the method of opening the door is not simple and obvious. There are documented accidents where there was significant delay in opening the cabin door or the door was not opened resulting in fatal injuries. However, given the view of CASA that no further action will be taken, the ATSB has closed the safety issue as not addressed.
The Australian Transport Safety Bureau recommends that the Civil Aviation Safety Authority takes safety action to address the certification basis for the design of the cabin doors in the Cessna 206, as wing extension beyond 10° will block the forward portion of the rear double door, significantly hampering emergency egress.
In response to AO-2020-010-SR-018, Safety Recommendation re C206 door configuration. CASA is not aware of any evidence to indicate that this aircraft does not meet the applicable certification standards as demonstrated by findings of compliance at the date of type certification by the FAA. The certification basis of this aircraft requires the proper functioning of exits for passenger egress to be demonstrated by tests as part of type certification (CAR 3.387). The FAA, as the State of Design, has investigated passenger egress from the rear cabin door and has not mandated any airworthiness actions. With the release of report AO-2020-010, CASA has issued Airworthiness Bulletin AWB 52-006 to communicate similar airworthiness information to that contained in EASA SIB 2020-16, Emergency Egress Difficulty, and NZ CAA CAN 25-003, Cessna 206 Emergency Egress Difficulty. AWN 52-006 Issue 1 has now been published on CASA’s website and a copy sent to all relevant subscribers (Copy attached). CASA will continue to monitor continued operational safety actions taken by the State of Design for the Textron Aviation C206 models and take appropriate actions. STCs issued by FAA and Transport Canada are automatically accepted by CASA under CASR Part 21. Therefore, a registered operator in Australia can purchase and incorporate STCs approved by these Authorities without further CASA approval if they elect to modify the forward door section of the rear cargo door configuration.
CASA was informed of the response from the FAA and advised they had nothing further to add.
Cessna 206 aircraft that feature a rear double cargo door do not meet the aircraft certification basis for the design of cabin exits. Wing flap extensions beyond 10° will block the forward portion of the rear double cargo door, significantly hampering emergency egress. This has previously resulted in fatalities.
The ATSB notes and disagrees with the view of the United States Federal Aviation Administration (FAA). The FAA states that they consider the Cessna 206 meets the certification standard and they believe the design is safe.
The ATSB disagrees and considers that the use of the cabin door as an emergency exit does not meet the certification requirements around emergency exits as the emergency exit is blocked by flap extension and the method of opening the door is not simple and obvious. There are documented accidents where there was significant delay in opening the cabin door or the door was not opened resulting in fatal injuries. However, given the view of the FAA that no further action will be taken, the ATSB has closed the safety issue as not addressed.
The United States Federal Aviation Administration (FAA) advised that they had no comment on any aspect of the draft report and did not provide detail of any safety action related to the identified safety issue. Consequently, the ATSB recommends that the FAA takes safety action to address the certification basis for the design of the cabin doors in the Cessna 206, as wing flap extension beyond 10° will block the forward portion of the rear double door, significantly hampering emergency egress.
This is our initial response to Federal Aviation Administration (FAA) Safety Recommendation 21.109 received on August 26, 2021. The Australian Transport Safety Bureau (ATSB) issued this recommendation as a result of the aircraft accident that occurred on January 29, 2020, when a Cessna Stationair U206G airplane, registered VH-AEE, and operated by Air Fraser Island, was engaged in flight training exercises involving emergency beach landing procedures, on Fraser Island, located in the Queensland Territory, Australia. After touching down, the airplane veered significantly to the left, toward the sea. The flight instructor took control of the airplane and conducted a go-around. Once airborne it was determined the rudder was jammed in the full-left position and the pilot had to apply full opposite aileron to maintain control of the airplane. Additionally, the airplane’s engine quit and it impacted the water. Both of the pilots escaped the airplane with minor injuries and swam to shore. The airplane was destroyed. 21.109.
The ATSB recommends that the FAA take safety action to address the certification basis for the design of the cabin doors in the Cessna 206, as wing flap extension beyond 10 degrees will block the forward portion of the rear double door, significantly hampering emergency egress. [AO-2020-010-SR-019]
FAA Comment. The FAA’s Aircraft Certification Service is currently reviewing the ATSB’s final report and its safety recommendation both internally and with the aircraft manufacturer, Textron Aviation’s Cessna Aircraft Company. I anticipate providing an updated response to this recommendation by December 31, 2022. 2 The FAA would like to thank the ATSB for submitting FAA Safety Recommendation 21.109 and its continued interest in aviation safety.
FAA Comment. As previously mentioned, the FAA’s Aircraft Certification Service reviewed the ATSB’s final report and the safety recommendation with the aircraft manufacturer, Textron Aviation’s Cessna Aircraft Company, regarding the design and operation of the Cessna 206 rear cabin doors.
The Cessna U206 airplane was first certified in 1964 under the Civil Air Regulations (CAR) 3, Small Airplanes Certification Basis. CAR 3, Section 3.387, required, in part, emergency exits on airplanes with closed cabins carrying more than five persons. The regulation required the emergency exits be readily accessible, that they not require exceptional agility of a person using them, and that they be distributed so as to facilitate egress without crowding in all probable attitudes resulting from a crash. Furthermore, the regulation also required the method of opening 2 of emergency exits be simple and obvious, and that the exits be arranged and marked so as to be readily located and operated even in darkness. The Cessna U206 was found to meet the applicable certification requirements during its initial type certification. The FAA also conducted a Special Certification Review in 1970, verifying the emergency exit cabin doors were in compliance with the manufacturer’s aircraft certification design basis.
The Cessna 206H airplane, certified in 1997, and the Cessna T206H airplane, certified in 1998, are both subject to the current aircraft certification standards of Title 14, Code of Federal Regulations Part 23, Amendment 23-10. Section 23.807 mandates, in part, that each emergency exit require no exceptional agility to be used in emergencies, have a method of opening that is simple and obvious, be arranged and marked for easy location and operation even in darkness, and have reasonable provisions against jamming by fuselage deformation. The regulation also requires the proper functioning of each emergency exit be shown by tests. The Cessna 206H and Cessna T206H airplanes were both found to meet the applicable aircraft certification standards during their type certification. Additionally, during the Cessna 206H/T206H airplane Canadian validation, the FAA conducted another review assessing compliance against part 23, amendment 23-10, and again found the emergency exit cabin doors were in compliance with its aircraft certification standard.
The FAA has discussed the Cessna 206 airplane emergency exit cabin door concern with other foreign civil aviation authorities as part of its original CAR 3 certification basis and safety reviews. During a safety review conducted in 2008, associated with an FAA safety recommendation submission, the FAA’s Small Airplane Directorate and Wichita Aircraft Certification Office (ACO), examined the procedures for passenger egress and determined the Cessna 206 airplanes demonstrated compliance with CAR 3, section 3.387 and section 3.768 as referenced in aircraft Type Certificate Data Sheet A4CE. It was noted during this safety review that current procedures to open the forward emergency exit cabin door as far as possible and then force the rear cabin door full open are compliant and adequate if properly briefed and understood by the flight crew. Another Cessna 206 airplane safety review was conducted in 2019, following a request by Transport Canada. The FAA again concluded the certification design of the emergency exit cabin doors does not constitute an unsafe condition.
We have considered the ATSB’s views and acknowledge the cabin door concern has been raised before. The FAA, in the original CAR 3 certification basis, in the special certification safety reviews, and again during certification with14 CFR Part 23 requirements in the 1990s, each determined the Cessna 206 airplane complies with the applicable requirements for its emergency exit design. Based on these factors, the FAA has concluded no further action is warranted at this time.
