EASA Aircraft Medical Installation and Evacuation Compliance with CS25 – Review presented by Sofema Aviation Services (SAS) www.sassofia.com
Background & Introduction – Ref Special Condition D-xx – Medical Evacuation (Issue 5) – EASA Comment
- As CS 25 does not contain requirements that specifically address medical evacuation configurations, Special Conditions are needed to establish a level of safety compatible with that intended by the applicable airworthiness code.
CS 25 References CS 25.803, 25.785(j), 25.785(h)(2), 25.1411(f), 25.1415(e) and 25.1447(c)(1)
EASA issued CM-CS-012 containing this related guidance (EASA CM No.: CM-CS-012 Issue 1 issued 30 March 2020).
Note Concerning CM:
- EASA Certification Memoranda clarify the European Union Aviation Safety Agency’s general course of action on specific certification items. They are intended to provide guidance on a particular subject and, as nonbinding material, may provide complementary information and guidance for compliance demonstration with current standards. Certification Memoranda are provided for information purposes only and must not be misconstrued as formally adopted Acceptable Means of Compliance (AMC) or as Guidance Material (GM). Certification Memoranda are not intended to introduce new certification requirements or to modify existing certification requirements and do not constitute any legal obligation.
CS 25 Stretcher Support Compliance
- Stretchers and their support units are typically compliant with CS 25.561 (but not CS 25.562).
- Fitting stretchers aft of bulky monuments will mitigate the absence of compliance with CS 25.562 (see GM2 CAT.OP.MPA.155(c)1).
Note: EASA does not require stretchers installations to comply with CS 25.562. In CS-25 amendment 13, EASA added the following text to CS 25.785(b):
- However, berths intended only for the carriage of medical patients (e.g. stretchers) need not comply with the requirements of CS 25.562.
- Design organisations should consider CS 25.785 (h)(2) on direct view to clarify whether the operator has specified cabin attendant seats to be occupied to ensure direct view.
- The stretcher typically provides an adequate restraining means for the occupant. This includes devices such as shoulder harnesses, the appropriate number of body-belts and/or end board, taking into consideration the aircraft flight loads and the loads as defined under CS 25.561, reducing loads on the occupant’s body to a minimum.
- Besides the protection of the occupant of the stretcher, all constructive features have to take into account the protection of other cabin occupants.
- Some installations might have a considerable impact on the ventilation of the cabin (subject to CS 25.831 specifications) and/or the effects of rapid decompression (subject to CS 25.365 specifications).
Medical Evacuation (Medevac) Configurations
- Foresees the installation of a certain number of stretchers to carry patients that could be incapacitated and/or non-ambulant. In some cases, a significant number of incapacitated patients could be carried on board.
- The stretchers may directly be attached to the aeroplane seat tracks or be restrained to a support unit that is attached to the aeroplane structure.
- The stretchers and their support units are compliant with §25.561 but do not comply with §25.562.
Evacuation Considerations
Ref App J of CS 25, the evacuation demonstration required to comply with §25.803, does not address the evacuation of incapacitated patients transported on a stretcher.
- Compliance with §25.803 evacuation demonstration stretcher installations have not been assessed.
o EASA expects the applicant to provide a concept of evacuation (to include the number of able-bodied persons involved in the evacuation).
Potential Issues
Applicants should segregate between installation provisions and parts of the approved configuration.
Equipment may be brought on board together with the patient(s) and considered as loose items
- 25.785(j), i.e. do not provide to passengers/crew members a means to steady themselves in case of turbulence (firm handhold),
- 25.785(h)(2), i.e. the existing cabin crew seats in the changed environment may be installed so that the cabin crew may have no direct view of all cabin areas during TT&L.
- 25.1447(c)(1) e.g. if stretchers are installed on top of another. (In case of cabin decompression, oxygen masks may not be automatically presented to the patients on the stretchers and life preservers might not be within easy reach of stretcher occupants.
- Stretchers sometimes incorporate mattresses, which may not be compliant with the overall §25.853 flammability requirement upgrade introduced by the cushion flammability test (oil burner) per CS 25 Appendix F Part II.
The Potential large number of stretchers in some of the medical evacuation layouts and the correspondingly relatively low number of seated occupants leads to the conclusion that, in certain cases, evacuation of stretcher-borne occupants will be significantly slower than that of other cabin occupants.
- Some stretcher occupants will not have automatic access to supplemental oxygen in the event of a cabin depressurization
- and/or will not have a life preserver (life jacket) within easy reach
- Movement around the cabin will not be aided by the normally expected provision of firm handholds in all areas
- Reduced cabin attendant “direct view” (ref. §25.785(h)(2))
EASA appreciates that aeroplane cabins are configured for the medical evacuation of a considerable number of critically ill patients who depend on rapid repatriation.
EASA agrees that practicable design solutions which would remove the above safety concerns are limited. Requiring literal compliance may lead to reducing the maximum number of stretchers allowed on the aircraft. This reduction would presumably result in more flights with an increase of the probability of an emergency evacuation of the aeroplane.
Therefore EASA maintains the interpretation that CS §25.562 is not applicable to stretchers.
This is further supported as per CS-25 Amendment 13. At the time of this CS-25 amendment, EASA added the following text to CS 25.785(b):
[…] However, berths intended only for the carriage of medical patients (e.g. stretchers) need not comply with the requirements of CS 25.562.
Having considered the benefit of evacuating injured or critically sick people from areas where, for many different reasons, their health and/or safety is at high risk, EASA is of the opinion that non-compliance with §25.803, §25.785(j), §25.785(h)(2), §25.1411(f), §25.1415(e) and §25.1447(c)(1), can be sufficiently compensated by showing compliance with the following Special Conditions.
Special Condition to CS 25.803, 25.785(j), 25.785(h)(2), 25.1411(f), 25.1415(e) and 25.1447(c)(1) at applicable Amdt as per product TCDS Medical evacuation configuration
a) In regards to seated occupants, each crew and passenger area must have emergency means to allow rapid evacuation in crash landings, with the landing gear extended as well as with the landing gear retracted, considering the possibility of the aeroplane being on fire.
In regards to stretcher occupants, all practicable design precautions and operational procedures must be developed to facilitate evacuation without compromising the egress of cabin attendants and other passengers.
- Precautions may include features such as location relative to normal passenger seating and emergency exits, easy release of stretchers from their attachments to the a/c to enable patients to be stretcher borne to emergency exits, easily accessed patient restraint buckles to alternatively allow removal and direct carrying of patients, associated training/briefing procedures for attendants, etc.
- Proposed design precautions and procedures will be evaluated by the Agency for acceptability. An entry shall be made in an AFM supplement to define the procedure to be followed for the evacuation of the occupants of the stretchers.
- In areas where closely spaced firm handholds cannot be easily provided as per §25.785(j), (e.g. along aisle portions where stretchers are installed) all practicable efforts must be taken to provide useable handholds to enable passengers to reach their designated seats.
- To the extent practicable, without compromising proximity to a required floor-level emergency exit, flight attendant seats must be located to face the cabin area for which the flight attendant is responsible.
- The stowage provisions for life preservers described in §25.1415 must accommodate one life preserver for each occupant for which certification for ditching is requested.
- In the case of each stretcher occupants, there must be a life preserver in a stowage location that enables an able-bodied assistant to quickly locate it and assist the stretcher occupant.
o Operational procedures must be developed (e.g. pre-flight briefing to appropriate persons) to facilitate that such retrieval and distribution will occur. - If certification for operation above 9144 m (30 000 ft) is requested, the dispensing units providing the required oxygen flow must be automatically presented to the occupants of the flight attendant and passenger seats and to occupants of the stretchers before the cabin pressure altitude exceeds 4572 m (15 000 ft) and the crew must be provided with a manual means to make the dispensing units immediately available in the event of failure of the automatic system.
o In case it is not practicable to have oxygen dispensing units automatically presented to all occupants of the stretchers, all efforts should be made to provide the safest alternative possible.
o The design of the dispensing units, any required pre-flight briefing, and/or cabin attendant training and assistance procedures must be substantiated and relevant information and limitations must be included in an AFM supplement. - The stretchers must provide an adequate restraining means for the occupant, taking into consideration the applicable ground and flight loads in addition to the requirements of CS §25.561.
- Moreover, the stretcher design must take into account the protection of other passengers (e.g. it must foresee appropriate padding of exposed protuberances, etc).
- The cushion function of the stretcher mattress requires the stretcher mattress to comply also with CS §25.853(c), and therefore successfully pass flammability testing of Part II of Appendix F on CS 252.
- Other dimensional requirements related to passageways, width of aisle, and exit size remain applicable without additional provisions for passage of stretcher or highly incapacitated occupant.
Note: Regarding the compliance with §25.853(c) in previous consultations EASA reiterated the policy to require CS §25.853(c), and therefore successfully pass flammability testing of Part II of Appendix F of CS 25 for stretcher mattresses.
Next Steps
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Aircraft Medical Installation, Airworthiness, CS25, easa part 21, Evacuation, Evacuation Compliance, flammability testing, SAS blogs, Stretcher Support
