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CFR 91.211
Associated Risks Due to Compliance
Background
The Rules

14 CFR 91.211

EASA-OPS

ICAO Annex 6

IS-BAO (Not really a rule, but…)
FAR 91.211 (b)(1)(ii)

Clearly written/understood

Commonly/intentionally ignored
EASA-OPS

Replaced JAR-OPS and EU-OPS

Cabin alt >10,000’ >30 mins

Cabin alt >13,000’
ICAO Annex 6

EASA-OPS mimics ICAO Annex 6.

Use of supplemental oxygen mandated
by cabin altitude.
IS-BAO

2015 IS-BAO Protocol changed to
harmonize with ICAO Annex 6.
Cabin pressure
>10,000 feet
> 30 mins
Cabin pressure
>13,000 feet
FAR 91.211(b)(1)(ii)
Non-Compliance

Why are otherwise compliant and
disciplined professional pilots choosing to
ignore FAR 91.211?

Why are the compliant pilots frustrated
with the current regulation?

Why aren’t the FAA and NTSB addressing
this situation?
Safety Management

Identification of the Hazard(s)

Risk assessment

Eliminate, Mitigate, or Accept
FAR 91.211(b)(1)(ii)
The Hazard

Hypoxia due to Depressurization

Explosive, Rapid, or Slow

Rapid Depressurization Above 41,000 ft.
•
9 – 12 seconds EPT
Risk Assessment

Severity of the Hazard

Probability of an Occurrence

Tolerability of Its Effects
FAR 91.211(b)(1)(ii)
Severity of the Hazard

Unmitigated Depressurization Event is
Categorized as Catastrophic
FAR 91.211(b)(1)(ii)
Probability

AC 25.1309
•
Safety Analysis required for all systems
and components.
•
Catastrophic (critical) failure condition
must be extremely improbable
(1.E9 or less)
FAR 91.211(b)(1)(ii)
Probability

Highly Unlikely
•
Based on an explosive or rapid
decompression event
FAR 91.211(b)(1)(ii)
Tolerability of Its Effects

Highly Unlikely/Catastrophic
= Acceptable Risk
Hazards Caused by
FAR 91.211 Compliance








Fatigue
CRM Interference
Vision Interference
Oxygen Depletion
Lung, throat, sinus irritation
Unsanitary Health Risks
Untimely Wear
Quick-donning Feature Negated
Compliance Hazards Fatigue

Mask not made for long duration use

Comfort feature marginally effective
Question:
Do you feel that wearing the oxygen
mask for an extended period of time
adds to pilot fatigue?
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Compliance Hazards
CRM Interference

Impaired communication

Pilot Wearing Mask is Effectively Isolated
Looking back on a 25 year career, this
flight was one of the most challenging
and dangerous flights I have ever
completed, including 10 years of U.S.
Navy night aircraft carrier operations.
Question:
Do you feel that the oxygen mask
interferes with CRM?
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Compliance Hazards
Vision Interference

Mask interferes with glasses

Mask blocks view of pedestal and lower
instrument panel
Compliance Hazards
Oxygen Depletion

Oxygen is consumed in NORMAL setting

Translation from psi to time/distance

Replenishment challenges at foreign
locations
Compliance Hazards
Lung, throat, sinus irritation

More time now spent breathing
dry oxygen

Bronchial irritation
Question:
Have you ever experienced any
physiological symptoms after using the
oxygen mask for an extended period of
time ?
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Compliance Hazards
Unsanitary Health Risks

Difficult to effectively clean

Hose cannot be cleaned

Stored with head bands in mask
Question:
Are you worried about getting sick after
using an oxygen mask in flight or during
training?
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Compliance Hazards
Untimely Wear

Designed for emergency use

Stored by flight crew
Compliance Hazards
Quick-donning Negated

Not easily re-stowed after routine use

Unsecured mask technique
Mitigation

Requires Understanding

Reduces Probability and/or Severity

Not permanent
Mitigation Options

Ignore FAR 91.211

Petition for Exemption

Don’t Fly Above FL410

Modify Oxygen System

Change FAR 91.211
Mitigation Options
Ignore FAR 91.211

Poor airmanship

Normalization of deviance culture
Question:
Do you believe that ignoring FAR 91.211
is a threat to a positive safety culture?
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Mitigation Options
Petition for Exemption

Common prior to 1986

No successful exemptions in 28 years

Only one application based on SMS risk
analysis
Mitigation Options
Don’t Fly Above FL410

Eliminates Hazards

Adds to Airspace Congestion

Higher Operating Expense

Higher Emissions
Question:
Do you fly below FL410 because of FAR
91.211?
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Mitigation Options
Modify Oxygen System

Fitted military style masks

Segregated emergency system
Question:
Would you prefer a modified oxygen
system over a rule change?
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Mitigation Options
Change FAR 91.211

Highly challenging option

Harmonize with ICAO Annex 6

Possibility to include additional mitigation
•
Training requirements
•
Equipment requirements
Question:
Are you in favor of changing FAR 91.211
to mimic ICAO Annex 6?
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Question:
Would you accept additional mitigation,
such as training or equipment
requirements with a rule change?
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HASO

NBAA High Altitude Supplemental
Working Group (HASO)

www.O2mask.org
Question:
Should we continue?
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CFR 91.211
Associated Risks Due to Compliance