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D195 Requirement for part 91 operations into europe

3/20/2017

Recent events in Europe have highlighted the D095 approval process for an MMEL as an MEL by the FAA, and its failure to meet the requirements of EASA .  As such, all Part 91 international operators will be expected to get D195 approval of their MELs, just as Part 135 and 121 must.  As of now, it seems the FAA will not require domestic operators to seek D195 approval, but that may change as the FAA codifies it procedures in the coming weeks.

 

NEF Program

Are you confused about the new Non-Essential Equipment and Furnishings (NEF) program? We'll try to shed a little light on the subject.

Historical Information

Many years ago the FAA created FAA Policy Letter PL-33, titled 'Passenger Convenience Items' to allow relief from certain nonessential articles in the aircraft cabin, galley and lavatory areas. The FAA since discovered that restricting the deferral process to these few items was unrealistic. Therefore, in 2005, the FAA created a new program under Policy Letter PL-116, termed 'Non- Essential Equipment and Furnishings', or NEF. PL-116 has since been re-designated as Master Minimum Equipment List Global Change GC-138, or simply MMEL GC-138.

What are NEF Items?

NEF are those items installed on an aircraft as part of the original type certification, Supplemental Type Certificate (STC), or other form of approved alteration that have no effect on the safe operation and would not be required by the applicable certification or operational rules. These items, if inoperative, damaged or missing, have no effect on the safe operation of the aircraft. Due to the variance of items involved, a complete list of these items need not appear in an operator's MEL.

Where will NEF items be identified?

Although NEF is an element of the MEL, NEF items need not appear in the MEL. The FAA does recommend listing the items in a separate document together with any applicable maintenance or operations (M or O) procedures and the associated repair intervals. We also recommend that the NEF list be retained with your MEL. If an operator elects not to develop this list, each NEF deferral must be treated as a 'newly discovered' item and subject to the NEF decision making process as provided in your NEF Program.

To help you understand what items fall under NEF, the FAA/ATA MMEL industry group has created an NEF Universal List to define those items that may be included in your program. This universal list provides a good starting point but some items may not be deferrable on your aircraft.

How are NEF programs approved?

NEF programs are developed by the operator and approved under the standard MEL approval process by the Certificate Holding District Office (CHDO).

Note: Part 91 operators (unless operated under 14 CFR 91, Subpart K) need not submit an NEF program for approval, but must have the program available to the FAA upon request.

What changes will occur in the MMEL?

MMEL Chapter 25 will be revised to remove 'Passenger Convenience Items' and display 'Non-Essential Equipment and Furnishings' Although the NEF program appears under Chapter 25, your list may contain items from other ATA chapters.

Even with MMEL Global Change GC-138, not all of the Master Minimum Equipment Lists have been revised at this point. The Flight Operations Evaluation Board (FOEB) will amend Chapter 25 at the next revision following the April 30, 2008 deadline.

What is required in the NEF program?

The fundamental elements of the NEF program include:

Procedures and processes for identifying items that may be deferred.

Documentation of inoperative, damaged or missing items.

Procedures for reporting deferrals to the FAA.

Procedures for follow-up corrective action.

Am I required to have an NEF program?

No, operators are not required to have an NEF program. If you elect not to have an NEF program, all NEF items, including passenger convenience items, must be operative to legally operate the aircraft.

For additional information please refer to FAA Policy Letter PL-116/MMEL GC-138 and FAA Order 8900.1 Volume 4, Chapter 4.

 

Briefing Card Study

Comprehension of Safety Briefing Card Pictorials and Pictograms: Presentation Factors and Passenger Attributes
Cynthia L. Corbett and Garnet A. McLean, FAA CAMI, Oklahoma City, OK.

Federal regulations require airlines to provide safety briefings and briefing cards to inform passengers of routine and emergency safety procedures onboard transport airplanes. The exact content and presentation media used for safety briefings and cards are the responsibility of the airlines to implement, as long as the required minimum safety information is delivered. Consequently, passenger safety briefings and briefing cards vary greatly, and passenger attention to such briefings has been poor at best. Studies have shown that typical passengers, even those who report that they pay attention to passenger safety briefings and briefing cards, have little personal knowledge and understanding of the information they've been given to improve their chances of survival. One strategy to increase safety knowledge among passengers is to improve the comprehensibility and appeal of safety briefings and briefing cards.

The present study was intended to address the current state of the art for airline safety briefing cards and was motivated, in part, by National Transportation Safety Board recommendations and research results demonstrating that passenger attention to safety information is waning. Pictorials and pictograms, selected from safety briefing cards currently used by airlines, and graphical symbols, approved by the American National Standards Institute (ANSI) and commonly found in buildings or other modes of transportation, were presented in open-ended-question format. The 785 participants were recruited from high schools, public and federal offices, cabin safety workshops at the FAA Civil Aerospace Medical Institute, and the SAE International Cabin Safety Provisions Committee, S-9.

Responses were categorized, based on correctness, and then transformed, using a weighting algorithm, to yield comprehension scores for each pictorial/pictogram. The scores ranged from 28.8% to 96.3%, with a mean comprehension of 65%. Only 29% of the scores exceeded the International Organization for Standards (67%) acceptance criterion, and only 8.3% exceeded ANSI (85%) acceptance criterion. Comprehension scores for the ANSI symbols ranged from 40.5% to 97.6%, for an average 'symbol literacy index' of 75%. Comprehension of pictorials/pictograms was related to the familiarity that cabin safety professionals and high flight-time passengers have with safety briefings and briefing cards.

Results indicate that safety briefing card pictorials/pictograms need to be designed and implemented with respect to novice passengers who do not have a prepotent understanding of the design and operation of transport aircraft, emergency equipment, and/or aircraft emergency procedures. Furthermore, textual clarifications to make safety information more meaningful could be expected to improve poor passenger attention to briefing cards that is prevalent throughout commercial aviation.