Aircraft Life Raft - Equipped to Survive conducted in-water tests of aviation and marine life rafts in January 2000. This was the third of a series of similar evaluations of aviation life rafts we've run since 1994. The results reported here represent a compilation of these tests.
Helicopter floats prevent helicopters from sinking or capsizing in the event of a crash landing or controlled ditching onto a body of water, allowing passengers and crew to evacuate safely. These emergency devices are stored in airframes or mounted externally to the lower structure of the helicopter, and they inflate using gases such as helium stored in pressurized cylinders.
Aircraft Life Raft
The manufacturer is supposed to prove to the FAA that the raft meets the agency's criteria before TSO approval is granted by the FAA. It is supposed to be a rigorous examination and series of tests and generally speaking, no significant leeway is supposed to be allowed from the TSO requirements unless the applicant can convince the FAA that its design results in an equivalent level of safety.
Testing And Evaluation
Remember that point as it is important later on. In Part Two, AVweb will present a "Life Raft Primer" - what features and equipment you should look for in a life raft. Don't miss it! The effort to reduce weight on some rafts was obvious, sometimes painfully so with significant decreases in safety and performance.
We were taken back by Air Cruisers' Al Wigert's explanation that the corporate air raft makers' number one priority was reduced weight, followed by price. When we asked where the performance stood, he told us it came after those.
He explained that while that "wouldn't be the priority (ranking) of the crews" who might someday have to depend upon the rafts, that is "clearly the priority of the (corporate aircraft) manufacturers" who are their primary customers.
Once we move beyond what's required for Part 135 operations, there is the question of who is required to have what kind of raft. Life rafts are mandated for only some over-water operations per the FARs.
Hypocritical Biz-Jet Manufacturers?
Those of us who fly light general aviation aircraft under Part 91 are not required to have a life raft on board for any normal over-water operations. (Note that, practically speaking, crossing the North Atlantic involves Canadian regulations which do have such requirements).
Not required perhaps, but still, you ought to have one, in our opinion. Probably the most notable change between TSO C70 and TSO C70a involves the design of single tube rafts and the effects of a deflated cell.
The older version has no requirement that the occupants be kept out of the water if a cell is lost, the newer version does. This would be a significant point if any of the rafts actually meet this standard, which they don't in my opinion.
Aviation life rafts are flotation devices that allow aircraft passengers to stay afloat and sail or row to safety during emergency water landings. These collapsible inflatables contain high-pressure gas, are stored in heavy-duty fiberglass cylinders and inflate in approximately 15 seconds either manually or automatically.
…Part Confusion
Part 91.509, "Survival equipment for over water operations," is part of Subpart F dealing only with Large (over 12,500 pounds MGTOW) and Turbine-Powered (jet or turboprop) Multiengine Aircraft. This does not cover your Cessna 182 or any other light GA aircraft, single or twin.
FAR 91.509(b)(2) requires only that "Enough life rafts..." be aboard: There is no mention of "approved" life rafts. This is a real sore point for some folks, like those manufacturing TSO'd rafts, who insist that the raft must be TSO'd.
You wouldn't expect it would make a big difference. In the larger and expensive aircraft covered by Part 91 Subpart F, you'd think most folks would want a TSO'd raft. Well, it seems some of these folks got their money by pinching pennies and try to go with the cheapest product, even if it means a significant reduction in safety.
In many cases they simply do not realize that to be the case. In other cases, they simply take what the aircraft manufacturer supplies, which may not be the best, simply the manufacturer's choice, for whatever reasons they may have.
…Testing The Rafts…
But wait; we're not finished. There's also FAR 25.1415 (b), which requires that "each life raft ... must be approved." So, regardless of what operations are being carried out, even under Part 91, transport category aircraft, which these days includes many bizjets, must use approved life rafts.
We tested the rafts in a wave pool, which made for a realistic test of the rafts' capabilities. As before, at the end of the test our volunteers, referring to themselves as "Raft Rats," were beaten up, bruised and exhausted.
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Since 1985, HRD has prided itself on becoming the largest independently owned Safety Equipment Repair Station in the world. We provide unparalleled support to the world's largest Airlines, Corporate Operators, FBOs, Airframe Manufacturers, Military and Government Agencies and General Aviation.
…Type Confusion…
Inflatable evacuation devices provide passengers and personnel with a fast and efficient means of escaping hazardous aviation situations while avoiding serious injury. Whether you're part of a commercial, military or corporate aviation crew, it's vital that your aircraft inflatables are functional and effective at all times.
Life vests are personal flotation devices that are mandatory for aircraft that navigate over bodies of water. This equipment provides sufficient buoyancy to keep users' heads suspended above water, whether they're awake or unconscious. In most cases, life vests contain a pair of air cells, or bladders, that inflate when their attached canister releases carbon dioxide.
You can ensure that your inflatables are equipped to engage in reliable and efficient operation during any emergency with aviation inflatable services at HRD Aero Systems. Our experts are prepared to inspect, maintain and repair any inflatable device for safe and lasting service.
Pragmatism aside, it's simply not prudent to travel over any significant body of water out of gliding distance from land without a life raft of some sort on board. To do so is foolhardy, especially so if you are flying over colder waters.
What Is Required? Confusion Reigns…
There is no question that the odds are in your favor if you ditch (see Equipped To Survive's "Ditching Myths Torpedoed!"), but carrying survival equipment is all about improving the odds. What gets even more confusing has been the claim to offer FAR Part 91, 121 and 135 kits as options for the non-TSO'd rafts.
In fact, the kits they offer may, indeed, include the items specified in the FARs. But, the kits, no matter what they call them, together with the unapproved non-TSO'd rafts are not legal, pursuant to the FARs, if an approved raft is required.
You might be hard pressed to figure that out from some of the sales brochures or sales pitches you get. There has been considerable confusion among many raft purchasers and users about what is required and what is approved.
This has often been aided and abetted by misleading nomenclature and, in a few instances, by patently misleading advertising by some manufacturers. To no one's great surprise, the FAA itself has not been clear on these questions at times.
Far Vs …
Picking the right raft can be difficult. Rafts come in a variety of flavors: single tube or double tube, single cell and multiple cell, those with and those without self-erecting canopies and insulated floors, those that are FAA TSO-approved and those that aren't.
Survival equipment provided with the raft varies a lot as well, both in quality and quantity. That's just to name a few areas of differences. Each is important, although some more than others. Most pilots don't fly over areas of water that they perceive to be dangerous.
So their perceived need for a life raft and their perceived requirements for the capabilities of that raft are minimal. However, it is important to remember that even a body of water as seemingly benign as Chesapeake Bay or Puget Sound can present significant dangers to a downed pilot and passengers, especially in colder months.
Pilots who are considering Caribbean overflights or jumping off from Narsarsuaq for Reykjavik or Santa Barbara for Hilo will have more critical requirements as they face more obvious dangers. Yet, even here, many do not appreciate the dangers they might face.
You Can Indeed Put A Price On Human Life
I also recognize that ultimate safety and performance may not be the sole consideration for a purchaser. Weight, size and price are also legitimate concerns and entirely appropriate as long as the purchaser is cognizant of the compromises that may be involved in overall performance and safety.
There will always be a range of products that are acceptable to a range of users who have different priorities. So far, so good, but now it gets confusing. Many manufacturers make both TSO'd and non-TSO'd rafts;
some make only TSO'd rafts. In some cases the differences are slight and virtually unnoticeable to the uninformed. In other cases the difference is major. One thing they all have in common is that virtually all manufacturers use FAA-approved materials, so even the ones whose rafts aren't TSO'd can legitimately claim that the rafts are constructed from materials "conforming to stringent government specification" or "approved
by the FAA.” They may also legitimately claim to hold an FAA certificate since they may be licensed to service rafts as an FAA-approved repair station. Both these statements may confuse the unwary buyer. Approved rafts, required under these FARs, must be manufactured by an FAA-certified manufacturer in accordance with designs approved by the FAA to meet the standards of the applicable TSO, in this case TSO C70a or its predecessor, TSO C70 or C12a (although C12a
…The Testers
is largely irrelevant at this point as far as general aviation rafts are concerned). The TSO stipulates the minimum design criteria and materials and performance specifications that must be met as well as some minimal raft equipment that must be included.
I asked the FAA, but they could only point me to an older Advisory Circular (AC 91-38A) which says "The liferaft requirements of Section 91.189(b)(2) (ed. – now 91.509) may be met by using: (1) Liferafts approved under FAR 37, Section 37.122, and marked TSO-C12c.
(2) Liferafts approved under FAR 37, Section 37.176, and marked TSO-C70″ (emphasis added). However, the AC is just that – advisory in nature. Note also the word "may." Winslow Life Raft Company, a division of Collins Aerospace, manufactures the finest marine and aviation emergency inflatable life rafts available on the market today.
Winslow has a tradition of excellence for over seventy-five years, combining superior quality and a wide array of standard features with unmatched performance. Requirements (i.e., what type of raft ("approved" or not specified) and what minimum equipment for the raft must be on the aircraft) are dealt with in the FARs dealing with equipment for "extended over water operations" (FARs 91.509 and 135.167
Worst Better Than None
for example). Each subpart has a list of required raft equipment that differs from one to the other. The United States Coast Guard sends two representatives, the Coast Guard's senior rescue swimmer, Master Chief Keith Jensen, and Lieutenant Commander Paul Steward from the Office of Search And Rescue at USCG Headquarters, both to participate and observe.
LCDR Steward noted that "these tests offer a unique opportunity to further our knowledge of recreational marine and general aviation life raft features and performance which can be extremely valuable information when conducting search and rescue operations."
A pilot who really wants a TSO'd raft, even if they aren't legally required to have it, and just figure they want one that the government has blessed, can often be bamboozled. To say nothing of those who are required to have a TSO'd raft and the appropriate equipment - they have also been known to purchase the wrong raft, much to their chagrin when the mistake is caught on an FAA inspection.
With FAA "encouragement" a few years ago, Eastern Aero Marine (EAM), who makes both types of rafts, changed its nomenclature to eliminate the confusion, no longer referring to the optional equipment kits for their non-TSO'd rafts by the
Survival Products Games?
FAR Part reference. However, if the aircraft is certified under Part 25, in other words as a transport-category aircraft, Part 25.1415 (b)(1) requires that "unless excess rafts of enough capacity are provided, the buoyancy and seating capacity beyond the rated capacity
of the rafts must accommodate all occupants of the airplane in the event of a loss of one raft of the largest rated capacity.” In other words, from a practical perspective, this requires a minimum of two life rafts.
This is also the requirement for Part 121 carriers, no matter their size or what they are carrying, cargo perhaps? In addition to the righting, boarding, stability and general performance tests, the Tempe Fire Department provided a hydrant and hose to test the effectiveness of the life raft's canopies in protecting survivors in extreme weather conditions.
The screams of volunteers emanating from inside the life rafts provided quick, eloquent testimony to any deficiencies that leave in the cold water. For those operations which require a life raft pursuant to the FARs, a life raft of the appropriate type must be available and it must be equipped with all the applicable equipment listed in the FARs.
Hostile Environment
In other words, a Part 135 operator needs an approved (TSO'd) raft equipped with the minimum equipment listed in 135.167(b)(3). We've all heard the old saw that "you can't put a price on human life." We'd like to think that was true, but there are significant, potentially life-and-death differences between the various rafts offered.
Similarly, price certainly seems to have some correlation with life-saving capability, although high price alone is no guarantee of performance. I've seen many high-priced rafts that I cannot recommend. Because the differences in price can be significant, and the differences in capability generally not very obvious, many pilots and operators often opt for the least expensive product, perhaps not realizing the tradeoffs they are making in safety.
Often, the only goal is to meet regulatory requirements at the lowest possible price and weight, as shortsighted as that attitude may be. Safety never enters into the equation. To perform our in-water evaluations, we enlisted volunteers to act as our typical survivors.
These individuals, both male and female, were comprised of both "life raft virgins," who had never deployed or been in a raft before, and some experienced "survivors" who had previous training or background in water survival and life rafts, either from
A Necessary Nuisance?
the military or commercial aviation, to add their perspective to our evaluation.
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