I would bet that I am not the only one involved with aviation who has had emergency evacuations on his mind. Many of us watching the nightmare crash and sinking of the Costa Concordia off the coast of Italy in January were horrified by the unprofessional approach to evacuating the ship. It certainly seems from the news reports that the number of deaths and serious injuries was likely exacerbated by the chaotic nature of the ship’s evacuation.

It’s hard to imagine that anyone in charge was prepared to lead a full-scale evacuation of the ship. And while cruise ships lack the kind of regulatory oversight that aviation has had (after all, “flag of convenience” is really just a euphemism for “flag of no regulation”) are the FAA, aircraft manufacturers and the airlines doing all that should be done to ensure emergency evacuations run quickly and smoothly?

The sinking of Costa Concordia should prompt soul-searching among all involved in emergency preparedness. For example, when was the last time anyone took a serious look at emergency evacuations that have resulted from real incidents or accidents? The last I can recall is an in-depth review the NTSB did of emergency evacuations more than a decade ago when I was a Board member.

Maybe it’s time to take another look at what has happened since. And what hasn’t happened? It would be a mistake not to take a lesson from the cruise ship tragedy and review how this industry is doing. Are the FAA’s regulations on demonstrating emergency evacuations doing the job? Are they as all-encompassing or as stringent as they need to be to protect passengers and crew in the event an evacuation is necessary? And it is certainly time to review the NTSB recommendations to see whether they have been addressed adequately

Exemption Review Needed

Looking at the FAA’s regulations and the NTSB recommendations from 2000, I have to wonder why on earth manufacturers and operators of passenger-carrying aircraft with fewer than 44 seats are exempt from the same evacuation demonstration requirements as larger aircraft. Of course, the problems of evacuations are obviously compounded and made more complex as the number of passengers grows. But evacuating smaller aircraft in the event of an emergency deserves demonstration and mandatory observation by the FAA.

Certainly, if the FAA is serious about one level of safety–and I have always been pretty skeptical of how serious it is–this is clearly one area that deserves attention. After all, it is pretty hard to argue that safety is comparable when certain commuter operations don’t meet the same safety tests as other passenger-carrying airline operations, based solely on the number of passenger seats.

Regardless of FAA mandates–which are minimum standards, after all–operators of all aircraft (commuters, air taxis and corporate) would be wise to practice emergency evacuations with their crews regularly (say, once or twice a year). Why not take the time to practice what could save lives in the event of an emergency? In the years I worked on emergency preparedness with government agencies, airlines and airports, it became clear to me that regular emergency drills can make evacuations quicker and more orderly. And it is all about getting out as quickly (and safely) as possible; speed saves lives when it comes to getting out of a cabin filling with toxic smoke or engulfed in flames. And if you fly regular customers, whether under Part 135 or 91, it makes sense to ensure that they know how to operate emergency exits and how to get out in the event of an emergency. Yes, I know, some operators don’t like to bring up the possibility of any flight having an emergency for fear of spooking their passengers or they fear that practicing evacuations could cause injuries. And I get both those issues. But at least as far as the latter issue, there are ways to practice emergency evacuations and minimize the risk of injuries.

I could not talk about this subject without bringing up the issue of unrestrained lap children. As long as the FAA refuses to mandate kid seats for the youngest–and most vulnerable–airline passengers, those under the age of two, there will be the real likelihood lap children will seriously compromise an emergency evacuation.

Quite apart from the danger unrestrained lap children pose to themselves, there is no question they can also potentially wreak havoc in an emergency evacuation. Imagine trying to evacuate an airplane with frantic parents searching for a lap child they were unable to restrain? As it is, the NTSB study in 2000 found numerous reports of evacuations hindered by passengers pushing, shoving and even fighting during tense, real-life evacuations. In one reported accident, the Safety Board attributed fatalities to delays caused by two passengers in a dispute. There are many reasons the FAA should be mandating kid seats; here’s one that affects all of us who fly.

Lastly, however, I would like to compliment the FAA on at least one significant action–or more accurately, inaction–regarding evacuation demonstrations. I feel that one who regularly blasts the FAA should be just as quick to point out what it has done well. In this case, the FAA has managed to hold the line–despite significant pressure from aircraft manufacturers–on mandating live evacuation demonstrations, at least for those aircraft covered by the regulations.

Many in the industry have been pushing for computer simulations for some time. In the 1990s, when I served on the Aviation Rulemaking Advisory Committee for aircraft evacuations, manufacturers were advocating to use computer simulations in lieu of full-scale live demonstrations. Certainly, computer modeling would save time and money (and some injuries, too) but I have not seen evidence to date that it would save lives. And that is the whole point of demonstrating emergency evacuations.