Cabin Safety Bulletin No. 3 - Expanded Use of Portable Electronic Devices (PEDs)
Who does this bulletin apply to?
This bulletin applies to passenger carrying regular public transport (RPT) and charter operators who are operating under ‘Exemption – passenger carrying small portable electronic device (PED) during flight’ or are looking to transition their operation to do so.
What is the purpose of this bulletin?
This bulletin is provided to guide operators seeking to apply or continuing to operate under the exemption that permits the expanded use of PEDs. It is provided as guidance to ensure appropriate policies and procedures are developed or maintained.
What this CSB does not cover
This bulletin does not address airworthiness requirements in relation to the expanded use of PEDs. Further guidance in respect to electromagnetic interference can be found in AC 21-53 Electromagnetic Capability.
In 2014 the Civil Aviation Safety Authority (CASA) permitted the expanded use of PEDs under an exemption. The exemption was against the requirements of CAO 20.16.3 paragraph 9.3 specifically, which requires the stowage of loose articles during certain stages of flight. The exemption permits passengers to continue to use their PEDs at all stages of flight without having to stow them.
Through the recent renewal of the exemption and further surveillance activities, it has been highlighted that operators may need to conduct a review to ensure that they are still meeting the requirements.
For those operators who have yet to transition, this document provides guidance to ensure that they can make an appropriate application that addresses cabin safety aspects.
What are the exemption conditions that must be applied?
The term ‘carrying’ in this context means the passenger can:
- Hold the device
- Place the device in their pocket
- Place the device in a magazine pocket of the passenger seat in front
The applicable conditions are:
- the operator or pilot in command of the aircraft must ensure that the carriage of the small electronic device by the passenger does not impede emergency egress from the aircraft during the operation;
- the operator or pilot in command of the aircraft must ensure that the passenger does not leave the small electronic device unattended during the operation;
- the operator of the aircraft must have documented processes and procedures covering the requirements for passengers carrying small portable electronic devices during the operation.
To meet these conditions operators must have appropriate procedures and crewmember training in place to ensure the safe use of PEDs at all stages of flight.
To meet these conditions, what should I do first?
- Assess the tolerability of the aircraft (details not covered in this bulletin, please see AC 21-53 Electromagnetic Capability)
- Conduct a risk assessment related to the expanded use of PEDs and develop appropriate mitigation strategies as required
- Develop policy and procedures
- Revise crew training programs
- Provide passengers with supplementary information prior to and during flight
- Monitor and follow up on any identified issues through your internal safety management system (SMS)
What should my risk assessment include?
Identified hazards and their potential consequences.
Below is one example. Please note that there will be multiple hazards and consequences. Refer to ICAO Cir340 Guidelines for the Expanded Use of PEDs for further detail:
Hazard Consequence(s) Improperly stowed/secured PEDs during take-off and landing
- Injury to occupants if PEDs become loose and/or projectile
- Impeded evacuation
- PEDs being crushed in passenger seats
- A safety risk assessment of the identified hazards and consequences (likelihood and severity of consequence). Determining if any of the risks can be eliminated, reduced to an acceptable level and if there is any residual risk, if that risk is at a tolerable level.
Mitigation strategies that address the identified risks that require action.
For example, to address the hazard identified above, an additional defence may be an announcement to passengers in the safety briefing, followed by a cabin secure check that ensures that PEDs are secured or stowed appropriately.
What needs to be covered in operational procedures?
Operational procedures should have been developed following an appropriate risk assessment process (as outlined above, with an output of a safety case for submission to CASA), which should include the following:
- Types of PEDs that can be used, and at what stages of flight
- Limitations on use including charging of devices during critical stages of flight
- Procedures during normal, abnormal and emergency situations e.g. refuelling, turbulence, PED smoke/fire events
- Suspected or confirmed electromagnetic interference (EMI) event
- Securing and stowage
- Passenger information and education
- PED distraction and the receipt of passenger safety information
- Passenger non-compliance with PED policy
- Training programs
- Staff use of personal and company issued PEDs
- Management of wireless services
- International operations and foreign regulations
- PED event reporting as part of the safety assurance program.
In relation to passenger care and crew response, the following should be considered in the development/review of procedures:
- Describe the communications methods used to keep passengers up to date with what is required
- Describe techniques that may be used to deal with passengers that are using their PEDs in a disruptive or unsafe way (using PED speakers instead of headphones, loud voice communications, etc.).
- Explain how the passengers will be kept informed as to when it is OK to use PEDs and when/how they should secure or stow them appropriately.
- Describe what passengers should do if they drop or lose their device to avoid it becoming a fire hazard (for example. they should refrain from moving their seat and contact a crew member).
What is the difference between ‘stowed’ and ‘secured’? What else do we need to ensure to meet the conditions of the exemption?
There is an important distinction between “stowing” and “securing” PEDs. If a PED is to be “stowed”, it must be placed into an approved carry-on stowage location. These locations have been designed and certified to comply with the requirements for retention of articles of mass during emergency landings.
Approved carry on stowage locations have specific weight and size limitations. When a PED is “secured”, it is restrained by a method which may not have been certified for retention of articles of mass to the emergency landing load limits.
To meet the conditions of the exemption, operators must ensure the following:
- Large PEDs (such as full-size laptop computers) must be stowed in an approved carry-on stowage location and not present an undue hazard in the event of severe turbulence, crash forces or emergency egress. Large PEDs are those that the operator has determined have a mass more than 1 kg or are of a size that would impede egress.
- Small PEDs must be stowed or secured at all times when seat belts are required to be worn. Passengers who do not wish to stow their PEDs should be encouraged to secure them on their person, such as in a garment pocket. Passengers may also secure small PEDs by placing them in seat pockets or holding them in their hands. A PED should not be left unsecured on an empty seat. Additionally on larger aircraft, if a passenger cannot locate their PED, they should not move their seat and be encouraged to contact a crew member for assistance. This is to avoid the possibility of the device being crushed and creating a fire hazard.
- Seat back pockets are generally designed to hold a maximum of 1.5 kg. The passenger safety information card, magazines, other literature and air sickness bag account for approximately 0.5 kg. When an operator conducts a safety risk assessment to determine an acceptable weight limit for the seat pocket, these items should be taken into account. As a general “rule of thumb”, small PEDs and any other personal items placed in the seat back pocket should not exceed a total mass of 1 kg and should not protrude to the point of impeding egress. The FAA provides additional guidance for US air carriers in InFO 09018.
- PED cords or accessories must not impede emergency egress.
- PED policy must discourage passengers from getting up from their seats to access the overhead storage bins or other stowage areas at a point in time that would present a hazard to themselves or the passengers around them.
The following documents may require revision to indicate the expanded use of PEDs. If you are already operating under the exemption, all documentation must already reflect this. This includes:
- Operations manuals
- Training material
- Internal checklists
- Passenger safety information cards
- Passenger briefing materials
What should be included in initial and ongoing crew training?
Training programs should include:
- Management of suspected or confirmed electromagnetic interference
- Smoke or fire from a PED or a battery and other similar scenarios
- Passenger use during emergencies
When should training occur?
- Initial training
- Recurrent training (particularly in relation to emergency procedures)
- As the safety assurance program dictates
What needs to be considered when passengers are airside with PEDs?
Passengers transiting to or from an aircraft can experience cognitive distraction from mobile phone or other PED use. This reduces situational awareness, increases unsafe behaviour and puts the passenger at greater risk of accidents.
Hazardous conditions that may need to be considered include:
- Other aircraft movements in close proximity and ground service or fuelling vehicles
- Night operations at remote aerodromes without adequate airside lighting may also present hazards that should be considered.
Currently some operators permit PEDs to be ‘ON’ during transit to/from the aircraft. It is recommended that operational procedures do not permit the use of PEDs during this time. If the aircraft is being refuelled passengers must not be permitted to utilise their device(s) on the tarmac and a staff member that has been appropriately trained must be present. ‘Exemption – using portable electronic devices when loading fuel’ addresses these requirements.
Monitoring and improvement
To ensure a process of continuous improvement and ongoing hazard/risk identification, operators should encourage the following be reported by crew members:
- Passenger behaviour/disruption related to PEDs
- Suspected or confirmed PED interference
- Damage to PEDs that had the potential to cause or has caused in-flight smoke or fire
- PED or battery failure that has resulted in a smoke or fire event
CASA will continue to conduct surveillance of activities related to the expanded use of PEDs.
The operator’s SMS or safety assurance program should continue to monitor occurrences to assist in identifying areas that require improvement.
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