The new FAA reauthorization bill, which passed the House on 26 September, includes a number of calls for the FAA to address common topics of debate when it comes to passenger safety and well-being, including forcing the agency to set minimum standards for aircraft seating. One key requirement is that the FAA review the design of aircraft oxygen masks within 180 days after the day of enactment.

This provision, under Section 581 of the bill, follows the engine failure and decompression incident aboard Southwest Airlines Flight 1380 from which images were shared on social media showing some passengers donning their masks improperly.

While Section 581 is brief, its impact will be significant if the Senate approves the bill. The Senate vote could take place as early as today, or be pushed out as the Kavanaugh deliberations take center stage.

The provision could result in great expense for manufacturers of this equipment, for airlines, and for international regulators. The 180-day time limit is itself a short window to review the design and come up with alternatives.

Changing a major functional element of safety equipment is not straightforward – new masks would need to be designed, prototyped, tested, proven, and manufactured, whilst the prior design would need to be replaced. Such an overhaul may not be limited to the US fleet. Because oxygen masks are common-design equipment, the new standard might be adopted by other regulators around the globe – if not immediately, then soon.

Manufacturers, airlines and regulators would have to come up with an agreed timeframe to replace the units currently in service. That will be governed in part by supply; that is, how quickly manufacturers can build the new mask apparatus based on their manufacturing capacity, the availability of raw materials and sub-components, as well as a re-tooling of the equipment used to build the parts and assembly.

There are oxygen masks overhead of every seat on commercial aircraft, so it is impossible to change them all at once. The process requires aircraft maintenance to remove the old equipment and install new units. As a result, there will be a mix of different types of oxygen masks on different aircraft within the same airline fleet, and from airline to airline.

Would that be more or less confusing to passengers? There is a precedent for mixed safety equipment. Life jackets, for example, have different methods of donning – often as a result of different national regulations or the airline cabin safety team’s specifications. The variation is limited by the FAA TSO (Technical Standard Order) but that is not universally adopted in other regions of the world. For example, the UK has its own specifications and a separate approval process for this equipment.

There are precedents for expediting a global change of critical safety parts. One that is particularly notable is the order to change and reinforce flight deck doors after the 9/11 attacks, to prevent a similar flight deck incursion.

Regulators prioritized the development, manufacturers pushed resources to build the doors quickly and airlines re-routed aircraft through maintenance facilities to install them immediately. It was an expensive and disruptive process, but one that was more than justified given the great tragedy that prompted it. Aviation could not allow that vulnerability to continue.

Whether oxygen mask replacement is treated with the same urgency will be a judgment call, based on likelihood of use. A careful study of human factors in emergencies might guide a re-design, and help determine whether the design needs to be changed. 180 days might not be enough time for that process.

Runway Girl Network reached out to the FAA for comment but had not heard back at the time of publication. Zodiac Aerospace said in a statement: “As world leader in oxygen systems, Zodiac Aerospace is closely following the topic, we are ready to cooperate and bring our expertise to the FAA.”

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