As airlines continue to seek more effective ways of disinfecting flight decks, passenger cabins and onboard facilities, Embraer has announced new technical guidance for the application of antimicrobial coatings and disinfectant solutions to the aircraft cabin, as well as how to safely sanitise the airframer’s flight decks using UV-C.
“According to these specifications,” says Embraer, “the utilization of UV-C lights in the flight deck region will eliminate the COVID-19 virus. The disinfectants, compatible with the aircraft materials, were developed based on extensive testing and ease of application for all surfaces in the passenger cabin and cockpit.”
Its guidance covers the E-Jet and E-Jet E2 family, the ERJ145 regional jet, and the EMB120 Brasilia turboprop: some 2500 Embraer aircraft based in over 80 countries.
But while Embraer has issued a press release announcing the guidance, Nicolás Morell Gonzalez, global corporate communications at Embraer, has declined to provide the document to Runway Girl Network, stating that there is “no particular reason” for the company to withhold it. When pressed, he cited an unspecified misrepresentation of technical guidance at some unspecified time in the past by an unnamed media outlet outside the aviation industry.
RGN asked questions about the nature of the document, the level of detail to which it goes; how it would move beyond the FAA’s special airworthiness information bulletin on disinfecting airplane interiors (SAIB NM-20-17) and similar generic advice; what is different for the four Embraer aircraft cabins to other aircraft; the extent that it covers embedded IFE, power, and other buyer-furnished equipment; whether there are different levels of guidance for different seats or seat types, and whether the guidance differs across types of colour, materials and finish.
After all, if the document is legitimately important for operators of these aircraft — many of which are playing a key role in keeping essential air travel moving during the pandemic — it stands to reason it must serve a purpose beyond industry-wide guidance such as SAIB NM-20-17 on which RGN reported last year. At that time, the FAA warned airlines that some of the additional cleaning and disinfection protocols they were using to combat the risk of onboard spread of COVID-19 came with risks including corrosion, embrittlement, increased flammability and electrical short circuit.
While Embraer refuses to provide its own document to RGN, the company provided a written response to our questions, attributed to Sérgio Cunha, vice president for technical services & support, which neither goes into any meaningful detail nor provides any information about if or how the document moves beyond the relevant regulatory directives. We provide Embraer’s written response, in full, below.
It seems that Embraer wants the plaudits from a press release announcing documentation on how to ensure cabin and flight deck safety, but does not want to discuss the specific details of that documentation. If aviation wants the public’s trust, this is not the way to go about it.
RGN: What is the nature of this document?
Embraer: Embraer released instructions for its customers through the aircraft maintenance documents, which highlight the approved materials or methods to be used in the cabin. In these documents, there are instructions on how different products or methods can be applied and also limitations for which aircraft areas the sanitization/disinfection products and methods selected by the operator can be used.
RGN: To what level of detail does it go?
Embraer: The aircraft maintenance document provides detail on the area where the operator can apply the chosen product or method according to the disinfectant’s recommendation. All of the approved materials to be used as disinfectants follow each manufacturer’s recommendation since the effectiveness of the material as a disinfectant is guaranteed by its manufacturing company.
RGN: How does it go beyond SAIB NM-20-17 and similar generic advice?
Embraer: During the development of SAIB NM-20-17, FAA created a working group with all OEMs to provide some generic warnings in relation to the methods that the operator may choose to disinfect their aircraft cabin. In summary, FAA had concerns about the methods and how they will impact the aircraft’s airworthiness. As one example, a given material available could attack the aircraft structure and consequently create some corrosion spots. So, guidance on the material and methods on how to apply it to the aircraft is under the OEM responsibility. It is expected from all the OEMs to verify the compatibility between the product and its own aircraft.
RGN: What is different for the four Embraer cabins to other aircraft?
Embraer: Embraer has the same interior finishing and systems suppliers as other aircraft OEMs in the industry, and we use similar materials, approved and certified by the proper authorities. We do not expect major differences, although our guidance information is exclusively for the cabins of our products and we do not know details regarding the specifics of other aircraft cabins.
RGN: To what extent does it cover embedded IFE, power, and other BFE? Are there different levels of guidance for different seats or seat types? Does the guidance differ across CMF types?
Embraer: For both questions the answer is similar. Each method has its own limitations that are highlighted in the documentation provided. So, the operator must choose the correct method allowed by Embraer to correctly disinfect the desired area without causing any damage during the disinfection procedure. The main driver for the differences in guidance, whenever it exists, is the type of material being disinfected or protected, and not the seat type or configuration.
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