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on § 25.841(a)(2) and (a)(3). AFA participated in the MSHWG but voted against submitting its
Final Report to the FAA. The commenter says that its opposition was based upon
“the lack of consensus within the MSHWG over the question of whether to allow cabin
altitude to exceed 40,000 feet following a rapid depressurization. We also objected to the
use of, for design purposes, an untested, unverified pressure-integral methodology, which
is apparently lacking even the most minimal validation, independent peer review of the
analysis method itself.”
The AFA attached a letter, dated July 3, 2003, expressing opposition to the FAA’s Draft Interim
Policy on Amendment 25-87 Requirements. The commenter states that the letter “fully supports
key elements of our critique on the Airbus petition for exemption.” The letter recommends that
the Draft Interim Policy not be adopted for the following reasons:
“the 40,000 foot cabin altitude represents a useful regulatory limit for high altitude flight
in the absence of sufficient, comprehensive data on human tolerance at high altitudes;
that the proposed pressure-time integral method lacks sufficient data and a rigorous peer
review to validate its use as a means of compliance; and that the FAA proposal represents
bad public policy since it represents means to circumvent existing regulations and may
reduce or even eliminate any motivation to validate the means of compliance.”
Another commenter, ALPA, also participated in the MSHWG and voted against submitting its
Final Report to the FAA. ALPA says that the “FAA’s aero medical experts had concerns
associated with several of the findings of the working group, some of the proposed language
discussed, and the amount of appropriate research available at the time.”
In terms of the MSHWG Final Report which examined available research studies on the
physiological effects of exposure to high cabin altitude, ALPA states that
 There was insufficient data available about the physiological effects;
 The data that was available did not represent a proper cross-section of the flying
public, and thus additional research was necessary to confirm the conclusions of the
MSHWG;
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 The Depressurization Exposure Integral (DEI) method, proposed in the report, was
“based on assumptions and extrapolations” that were not supported by research, and
not all members of the MSHWG agreed with the methodology.
ALPA further points out that additional research into the physiological effects of exposure to
high cabin altitude has not been conducted to date. Specifically, the commenter says that “Much,
and possibly all, of the research to date using humans has been limited to young, healthy, and fit
test subjects….Further testing is necessary to ascertain the resultant effects on a population more
representative of the traveling public.” ALPA adds that the DEI methodology has not yet been
validated.
2. Holes from uncontained engine rotor failures
The AFA takes issue with the way Airbus—using data from historical instances of uncontained
engine rotor failures—determined the size of the holes which such events would cause in the
fuselage and/or the wings of the A380. The commenter states that “…it seems counter-intuitive
to assume that equivalent hole-area scales by the fan diameter ratio rather than some other, more
conservative factor, such as the square of the diameter ratio….So while there will be larger holes,
one would also expect there will be more of them.”
3: Use of supplemental oxygen
One commenter, AFA, states that
“The sweeping conclusion inferred in [Section 2-2, final paragraph, p. 9 of the Airbus
petition] that the combination of existing FAA regulations on oxygen equipment and
A380 emergency descent rates will ‘adequately’ protect all passengers (not to mention
crew) is clearly unsupportable. No rapid, ‘worst-case’ cabin depressurization can
possibly result in no adverse consequences to the airplanes’s occupants.”
AFA goes on to say that, “…were the FAA to allow this exemption, we strongly urge the FAA to
do so only after ensuring that each and every one of the following MSHWG recommendations
(Reference 2, pp. 41-42) are first incorporated into the A380 design and operational plan….”
Another commenter, ALPA, indicates that
“Before the FAA considers granting this exemption, …there must be close examination
of the descent profiles and passenger systems being proposed by the petitioner to
determine the extent of cabin exposure times and how the oxygen system design will
　
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