EuropeanAviationSafetyAgency 16May2008

NOTICEOFPROPOSEDAMENDMENT(NPA)NO200811

DRAFTDECISIONOFTHEEXECUTIVEDIRECTOROFTHEEUROPEANAVIATION
SAFETYAGENCY

AMENDING
DECISIONNO.2003/13/RMOFTHEEXECUTIVEDIRECTOROFTHEEUROPEAN
AVIATIONSAFETYAGENCY
of14November2003on
Certificationspecificationsincludingairworthinesscodesandacceptablemeansof
complianceforsailplanesandpoweredsailplanes(CS22)
and

DECISIONNO.2003/18/RMOFTHEEXECUTIVEDIRECTOROFTHEEUROPEAN
AVIATIONSAFETYAGENCY
of14November2003on
Certificationspecificationsincludingairworthinesscodesandacceptablemeansof
complianceforverylightaeroplanes(CSVLA)

Exits

R.F00802EuropeanAviationSafetyAgency,2007.Allrightsreserved.Proprietarydocument. Page1of12
 NPA200811 16May2008

TABLEOFCONTENTS

A. EXPLANATORYNOTE .......................................................................................... 3
I. GENERAL................................................................................................................3
II. CONSULTATION .........................................................................................................3
III.COMMENTRESPONSEDOCUMENT .....................................................................................4
IV. CONTENTOFTHEDRAFTDECISION ...................................................................................4
V. REGULATORYIMPACTASSESSMENT ..................................................................................8
B. DRAFTDECISION ............................................................................................. 11

I. DRAFTDECISIONTOCS22.......................................................................................11
II. DRAFTDECISIONTOCSVLA......................................................................................12

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 NPA200811 16May2008

A. EXPLANATORYNOTE

I. General
1. The purpose of this Notice of Proposed Amendment (NPA) is to envisage amending
Decision 2003/13/RM of the Executive Director of 14 November 20031 and to envisage
amending Decision 2003/18/RM of the Executive Director of 14 November 20032. The
scope of this rulemaking activity is outlined in ToR VLA.004 and is described in more
detailbelow.
2. TheAgencyisdirectlyinvolvedintheruleshapingprocess.ItassiststheCommissionin
its executive tasks by preparing draft regulations, and amendments thereof, for the
implementationoftheBasicRegulation3 whichareadoptedasOpinions(Article19(1)).
It also adopts Certification Specifications, including Airworthiness Codes and Acceptable
MeansofComplianceandGuidanceMaterialtobeusedinthecertificationprocess(Article
19(2)).
3. Whendevelopingrules,theAgencyisboundtofollowingastructuredprocessasrequired
by Article 52 of the Basic Regulation. Such process has been adopted by the Agencys
ManagementBoardandisreferredtoasTheRulemakingProcedure4.
4. This rulemaking activity is included in the Agencys rulemaking programme for2008.It
implementstherulemakingtaskVLA.004.
5. ThetextofthisNPAhasbeendevelopedbytheAgency,followingthedevelopmentofa
Regulatory Impact Assessment (RIA) by a dedicated Rulemaking group. It is submitted
for consultation of all interested parties in accordance with Article 52 of the Basic
RegulationandArticles5(3)and6oftheRulemakingProcedure.

II. Consultation
6. To achieve optimal consultation, the Agency is publishing the draft decision of the
ExecutiveDirectoronitsinternetsite.Commentsshouldbeprovidedwithin3monthsin
accordance with Article 6(4) of the Rulemaking Procedure. Comments on this proposal
shouldbesubmittedbyoneofthefollowingmethods:

CRT: Send your comments using the CommentResponse Tool (CRT)

availableathttp://hub.easa.europa.eu/crt/

Email: Only in case the use of CRT is prevented by technical problems

theseshouldbereportedtotheCRTwebmasterandcommentssent
byemailtoNPA@easa.europa.eu.

Correspondence: If you do not have access to internet or email you can send your
commentbymailto:

1
Decision No 2003/13/RM of the Executive Director of the European Aviation Safety Agency of
14.11.2003 on certification specifications, including airworthiness codes and acceptable means of
complianceforsailplanesandpoweredsailplanes(CS22).
2
Decision No 2003/18/RM of the Executive Director of the European Aviation Safety Agency of 14
November2003oncertificationspecifications,including airworthinesscodes andacceptablemeans of
complianceforverylightaeroplanes(CSVLA)
3
Regulation(EC)No216/2008oftheEuropeanParliamentandoftheCouncilof20February2008on
common rules in the field of civil aviation and establishing a European Aviation Safety Agency, and
repealingCouncilDirective91/670/EEC,Regulation(EC)No1592/2002andDirective2004/36/EC(OJL
79,19/03/2008,p.1)
4
Management Board decision concerning theprocedure tobe appliedby the Agency for the issuing of
opinions, certification specifications and guidance material (Rulemaking Procedure), EASA MB 08
2007,13.6.2007

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 NPA200811 16May2008

ProcessSupport
RulemakingDirectorate
EASA
Postfach101253
D50452Cologne
Germany

Comments should be received by the Agency before 16 August 2008. If received after
thisdeadlinetheymightnotbetakenintoaccount.

III. Commentresponsedocument
7. All comments received in time will be responded to and incorporated in a comment
responsedocument(CRD).TheCRDwillbeavailableontheAgencyswebsiteandinthe
CommentResponseTool(CRT).

IV. Contentofthedraftdecision
8. Background
The Agency has received 2 safety recommendations5 issued by the Air Accident
Investigation Branch (AAIB) of the UK Department of Transport following unrelated
accidentstoUKregisteredaeroplanes. Inbothcases,nonfatalaccidentsoccurredwhere
theaeroplanescametorestinaninvertedpositionwiththeoccupantsunabletoescape
unaidedduetothedesignofthecanopy,whichopenedupwards.
Bothrecommendationsaresimilarincontentandstatethefollowing:
SafetyRecommendation2004107
The European Aviation Safety Agency (EASA) should review the requirements for
the design of exits and the provision of safety equipment within the Certification
SpecificationsforVeryLightAeroplanes(CSVLA),toenablerapidescapefromsuch
aircraftinanynormalorcrashattitudeincludingturnover.
In response to the recommendations, the Agency initiated rulemaking task VLA.004
Exits and a rulemaking group was formed to assess the case for amending the
certification specifications to improve escape possibilities from a turnover position. The
TermsofReferenceforthegroupwasnotlimitedtoCSVLAbutincludedothercategories
ofsmallaeroplanes(CS23andCS22),wherethisissuecouldbeequallyapplicable.This
NPAisdevelopedbytheAgencybasedontheoutcomeofthisactivity.
9. StatisticalAnalysis
A detailed analysis of accident datahasnot been possible forthis task asno European
wide accident reporting system covering the applicable category of aeroplanes is
currentlymandated.ECDirective2003/42/EConoccurrencereporting6 isapplicableonly
to turbinepowered or public transport aircraft. Furthermore, there is no reliable data
regardingthenumberofflightsandflighthoursmadebyregisteredaircraft.
Some states and foreign authorities maintain an occurrence reporting system that is
voluntary for small aircraft. Data from these reporting systems has been obtained and
some similar eventshavebeenidentified(Seetable below).However,thisdatacannot

5
AAIBSafetyRecommendationNumber2004107(10July2004).
http://www.aaib.dft.gov.uk/cms_resources/GBXDO_305.pdf
AAIBSafetyRecommendationNumber200370(11August2002).
http://www.aaib.dft.gov.uk/cms_resources/dft_avsafety_pdf_023439.pdf
6
Directive 2003/42/EC of the European Parliament and of the Council of 13 June 2003 on occurrence
reportingincivilaviation

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 NPA200811 16May2008

be considered as an exhaustive list, but is provided here only as examples to illustrate

thetypeofeventsthatcanoccur.

Applicable
No Aircraft Date OccupantEscapedetails Reference
A/cData
1 Fournier 26/09/1997 FatalAccident MTOW680kg AAIBBulletin
RF5B Aeroplanecrashedinvertedandburstinto July1998.
GBAPA flames. Singlemain&
tailwheelu/c
2 Cozy 10/07/2004 The aircraft was quickly righted by MTOW680kg AAIBBulletin
GBXDO severalpeoplewhowereatthesceneand March2005.
the pilot then exited normally from the Tricycleu/c
relatively undamaged cockpit, once the
canopy, which opens upwards on a
forwardhinge,wasfreetoopen.
3 TriRKis 11/08/2002 Although uninjured [the occupants] were MTOW635kg AAIBBulletin
GBXJI unable to get out of the aircraft because June2001.
thegullwingdoors wereheldshutbythe Tricycleu/c
weight of the aircraft. The pilot used a
hand held fire extinguisher to break the
perspex windscreen and, in doing so,
activated the extinguisher filling the
cockpit with extinguishant. At that point
twopeople arrived fromthe control tower
and righted the aircraft. The two
occupants werethenabletoexitnormally
through the doors. There was no fire and
they suffered no ill effects from the
contentsofthefireextinguisher.
4 Robin 23/09/2006 FatalAccident. MTOW Brosfr
DR400500 Indications are that the single occupant 1060kg Flugunfallunt
HBKFE survived the crash but was subsequently ersuchungen
unable to escape from the inverted Tricycleu/c (BFU)
position, despite aid from other people at
thescene.Aircraftcaughtfire.
5 GlobeSwift 12/02/2006 Pilot and passenger exited after kicking MTWA890kg NTSB
N80715 outthecanopy LAX06LA112
Tailwheel
6 Harmel 15/10/2005 The pilot and passenger exited the MTOW730kg NTSB
RV6A airplane after airport rescue personnel LAX06CA019
Homebuilt brokethecanopy Tricycleu/c
N221MH

7 Pitts 22/02/2006 exit from the airplane was aided by a MTOW770kg NTSB
Special cracked canopy He manually broke a CHI06LA085
N55MW hole through the canopy and exited the Tailwheel
airplane

Table1:Examplesofaccidentsinvolvingturnoverofsmallaeroplanewherethesafetyof
thoseonboardwasseverelycompromisedduetotheirinabilitytorapidlyescape.

The data set includes one fatal accident (Ref: Table 1 No.1), where the upturned
aeroplane subsequently caught fire. However, it remains uncertain from the accident
reportastowhetherthesingleoccupantcouldhavesurvivedhadegressbeenpossible.
The Agency is also aware of a similar accident in Switzerland (Ref: Table 1 No.4).
Although the BFU investigation is still ongoing, initial indications are that the accident
aeroplaneexperiencedanengineprobleminflightthatresultedinaforcedlanding,with
the aeroplane coming to rest in an inverted position. The single occupant survived the
impact,butwassubsequentlyunabletoescape,evenwiththeassistanceofmembersof
the public who attended the scene. The aeroplane subsequently caught fire resultingin
thedeathoftheoccupant.

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10. ReviewofExistingRequirements

A review of the existing EASA Certification Specifications has identified the following
designrequirementsapplicabletodifferentcategoriesofaeroplanes.

a) CS23
CS23.807Emergencyexitsstatesthefollowing:
CS23.807Emergencyexits
(a) Number and location. Emergency exits must be located to allow escape
withoutcrowdinginanyprobablecrashattitude.
AMCtoCS23.807makesdirectreferencetoFAAAC2317.Thecurrentversion,AC
2317Bdated12April20057,providesthefollowingguidanceonthisissue:
23.807Emergencyexits

Emergency exits should allow escape without crowding in any probable crash
attitude. The inverted position is considered probable for both tail wheel and
tricycle gear airplanes. This applies to airplanes with doors, forward sliding
canopies, rearward sliding canopies and jettisonable canopies. If escape in an
inverted attitude is not obvious or is questionable, then compliance should be
shown.
It is not acceptable for certification purposes,except for acrobatic airplanes (
23.807(b)(5)),to rely on an emergency procedure requiringcanopy jettisoning
beforeanaccidentoccurs.
The AC material makes clear reference to the inverted position and furthermore
identifies this condition as a probable event, irrespective of the landing gear
configuration.
The Agency believes that CS 23.807 together with the related AMC provides a
sufficientminimum standardto address emergencyegress froman invertedposition
forthiscategoryofaeroplane.

b) CSVLA
CSVLA783Exits,statesthefollowing:
CSVLA783Exits
(a) The aeroplane must be so designed that unimpeded and rapid escape is
possibleinanynormalandcrashattitudeexcludingturnover.
(b)
NoAMCisprovided.
JARVLA (subsequently CSVLA) was originally developed to create a simple and
inexpensiveclassofsmallaeroplanestoofferanalternativetomicrolightsthathadno
common European airworthiness standards. The turnover attitude was specifically
excluded from JARVLA 783, Exits. When JARVLA 783(a) was originally developed
(published 26 April 1990), it was considered that a requirement coming from JAR
22.807(a)wouldbemoreappropriatethanFAR23.783(a).Crashattitudesweretaken
into account, except the turnover position, as including turnover was thought to
precludetheuse of canopies. For turnovers it was consideredthat thecanopy must
beopenedpriortothecrash.

7
TherelevanttextofAC2317B23.807remainsunchangedfromAC2717dated25April2000

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TheAgency,in reviewingtheoriginal justification forexcludingturnoverin JARVLA,

believesthatanoperationalprocedurethatrequiresthecanopytobeopenedpriorto
a crash is neither realistic nor practicable in many cases (e.g. forward hinged
canopy).AC2317statesthattheinvertedpositionshouldbeconsideredprobablefor
bothtail wheel andtricyclegear aeroplanes forcompliance with CS23/FAR Part23.
Furthermore, an examination of occurrence records as part of this task, although
limited in scope and depth of analysis due to the unavailability of data, does show
thatitisnotuncommonforsmallaircraft,includingthoseintheVLAcategory,toturn
overduringacrash.TheAgencythereforeseesnojustificationwhythisshouldnotbe
equally applicable to aeroplanes in the VLA category. This NPA proposes that the
certification specification is amended so that turnover is not excluded from CSVLA
whenconsideringpostcrashescapeprovisions.
The use of canopies is common in VLA certificated aeroplanes. Typically they are
made of materials such as: Plexiglas, acrylic,polycarbonate,etc.Oneofthespecific
characteristics of such materials is their lack of frangibility. Tests have shown that
often it is necessary to "puncture" a canopy before the panel will yield. Blunt
applicationofforceaimedatbreakingthecanopymaynotbesufficient.Althoughthe
currentregulationsdonotrequiretheinstallationofacrashaxeorsimilartoolinlight
aircraft, some national aviation authorities are now issuing recommendations to
operatorstovoluntarilyconsidertheinstallationofsuchequipment.Inconsideringthe
inverted position, the use of such equipment would be an acceptable means of
complianceifitwasdemonstratedthatrapidescapewasthenpossible.
InreviewingCSVLA,theAgencyhasalsoconcludedthatthetextofCSVLA783(a)is
misplacedandproposestomoveittoCSVLA807,withappropriatechanges.Thiswill
provideconsistencythroughouttheCSs.

c)CS22
CS22.807Emergencyexits,statesthefollowing:
CS22.807Emergencyexit
(a) The cockpit must be so designed that unimpeded and rapid escape in
emergency situations during flight and on the ground is possible with the
occupantwearingaparachute.
(b)
NoAMCisprovided.
Atpresent,CS22hasageneralrequirementthatthecockpitmustbesodesignedto
allowrapidandunimpededescape.Theturnoverconditionisnotspecificallyexcluded
bytheruleandisthereforeinterpretedasbeingalreadyrequired.
Current certification practice recognises differences between configurations of
sailplanes/powered sailplanes and that some types may be more susceptible to
turnover than others. Most conventional sailplanes with a close coupled single main
undercarriage are deemed not to be susceptible to turnover and the lack of
occurrence reports identified as part of the statistical analysis tends to confirm this
conjecture. Furthermore, without an engine and fuel system fitted, there is no
additionalfirehazard.Forothertypes,particularlytouringmotorgliders,whichare
fitted with an engine and may have tricycle or main/tail wheel undercarriage
configurationssimilartoCSVLAtypes,theriskofturnovermaybemorepronounced
andescapefromaturnoverpositionmaybeconsideredduringcertification.
The Agency believes that the current rule, which provides an objective requirement
coveringallaircraftinthiscategory,remainsappropriate.However,furtherguidance
isgiveninanewAMCinordertoprovideclearacceptablemeansofcompliance.This
takestheformofathreepartassessmentasfollows:

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 NPA200811 16May2008

1. Assess susceptibility to turnover and the likelihood of additional postcrash

hazards(e.g.fire).
2. Ifitisdeterminedthatadesignisnotsusceptibletoturnovernofurtheractionis
necessary.If however turnover remains a distinct possibility or is questionable
and additional hazards may be present, provision should be made in the basic
designtoallowtheoccupantstorapidlyescapefromaninvertedposition.
3. Asanalternativetoprovisionswithinthebasicdesign,itisacceptabletoinstall
equipment (e.g. crash axe)that wouldpermittheoccupant(s) to makearapid
escape from the inverted position. In this case, it would not be necessary to
consider the wearing of a parachute, as escape could be made more rapidly if
theoccupants released their parachutes prior to egress rather than attempt to
enlargeanescapeopeningorriskgettingentangled.

TheenvisagedchangetoDecision2003/13/RM(CS22)is:

In Book 1 SUBPART D Design & Construction, introduce a reference to new AMC

22.807(a). Add a new AMC 22.807(a) to give guidance on assessing configurations
susceptible to turnover and, where appropriate, that the turnover condition is properly
addressedtoprovidetheabilityforpersonsonboardtoescapeaninvertedaircraft.

TheenvisagedchangetoDecision2003/18/RM(CSVLA)is:
InBook1SUBPARTDDesign&Construction,amendCSVLA.783ExitsandCSVLA.807
Emergency exits. The change will delete the exclusion of turnover as a design
consideration in order to enable persons onboard to escape an inverted aeroplane.
AdditionalAcceptableMeansofCompliance(AMC)isprovidedinBook2.

V. RegulatoryImpactAssessment

11. Purposeandintendedeffect
a. IssuewhichtheNPAisintendedtoaddress
Accident investigations and occurrence reports associated with small aircraft have
highlightedapotentialsafetyissueregardingemergencyegressfromanaircraftin
an inverted position. The issue is particularly relevant in the case of aircraft
equippedwithgullwingdoorsoraslidingcanopy,wheretheweightoftheupturned
aircraft on the exit prevents it from opening. In combination with additional post
crash hazards such as fire, this situation could severely jeopardise the safety and
survivabilityofoccupants.
TheobjectiveofthisNPAistoproposeachangetothedesignstandardsappliedto
smallaeroplanes(CSVLAandCS22),inthelightofrecentaccidentsandincidents
involvingescapefromanaircraftinaninvertedposition.
b. Scaleoftheissue(quantifiedifpossible)
The number of VLA and small aeroplanes in the EC that can be considered to be
vulnerabletotheaddressedriskareestimatedatseveralthousands.
Due to the limited data available, it has only been possible to identify a small
number of actual accidents and incidents where small aeroplanes ended in a
turnover attitude and where the occupants had difficulty exiting or required
assistance.
c. BriefstatementoftheobjectivesoftheNPA
The objective is to improve the escape possibilities from a turnover attitude for
smallaircraftforwhichthisriskexists.

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12. Options
Theidentifiedoptionsare:
Option1: Donothing
Option2: Change Certification Specifications to ensure the design of future small
aeroplanestakedueconsiderationoftheinvertedposition.
Option3: AsOption2butalsoincluderetroactiveapplicationtoimprovethesafety
ofthecurrentfleet.

13. Sectorsconcerned
Designers of small aircraft (CSVLA, CS22) and organisations involved in major
modificationstothoseaircraft.
Individualowners/operatorsofsmallaircraft.

14. Impacts

a. Allidentifiedimpacts

i. Safety
Option1: Would have no effect on safety. Accidents and incidents involving
turnover would continue to occur, jeopardising the safety of those
onboard.
Option 2: Changesto CSVLA will ensure that new designs will incorporate a
higher minimum standard that addresses occupant escape,
including the turnover condition. Due to the low number of new
General Aviation designs being type certificated and the low
exchangerate of aircraft (i.e.new designs replacingolderones),a
changeintheCSswillhavelittleimmediatesafetybenefit.
Thechangeto CS22 willhaveno safety benefit butisintendedto
provide clarification to the existing certification specification and
certificationpractice.
Option3: The same as Option 2 plus retroactive application aimed at
enhancing safety levels on the existing fleet would ensure existing
types met the intent of the new design standard. A quantified
assessment of the safety benefit hasnot been possible due to the
lackofoccurrencedataonwhichtoperformadetailedanalysis.Two
fatal accidents where the aircraft attained an inverted position
following a crash have been identified. However, the occupants
inability to escape has not been positively identified as a causal
factorineitheroccurrence.

ii. Economic
Option1: Mayhaveanegativeeconomicimpactiffatalaccidentscontinueto
occur and it can be establishedthat the inability to escape from a
turnoverattitudeisadirectcausalfactor.
Option 2:Theintroduction ofamendedcertification specifications and/orAMC
would only apply to new designs or major modifications. The
economic impact would therefore be minimal in relation to the
overalldesignandcertificationcost.
Option3: Retroactive action that required modification to the basic design
would have a large economic burden on operators/owners.

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Installationofemergencyescapeequipmentintotheexistingfleetis
consideredaseconomicallyacceptable.

iii. Environmental
Noenvironmentalimpacthasbeenidentified.

iv. Social
Nosocialimpacthasbeenidentified.

v. OtheraviationrequirementsoutsideEASAscope
FAA: Sailplanes and VLA are addressed as a special class in accordance with
FAR 21.17(b). The appropriate airworthiness standard is specified by the
administratorandcanrefertoCS22/CSVLA,ifappropriate.

b. Equityandfairnessintermsofdistributionofpositiveandnegativeimpactsamong
concernedsectors.
Noequityandfairnessissueshavebeenidentified.

15. SummaryandFinalAssessment

a. Comparisonofthepositiveandnegativeimpactsforeachoptionevaluated:
Option1: No effects on safety. May have a negative economic impact if fatal
accidentscontinuetooccuranditcanbeestablishedthattheinabilityto
escapefromaturnoverattitudeisadirectcausalfactor.
Option2: There will be a positive effect on safety for CSVLA with moderately
negativeeconomical consequences.Theproposedchangeto CSVLA will
provide a clear requirement that turnover must be considered in future
designsandwillbeconsistentwiththeotherCSs.
ForCS22,nochangeinstandardisproposed,butclarificationisgivenin
newAMC22.807toensuretheturnoverconditionisproperlyconsidered
insailplanedesign.
Option3: The case for retroactive action of design changes is considered to be
unsubstantiated. A qualitative assessment indicates that the economic
impact of design changes far outweigh the likely safety benefits.
Retroactive installation of emergency escape equipment within the
cockpit may be more economically feasible. However, without a clear
safetybenefithavingbeenestablishedandthepossibleadditionalhazard
that such equipment could bring, the Agency will not mandate the
retroactive installation of crash equipment. It is recognised that some
NAAsarerecommendingthevoluntaryinstallationofcrashaxesandthe
Agencysupportssuchanapproach.

b. A summary of who would be affected by these impacts and issues of equity and
fairness:
Theproposalswouldequallyaffectmanufacturersandcustomers/operators.

c. Finalassessmentandrecommendationofapreferredoption:
AfterdueconsiderationtheAgencydecidedthatOption2istobepreferred.Thiswill
ensure that the minimum standard defined in CSVLA is enhanced to include
turnoverandimproveegressfromanupturnedaeroplane.CS22isamendedbythe
additionofAMCtoprovidegreaterclarificationforcompliancewithCS22.807.

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B. DRAFTDECISION

Thetextoftheamendmentisarrangedtoshowdeletedtext,newtextornewparagraph
asshownbelow:
deletedtextisshownwithastrikethrough: deleted
newtextishighlightedwithgreyshading: new
.
indicates that remaining text is unchanged in front of or following the reflected
amendment.

I. DraftDecisiontoCS22
Article1

Decision 2003/13/RM of the Executive Director of the Agency of 14 November 2003 is

herebyamendedasfollows:

Book1
SUBPARTB Design&Construction

CS22.807Emergencyexit

(a) The cockpit must be so designed that unimpeded and rapid escape in emergency
situations during flight and on the ground is possible with the occupant wearing a
parachute.(SeeAMC22.807(a))

(b)

Book2

AMC22.807(a)EmergencyExit

When assessing ground escape, the possibility of the aircraft coming to rest in an
inverted (turnover) position should be determined together with an evaluation of post
crash hazards that could endanger the occupants in such an attitude (e.g. the risk of
fire).

If it is determined that a design is not susceptible to turnover or the evaluation

determines that there is unlikely to be any life threatening postcrash hazard that
demandsrapidoccupantegress,thennofurtheractionisnecessary.Ifhoweverturnover
remainsadistinctpossibilityorisquestionableandpotentiallylifethreateningpostcrash
hazardsmayexist,provisionsshouldbemadeinthebasicdesigntoallowtheoccupants
tomakearapidescapefromaturnoverposition.

As an alternative to provisions within the basic design, it is acceptable to install

equipment (e.g. crash axe) that would permit the occupant(s) to make a rapid escape
from the inverted position. In such a case, it would not be necessary to consider the
wearingofaparachute,asescapecouldbemademorerapidiftheoccupant(s)released
their parachute(s) prior to egress rather than attempt to enlarge an escape opening or
riskgettingentangled.

Acanopycouldbeacceptedascompliantwiththeturnoverprovision,ifqualifiedescape
equipment (e.g. a crash axe) or specific design features (e.g. identified weakpoint) on
thecanopyareprovided.

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II. DraftDecisiontoCSVLA
Article2

Decision 2003/18/RM of the Executive Director of the Agency of 14 November 2003 is

herebyamendedasfollows:

Book1
SUBPARTDDesign&Construction

CSVLA783Exits

(a) Theaeroplanemustbesodesignedthatunimpededandrapidescapeispossiblein
anynormalandcrashattitudeexcludingturnover.

(b) Noexitmaybelocatedwithrespecttoanypropellerdiscsoastoendangerpersons
usingthatexit.

CSVLA807Emergencyexits

(a) Theaeroplanemustbesodesignedthatunimpededandrapidescapeispossiblein
anynormalandcrashattitude.(SeeAMCVLA807(a))

(b) Where exits are provided to achieve compliance with CSVLA 783 (a),The opening
system must be designed for simple and easy operation. It must function rapidly
andbedesignedsothatitcanbeoperatedbyeachoccupantstrappedinhisseat,
and also from outside the cockpit. Reasonable provisions must be provided to
preventjammingbyfuselagedeformation.

Book2

AMCVLA807(a) Emergencyexits

Unless otherwise justified, the inverted position (turnover) should be considered

probable. If escape in an inverted position is not obvious or is questionable, then
complianceshouldbedemonstrated.

Acanopycouldbeacceptedascompliantwiththeturnoverprovision,ifqualifiedescape
equipment (e.g. a crash axe) or specific design features (e.g. identified weakpoint) on
thecanopyareprovided.

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