The FAA is considering changing high-altitude oxygen equipment requirements, and a key business aviation executive involved in the issue expressed hope that “something is going to happen soon that is very positive.”
After a four-plus-year effort to gain attention on concerns surrounding mandates for high-altitude oxygen masks in business aircraft, Rick Miller, chief pilot for Merck Sharp & Dohme Corp. and chairman of the NBAA High Altitude Supplemental Working Group (HASO), spoke at the Bombardier Safety Standdown on Tuesday. He said that the FAA met with leaders on the issue in May and opened a productive dialog on potential changes to FAR 91.211.
That meeting resulted in a strategy on the issue, Miller said, adding he is encouraged that the FAA planned to act on their concerns, although he wasn’t able to say just yet what the final result might be.
Under 91.211, pilots must continuously wear an oxygen mask when flying above FL410 and when only one pilot is available at FL350. If two pilots are on the flight deck between FL350 and FL410, oxygen masks must be within reach. Data suggests that 60 percent to 80 percent of pilots do not comply with the requirement to don oxygen masks, he said, expressing a belief this number might actually be closer to 90 percent.
Miller, who has written a paper and given a number of presentations on the issue, said noncompliance is not a matter of lazy or undisciplined pilots. Instead, he believes the risks of using the masks outweigh the benefits. Concerns arise over potential fatigue setting in from extended use, interference with cockpit resource management, interference with vision, possibility of contamination of oxygen masks, and possible health risks from prolonged exposure to 100 percent oxygen, among others.
It was actually a noncompliant event that motivated Miller to begin the campaign for change. He learned of the event and subsequently reached out to the pilots involved. His concern was that he had to require his pilots to comply with a rule that none of them liked, but that he would have trouble continuing to mandate such compliance if others were not setting examples.
This led to a dialog that expanded to others in the industry, and Miller eventually discussed his concerns at an OEM conference. NBAA subsequently worked with Miller to form the HASO working group, which has since been joined by numerous safety experts, business aircraft operators, and manufacturer representatives, among others.
The group sent out a survey to pilots on the issue and received 2,000 responses, many with detailed comments, underscoring the interest in a change to 91.211. Miller believes the strong response caught the attention of the FAA, which led to the collaboration on the issue.