Consultation expired with comments. The corresponding Comment Response Document (CRD) has been completed by EASA and the Special Condition has not been changed based on the comments received.
Details
Identification of issue
Following the events of September 11, 2001, the FAA adopted standards for flightdeck security in January 2002 by adding 14 CFR 25.795 and amending 14 CFR 121.313. Those amendments were intended to make the flightdeck resistant to forcible intrusion and small firearms, and prevent unauthorized entry into the flightdeck.
These requirements were based on International Civil Aviation Organization (ICAO) standards, and the recommendations of the Aviation Rulemaking Advisory Committee (ARAC) Design for Security Harmonization Working Group. ARAC included representatives of aircraft owners and operators, airmen and flight crewmembers, airports, aircraft maintenance providers, aircraft manufacturers, public citizen and passenger groups, training providers, and labour organizations.
Even a strong and secure flightdeck door, however, must occasionally open to accommodate necessary activities such as lavatory breaks and meal service. Between the time of opening and closing the flightdeck door (door transition), the open flightdeck has some degree of vulnerability to attack. Such an attack could happen quickly, and leave insufficient time for the cabin crew to react.
Therefore, in 2007, the FAA promulgated requirements to address the security of the flightdeck when the flightdeck door was opened, however briefly. Specifically, the FAA adopted operating requirements 14 CFR §§ 121.584, “Requirement to view the area outside the flightdeck door,” and 121.587, “Closing and locking of flightcrew compartment door,” to require that the flightdeck door be locked when the airplane is in operation, unless it is necessary to open it to permit access by authorized persons, and required compliance with FAA-approved procedures for opening the door.
As a result of these new US operating requirements, concerned air carriers and type design holders developed various methods and designs, including the use of crewmembers and equipment and, in limited cases, IPSBs, to help secure the flightdeck during the period when the flightdeck door was open during flight.
To provide guidance and recommendations for these different methods and designs, RTCA formed a committee to develop recommended procedures and standards for airplane secondary barriers. In 2011, RTCA produced DO-329, “Aircraft Secondary Barriers and Alternative Flight Deck Security Procedures.” DO-329 describes various means of addressing the times when the flightdeck door must be opened. In this context, these means can be combinations of people, procedures and/or equipment. The document does not recommend one of these means over another, but provides advice on the use of each one to meet the objective of a secure flightdeck. Subsequently and based on the RTCA's report, the FAA issued Advisory Circular (AC) 120-110, “Aircraft Secondary Barriers and Alternate Flight Deck Security Procedures,” in 2015. That AC references various means of compliance with § 121.584(a)(1), which prohibits the flightdeck door from being unlocked during flight unless the operator has an approved procedure and visual device to verify that the area outside the flightdeck door is secure.
On October 5, 2018, U.S. Congress enacted the FAA Reauthorization Act of 2018 (the “Act”). Section 336 of the Act required the FAA to issue an order requiring installation of a secondary flightdeck barrier on each new aircraft that is manufactured for delivery to a passenger air carrier in the United States operating under provisions of part 121.
On June 20, 2019, to facilitate the implementation of the mandate in section 336 to require secondary barriers on certain aircraft, the FAA tasked ARAC to recommend standards for IPSB. The ARAC formed the Flightdeck Secondary Barrier Working Group (the “Working Group”), under the Transport Airplane and Engine Subcommittee, to carry out the tasks. The Working Group included representatives from manufacturers, air carriers, and pilot and flight attendant unions. On February 27, 2020, the Working Group submitted its report to ARAC.
With the adoption of amendments 14 CFR 25-150 and 121-389, an Installed Physical Secondary Barrier (IPSB) meeting the design requirements included in new paragraph (4) of 14 CFR 25.795(a), must be installed on aeroplanes manufactured after August 25, 2025, and required by 14 CFT 121.313(f) to have a door between the passenger and pilot or crew rest compartments, and for passenger-carrying transport category airplanes that have a door installed between the pilot compartment and any other occupied compartment. FAA AC 25.795-10 provides an acceptable means of compliance with the requirements of 14 CFR 25.795(a)(4).
As clarified in the FAA AC 25.795-10, the deployment of the IPSB may affect compliance with other applicable requirements, such as the pressurized compartment loads required by 25.365, the crash loads of 25.561, the emergency evacuation requirements of 25.803, and the aisle width requirements of 25.815. The assumption on which the rule is based is that any IPSB will only be deployed for a short amount of time. Therefore, compliance with requirements other than 25.795(a)(4) may be demonstrated considering only the configurations in which the IPSB is stowed.
The IPSB installation requirements introduced in 14 CFR Part 25 and Part 121 have no equivalent in the EU regulatory system.
EASA applicable regulation for commercial air transport operations does not require the installation of an IPSB on large aeroplanes. However, for installations on large aeroplanes models for which EASA is Primary Certification Authority and are flown by operators required to comply directly with US 14 CFR Part 121 or by other operators that are voluntarily installing it, EASA proposes the introduction of the following special condition and the associated means of compliance to complement the applicable CS-25 certification specifications.
