NOTE: The purpose of this FAQ is to explain how the operator and the Competent Authority (National Aviation Authority) conclude the minimum number of cabin crew required on the operator’s aircraft. This FAQ does not provide specific numbers for aircraft types or individual aircraft. The minimum number of cabin crew may vary on each aircraft, depending on the certification history of that aircraft. To learn the minimum number of cabin crew on your aircraft, please, consult your Competent Authority. To have a better view and understanding of the explanation below, this FAQ should be read together with the rule ORO.CC.100 (Regulation (EU) No 965/2012 – ‘Air Operations’, Annex III (Part-ORO), Subpart-CC, paragraph ORO.CC.100).
Minimum number of cabin crew is established during the certification process of each aircraft. As of 3rd July 2017, it is required that this number is clearly written in the certification documentation issued for each aircraft (reference: EASA Certification Memo CM-CS-008 Issue 01, issued in July 2017). Therefore, when developing standard operating procedures, the operator applies the number written in the certification documentation (this is required by the ‘Air Operations’ rule paragraph ORO.CC.100(b)(1)). However, historically, not all aircraft had this number written/defined in the certification documentation, and in this case, the operator uses a calculation method in accordance with the ‘Air Operations’ rule paragraph ORO.CC.100(b)(2).
Therefore, the operator and the National Aviation Authority must refer to the certification documentation issued for the aircraft in question to see if the minimum number of cabin crew is written/defined in the certification documentation.
Airworthiness certification documentation of your aircraft issued:
- Before 3rd July 2017: the operator may apply the calculation method in accordance with the rule ORO.CC.100(b)(2)) only in cases where the certification documentation does not include the minimum number of cabin crew.
- After 3rd July 2017: the operator must apply the number of cabin crew specified in the certification documentation in accordance with the rule ORO.CC.100(b)(1).
Background: In accordance with Regulation (EU) No 965/2012, paragraph ORO.CC.100, when establishing the number of cabin crew needed for each aircraft and flight, the operator has to consider all operational aspects as required by ORO.CC.100(a) and the associated AMC1 ORO.CC.100. Paragraph ORO.CC.100(b) then provides the methods for determining the minimum number of cabin crew, i.e. by either applying the number established during the certification process or by a calculation of 1 cabin crew member per 50 installed passenger seats.
The development stage of Regulation (EU) No 965/2012 (AIR OPS) initially did not include the paragraph (b)(2), i.e. the ‘1 per 50’ calculation, in ORO.CC.100. This inclusion was done last minute in a way that resulted in the overall lack of clarity of ORO.CC.100(b), i.e. how to establish the minimum required number of cabin crew. This led to some implementation difficulties for operators when the new operational rules (AIR OPS) were introduced. To help with the implementation, EASA published SIB 2014-29, which provided detailed information on how to comply with ORO.CC.100. The SIB was supported by the EU Members States, however resulted in a strong opposition by EU operators. As a result, discussions were held in 2015 between EASA and IATA/IACA on the application of ORO.CC.100(b), i.e. how to establish the minimum required number of cabin crew. EASA acknowledged that the interpretation of ORO.CC.100(b) was unclear. As an outcome of these discussions, on 7th December 2015 EASA communicated to the stakeholders the ‘EASA conclusions following the consultation on the proposed Certification Memo and Safety Information Bulletin on minimum cabin crew for twin‐aisle aeroplanes’.
On 3rd July 2017, EASA published the Certification Memo EASA-CM-CS-008 Issue 01. This document clarifies to aircraft manufacturers and design organisations that the number of cabin crew assumed in their evacuation certification activity must be clearly stated in their documentation. Following the publication of the EASA Certification Memo, the relevant Type Certification Data Sheets (TCDSs) have been amended and now include the minimum number of cabin crew already established by the aircraft manufacturers. In some cases the applicable minimum number of cabin crew for a particular aircraft may be different to that shown in the TCDS, for instance in case of specific cabin layouts if a lower number of cabin crew was approved by EASA.