august 2018 safety team report6443 8/6/2018 sent to erc for review aircraft door\slide/partial slide...

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Safety Team Report Michael Massoni – Operational Safety Chair …The mission of the Unions Safety Team is to provide Union Leadership in all issues of health & safety; Technical Counsel to the TWU Executive Board; Representation to our Membership; Stewardship within our Company, Industry, its regulatory bodies and most importantly, facilitate Effective Communications between all… To: TWU Local 556 Executive Board CC: Thom McDaniel Date: August 9, 2018 Re: August 2018 EB Safety Team Report Currently the Safety Team has the following open and/or resolved action items: Aviation Safety Action Program (ASAP) – Reports Under ERC Review: 27 ID Event Date Status Summary 6324 7/17/2018 Sent to ERC for review AIRCRAFT DOOR\SLIDE/DISARMING PROCEDURE - I made PA to disarm doors for Ops. B FA did the Aft Doors disarmed PA but did not actually disarm doors. 6326 7/18/2018 Sent to ERC for review MINIMUM CREW/BOARDING - While I was using the LAV, the A FA and OPS boarded our AC 5 mins early. I was not ready and not in my boarding position 6329 7/16/2018 Sent to ERC for review IEFB/MISSING IEFB - Left IEFB on a/c during an unscheduled swap. Notified last min during taxing to gate in HOU. 6337 7/19/2018 Sent to ERC for review ALCOHOL/CONSUMED OWN ALCOHOL - PASSENGER CONSUMPTION OF PERSONAL ALCOHOL 6365 7/24/2018 Sent to ERC for review AIRCRAFT DOOR\SLIDE/DISARMING PROCEDURE - Disarming doors 6366 7/23/2018 Sent to ERC for review IEFB/MISSING IEFB - IEFB was not in my carryon. 6367 7/20/2018 Sent to ERC for review CABIN EMERGENCY/EVACUATION - After boarding, while still at the gate with the forward entry door still open, FAs had to evacuate the aircraft. 6380 7/27/2018 Sent to ERC for review IEFB/MISSING IEFB - Gate Check 6398 7/30/2018 Sent to ERC for review IEFB/MISSING IEFB - I left my iPad on the plane 6406 7/27/2018 Sent to ERC for review IEFB/MISSING IEFB - EFB had slipped out of my bag in forward bin, did not discover until right before boarding.

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Page 1: August 2018 Safety Team Report6443 8/6/2018 Sent to ERC for review AIRCRAFT DOOR\SLIDE/PARTIAL SLIDE DEPLOYMENT - Partial slide deployment ... All of 2014 = 2119 All of 2013 = 1138*

Safety Team Report Michael Massoni – Operational Safety Chair

…The mission of the Unions Safety Team is to provide Union Leadership in all issues of health & safety; Technical Counsel to the TWU Executive Board; Representation to our Membership;

Stewardship within our Company, Industry, its regulatory bodies and most importantly, facilitate Effective Communications between all…

To: TWU Local 556 Executive Board CC: Thom McDaniel Date: August 9, 2018 Re: August 2018 EB Safety Team Report Currently the Safety Team has the following open and/or resolved action items: Aviation Safety Action Program (ASAP) – Reports Under ERC Review: 27 ID Event Date Status Summary 6324 7/17/2018 Sent to ERC for review AIRCRAFT DOOR\SLIDE/DISARMING PROCEDURE - I made PA to disarm doors for Ops. B FA did the Aft Doors disarmed PA but did not actually disarm doors. 6326 7/18/2018 Sent to ERC for review MINIMUM CREW/BOARDING - While I was using the LAV, the A FA and OPS boarded our AC 5 mins early. I was not ready and not in my boarding position 6329 7/16/2018 Sent to ERC for review IEFB/MISSING IEFB - Left IEFB on a/c during an unscheduled swap. Notified last min during taxing to gate in HOU. 6337 7/19/2018 Sent to ERC for review ALCOHOL/CONSUMED OWN ALCOHOL - PASSENGER CONSUMPTION OF PERSONAL ALCOHOL 6365 7/24/2018 Sent to ERC for review AIRCRAFT DOOR\SLIDE/DISARMING PROCEDURE - Disarming doors 6366 7/23/2018 Sent to ERC for review IEFB/MISSING IEFB - IEFB was not in my carryon. 6367 7/20/2018 Sent to ERC for review CABIN EMERGENCY/EVACUATION - After boarding, while still at the gate with the forward entry door still open, FAs had to evacuate the aircraft. 6380 7/27/2018 Sent to ERC for review IEFB/MISSING IEFB - Gate Check 6398 7/30/2018 Sent to ERC for review IEFB/MISSING IEFB - I left my iPad on the plane 6406 7/27/2018 Sent to ERC for review IEFB/MISSING IEFB - EFB had slipped out of my bag in forward bin, did not discover until right before boarding.

Page 2: August 2018 Safety Team Report6443 8/6/2018 Sent to ERC for review AIRCRAFT DOOR\SLIDE/PARTIAL SLIDE DEPLOYMENT - Partial slide deployment ... All of 2014 = 2119 All of 2013 = 1138*

6408 7/29/2018 Sent to ERC for review IEFB/MISSING IEFB - delayed flight due to confusion on the process of printing out a manual 6411 7/31/2018 Sent to ERC for review IEFB/NON-FUNCTIONING - IEFB 6418 7/29/2018 Sent to ERC for review SPECIAL PAX/UMs - Failed to sign off UM 6424 8/2/2018 Sent to ERC for review AIRCRAFT DOOR\SLIDE/DISARMING PROCEDURE - Disarmed galley door before Jetbridge arrived. 6434 8/1/2018 Sent to ERC for review AIRCRAFT DOOR\SLIDE/PARTIAL SLIDE DEPLOYMENT - girt bar came out of brackets on fwd galley door, engaged, when opening the door the slide starting to come out of the b 6443 8/6/2018 Sent to ERC for review AIRCRAFT DOOR\SLIDE/PARTIAL SLIDE DEPLOYMENT - Partial slide deployment 6444 8/6/2018 Sent to ERC for review AIRCRAFT DOOR\SLIDE/ARMING PROCEDURE - Did not arm entry door slide in brackets 6446 8/6/2018 Sent to ERC for review IEFB/MISSING IEFB - lost IEFB 6449 8/7/2018 Sent to ERC for review IEFB/LOW BATTERY - Upon leaving my house my EFB was fully charged. Once on a/c EFB had not held charged 6450 8/4/2018 Sent to ERC for review IEFB/MISSING IEFB - left EFB on pervious aircraft 6451 7/29/2018 Sent to ERC for review JUMPSEAT/INOPERATIVE - Aft jumpseat INOP. 6453 8/8/2018 Sent to ERC for review FATIGUE/OTHER - scheduling call 6454 8/7/2018 Sent to ERC for review FLIGHT ATTENDANT DUTIES AND RESPONSIBILITIES/OTHER - Water service 6455 8/8/2018 Sent to ERC for review AIRCRAFT DOOR\SLIDE/PARTIAL SLIDE DEPLOYMENT - Slide fell out of bustle 6456 8/6/2018 Sent to ERC for review FLIGHT ATTENDANT DUTIES AND RESPONSIBILITIES/OTHER - Bursting soda cans 6457 8/8/2018 Sent to ERC for review OWWE/PAX BRIEFED AFTER TAKEOFF - Failure to ask over wing if willing and able to assist in evacuation 6458 8/5/2018 Sent to ERC for review IEFB/MISSING IEFB - My iPad/manual was left on another AC after I was told to leave the AC during boarding and rush to another flight ASAP Reports received 2018 Year-to-Date: 1070 Accepted Reports Year-to-Date: 881 Excluded Reports to date: 20 Open Reports: 27 Total Reports Received in 2017 947 Total Reports Received over the Life of Program 7808

Page 3: August 2018 Safety Team Report6443 8/6/2018 Sent to ERC for review AIRCRAFT DOOR\SLIDE/PARTIAL SLIDE DEPLOYMENT - Partial slide deployment ... All of 2014 = 2119 All of 2013 = 1138*

Southwest Airlines Event Notification System (ENS) Fielded Events for Period: 07/10/18 through 08/09/18 = 264 Emergencies Declared for Period = 22 2018 Year-to-Date = 1282 All of 2017 = 2371 All of 2016 = 2887 All of 2015 = 2843 All of 2014 = 2119 All of 2013 = 1138* All of 2011 = 1609 All of 2010 = 1413 All of 2009 = 1210 *ENS tracking and trending was suspended for the period of May 2012 – June 24th, 2013 – However ENS follow-up was maintained throughout this period. The Safety Team has re-established the practice of tracking and trending all ENS events and will include the same in all Safety Team Reports SWALife Hot Aircraft Event Reporting 07/10/18 through 08/09/18 = 131 2018 Year-to-Date = 377 2017/2018 Year-over-Year Comparative = +40 (+11.87%) All of 2017 = 396 = 34.3% Decrease Year-over-Year All of 2016 = 535 = 32% Decrease Year-over-Year All of 2015 (Benchmark High) = 788 Latest Hot Aircraft Reporting Overview (Normalized with all other Sources) 23JUL18-29JUL18:

Page 4: August 2018 Safety Team Report6443 8/6/2018 Sent to ERC for review AIRCRAFT DOOR\SLIDE/PARTIAL SLIDE DEPLOYMENT - Partial slide deployment ... All of 2014 = 2119 All of 2013 = 1138*

Hot Aircraft Overview 07.23.2018 - 07.29.2018

PHXMDWHOULASATLDALDENMCOBWISTLSANSJCFLL

OAKSFOSMFLAXBNAMSYAUSLGATPARNOSLCINDMCI

ONTSATBDLBURCLTDCADTWMKEPDXPHLPNSPVDRDUABQBOSBUFCHSCMHELP

GEGGSPHRLIADLBBLGBMAFMSPOKC

PITSEASJUSNATUS

3929

2219

1716

14141312

10109999877

5554433332222222222211111111111111111111

Hot AC Total by City

Jul 23 Jul 24 Jul 25 Jul 26 Jul 27 Jul 28 Jul 290

20

40

60

Rep

ort C

ount

0.0%

0.5%

1.0%

1.5%

% o

f Flig

hts

Daily Employee Report Submissions and % of Flights

Data Type

Hot AC Reports

7/16/2018 7/23/2018

% Difference

7/16/2018 7/23/2018

ACARS

FO SOPI

IF SOPI

Inflight Form

Grand Total 350

42

2

2

304

422

59

1

3

359

-17.06%

-28.81%

100.00%

-33.33%

-15.32%

Reports by Type - 2 Week Lookback

0 1,000 2,000Report Count

June 2017

2018

July 2017

2018

1,703

1,645

1,649

1,641

Year over Year Comparison

20.57%

78.00%

1.43%

Hot Aircraft by Fleet

700

800

MAX 8

Fleet Hot AC Reports % of Flights**

700

800

MAX 8 1.04%

1.20%

1.28%

5

72

273

Page 1

The percentages for the Top 20 Stations are based on the number of Hot AC Events reported on and the numberof flights that departed from each city during the respective week.

**Percent of Hot AC Events to Total Flights per Fleet Please note: Fleet not available for every report

GS

P

CLT

PH

X

PN

S

SFO HR

L

LGA

LGB

IAD

LBB

ATL

HO

U

RN

O

SLC

MS

Y

SJC

MA

F

MD

W

SM

F

BD

L

0

10

20

30

40

Rep

ort C

ount

0.0%

1.0%

2.0%

3.0%

4.0%

5.0%

% o

f Flig

hts

Stations - Top 20 Based on % of Flights

Percent of total Hot AC Reports received

Page 5: August 2018 Safety Team Report6443 8/6/2018 Sent to ERC for review AIRCRAFT DOOR\SLIDE/PARTIAL SLIDE DEPLOYMENT - Partial slide deployment ... All of 2014 = 2119 All of 2013 = 1138*

Page 2

AC Number

491

705

253

474

554 4

4

4

5

5

Aircraft with four or morereports

Hot AC Reports Hot AC Events0

100

200

300

Cou

nt

350 345

Reports versus Events

'Hot' Aircraft and Gates

Station Gate

PHX C1

C17

DEN C28

HOU 46

SAN 4

SJC 23

SMF B14

4

4

3

3

3

3

3

Gates with three or morereports

7/16/2018 7/23/2018

% Air Not Connected

% Ops Agent Not Present

% Ramp Agent Not Available 3.95%

3.95%

37.50%

2.23%

1.67%

33.15%

AB

QA

TLA

US

BD

LB

NA

BO

SB

UF

BU

RB

WI

CH

SC

LTC

MH

DA

LD

CA

DEN

DTW EL

PFL

LG

EG GSP

HO

UH

RL

IAD

IND

LAS

LAX

LBB

LGA

LGB

MA

FM

CI

MC

OM

DW

MK

EM

SPM

SYO

AK

OK

CO

NT

PDX

PHL

PHX

PIT

PNS

PVD

RD

UR

NO

SAN

SAT

SEA

SFO

SJC

SJU

SLC

SMF

SNA

STL

TPA

TUS

0

5

10

15

Air Not Connected

Ops Agent Not Present

Ramp Agent Not Available

Date Flight Number Station Message

7/25/2018 378 MCO NICE JOB

7/26/2018 2062 SLC GREAT STATION

TPA GREAT STATION

7/27/2018 2406 LAS NICE JOB

2421 ATL NICE JOB

SAN GREAT JOB

Hot AC Reports are the total number of reports received. Hot AC Eventsare the unique number of Hot AC occurences, taking into accountmultiple reports for the same event.

Ground OperationsAs reported by the Pilot Group through ACARS messaging.

If this section is left blank, it is intentional and means there were no "good" messages from the Pilots this week.

Good Job ACARS

Page 6: August 2018 Safety Team Report6443 8/6/2018 Sent to ERC for review AIRCRAFT DOOR\SLIDE/PARTIAL SLIDE DEPLOYMENT - Partial slide deployment ... All of 2014 = 2119 All of 2013 = 1138*

Page 3

0 1 2

Complaint Count

NullATLAUSBURDCAFLL

HOULAX

MDWMKEPHXTUS

111111111111

Pax Complaints by Originating City

7/23/2018 7/24/2018 7/25/2018 7/26/20180

2

4

6

Com

plai

nt C

ount

Pax Complaints by day

Customer Hot AC Complaints for the week of 07/23/18 to 07/29/18

0 20 40 60 80 100 120 140 160 180 200 220

Complaint Count

June 2017

2018

July 2017

2018

160

134

214

78

Year over Year Customer Complaints

Inspection data for all Aircraft typesTech Ops Inspection Volumes for the week of 07/23/18 to 07/29/18

An aircraft ducting or pack inspection is made when complaints indicate that a "hot" cabin is contributed to aircraft equipment. Sources of complaints areInflight SOPI and Hot Aircraft Events from the weekly reports.

Page 7: August 2018 Safety Team Report6443 8/6/2018 Sent to ERC for review AIRCRAFT DOOR\SLIDE/PARTIAL SLIDE DEPLOYMENT - Partial slide deployment ... All of 2014 = 2119 All of 2013 = 1138*

Open Discussion Items: - OSHA 300 Log Email Distribution to DEBM’s - Southwest Flight 1380 (WN1380) Update: The Flight Attendants are still off work and are recuperating. It is now unclear as to when they will return to work. Management wants to work with them (on an individual basis) to ensure all of their needs are met as it relates to further time off and return to work plans. During the week of August 6th, Management set up an individual meeting with one of the 1380 Flight Attendants in order to assess her well-being and give her options on returning or not returning to work. This meeting was set-up without the knowledge of 556 Safety or the Union as a whole, for that matter. Apparently, information about the meeting was somehow conveyed to the 1380 Pilots and/or SWAPA who contacted 556 Leadership directly. This is another example of miscommunications that have occurred involving the 1380 Pilots and SWAPA acting (with all good intentions, I’m sure) on behalf of the 1380 Flight Attendants. Ultimately, 556 Leadership did attend the meeting which had a positive outcome including the Flight Attendant being offered the rest of the year off with full ((high line) pay and per diem). With all of this, I want to take this opportunity to overview the protocols 556 has operated under for a very long time as it relates to major accident investigations and Crew Member post event wellness, fitness for duty and care: 556 Safety/Go-Team’s main role in a major incident/accident event such as Flight 1380 is accident/incident investigation. We do this by ensuring Party Status in the NTSB investigative process in order to: 1.) Protect the Crew Member’s rights throughout the on-site investigation; 2.) Act as subject matter experts to the NTSB on SWA Inflight Operations policies and procedures relating to the event; and 3.) Use knowledge gained through the investigation and causal factor definitions in the NTSB Final Report to help ensure similar type accidents do not occur again thereby benefitting all SWA Flight Attendants/TWU Local 556 Members. That being said, we (556 Safety) traditionally are not directly involved with the accident Crews physical and/or emotional aftercare (post site investigation). These duties usually fall to CISM, Mental Health Professionals and 556 Leave/Grievance Specialists and/or EB Members as applicable working in conjunction with Management. I am saying this because I don’t want there to be any confusion should another miscommunication arise concerning the 1380 Flight Attendant Crew and what 556 Safety is or is not doing on their behalf. With that, Michele Moore will continue to interact with the Crew (when requested) and it is still expected that the majority of wellness checks will continue to come from the CISM side of the house. Speaking of Michele and her interactions with the Crew, Michele flew a roundtrip with one of the Flight Attendants who was “observing” a flight. Michele was asked to work a 2 day with the Flight Attendant the following week. Unfortunately, at the last minute, the Flight Attendant did not feel she was ready to come back and the 2-day trip plan was canceled. The entire 1380 Crew will fly to Austin in August to meet Governor Abbot and are doing a press visit in September in California. They will also be attending a Gala in New York at an event the Captain will be speaking at.

Page 8: August 2018 Safety Team Report6443 8/6/2018 Sent to ERC for review AIRCRAFT DOOR\SLIDE/PARTIAL SLIDE DEPLOYMENT - Partial slide deployment ... All of 2014 = 2119 All of 2013 = 1138*

And finally, we have received notification that the official NTSB Public Hearing on flight 1380 has been set for November 14th, 2018 in Washington, D.C. The Flight Attendant Crew is not being called to testify and are not being required to attend. Michael Massoni and Michele Moore will be attending as Members of the Survival Factors Group but will not be testifying in the proceedings. - Aircraft Door Procedures Working Group: The group will be meeting on Thursday August 16 in order to provide an opportunity for Inflight stakeholders to discuss the proposed door disarming procedural change with other departments prior to seeking Leadership approval. The working group would like to ensure that the proposed internal change aligns with all operational partners’ procedures when arriving at the gate. - Needle Stick Working Group The groups accepted (by SWA Senior Leadership) proposed mitigations are: - Customer facing improvements including Passenger Education (through Southwest: The Magazine, placards in LAVS etc. <and> - Expanded awareness and training in RT We are still awaiting a full implementation plan schedule from Management. Uniform/Allergy Issues 556 Safety continue to meet (via HASC) with the company to discuss the health issues that our Members are experiencing. As previously communicated, the Safety Team was notified that due to the concerns discussed at previous HASC meetings, a Toxicology study will be conducted at the Company’s expense. Assurances were given that all pieces would be tested and the results supplied to us as soon as the testing was completed. Test results on individual pieces have started to come in to SWA Corporate Safety. We have been informed that once all results are in the Company will need time to review them and put a summary and communication plan together. 556 Safety has requested the Company confirm with the lab an estimated date that all results will be in as we will need to set a date to meet and review the summary and report in total. This so we can coordinate communications to our EB and work force at large. Cabin Fume Industry Meeting As you all are aware, the Federal Aviation Administration (FAA) issued SAFO 18003, Procedures for Addressing Odors, Smoke and Fumes In Flight, on March 26, 2018. The stated purpose of the SAFO is to identify the need to enhance flight crew procedures to mitigate the risk to passengers and crew in odor, smoke or fume events. The FAA recommends that operators, under their existing Safety Management System (SMS) structure, review their procedures to ensure they address a range of conditions that may exist during such events. The FAA further recommends that operators collaborate with others including manufacturers, other operators and regulators to identify risks and further enhance mitigation procedures as appropriate. In our efforts to collect appropriate data from which an Industry risk analysis can be performed, the FAA has provided A4A relevant data from its Service Difficulty Report (SDR) database and an initial analysis has been performed by our members.

Page 9: August 2018 Safety Team Report6443 8/6/2018 Sent to ERC for review AIRCRAFT DOOR\SLIDE/PARTIAL SLIDE DEPLOYMENT - Partial slide deployment ... All of 2014 = 2119 All of 2013 = 1138*

Airline for America (A4A) their Member carriers and designated Labor Representatives met on July 24, 2018, in Washington D.C. The purpose of the meeting was to share the SDR analysis performed and to assist in developing appropriate industry mitigation measures. A4A believes that a collaborative approach among operators, labor representatives, manufacturers and government regulatory agencies can successfully reduce any risk associated with these serious safety of flight events. Michael Massoni represented TWU at this meeting and was subsequently placed on the “Mitigation Measures” working group (one of 4 different working groups formed at this meeting) as a part of a joint task force dealing with the problem of cabin fume events. 2Hot2Cold Michael Massoni attended the 2hot2cold roll-out media event in Washington D.C. As a follow-up to that event 556 Safety ensured appropriate comments were filed as it relates to the AFA-CWA Petition to the Secretary of Transportation to Conduct Rulemaking to Prevent Incidents of Extreme On-Board Temperature Conditions on Commercial Airplane Flights filed with the Office of the Secretary, Department of Transportation DOT-OST-2018-0097. The following comments were submitted by TWU International in the matter:

Page 10: August 2018 Safety Team Report6443 8/6/2018 Sent to ERC for review AIRCRAFT DOOR\SLIDE/PARTIAL SLIDE DEPLOYMENT - Partial slide deployment ... All of 2014 = 2119 All of 2013 = 1138*

July 26, 2018 U.S. Department of Transportation Office of the Secretary 1200 New Jersey Ave SE Washington, DC 20590

RE: Petition to the Secretary of Transportation to Conduct Rulemaking to Prevent Incidents of Extreme On Board Temperature Conditions on Commercial Airplane Flights Petition Submitted by the Association of Flight Attendants-CWA, AFL-CIO Office of the Secretary, Department of Transportation DOT-OST-2018-0097

On behalf of the Transport Workers Union of America, AFL-CIO (TWU), I write to support the petition for rulemaking submitted by the Association of Flight Attendants-CWA, AFL-CIO (AFA) to the Department of Transportation (DOT) in the docket captured above. The petition requests that DOT conduct a rulemaking to establish operational temperature standards on commercial aircraft and apply those standards to all passenger flights operated by U.S. commercial airlines and to foreign commercial airlines that operate flights into and/or destined for the U.S. The TWU urges DOT to fulfill the petition to ensure appropriate temperatures in aircraft cabins through all phases of flight. The TWU represents 145,000 transportation workers across all modes of transportation, including more than 20,000 flight attendants working at Southwest Airlines, JetBlue, Allegiant Air, and Flight Services International. TWU flight attendant members have firsthand experience working in both stifling hot and shivering cold aircraft cabins, where they must carry-out their important safety and security responsibilities while interacting with often unhappy and uncomfortable passengers. These experiences have occurred at airports across the country and around the world, and during various phases of flight. Many instances of extreme cold or heat in the cabin occur while the aircraft is on the ground. These extreme cabin temperatures can be exacerbated when the aircraft is parked at a gate or while waiting on the tarmac, where exposure to the harsh ground environment continues. Those same uncomfortable conditions often remain once inflight if aircraft systems are unable to mitigate the extreme temperatures. Malfunctioning systems and failing seals also can contribute to uncomfortable inflight cabin temperatures.

Page 11: August 2018 Safety Team Report6443 8/6/2018 Sent to ERC for review AIRCRAFT DOOR\SLIDE/PARTIAL SLIDE DEPLOYMENT - Partial slide deployment ... All of 2014 = 2119 All of 2013 = 1138*

Scheduled and Standing Meetings: Monday August 13, 2018 – ASAP September InfoShare Industry Planning Committee Telecon Thursday August 16, 2018 – IF Aircraft Door Procedures Interdepartmental Coordination Monday August 20, 2018 – 737-800/G7/Max 8 Procedure Congruency for Flight Attendant Handbook Revision Wednesday August 22 – Saturday August 25, 2018 – Pride-at-Work National Convention Monday August 27, 2018 – Monthly Health and Safety Coordination (HASC) Meeting Tuesday August 28, 2018 – Safety Team Catch-Up Session

Sweltering hot or frigidly cold cabin environments create health risks for flight attendants and passengers. Reports of passengers and crewmembers sweating heavily, becoming ill, and passing out due to high cabin temperatures, for example, are alarming and clearly demonstrate the need to better control the aircraft environment. Currently, federal law requires air carriers to create emergency contingency plans that address, among other things, how they will provide comfortable cabin temperatures for passengers onboard an aircraft when a departing flight is delayed or disembarkement is delayed. However, there are no DOT standards limiting the operational temperatures inside the cabin. Given the hardships imposed on passengers and flight attendants when cabins become too hot or too cold, we urge the DOT to begin a rulemaking proceeding and promulgate a regulation that sets operational temperature standards for aircraft cabins during all phases of flight.

Sincerely,

John Samuelsen International President