Risk Assessment of Proposed ARFF Standards (2011)

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49 CHAPTER 6 CONCLUSIONS After reviewing the 81 “accidents of interest” to this study, the research team concluded that the information contained in many of the accident records was not conducive for determining reductions in fatalities and serious injuries based upon changing the ARFF standards, i.e., the data was not to the level of detail required to make a conclusive determination that a change in standards would have reduced fatalities and/or serious injuries. The data for estimating reductions in serious injuries is particularly weak since the timing and cause of the serious injury is frequently not included in the accident report. At best, only subjective judgments could be made and even if the subjectivity was considered to be acceptable from a research perspective, there would be a question about consistency. Notwithstanding the lack of detailed data, based upon the information contained in the accident reports, the research team’s collective judgment was that a change in ARFF standards would not have reduced fatalities or serious injuries in any of the accidents reviewed as part of this research effort with the possible exception of one accident . For that accident, the regulations in effect at the time did not require an ARFF response for either aircraft since both aircraft had less than 31 passenger seats. Subsequent to the accident the regulation was changed for an ARFF response meeting the regulatory requirements for a Part 139 Index A airport. The research team’s estimated reduction of 1 to 12 fatalities is based upon the current FAA standard (see case study in Chapter 5). A similar reduction is estimated for the ICAO standard. In contrast it is estimated that if the current NFPA standard had been in effect, the reduction would have been 3 to 14 fatalities. This increased reduction over those estimated by the research team for the FAA and ICAO standards is based solely on having three firefighters at the scene to assist in suppression of the fire and extrication of the people on board the aircraft. There are several accidents where the passengers were seriously injured during the evacuation of the aircraft. Neither the FAA nor ICAO address staffing evacuation slides to assist deplaning passengers from being injured during the evacuation. NFPA does address this situation in NFPA 402 with the following generalized statement “If time and conditions permit, ARFF personnel should assist in the off-loading of evacuees at the base of the evacuation slides to minimize injuries.” Furthermore the training programs set forth by each of the three organizations do not include any training to be conducted in evacuation assistance. There is a question as to how firefighters would be able to help people avoid these injuries. As stated previously, the serious injuries in these evacuation events are mainly bone fractures that are normally not life-threatening. Overall, there is no conclusive evidence in the accident reports to indicate that accident fatalities or serious injuries would be reduced by replacing the current Part 139 ARFF standards with those found in ICAO Annex 14 or in NFPA 403 and its associated documents.