As winter is upon us in North America, now's the time to make that vacation trip to warmer, more relaxed climes. But such flights often involve long overwater legs and bring with them their own challenges, not least of which is which equipment to add to your load. AVweb Special Projects Editor Doug Ritter — whose Equipped To Survive Web site offers the most comprehensive online resource for independent reviews of outdoors gear and survival equipment — assembled this in-depth, four-part look at aviation life rafts. Don't leave home without one.
September 1, 2000
|About the Author ...
Doug Ritter is former
News Editor of AVweb and now contributes on special projects. An experienced
and respected aviation journalist, Doug is a contributing editor to
Aviation Consumer and
Safety and a former contributing editor to Flight Training. He also writes
for CODE ONE and AOPA Pilot, as well as other aviation publications.
best known for his insightful product evaluation and comparison articles, his
interpretation and explanation of complex technical and engineering concerns
related to aircraft systems and products, and his in-depth investigation of
aviation products, flight safety, and human factors issues. He is a leading
expert in the area of aviation survival and a working member of the SAE
Aerospace Council S-9 Cabin Safety Provisions Committee and S9-GA General
Doug is also the publisher and editor of Equipped
to Survive, a web site devoted to survival equipment and techniques.
four-part series, AVweb will provide an in-depth look at aviation
life rafts. We'll examine the regulatory requirements, the common-sense
requirements and what you should look for when selecting a life raft. We
also examine both the approved and unapproved rafts for the GA market
and let you know which ones will more likely save your life if you ever
need to use them.
pilots don't fly over areas of water that they perceive to be dangerous. So
their perceived need for a life raft and their perceived requirements for the
capabilities of that raft are minimal. However, it is important to remember
that even a body of water as seemingly benign as Chesapeake Bay or Puget Sound
can present significant dangers to a downed pilot and passengers, especially
in colder months. Pilots who are considering Caribbean overflights or jumping
off from Narsarsuaq for Reykjavik or Santa Barbara for Hilo will have more
critical requirements as they face more obvious dangers. Yet, even here, many
don't appreciate the dangers they might face.
A Necessary Nuisance?
pilots and operators consider rafts to be a necessary nuisance, required by
regulation, or a spouse's insistence. Of the GA pilots who are taking the
prudent course, few realize that many of the rafts they are relying on for
their over-water safety are downright deficient in one way or another. Better
than nothing, to be sure, but a lot worse than users have reason to expect.
For the rest, "making-do" with a cheap and likely poorer-performing
raft may be sufficient to satisfy those nagging voices inside our heads.
Pilots can rationalize to themselves that they're better than nothing, they
usually work adequately, and that no Part 91 light general aviation flyer is
about to shell out between $3,500 and $7,000 for a fabrication of cloth that
will spend most of the year in the bottom of the closet or in the corner of
Some, obviously, don't feel that way. In any case, before making that
rationalization, pilots should understand what they are buying.
Pragmatism aside, it's simply not prudent to travel over any significant
body of water out of gliding distance from land without a life raft of some
sort on board. To do so is foolhardy, especially so if you are flying over
colder waters. There is no question that the odds are in your favor if you
ditch (see Equipped To
Myths Torpedoed!"), but carrying survival equipment is all about
improving the odds.
There are plenty of stories of those who have survived a ditching in open
water without a raft, just wearing a life vest or sometimes nothing at all to
keep them afloat. Some of their stories are told on Equipped To Survive:
Lessons Learned: True Life Ditching Experiences. They were very, very lucky.
Ask any of them and most will tell you so. What you don't hear about very
often, for obvious reasons, are those few who don't return to tell a tale of
survival against the odds.
Any large body of water an ocean or a large lake such as one of the
Great Lakes in the U.S. is a very unforgiving, hostile environment.
Hypothermia is a constant deadly specter, even in warmer waters such as in the
Caribbean. It just takes longer in warmer waters. In colder waters, which
covers most waters, at least some if not all of the year above 30 degrees
North latitude and below 30 degrees South latitude, death from hypothermia can
come in a few short hours or even minutes. A raft is your best protection from
hypothermia, though as we shall see, the degree of added protection can vary
markedly. If you value your own life or those of your passengers or loved
ones, you should seriously consider a life raft of some sort if you're flying
much beyond gliding distance from land. A life vest (also referred to as a
life preserver or personal flotation device (PFD)) just isn't enough in our
Picking the right raft can be difficult. Rafts come in a variety of
flavors: single tube or double tube, single cell and multiple cell, those with
and those without self-erecting canopies and insulated floors, those that are
FAA TSO-approved and those that aren't. Survival equipment provided with the
raft varies a lot as well, both in quality and quantity. That's just to name a
few areas of differences. Each is important, though some more than others.
What Is Required? Confusion Reigns...
has been considerable confusion among many raft purchasers and users about
what is required and what is approved. This has often been aided and abetted
by misleading nomenclature and, in a few instances, by patently misleading
advertising by some manufacturers. To no one's great surprise, the FAA itself
hasn't been clear on these questions at times.
Requirements (i.e., what type of raft ("approved" or not
specified) and what minimum equipment for the raft must be on the aircraft)
are dealt with in the FARs dealing with equipment for "extended over
water operations" (FARs 91.509
for example). Each subpart has a list of required raft equipment that differs
from one to the other.
Approved rafts, required under these FARs, must be manufactured by an
FAA-certificated manufacturer in accordance with designs approved by the FAA
to meet the standards of the applicable TSO, in this case TSO
C70a or its predecessor, TSO C70 or C12a (though C12a is largely
irrelevant at this point as far as general aviation rafts are concerned). The
TSO stipulates the minimum design criteria and materials and performance
specifications that must be met as well as some minimal raft equipment that
must be included.
The manufacturer is supposed to prove to the FAA that the raft meets the
agency's criteria before TSO approval is granted by the FAA. It is supposed to
be a rigorous examination and series of tests and generally speaking, no
significant leeway is supposed to be allowed from the TSO requirements unless
the applicant can convince the FAA that its design results in an equivalent
level of safety. Remember that point as it is important later on.
Probably the most notable change between TSO C70 and TSO C70a involves the
design of single tube rafts and the effects of a deflated cell. The older
version has no requirement that the occupants be kept out of the water if a
cell is lost, the newer version does. This would be a significant point if any
of the rafts actually met this standard, which they don't in my opinion.
FAR 135 vs. 91...
For those operations which require a life raft pursuant to the FARs, a life
raft of the appropriate type must be available and it must be equipped with
all the applicable equipment listed in the FARs. In other words, a Part 135
operator needs an approved (TSO'd) raft equipped with the minimum equipment
listed in 135.167(b)(3).
far, so good, but now it gets confusing. Many manufacturers make both TSO'd
and non-TSO'd rafts; some make only TSO'd rafts. In some cases the differences
are slight and virtually unnoticeable to the uninformed. In other cases the
difference is major. One thing they all have in common is that virtually all
manufacturers use FAA-approved materials, so even the ones whose rafts aren't
TSO'd can legitimately claim that the rafts are constructed from materials
"conforming to stringent government specification" or "approved
by the FAA." They may also legitimately claim to hold an FAA certificate
since they may be licensed to service rafts as an FAA-approved repair station.
Both these statements may confuse the unwary buyer.
What gets even more confusing has been the claim to offer FAR Part 91, 121
and 135 kits as options for the non-TSO'd rafts. In fact, the kits they offer
may, indeed, include the items specified in the FARs. But, the kits, no matter
what they call them, together with the unapproved non-TSO'd rafts are not
legal, pursuant to the FARs, if an approved raft is required. You might be
hard pressed to figure that out from some of the sales brochures or sales
pitches you get.
A pilot who really wants a TSO'd raft, even if they aren't legally required
to have it, and just figure they want one that the government has blessed, can
often be bamboozled. To say nothing of those who are required to have a TSO'd
raft and the appropriate equipment they also have been known to purchase
the wrong raft, much to their chagrin when the mistake is caught on an FAA
inspection. With FAA "encouragement" a few years ago, Eastern Aero
Marine (EAM), who makes both types of rafts, changed its nomenclature to
eliminate the confusion, no longer referring to the optional equipment kits
for their non-TSO'd rafts by the FAR Part reference.
One manufacturer who has contributed a great deal to this confusion over
the years has been Survival Products. Their somewhat misleading advertisements
have been a source of trouble for more than one less-than-keen-eyed operator,
to say nothing of many even less knowledgeable consumers. While Survival
Products used to be an FAA-certificated repair station, even that approval was
pulled a number of years ago due to discrepancies, though they now manufacture
FAA-approved rafts. The
problem became bad enough that the FAA felt it necessary to issue an
"Unapproved Parts Notification," a warning about the company's
products and misleading advertising. They have since cleaned up their act
considerably and have also introduced a line of TSO'd rafts, but many of those
rafts are still in circulation and as a result the confusion persists among
those who own, sell, and service them.
...Part 91 Confusion..
Once we move beyond what's required for Part 135 operations, there is the
question of who is required to have what kind of raft. Life rafts are mandated
for only some over-water operations per the FARs. Those of us who fly light
general aviation aircraft under Part 91 are not required to have a life raft
on board for any normal over-water operations. (Note that, practically
speaking, crossing the North Atlantic involves Canadian regulations which do
have such requirements). Not required perhaps, but still, you ought to have
one, in our opinion.
91.509, "Survival equipment for over water operations," is part of
Subpart F dealing only with Large (over 12,500 pounds MGTOW) and
Turbine-Powered (jet or turboprop) Multiengine Aircraft. This doesn't cover
your Cessna 182 or any other light GA aircraft, single or twin. FAR
91.509(b)(2) requires only that "Enough life rafts..." be aboard:
There is no mention of "approved" life rafts. This is a real sore
point for some folks, like those manufacturing TSO'd rafts, who insist that
the raft must be TSO'd.
I asked the FAA, but
they could only point me to an older Advisory Circular (AC 91-38A) which
says "The liferaft requirements of Section 91.189(b)(2) (ed. - now
91.509) may be met by using: (1) Liferafts approved under FAR 37,
Section 37.122, and marked TSO-C12c. (2) Liferafts approved under FAR 37,
Section 37.176, and marked TSO-C70" (emphasis added). However, the AC is
just that advisory in nature. Note also the word "may."
From this I conclude that there is no regulatory basis for requiring a
TSO'd raft for Part 91 operations. Further support to that interpretation is
given because Part 135.167(b) says "Enough approved life rafts..."
This FAR clearly requires an approved raft it must be TSO'd. The result is
a a typical FAA muddle; your best bet, if it's a concern, may be to get the
FAA to issue you a written ruling, possibly avoiding problems over
interpretation later on.
But wait; we're not finished. There's also FAR
25.1415 (b), which requires that "each life raft ... must be
approved." So, regardless of what operations are being carried out, even
under Part 91, transport category aircraft, which these days includes many
bizjets, must use approved life rafts.
You wouldn't expect it would make a big difference. In the larger and
expensive aircraft covered by Part 91 Subpart F, you'd think most folks would
want a TSO'd raft. Well, seems some of these folks got their money by pinching
pennies and try to go with the cheapest product, even if it means a
significant reduction in safety. In many cases they simply do not realize that
to be the case. In other cases, they simply take what the aircraft
manufacturer supplies, which may not be the best, simply the manufacturer's
choice, for whatever reasons they may have.
Added confusion comes from the regulatory definitions of the different type
of life rafts. The TSO separates life rafts into Type I, "for use in any
category aircraft," and Type II, "for use in non-transport-category
aircraft." Type I rafts have double tubes, in other words, two tubes
stacked on top of one another. Type II rafts have a single tube with bulkheads
to divide it up into at least two separate chambers. You will note that a
non-transport category aircraft isn't necessarily the same as a non-Subpart F
aircraft. So many bizjets can legally use a Type II, single tube life raft
when a life raft is required for commercial operations. However, just to add
another dash of confusion to the recipe, some aircraft include the requirement
for an approved life raft in their type certification even when otherwise not
...And How Many?
Want more confusion? Try to figure out how many life rafts are required on
board your bizjet. Under FARs Part 91 Subpart F and Part 135 you only required
to have "enough approved life rafts of a rated capacity and buoyancy to
accommodate the occupants of the aircraft."
However, if the aircraft is certified under Part 25, in other words as a
transport-category aircraft, Part
25.1415 (b)(1) requires that "unless excess rafts of enough capacity
are provided, the buoyancy and seating capacity beyond the rated capacity of
the rafts must accommodate all occupants of the airplane in the event of a
loss of one raft of the largest rated capacity." In other words, from a
practical perspective, this requires a minimum of two life rafts. This is also
the requirement for Part 121 carriers, no matter their size or what they are
carrying, cargo perhaps?
Hypocritical Biz-Jet Manufacturers?
effort to reduce weight on some rafts was obvious, sometimes painfully so with
significant decreases in safety and performance. We were taken aback by Air
Cruisers' Al Wigert's explanation that the corporate air raft makers' number
one priority was reduced weight, followed by price. When we asked where
performance stood, he told us it came after those. He explained that while
that "wouldn't be the priority (ranking) of the crews" who might
someday have to depend upon the rafts, that is "clearly the priority of
the (corporate aircraft) manufacturers" who are their primary customers.
In an industry that is always boasting about their advanced safety
equipment and uncompromising safety standards, we are at a loss to understand
the bizjet manufacturers who appear to be forcing the weight issue without
regard to resulting decreased safety margins. Hard to fathom on
multimillion-dollar jets flying the world's top executives and personalities.
One wonders if the people signing the check realize the liberties being taken
with their safety to allow those extra few bottles of wine on board?
That is not to say that all bizjet manufacturers operate in such a manner,
but if you happen to be in the market for one, you might ask what raft is
included. That may tell you something about the manufacturer's real attitude
towards your safety; a view beyond their marketing hype.
You Can, Indeed, Put A Price On Human Life
We've all heard the old saw that "you can't put a price on human
life." We'd like to think that was true, but there are significant,
potentially life-and-death differences between the various rafts offered.
Similarly, price certainly seems to have some correlation with life-saving
capability, though high price alone is no guarantee of performance. I've seen
many high-priced rafts that I cannot recommend. Because the differences in
price can be significant, and the differences in capability generally not very
obvious, many pilots and operators often opt for the least expensive product,
perhaps not realizing the tradeoffs they are making in safety. Often, the only
goal is to meet regulatory requirements at the lowest possible price and
weight, as shortsighted as that attitude may be. Safety never enters into the
I also recognize that ultimate safety and performance may not be the sole
consideration for a purchaser. Weight, size and price are also legitimate
concerns and entirely appropriate as long as the purchaser is cognizant of the
compromises that may be involved in overall performance and safety. There will
always be a range of products that are acceptable to a range of users who have
Worst Better Than None
me make it very clear that even the worst raft reviewed here is better than no
raft at all. Even those rafts we don't think much of or are that we find
unacceptable often have saves they can claim. In most cases they prove
adequate, since most ditchings don't require the advanced features found in
better rafts and failures of well-maintained rafts are relatively rare.
However, a note of caution: Some unacceptable rafts are more unacceptable than
others. A design that makes it extraordinarily difficult or impossible to
enter from the water unassisted, such as the Hoover FR-6, Survival Products
Type I, or Air Cruisers 13-person, has a higher potential for tragedy.
As long as "better than nothing" is an acceptable standard of
safety for you and your passengers, you can probably get by with any of the
rafts which I've otherwise found unacceptable or marginal, with the caveat
above noted. The fact remains that in most cases, they will save your life.
Most, but not all. It's simply a matter of risk management and occasionally
of playing the odds.
Testing and Evaluation
Equipped to Survive
conducted in-water tests of aviation and marine life rafts in January 2000.
This was the third of a series of similar evaluations of aviation life rafts
we've run since 1994. The results reported here represent a compilation of
In conducting our evaluations, we concentrated on the sizes most commonly
used by general aviation pilots, from 2-person to 13-person rafts. For our
comprehensive 2000 test, we asked for both 4-person rafts, typical of light GA
use, and 10- to 13-person life rafts commonly used on larger corporate jets.
Except for rafts aimed solely at the light GA market, we requested that all
rafts be equipped to FAR Part 135 specification. While some manufacturers have
cooperated fully, in some cases we were forced to obtain test rafts through
other channels due to lack of cooperation.
Below are listed the manufacturers covered in this review, the abbreviation
or name used for them in this review, and the years their life rafts were
- Air Cruisers Co. (Air Cruisers): 2000
- BFGoodrich Aerospace - Aircraft Evacuation Systems (FKA: Pico)
(BFGoodrich or BFG): 1993, 1996, 2000
- Eastern Aero Marine (EAM): 1993, 1996*, 2000*
- Hoover Industries (Hoover): 1993, 2000
- Revere Aerospace Products (RFD/Revere): 1996
- Survival Products, Inc. (Survival Products or SPI): 1993*, 1996*,
- Winslow LifeRaft Co. (Winslow): 1993, 1996, 2000
* Raft acquired for test without cooperation of manufacturer.
Survival Products Games?
the 2000 tests, Survival Products, which had just recently introduced a new
line of TSO'd life rafts, initially declined to participate, as they had every
time before. They cited their continuing unwillingness to allow their rafts to
be tested without a representative present. After our phone conversation and
rejection, we wrote Survival Products in a last-ditch attempt to cajole them
into participating, especially considering the introduction of their new rafts
at an enticing price point.
In a follow-up phone conversation with Survival Products Vice President
Donna Rogers, the company had an apparent change of heart: Rogers told us that
in light of the letter, they had reconsidered and wanted to participate. But
then, in the same breath, she told us that, "unfortunately," the
demand for their new TSO'd rafts was so great and their backlog so long, that
they couldn't possibly spare any rafts to send us until well after our
deadline; their customers must come first. Yet, the next day and later that
same week associates were able to call up, speak to Rogers, and order these
same impossible-to-obtain rafts for nearly immediate delivery (without asking
for any special handling), one in a week, the other within two, over a month
before our deadline. Biting the bullet, we purchased the rafts through these
proxies without SPI's knowledge. The rafts we purchased were subsequently
serviced and then sold, at a discount, with the new owners fully aware of the
...Testing The Rafts...
tested the rafts in a wave pool, which made for a realistic test of the rafts'
capabilities. As before, by the end of the test our volunteers, referring to
themselves as "Raft Rats," were beat up, bruised and exhausted. And
In addition to the righting, boarding, stability and general performance
tests, the Tempe Fire Department provided a hydrant and hose to test the
effectiveness of the life raft's canopies in protecting survivors in extreme
weather conditions. The screams of volunteers emanating from inside the life
rafts provided quick, eloquent testimony to any deficiencies that let in the
Using the wave pool ensured consistent conditions and enabled accurate
comparisons and measurements. With the wave machine cranked up to give its
most aggressive waves, one Raft Rat with extensive sailing experience noted,
"the waves are a whole lot more realistic than I expected, it really is
like being in the ocean." Subsequent open-ocean testing of many of the
same life rafts previously tested in the wave pool have proved the results are
accurate and scalable.
perform our in-water evaluations, we enlisted volunteers to acted as our
typical survivors. These individuals, both male and female, were comprised of
both "life raft virgins," who had never deployed or been in a raft
before, and some experienced "survivors" who had previous training
or background in water survival and life rafts, either from the military or
commercial aviation, to add their perspective to our evaluation.
We had a wide range of body types, sizes and weights, which served to show
up some deficiencies we might have otherwise not noticed. These volunteers
came from throughout the U.S. and one survival instructor even came from
Norway. Two couples who attended did so expressly to finalize their decision
for a life raft purchase.
The United States Coast Guard sent two representatives, the Coast Guard's
senior rescue swimmer, Master Chief Keith Jensen, and Lieutenant Commander
Paul Steward from the Office of Search And Rescue at USCG Headquarters, both
to participate and observe. LCDR Steward noted that "these tests offer a
unique opportunity to further our knowledge of recreational marine and general
aviation life raft features and performance which can be extremely valuable
information when conducting search and rescue operations."
Both Coasties provided extremely useful feedback. Jensen, because of his
many years of practical on-the-scene experience with the sorts of conditions
and situations users of these life rafts might face, provided extraordinarily
valuable references and feedback throughout the event. His experience helped
to identify numerous deficiencies that might have otherwise gone unnoticed, as
well as identifying those features which enhance survivability. Members of the
Arizona Wing of the Civil Air Patrol and the United States Coast Guard
Auxiliary Division 10 provided logistical support and testing volunteers for
the initial in-water tests and later assisted in other testing. We could not
have done it without their able and enthusiastic help.
After completing the wave pool tests, the rafts were moved to a warehouse
where we meticulously detailed each life raft, measuring them, taking
gigabytes of digital photos and making notes of design features and equipment
both good and bad. Sea anchor/drogue effectiveness, manual inflation pump
tests and other equipment tests were also conducted. Each Survival Equipment
Pack (SEP) was opened and the contents analyzed and photographed, and where
As potential problems became evident with many rafts, even in our benign
test venues, we had to wonder how a downed pilot and passengers, probably in
shock, possibly injured, could manage in any sort of sea state, cold water or
wind condition. This became an overriding concern and one that we kept firmly
in mind during our testing.
With the foregoing as preamble, I hope I've laid the regulatory and
features-related groundwork involving aviation life rafts for the remaining
three parts of this series. In subsequent installments, we'll look at the
various features and equipment available from each manufacturer and then dive
in for some in-depth examinations of single- and double-tube rafts. We'll wind
up Part Four with some specific product- and manufacturer-related conclusions.
By then, you'll know exactly what to look for in an aviation life raft and,
hopefully, won't get that sinking feeling if you ever have to use one.
This article is Part
One of a four-part series, subsequent installments of which will be
published two weeks apart.
In Part Two, AVweb
will present a "Life Raft Primer" what features and equipment you
should look for in a life raft. Don't miss it!