September 1, 2000 Aviation Life Rafts, Part One: Requirements and Expectations

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by	Doug Ritter

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 The Aviation Consumer and Aviation Safety and a former contributing editor to Flight Training. He also writes for CODE ONE and AOPA Pilot, as well as other aviation publications. Doug is 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 Aviation Sub-Committee. Doug is also the publisher and editor of Equipped to Survive, a web site devoted to survival equipment and techniques. Articles in This Series Part One: Requirements and Expectations Part Two: A Life Raft Primer Part Three: Single-Tube Life Rafts Part Four: Double-Tube Life Rafts Supplement: Manufacturer Contact Information

In this 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.

Most 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?

Many 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 the hangar.

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 Survive's "Ditching Myths Torpedoed!"), but carrying survival equipment is all about improving the odds.

Hostile Environment

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 opinion.

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...

There 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 and 135.167 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).

So 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.

Part 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.

...Type Confusion...

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 required.

...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?

The 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 equation.

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 different priorities.

Worst Better Than None

Let 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 these tests.

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 tested:

• 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*, 2000*
• Winslow LifeRaft Co. (Winslow): 1993, 1996, 2000

* Raft acquired for test without cooperation of manufacturer.

Survival Products Games?

For 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 circumstances.

...Testing The Rafts...

We 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 wet.

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 cold water.

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.

...The Testers

To 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 appropriate, tested.

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.

Conclusion

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.