'Country of Final Assembly' Required on Safety Cards

Airlines have one year to provide information to passengers indicating the country in which the airplane they are flying was assembled.

The Federal Aviation Administration (FAA) is incorporating that information on the safety cards placed in seat-back pockets, a stratagem playing to mixed reviews. Some believe the safety card is an appropriate place for the required notice, while others believe this dilutes and distracts attention from the primary safety message of the card.

How the safety card became the instrument for this newly required information shows the significant difference between the words "an" and "the," a seemingly subtle yet significant point that will be addressed shortly.

The final rule issued June 29 by the FAA responds to a congressional requirement to include the country of final assembly. The provision was added to the FAA's Fiscal 2003 Reauthorization Act, without which there would be no FAA. The requirement was included in the bill at the direction of Rep. John Mica (R-Fla.), chairman of the House transportation and infrastructure aviation subcommittee. Mica has said the intent is to provide the consumer with additional information, akin to that found on clothing labels, for example.

However, the mandate may stem from a larger controversy over trade. Last year, legislators unhappy with the perceived lack of support by U.S. allies such as France for the war in Iraq attempted to pass "Buy American" legislation that was opposed by the U.S. aerospace industry. That failed effort has been revived this year with proposed legislation that would eliminate offsets. Offsets are agreements in which a customer nation is guaranteed jobs from the seller as part of the deal. Opponents of offsets maintain that the practice bleeds away U.S. jobs.

Hence, the "country of final assembly" mandate for airliners adds visibility to the larger debate over international trade issues and discontent with tepid international support for the U.S. war in Iraq.

Now to the difference between "an" and "the." The legislation said:

"The Secretary of Transportation shall require ... an air carrier using an aircraft to provide scheduled passenger air transportation to display a notice, on an information placard available to each passenger ... that informs the passengers of the nation in which the aircraft was finally assembled." (Emphasis added)

This language suggests that a separate card can be printed and inserted into the seat-back pocket.

However, the committee report accompanying the legislation interprets the statute as calling for the information to be made available "on the placard in the seat back pocket." (Emphasis added)

The FAA interpreted this language as clear guidance that Congress intended the information to be incorporated onto the existing safety information placard. However, neither the statute nor the committee report specifically identified the safety information card as the place for the notice.

Airlines have until June 2005 to ensure that more than 750,000 seat-back pockets contain safety cards with the required information. Given that the normal replacement cycle for the cards would not meet the 12-month deadline, the FAA is allowing operators to print stickers and have their cabin cleaning staffs affix them to the current safety cards. At an estimated cost of 50 cents per sticker, the FAA figures that the total cost will be around $522,000. That cost is for stickers and the management time for each carrier to ensure that the stickers are applied.

The order affects U.S. carriers only. The initiative was exempted from a cost-benefit calculation, the the FAA explaining the waiver on the grounds that "Congress, which reflects the will of the American people, has determined that this final rule is in the best interest of the nation and therefore provides a benefit." Sources say an economic analysis was performed and the rule was judged "not cost beneficial." Politics trump process.

Industry was not afforded an opportunity to comment. An FAA source explained, "Many of the air carriers impacted may have wanted to comment, however we do not have the authority to write a rule that is in conflict with the statute, so any comments received not in accordance with the statute would not have been considered."

Reactions ranged from strong support to outright opposition.

Hans Ephraimson, head of the Air Crash Victims Family Group, said, "We have been asking for this for a long time and had hoped it would be done voluntarily."

"Nobody knows the provenance of an airplane, so at least this is a way to provide the information," he added. "The safety card has a diagram of the airplane, so this is an appropriate place to put the country of assembly."

Paul Hudson, director of the Aviation Consumer Action Project (ACAP), questioned the appropriateness of the mandate. It is one thing for a purchaser of a product to be provided information on where the product was built or assembled, "but in this case the passenger is not the purchaser."

Moreover, Hudson went on to say, country of final assembly provides nil information of any value to the consumer. For example, he said, "The dollar value of the domestic content should be shown." Such information would accord with product labeling laws in the United States for automobiles, and for the Swiss watch industry.

Hudson pointed out that the engines may be just as important as the airframe, and might be included in the notification. He cautioned that the generalized label being mandated could mislead passengers. "They might think because they're flying on an American airplane they're safer because it was built and maintained in the United States. But major components may have been manufactured overseas and the maintenance work may be performed at an overseas repair station."

FAA oversight of overseas maintenance practices has been found deficient (see ASW, July 21, 2003).

Another industry observer said it would be far more useful from a passenger point of view to display the airplane's year of manufacture.

Clay McConnell, an Airbus official, said, "The safety card seems a strange place to put this information because all aircraft have to meet the same safety requirements regardless of where they're assembled."

ACAP's Hudson agreed, saying, "All aircraft have to be certified by the FAA, so this labeling requirement is irrelevant for safety."

In fact, putting the country of assembly (France or Germany in the case of Airbus, depending upon the model) on the safety information card conflicts with its purpose. Chris Witkowski, director of air safety, health and security with the Association of Flight Attendants (AFA), declared the requirement "sets a dangerous precedent."

"Putting non-safety information on the emergency safety card distracts the passenger from the purpose of the card" to provide life-saving information in an emergency. His critique said the country of assembly mandate conflicts with the need for a simple, uncluttered card design.

In fact, placing the country of assembly on the safety card conflicts with the FAA's own guidance on safety cards issued last year.

Humorists had a field day with the requirement. One said, "Airbus should make stickers with the subtitle, '51% market share and climbing!' "

Another suggested that if the passengers are to be provided with a meaningful safety-related disclosure, the notice should be more detailed. >> Contacts: Ephraimson, e-mail ACVFA@cs.com; Hudson, e-mail ACAP1971@hotmail.com; Witkowski, e-mail cwitkowski@afanet.org; McConnell, e-mail clay.mcconnell@airbus.com <<

The Meaning of 'Swiss Made'
A law "regulating the use of the name 'Swiss' for watches" sets out the minimum conditions that have to be fulfilled before a watch merits the "Swiss made" label.

This law is based on a concept according to which the Swiss quality depends on the amount of work actually carried out on a watch in Switzerland, even if some foreign components are used in it. It therefore requires that the assembly work on the movement (the motor of the watch) and on the watch itself (fitting the movement with the dial, hands and the various parts of the case) should be carried out in Switzerland, along with the final testing of the movement. It also requires that at least 50 percent of the components of the movement should be manufactured in Switzerland.

Source: Federation of the Swiss Watch Industry, http://www.fhs.ch/en/swissm.php

Compare & Contrast
2003 - FAA Advisory Circular AC No. 121-24C, Passenger Safety Information Briefing and Briefing Cards, July 23, 2003, p. 6:

Design. The card should have an eye-catching tile or symbol identifying itself as safety or emergency instructions ... The method used to depict equipment and actions can be pictures of people, diagrams, drawings, words, or combinations of these ... All depictions should be easy to understand and not complex. Cards should also be interesting and attractive so passengers will want to read them. For example, a multicolored card, which has pictures and drawings, will be picked up and read more often than a black and white printed card.

Extraneous information. Passenger safety briefing cards should contain only information that is essential for safety. For example, advertising, schedules, or promotional information is not safety-related and should not be on the cards.

2004 - Federal Aviation Regulations, US dollars121.571 (extracts):

Each certificate holder must carry on each passenger-carrying airplane, in convenient locations for use of each passenger, printed cards supplementing the oral [safety] briefing. Each card must contain information pertinent only to the type and model of airplane used for the flight, including -

(1) Diagrams of, and methods of operating, the emergency exits;

(2) Other instructions necessary for the use of emergency equipment; and

(3) No later than June 12, 2005, for Domestic and Flag scheduled passenger-carrying flights, the sentence, "Final assembly of this airplane was completed in (INSERT NAME OF COUNTRY).

Tongue in Cheek Disclosure
The 'Country of Final Assembly' notice in its entirety to read:

Final assembly of this aircraft was carried out in the United States. However, the engines are French, the fuel was uplifted from wherever the aircraft just arrived from, the lavatory water may or may not be potable and the food is from our catering contractor in Gabon. Maintenance this week was provided by our contractor in Haiti.

Most of the urgent airworthiness directives and the odd service bulletin have been carried out.

As part of our product disclosure statement, we need to advise you that the company has filed for Chapter 11 bankruptcy, has just been fined $10 million by the FAA for illegal carriage of hazardous materials, and so has been unable to make payroll. This will explain why the flight attendants are circulating with the alms box. Please deposit any small change.

Thank you for your attention, and good luck.


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The Card Is Being Corrupted

Concerns of the Association of Flight Attendants:
Putting non-safety information on the emergency safety card distracts the passenger from the purpose of the card - to provide essential information necessary to passenger survival in an emergency.

This is not a trivial concern. AFA has been in the forefront of promoting the safety and effectiveness of emergency evacuation procedures and equipment for decades. According to a study, cited by the National Transportation Safety Board (NTSB), one of the recommended guidelines for the design of emergency information cards was that "a simple, uncluttered, systematically organized card format enhances acceptance by the reader." (NTSB, Safety Study, Airline Passenger Safety Education: A Review of Methods Used To Present Safety Information, NTSB/SS-85/09, p. 13, Washington, D.C.)

The cited study stressed the importance of determining the information that passengers needed to know and the best educational approach in the delivery, such that retention of required information is enhanced. ("Passenger Emergency Briefing Cards: Recommendations for Presentation Style," H.B. Altman, D.A. Johnson, D.I. Bolm, Eighth Annual SAFE Symposium Proceedings, Vol. 2, pp. 455-474, 1970)

The following case is one example of how concise safety information, combined with flight attendant verbal instructions, can markedly improve on the use of emergency evacuation slides. Tests were conducted to determine if safety card improvements would increase the flow of persons per slide and thus decrease the time to evacuate the airplane. It was shown by Douglas [Aircraft] that the evacuation rate could be increased by adding the instructions "JUMP, DON'T SIT" to the safety card and by having the flight attendant shout "JUMP" at each exit. These instructions were effective in preventing persons from sitting at the top of the slide, and subsequently were incorporated on safety cards and in flight attendant evacuation instructions. (NTSB/SS-85/09 at p. 13)

The Safety Board has testified that the problems associated with passenger safety education had to be addressed in a systematic program to determine exactly what and how much information needs to be presented and can be assimilated by the flying public, and how best to present the information to improve comprehension and retention. (id, p. 9)

The information on each aircraft's country of final assembly could be placed somewhere other than the safety card. The approach of adding it to the safety cards may have been thought to save printing costs, but apparently the cost of adding information to the safety card, which may distract the passenger from that which is essential to his or her survival, was overlooked.


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