Volume 3 GENERAL TECHNICAL ADMINISTRATION
CHAPTER 33 CABIN SAFETY AND FLIGHT ATTENDANT MANAGEMENT
Section 4 Safety Assurance System: Flight Attendant Requirements
NOTE: This section is related to Safety Assurance System (SAS) Elements 5.1.1 (OP), Training of Flight Attendants, 5.2.1 (OP),
Crewmember Duties/Cabin Procedures and 5.2.4 (OP), Passenger Handling.
3-3511 NUMBER OF FLIGHT ATTENDANTS (F/A) REQUIRED AT STOPS WHERE PASSENGERS REMAIN ONBOARD, PART
121.393. In 1985, John Cassady, Assistant Chief Counsel, International
Law, Legislation, and Regulations Division (AGC-200) of the Federal Aviation
Administration (FAA) issued a legal interpretation that stated that during the
boarding and deplaning process, all of the F/As required by Title 14 of the
Code of Federal Regulations (14 CFR) part
121.391(a) must be onboard the aircraft. During deplaning or boarding at
all points, including an intermediate stop, the full FAA minimum F/A complement
must be onboard. The only time the number may be reduced, per §
121.393(b) (formerly codified at §
121.391(a)(3)), is when all the remaining onboard passengers are continuing
on to the next destination and at a time when no other passengers are deplaning
or boarding. To view the most recent legal interpretation regarding this issue, go to
is the position of Flight Standards Service (AFS) that, pending any amendment to §
121.393, the current regulations require the following:
A. Boarding and Deplaning. During the passenger boarding and deplaning phase on each flight, all of the F/As required by §
121.391(a) must be onboard the airplane.
B. Intermediate Stop. During an intermediate stop where passengers remain onboard, the number of required F/As, or persons trained in emergency procedures as per §
121.393(b)(2), may be reduced according to
§ 121.393(b). However, during the deplaning and boarding phase at an intermediate
stop where passengers remain onboard, all of the F/As required by §
121.391(a) must be onboard the airplane.
3-3512 DISTRIBUTION OF F/As. Part
121 stipulates that F/As must be uniformly distributed throughout the
operation of the flight. This includes when the aircraft is in-flight, parked at the gate,
moving on the surface, taking off, and landing. The most important part of this
requirement pertains to placing F/As in locations that will provide the most
effective egress of passengers in the event of an emergency evacuation.
A. Purpose. The purpose of this requirement is to avoid having
several F/As assigned to a sparsely occupied compartment when most of the passengers
are grouped in another compartment having only one F/A.
B. Required Placement. Information regarding the required placement
of F/As for takeoff and landing for an aircraft can be found in either the Type
Certificate Data Sheet (TCDS) or the Flight Standardization Board (FSB) report.
For example, those documents require the stationing of F/As at both the 3L and
3R positions on the McDonnell Douglas DC-10 and McDonnell Douglas MD-11 aircraft.
Principal operations inspectors (POI) may assist air carriers in obtaining this
information by contacting the appropriate Aircraft Evaluation Group (AEG).
C. Change of Location. The POI should not approve a change to
the location of required F/A stations reflected in the TCDSs without the following
1) Carefully analyzing the “request for a change” in order to determine that the assigned evacuation duties of the F/As will meet the provisions of part
121. Consideration to change the location of the required F/A stations
should be based on changes in the cabin configuration such as number of seats, location of galleys, or F/A duties.
2) Consulting with the appropriate AEG should establish the reason
for the location of the required F/A stations. In some aircraft, this location
is quite critical while in others it may make little or no difference.
3) Considering if a partial evacuation demonstration, as required by part
121, is necessary.
3-3513 DUTY ASSIGNMENT OF REQUIRED AND NONREQUIRED F/As. Part
121 requires that, during taxi, the F/A complement required by §
121.391 remain at their duty stations with safety belts and shoulder harnesses
fastened, except to perform duties related to the safety of the aircraft and
its occupants. All F/As, even those in excess of the minimum crew complement,
must keep their safety belts and shoulder harnesses fastened unless the F/A
is performing duties related to the safety of the airplane and its occupants.
These duties may include:
· Safety briefings,
· Compliance checks of seat belt fastening,
· Conducting passenger briefings,
· Ensuring passenger compliance with stowage of the food and beverage tray,
· Ensuring passenger compliance with the seatbelt and no smoking placards/lights,
· Checking for the proper stowage of carry-on baggage,
· Attending distressed passengers, or
· Responding to emergency situations.
NOTE: Because the pertinent regulation states that only required F/As
may get up to perform safety‑related duties, technically those in excess of
the required number were not able to get up during aircraft movement. AFS has
granted a petition for exemption that allows all F/As to perform safety‑related
duties during movement on the surface when the number of F/As aboard a particular
flight exceeds the number required by part
121. To view this exemption, go to the FAA’s Automated Exemption System
(AES) at http://aes.faa.gov and type “5533” in the blank “Exemption/Docket No.” field.
A. Minimum F/A Requirement. Part
121 states the requirements used to determine the minimum number of F/As
for each passenger-carrying airplane operated by an air carrier.
B. F/A Training. The F/As who make up the minimum complement,
specified in the air carrier’s operations specifications (OpSpecs), must be
fully trained in accordance with part
121 subpart N and qualified on that type airplane in accordance with part
121 subpart O.
1) Some air carriers may use only the minimum number of F/As,
while others occasionally or frequently use F/As in excess of the number required.
In accordance with §
121.392, any person identified by the air carrier as an
F/A on an aircraft must be trained and qualified in accordance with part
121 subparts N and O. This includes F/As in excess of the number required
121.391(a) and when F/As are not required by §
2) An F/A in the process of meeting Operating Experience (OE) requirements is not qualified and cannot be used as a “required” F/A. Section
121.434(e) states, in part, “flight attendants receiving operating experience
may not be assigned as a required crewmember.” In accordance with §
a qualifying F/A who is receiving OE must be identified to passengers as a qualifying
F/A. Air carriers may determine how they want to identify these individuals
to passengers, as appropriate for their operation. Some possible methods would
be to differentiate their uniform from that of a fully qualified F/A, identify
F/As in training as “trainees” via nametags, or to make an announcement to passengers
before the aircraft pushes back from the gate.
C. Required F/As. Part
121 does not require the use of extra or nonrequired F/As. The capability
to handle emergency situations and emergency evacuations is based on the complement
of required F/As. The duties assigned to the required complement of F/As must
be realistic, be capable of being practically accomplished, and take into account
the possible incapacitation of an individual crewmember.
D. Additional F/As. If an air carrier uses more trained and qualified F/As than are required by part
121, then the air carrier should have a procedure whereby the F/As required
to fulfill the regulatory requirements are appropriately assigned. The extra
F/As need to be identified.
E. Distribution of Extra F/As. The air carrier should evenly
distribute extra F/As. The air carrier’s manual should contain procedures which
identify the required and nonrequired F/As. The air carrier should not assign
duties to the extra F/As who would mandate their presence and duty assignment
in the event of an emergency situation, such as an evacuation.
3-3514 USE OF NON-F/A PERSONNEL IN AIRCRAFT CABINS. U.S. air carriers
periodically use company employees in the cabins of its aircraft for the purpose
of conducting certain passenger service activities, such as serving beverages,
conducting customer relations, or acting as translators. These persons are not
assigned to flights to perform safety duties. These company employees are not
acting in the capacity of an F/A nor are they, in general, trained or qualified
to act as a F/A. The regulations do not prohibit the use of non-F/A personnel
by an air carrier. However, their presence could conceivably interfere with
the F/As if they were not properly instructed. The following guidance should
be considered when non-F/A personnel are used by an air carrier.
A. Status of Non-F/A Personnel. Air carriers may use these individuals
to perform activities limited to passenger service. They are a different category
of cabin personnel and are not persons trained as F/As.
B. Applicable Regulations. Non-F/A personnel are subject to the same provisions of part
121 as passengers. For example, they must receive a pretakeoff briefing,
must be seated for movement on the surface, takeoff, and landing, and must stow their carry-on baggage as required by part
121. They must also comply with the seatbelt requirements of part
121. They may not conduct any activities during movement on the surface.
C. Instruction. These individuals should receive enough instruction
that they know what activities they may perform and equipment they may or may
not operate so as not to interfere with the F/As. If they operate equipment
they must carry the applicable parts of the F/A manual. The appropriate parts
of the manual should provide enough information to ensure that they understand
their duties and procedures, and to ensure that they do not interfere with the
F/As’ duties and procedures.
D. Assignment of Activities. The activities assigned to these
individuals should be clearly distinguishable from the duties assigned to the
F/A. They should not be permitted to operate any equipment or systems for which
specific training is required by part
121 like electrical galley equipment, heating and ventilation controls for
the cabin, and the public address (PA) system (except to perform language translator
duties for passenger briefings).
E. Identification of Non-F/A Personnel. The air carrier may want to have these individuals distinguishable from the F/As. They can be distinguishable through
the use of an identification card, a different uniform, or some other means.
RESERVED. Paragraphs 3-3515 through 3-3530.