CC6345

27th March 2024

Reduced Safety Equipment

Initial Report

During our preflight safety checks we became aware that there were 2 BCF extinguishers missing from doors 2 and doors 3, and 1 from the flight crew rest area. This meant that there were only 2 BCF in the cabin and 1 in the flight deck. On checking the tech log it revealed that the 3 BCFs had actually been removed at AAA.

I brought this to the attention of the flight crew who were adamant that we could go as long as we had 2 BCFS and 2 water extinguishers in the cabin. Apparently this was on the MEL but as cabin crew we don’t have access to that and flight crew did not actually show me. The BCF and water were all  at doors 1 and 4 with nothing in between so, we repositioned them so we had 1 at doors 1 and 1at doors 3.

Only having 2 BCFs is less than half of our normal equipment, I find it totally unacceptable. A night flight with tired crew and I am having to try and remind them at every opportunity where the operational BCF are in case of an emergency and we spend most of the flight time over the Atlantic.

Company Comment

There are two responses to this answer. The first will is the regulatory explanation and the second addresses how this might feel on the day.

For the {aircraft type}…

  1. A minimum of 4 serviceable extinguishers are available in the cabin of which 2 must be BCF and one must be water; 1 serviceable BCF extinguisher is available on the flight deck.
  2. The regulation we refer to UK REG (EU) 965/2012 (Air Ops), contains a hand fire extinguisher section (CAT.IDE.250) and states various requirements including number installed. The minimum number of hand extinguishers with the maximum passenger seating operation on the {aircraft type} is 4. To meet this requirement, refer to point 1 above.

On this occasion, the flight crew’s assessment is correct and meets the regulatory requirements. Cabin crew do not have access to the MEL as it is a flight crew function. The role of the SCCM is to collect the equipment checks from the cabin crew and report their findings to the flight crew, which includes any anomalies.  The Commander is responsible for ensuring the flight is operated compliantly, hence the flight crew consult the MEL as and when required.

We understand how the reporter felt when they were presented with 2 fire extinguishers in the cabin, when there is usually 4. They correctly repositioned the 2 they had throughout the cabin.  The third being the water extinguisher and the fourth in the flight deck. If the reporter has completed a safety report, we would be able to share this feedback with the engineering team to ensure if equipment is missing it is repositioned. When we have debriefed previous incidents where a fire extinguisher was used, the crew reported that they used a few squirts to contain the fire. For most incidents, they did not use it apart from standing by with it. The main control is to break the components of the fire triangle where all three elements (fuel, heat and oxygen) are required to start a fire.  Cabin crew are annually trained, and rehearse through practical means isolating electric’s which could prohibit ‘heat’. Examples are isolating the power by switching the oven off and pulling the circuit breakers, or switching the IFE off, or submerging a PED in water etc. Informing the flight crew immediately, will help as they will consult their checklists. They may further isolate power to various parts of the cabin too. Successfully completing this action will likely put or reduce the fire without use of the BCF, although crew will be standing by with a fire extinguisher just in case as part of the fire drill. The fire extinguisher lasts for about 15 seconds. This does not sound long when verbalised, but, using it, together with the volume of the extinguishant, means fully using a bottle is unlikely provided isolation measures, if applicable to the incident are followed. This response is based on the fires commonly reported in industry and experienced within our operation.

CAA Comment

Flights are required to be operated in accordance with the Minimum Equipment List (MEL), which states the minimum permitted quantity of serviceable equipment required to dispatch a flight. Whilst cabin crew generally do not use the MEL it should be accessible for reference. Safety equipment should not be repositioned by cabin crew unless it can be correctly stowed in a location marked for its stowage, and only with the authority of the captain and ideally performed by an engineer.

CHIRP Comment

The Master Minimum Equipment List (MMEL) is a document, developed by the manufacturer and approved by the State of Design, that lists the equipment which may be inoperative at the commencement of flight without affecting safe operation of the aircraft.

Operators then produce their own Minimum Equipment List (MEL) which is approved by the Regulator but, if this differs from the MMEL, it may only be via the inclusion of more restrictive limitations.  In the event of any defects being notified or arising before take-off, the Commander must review them against the MEL to ensure the aircraft can still be safely dispatched.  The continued operation of an aircraft with permitted defects should always be minimised, though mitigations or alternative measures may be put in place until maintenance action can clear the problem.

The crew onboard should be working as a team, and if the SCCM is unsure of the content of the MEL then they should feel that they can clarify their concerns with the flight crew. The MEL is supposed to not only detail the allowable deficiencies but also how to comply with them, so the decision about how best to distribute the remaining extinguishers should be easily identified. The MEL should say exactly what is required and where it should be.