CC6640(A)/ CC6660(A)/ CC6764(A)/ CC6769(A)

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15th October 2024

Pushback with PAX standing

Initial Report

CC6640 Report text: The flight was full in all cabins. Boarding was from door 2 Left. Lots of hand baggage. The last pax boarded and the ground staff requested for the main pax door to be closed. I closed the pax door and immediately called the Flight Crew to advise of the situation on the cabin. Advising them that the last pax had just boarded but the queue for the pax making their way to their seats was congested and backed all the way back to door 2. So pax queuing from door 2 Left and Right virtually down to door 4 Left and Right. I also advised them that all the overhead lockers were still open, loaded with heavy bags. I asked the flight crew to hold off pushing back until we had the situation under control. Despite this, a couple of mins later we started to push back. This delayed us being able to arm our doors as some crew on the left hand side could not get to their door due to the congestion in the cabin and them being in the cabin trying to manage the situation of hand-baggage and the queue of pax still making their way to their seats.

After the off, I spoke with the captain and asked why after communicating the situation in the cabin did we still push back? I was told to look at OM-B [reference] where it states that “This procedure should not prevent the aircraft from pushing back” So, in my opinion, to pushback with a situation like this in the cabin with pax literally queuing all the way to door 4 making their way to their seats and all of the overhead lockers open, loaded with heavy bags, seems unsafe. It says in the manual that we can push back with pax stood up, it seems that no consideration is given to the situation in the cabin. For example: the amount of pax stood up literally walking to their seats, having literally just boarded the aircraft; the level of congestion in the cabin; and all the overhead lockers still open full of large heavy bags.

CC6660 Report text: As soon as boarding was complete and door closed the beacon light came on and we started pushing back as soon as Jetty was removed. No consultation from flight crew regarding this. We had many passengers still in the aisles locating their seats and trying to find overhead bin space. Many pax voiced their concern at this stating they felt uneasy and unsafe. I have to agree as I was made to try to locate spaces for many bags having to take them myself and also situate passengers quickly all whilst pushing back and trying to remain stable. This coupled with arming doors is not a safe procedure and could really make someone blow a slide if they were prone to distraction/heavy workload. Just because we are able to do so in our manuals doesn’t make it right to. We can pushback but can’t taxi under own power, I feel this should be changed to cannot pushback whilst pax are still moving about. I understand time constraints etc, but for the sake of a few minutes delay surely operating in a safe manner/preventing mistakes should be the priority.

CC6764 Report text: Whilst operating a flight as a cabin crew member, there were still a lot of passengers who had not taken their seats or put their bags in the overhead lockers, nor were the overheads closed. We then noticed we started to pushback and continued to do so until our senior cabin crew member phones the flight crew that we were not yet prepared. This could have had a seriously dangerous outcome since many passengers were still in the aisles with luggage around on the floor. We did not have enough time as cabin crew to clear what needed to be clear and stow and secure equipment. The most dangerous part was that we had an aircraft change and had a 10 crew compliment which is the minimum requirement. The crew had to work extra hard and took longer to make sure the pax and the plane was ready for taxi and take off. Ground staff, flight crew and the company should have given us more time to prepare as an incident could have occurred.

CC6769 Report text: On a recent flight, we were slightly delayed so the ground staff were very keen to get everyone onboard. The door was closed fairly quickly after the last passenger boarded and we started pushing back soon after that. The pushback happened when there were a good 50-60 passengers, complete with baggage, still standing in the aisles. We then had a frantic time trying to get everyone seated and have their baggage stowed away – most customers having more than their allowance, and bags having to be spread around the aircraft. This made us look very unprofessional and wasn’t a good start to the flight. Another concern was that we were moving and the doors were unarmed at this point. I find this is happening more and more in an effort to improve on time performance. I feel there was a breakdown in communication between the SCCM and flight crew and, on relaying my concerns, I was told ATC were pressuring us to go.

Company Comment for CC6640

We know that boarding is the busiest time of the crew members’ duty. During boarding, it is important for crew members who do not have door ground responsibility to manage the cabin, overhead lockers and stowage of passengers’ smaller items under the seat in front. The SCCM may consider crew from other cabins to assist where required and reduce the offering of the pre-departure service until after take-off. We would recommend completing the required report. The reporter is correct that our procedure cited in the manual permits the aircraft to push back, yet taxi will not commence unless the cabin is in an acceptable state, which relies on the SCCM maintaining communication with the flight crew, which it appears in this situation did occur. If it is felt that the conditions in the cabin are not being taken into consideration we encourage reporting on this also.

CAA Comment

Pushback is not specifically covered under regulatory requirements as other phases of flight, including taxi, are.

CAT.OP.MPA.225 Seats, safety belts and restraint systems

(b) Passengers

(1) Before take-off and landing, and during taxiing, and whenever deemed necessary in the interest of safety, the commander shall be satisfied that each passenger on board occupies a seat or berth with his/her safety belt or restraint system properly secured.

CAT.OP.MPA.230 Securing of passenger compartment and galley(s)

(a) The operator shall establish procedures to ensure that before taxiing, take-off and landing all exits and escape paths are unobstructed.

(b) The commander shall ensure that before take-off and landing, and whenever deemed necessary in the interest of safety, all equipment and baggage are properly secured.

AMC1 CAT.OP.MPA.160 Stowage of baggage and cargo

(g) checks should be made before take-off, before landing and whenever the ‘fasten seat belts’ signs are illuminated or it is otherwise so ordered to ensure that baggage is stowed where it cannot impede evacuation from the aircraft or cause injury by falling (or other movement), as may be appropriate to the phase of flight.

CAT.GEN.MPA.105 Responsibilities of the commander

(a) The commander, in addition to complying with CAT.GEN.MPA.100, shall:

(1) be responsible for the safety of all crew members, passengers and cargo on board, as soon as the commander arrives on board the aircraft, until the commander leaves the aircraft at the end of the flight.

Under CAT.OP.MPA.225 and CAT.OP.MPA.230, the provision of ‘whenever deemed necessary in the interest of safety’ is intended to cover eventualities such as turbulence, decompression and other emergencies or unforeseen circumstances. Amending the regulations above, or CAT.OP.MPA.205, is not a quick process (as inferred by CHIRP), and is not currently on the Flight Operations Rulemaking programme. Amending implementing rules is currently a 2-3 years-long process.

If an operator permits passengers to be standing during pushback, what would be of interest is what risk assessment has been performed, and how identified risks are managed/mitigated.

CHIRP Comment

There are clear risks in conducting pushback whilst passengers are not seated, and even greater when they may still be stowing bags; it wouldn’t take much for a sudden stop during pushback to cause chaos and potentially passenger injuries. Also, if there was not enough room for bags in the overhead lockers then some might need to go into the hold so, if the aircraft doors are closed and pushback has begun, this would obviously not be possible. The fact that the cabin crew could not make their way to the doors in some of these situations during pushback also has clear safety implications if an emergency were to occur. We do not think that it is sensible to pushback whilst passengers are not seated, no matter what the operational pressures might be to do so.

More philosophically, passengers will be unlikely to be able to differentiate between pushback and taxiing and so, if they perceive that the aircraft is moving for pushback and they are not required to be seated, they will not understand why there is a restriction when the aircraft is taxiing (either before take-off or after landing); in their minds there is, understandably, no difference.

In regulatory terms, The Air Navigation Order 2016 PART 5, CHAPTER 2, SECTION 2, Article 71 states that:

Passengers to be seated and properly secured

71. The pilot in command of an aircraft other than a balloon must ensure that:

(a) prior to and during taxiing, take-off and landing; and

(b) whenever deemed necessary in the interest of safety,

each passenger on board occupies a seat or berth and has their safety belt or restraint device properly secured.

Whilst the ANO is clear about passengers being seated during taxi and ‘prior to taxiing…’, there’s no specific reference to pushback; so, provided that passengers are seated prior to taxiing (i.e. moving under the aircraft’s own power and after pushback) then the regulation could be said to have been complied with.

Similarly, as noted by the CAA, CAT.OP.MPA.230 Securing of passenger compartment and galley(s) does not include any reference to pushback and simply requires operators to have procedures for securing the cabin for only taxi, take-off and landing, not during pushback.

For its part, AMC1 CAT.OP.MPA.205 Push back and towing – aeroplanes seems to refer to pushback and towing as ‘pre- or post-taxi positioning…’ thereby implying pushback is not a part of taxiing and seeming to reinforce the inapplicability of Article 71 to have passengers seated.

It appears then that there is a loophole in the regulations because pushback is not necessarily within the definition of ‘taxiing’. It seems common-sense to us that passengers should be seated before pushback and that this loophole could be closed by the ANO including something like: “Prior to and during pushback, taxiing, take-off and landing…’ but we recognise that ANO changes are not a quick solution.

In the interim, the CAA might consider amending CAT.OP.MPA.205, CAT.OP.MPA.225 and CAT.OP.MPA.230 to specifically include passengers being seated for pushback. With some airports moving towards aircraft being towed to the holding point in future to save fuel/ noise/ emissions etc, this issue will only become more pertinent.

For those companies that allow pushback with passengers standing and potentially stowing bags, we assume that they have processes in place to risk-assess such practices; this risk assessment should probably involve their legal teams in consideration of any potential injuries that might be caused to passengers from falls or from baggage drops from overhead bins should an abrupt stop, abnormality or unsteady progress occur during the pushback.