For the purpose of this policy letter a non-frangible lock means “a lock which will not shear when a reasonable amount of force is exerted by a person who is intent on breaking through a secured door or barrier”.

1. The aeroplane is equipped with a door between the passenger compartment and the flight deck, with a locking mechanism, which can only be unlocked from within the flight deck,
2. If equipped with a crew rest facility, which is accessible from both the flight deck and the passenger compartment, a lockable door is installed between the crew rest facility and the passenger compartment.

All-Cargo Aeroplanes. For the purpose of Section 705.80 of the CARs, a new definition, “all-cargo aeroplane” meaning “an aeroplane that is equipped and used mainly for the carriage of goods,” was included in Section 705.80 of the CARs (this does not include combi aircraft).

As there was no means to ensure that a person who is intent on using an aeroplaneas a weapon could not board an all-cargo aeroplane and since many all-cargo aeroplanes already had flight deck doors, it was determined that these aeroplanes should also meet the same regulatory requirements for flight deck doors.

In order to preclude removal of flight deck doors as a means to avoid compliance with the new rule, the Federal Aviation Administration (FAA) established that the flight deck door regulations for all-cargo aeroplanes would be effective on January 15, 2002, the date that the amendment was issued. Thus in harmonization with the FAA, all-cargo aeroplanes operated by a Canadian air operator, that were equipped with a flight deck door on January 15, 2002, are required to be equipped with a door between the flight deck and another occupied compartment, with a lock which can only be unlocked from inside the flight deck. If the aeroplane is equipped with a crew rest facility that is accessible from both the flight deck and another occupied compartment, a lockable door must be installed between the crew rest facility and that compartment.

Applicability of Section 705.80 of the CARs to an all-cargo aeroplane. In the case of an all-cargo aeroplane , an occupant is any person referred to in Section 705.16 of the CARs. Thus, when such a person is on board an all-cargo aeroplane and not occupying the flight deck, or restricted from occupying the flight deck in accordance with Section 705.27 of the CARs, the aeroplane requires a lockable flight deck door in accordance with Section 705.80 of the CARs.

An air operator is not required to install a flight deck door on an all-cargo aeroplane if the aeroplane did not have a flight deck door on January 15, 2002 or if it was type certified prior to January 1, 1958. In this case a pilot-in-command (PIC) could operate such an aeroplane, with a person occupying a compartment other than the flight deck, even though the aeroplane is not equipped with a flight deck door or lock.

If an all-cargo aeroplane had a door on January 15, 2002 but there is no intent to carry any person on board that will occupy a compartment other than the flight deck, the air operator is not required to comply with the requirements of Section 705.80 of the CARs.

In all cases the requirements of provision Section 705.27 of the CARs, admission to the Flight Deck, must be met.

Exemption to Subsection 571.06(1) and from Sections 705.134, 705.135, 705.137, 705.138 and 705.139 of the CARs. This exemption originally issued on October 9, 2001 was re-issued April 5, 2002. The exemption permits air operators to make modifications to flight deck doors and to revise and implement safety and emergency procedures related to the modifications to the flight deck doors, in the Company Operations Manual, Aircraft Operating Manual, Standard Operating Procedures or Flight Attendant Manual, that enhance security, without prior Transport Canada approval.

Further information on the exemption can be found at the Aircraft Certification Enhanced Security Measures website: http://www.tc.gc.ca/civilaviation/certification/security/TCCAActions.htm.

The new exemption was issued to ensure that air operators could continue to modify the flight deck doors and locks of aircraft brought into service between May 1, 2002 and April 9, 2003 in order to comply with the requirements of Section 705.80 of the CARs. The exemption will expire April 9, 2003 when all aeroplanes for which Section 705.80 of the CARs is applicable, must have doors that meet the new design criteria defined in airworthiness Standard 525.795 of the CARs.

It is expected that the temporary locking devices will reinforce the existing flight deck doors and thereby improve security. The following types of door locks are considered to meet the intent of regulation Section 705.80 of the CARs:

1. A steel bar;
2. A non frangible deadbolt; or
3. A modification of the aircraft door lock such that it cannot be unlocked from outside the flight deck. The locking latch must be non frangible.

It was recognized that such modifications would introduce concerns for safety during emergency situations. However, these were assessed as acceptable risks for the interim period of time in the interest of immediate improvements to security.

The exemption states that persons signing the maintenance release, in respect of modifications to flight deck doors to provide additional security features, are exempt from the requirement to use approved data, subject to conditions. One of the conditions is that the air operator submit to the Director, Aircraft Certification no later than August 1, 2002:

1. A detailed description of any major or minor changes to the aircraft that have been accomplished or are intended to be accomplished to satisfy Section 705.80 of the CARs in effect on April 10, 2002; and
2. A list of the airworthiness requirements for which compliance has not yet been shown, and a plan and schedule for accomplishment of the changes necessary to establish compliance with all applicable airworthiness requirements by April 9, 2003.

More details on this process can be found in Aircraft Certification Policy Letter 92, which provides advisory material and details on the exemption and how to submit data to Transport Canada Civil Aviation (TCCA). This document can be accessed at the following website: http://www.tc.gc.ca/CivilAviation/certification/guidance/menu.htm.

Control of Flight Deck Door Keys. The manufacturer's key for the flight deck door may have multiple purposes, such as, to open medical supplies or other cabinet doors inside the cabin. In order to ensure the security of the flight deck, while permitting cabin crew to have access to the flight deck key for those other purposes, restrictions on when cabin crew could have access to the key were included in this regulation. Accordingly, this section prohibits any person, other than a flight crew member, to have access to a key that can unlock the flight deck door unless the required locking device required by Section 705.80 of the CARs is installed and in use.

New Door Design. After April 9, 2003, a door must be installed that meet the design requirements of the new Airworthiness Standard, Section 525.795 of the CARs - Security Considerations. This section establishes door design criteria for impact, tensile load on the handle or knob and resistance to small arms fire and fragmentation devices. Also after this date, Subsection 705.80(6) of the CARs requires that the locking device and any other system used to control access to the flight deck can be operated from each flight crew member position. This provision is applicable to the pilot and co-pilot positions only. The intent was to ensure that if one pilot became incapacitated, the other pilot would still be able to operate the controls for the flight deck door lock while flying the aeroplane. This would also provide a means for the pilot remaining at the controls to allow another crew member to enter the flight deck and provide assistance while flying the aeroplane. In order to meet these requirements the pilot's seat must be positioned so that they are able to view the primary instruments and fully deflect all flight controls.

Section 705.45 of the CARs - Closing and Locking of Flight Deck Door. This is a new regulation, which requires the pilot-in-command (PIC) of an aeroplane, which is required by Section 705.80 of the CARs to be equipped with a lockable flight deck door, to ensure the door is closed and locked from the moment the passenger entry doors are closed in preparation for departure until they are opened on arrival.

The PIC of any other transport category aeroplane for which Section 705.80 of the CARs is not applicable, but which is equipped with a flight deck door must also ensure the door is closed, and if equipped with a lock, the door is locked during aircraft operation.

The flight deck door may be unlocked and opened when crew members and other authorized persons are required to exit or enter the flight deck in the performance of their duties, for physiological needs or for overriding concerns related to the safety of flight. Persons entering or leaving the flight deck must follow procedures established in the company operations manual.

Overriding Safety of Flight Considerations. Ultimately, the PIC will determine when an overriding safety of flight consideration warrants opening the flight deck door. Circumstances which may be considered overriding safety of flight concerns include but are not limited to the following:

1. Visual inspections to confirm such things as a potential fuel leak, engine condition, visual gear/flap configuration, inspection of contaminated surfaces, etc.;
2. safety/emergency procedures; such as pilot-in-incapacitation or fire fighting;
3. Abnormal or emergency landings where safety procedures requires that the door be open for landing;
4. To communicate essential information where there is no appropriate alternative under the circumstances.

Section 705.27 of the CARs Admission to Flight Deck, was amended to specify who may be allowed on the flight deck during flight, which includes, flight crew, Transport Canada air carrier inspectors, employees of the company, a wholly owned subsidiary or a code share partner and any person who has expertise related to the flight operation and whose service is required by the operator. This section also specifies the required identification that must be presented by an authorized individual and that company procedures will be established for authorizing individuals on the flight deck. The intent of these changes is to ensure that only persons involved with flight operations, flight safety or other legitimate reason are provided with access to the flight deck. By reducing the number of additional persons on the flight deck, the potential number of times for opening and closing the flight deck door is also minimized, further enhancing security.

The PIC or his representative must properly identify persons authorized by the air operator to occupy the flight deck. Transport Canada inspectors with proper identification retain the right to access granted in the Aeronautics Act. Nothing in this regulation is meant to limit the authority of the PIC to exclude any person from the flight deck in the interest of safety. This would apply in situations such as an emergency or where the identity of the person cannot be established with certainty.

Standard 725.135 of the CARs - Contents of Company Operations Manual. This standard was amended to mandate procedures that must be included in the manual after April 9, 2003. Since the intrusion resistant doors will have replaced the temporary locking devices by that date, the procedures will address the new door design. The company operations manual must include the following:

Procedures for controlling access to the flight deck that include:

1. A means to determine an individual's employer and their position/occupation in the company;
2. A means to identity each person that is given authorization;
3. A method of authorizing an individual to occupy the flight deck; and
4. A means to enable all company personnel involved with the boarding or operation of the flight (e.g. ticket agents, cabin crew, flight crew, etc.) to verify a person's authorization and their identify.

Procedures for opening, closing and locking the flight deck door:

1. For all situations and phases of flight on the ground and in the air.

Procedures to verify the identity of a person authorized to access the flight deck describing:

1. Acceptable forms of identification
2. Enhanced crew briefing to ensure all crew members are aware of who will occupy the flight deck, their credentials and their function.

Procedures for enabling a crew member to enter the flight deck in the event that a flight crew member becomes incapacitated; and

Procedures to control access to a crew rest facility from the passenger compartment, if the aeroplane is equipped with a crew rest facility that can be accessed from the flight deck and from the passenger compartment.

Standard 725.124 of the CARs – The Training Program. The training program was amended to require training on the above procedures. It is expected that the training program will be sufficiently detailed to address all aspects of the procedures.

Guidance on Developing Procedures. The following must be considered when developing safety and emergency procedures:

1. The means and methods by which the crew members will communicate between the flight deck and the cabin;
2. Minimum Equipment List (MEL) relief for the Public Address (PA) system shall not be exercised where communication procedures in normal or emergency situations require the use of these systems;
3. The methods by which the flight crew determine the security of the area near the flight deck door and the identity of a person requesting access whenever there is a requirement to open the door (e.g. the use of peep holes, code words, interphone, etc.);
4. Procedures shall be developed with an aim to minimize the need to open the flight deck door during flight;
5. Procedures shall consider pilot incapacitation for the following situations:

1. Both pilots are in the flight deck and one pilot becomes incapacitated; and

2. One pilot is out of the flight deck and the pilot remaining at the controls becomes incapacitated. For aeroplane not equipped with a means to access the flight deck from the passenger compartment, such as a key pad, a third crew member must be brought into the flight deck prior to the pilot leaving in order to protect access to the flight deck in the event of incapacitation of the remaining pilot.

Additionally the following considerations for security should be made when developing procedures:

1. Primary and secondary methods of communicating with the flight deck;
2. Methods of communication to advise the flight deck when access is required (e.g. chimes, knocks, interphone, etc.);
3. Security enhanced crew briefings to include a review of normal and emergency procedures to be used for flight deck access.
4. Limiting Access to the area in the immediate vicinity of flight deck door;
5. Emphasise use of the flight deck/cabin interphone as the primary method of communication;
6. Promote the use of seat belts during flight to help monitor passenger activity and to keep aisles clear;
7. Promote an increase in cabin supervision as a means to observe suspicious passenger behaviour;
8. Passenger management to minimize congestion at lavatories located near the flight deck;
9. Provide a clear area around the flight deck entrance when pilots leave or enter the flight deck;
10. Maximize flight attendant view of the flight deck door area when feasible in the course of its duties;
11. Promote the use of the forward lavatory by the flight crew whenever it is practicable; and
12. Minimize passenger view of the flight deck entrance area by use of curtains.

Company Manuals and Training Programs. All applicable air operator documents, such as manuals and training programs, must be amended to reflect the new procedures and submitted to Transport Canada, for approval prior to April 9, 2003.

MASTER MINIMUM EQUIPMENT LIST (MMEL) CHANGES. Global Change 5 to the MMEL incorporated the need for enhanced security requirements, which are compatible with the requirements of FAA policy letters 9, 24 and 83. The changes affect the following systems.

• 23.8 Crew Member Interphone System
• 23.9 Passenger Address System
• 23.10 Handsets
• 23.11 Alerting System
• 26.8 Lavatory Fire Extinguisher Systems
• 26.9 Lavatory Smoke Detection Systems
• 38.1 Potable Water Systems
• 38.2 Lavatory Waste Systems

Further information on Global Changes can be found at the following Aircraft Certification Website for MMEL: http://www.tc.gc.ca/CivilAviation/certification/projects/mmel/menu.htm.

An air operator may request MEL relief in order to be able to operate an aeroplane with the remote door locking mechanism inoperative, provided such relief is permitted in the MMEL revision or in the TC supplement. In such cases, procedures similar to the pilot incapacitation procedures shall be required. A third crew member must be brought into the flight deck prior to a pilot leaving in order to protect access to the flight deck when;

1. the remaining pilot is unable to operate the locking mechanism or any other system used to control access to the flight deck from the pilot's position; or
2. the flight deck door cannot be unlocked from the cabin side by use of a keypad or similar device.

Exemptions and Exclusions. DC-3 and Convair 580 aeroplanes have been identified as being initially type certified prior to January 1, 1958 and are therefore excluded from the provisions of Section 705.80 of the CARs. However, those equipped with a door, and a lock, as the case may be, are subject to the requirements of the applicable parts of Sections 705.45 and 705.27 of the CARs.

Hawker Siddeley HS 748 aeroplanes that do not already have a flight deck door have been exempted from some of the provisions of Section 705.80 of the CARs via an exemption valid until April 9, 2003.

HS 748 aeroplanes that are equipped with a flight deck door that cannot be closed while the observer seat is occupied are exempt from the requirements of Section 705.45 of the CARs via an exemption valid until April 9, 2003.

HS 748 aeroplanes will be required to comply with Sections 705.45/705.80 of the CARs no later than April 9, 2003 when new intrusion resistant doors must be installed in all aeroplanes affected by these regulations.

HS 748 aeroplanes that did not have a flight deck door on January 15, 2002 and are operated as an all-cargo aeroplane are not required to comply with Section 705.80 of the CARs.