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Naïve Subject Testing – Suite Emergency Passage Features

Applicants for type design approval are working to support their airline customers by installing passenger suites that include doors between the passenger and exit. To install these doors, an exemption to 25.813(e) is required in which one of the conditions of the exemption is that the applicant must show the emergency passage feature (EPF) is simple and obvious to open. Applicants achieve this showing by completing a naïve subject test. The test method currently being used combines test parameters from the naïve subject test for evacuation specified in Part 25 Appendix J, the naïve subject test for life vest donning specified in TSO-C13, and the naïve subject test for floor proximity markings outlined in AC 25.812-1 and AC 25.812-2a. The test method has several variables involved that are debated amongst regulators and applicants on how they should be controlled. As a result, the test is run inconsistently, and variations in how the test is performed has led to an unlevel playing field amongst applicants, delays in certification testing by seat suppliers, and conflicting design approvals.