Cathy Scheu 

Flight Service 

Managing Director Policies, Training and Administration 

February 9, 2015 

Docket Management Facility 

U.S. Department of Transportation 

1200 New Jersey Avenue, SE 

West Building Ground Floor 

Room W12-140 

Washington, DC 20590 

RE: Requested Relieffrom 14 CFR § 121.311(b) 

American Airlines'\... 

American Airlines is writing to request an exemption from 14 CFR § 121.311 (b) to the 

extent required for infants/children traveling on American Airlines to be able to use an 

FAA-approved Child Restraint System (CRS) in an obliquely oriented seat (not forward 

facing) on Boeing 777 and Boeing 787 aircraft during all phases of flight. 

The pertinent section from 14 CFR part 121 Seats, safety belts, and shoulder harnesses 

from which American Airlines seeks relief is: 

§121.311 Seats, safety belts, and shoulder harnesses. 

(b) (2) 

(iii) The certificate holder complies with the following requirements: 

(A) The restraint system must be properly secured to an approved forward-facing seat or 

berth; 

Background: 

Title 14, Code of Federal Regulations (CFR) § 25.785(d) requires that each occupant of a 

seat that makes more than an 18° angle with the vertical plane containing the airplane 

centerline must be protected from head injury by a safety belt and an energy absorbing 

rest that will support the arms, shoulders, head, and spine, or by a safety belt and 

shoulder harness that will prevent the head from contacting any injurious object. This 

provision, adopted in 1969, reflected the FAA's conclusion that a maximum 18-degree 

angle would provide an adequate level of safety based on tests that were performed at 

that time. This requirement clarified the definition of sideward-facing seats. 

4255 Amon Carter Blvd 

MD 4290 

Fort Worth, TX 76155 

817-963-6952 Office 

817-931-9215 Fax 

cathy.scheu@aa.com 
American Airlines"'-.. 

The seating configuration, for the o'blique.:facing premium class passenger seats in Boeing 

model 777 and 787 aircraft operated by American Airlines and approved by the FAA may 

result in up to a maxirnumangle of 28° to the aircraft centerline for the seat occupant. 

Therefore, these.seats are. not forward facing as defined by regulation. An Equivalent 

Level of Safety Finding was made for the following regulations relative to the ZSUS Z938 

model oblique-facing Business Class Passenger Seats on the AA fleetto address the 

classification of this seat model design as forward & aft facing for purposes of meeting 14 

CFR 25.652 & 25.785 requirements. 

14 CFR 121.311 (b)(2)(iii)(A) requires certificate holders to ensure that CRS are properly 

secured to an approved forward-facing seat or berth. Because the oblique-facing 

premium class passenger seats in l3oei.ng rnodel 777-200 :and 787 aircraft operated by 

American Airlines are not forward facing, FAA approved CRS cannot be used in those 

seats. As a result of this, safety is diminished for children traveling with parents in the 

premium cabin in that they would have to be held in the parent's lap. This restriction also 

creates operational challenges in tJ;\e,event of aircraft equipment changes should a parent 

traveling with a child in a CRS have booked a flight on an ·aircraft type that c;illows use of 

CRS in premium cabins. · · · 

Proposal: 

Based on the equivalent level of $afety demonstrated during certification of the ZSUS 

Z938 model seats, American Airlines proposes allow use of CRS in the obliquely oriented 

toward the forward of the cabin seats premium cabin seats. American Airlines does not 

propose allowing CRS in obliquely oriented seats toward the aft of the aircraft. 

Equivalent level of safety to that of the affected regulation: 

American Airlines understands the regulation is written to create a high ievel of safety for 

each individual passenger by ensuring that they are securely restrained in an aircraft 

during all phases of flight.. The regulation also ensures that the operational use of FAA 

approved CRS, only in a forward facing seat, is consistent with the certification basis and 

performance testing·fo'rCRS.·' 

. ' . ~ ' ' -•. . 

This proposal will prOvide an ·eguivalenflevel of safety to that of the affected regulation er\ • ", ·'' • • 

based on the equivalent l~vel'6f safetyju$fifications documented in TAD ELOS 

Memorandum BY31'3~c-Yci~tedMarch.5, 2014.and approved for the Type Design 

certification of the seat designand installation. B1313-C-1 established an ELOS for the 

forward oblique angled seats with respect to occupant injury testing. Specifically, this 

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means of compliance established that the design of the ZSUS:Z938 model forward side-

.facing seats are such that the reactions of the occupant to dynamic loads are the same as 

those for an occupant in a standard facing seat' installed at an angle 18 degrees or less 

from the airplane centerline. STC ST1 0498SC approved compliance to the ELOS for the 

design and installation of these seats on the AA 777-200. · Installation of this mQd_el seat 

on the AA 781-8 was accomplished via a siinil~r ELOS issued to the Boeing 9ompany and 

Type Design approval under TC T00021SE. 

Public Interest: 

Enhancing safety is ih the public interest. All<:>wing use of CRS in obliqu.ely oriented seats 

· enhances the level of safety by allowing~ children under the age of two to be secured in a 

CRS rather than on a parent's lap. · · · 

lfit is necessary to put a·summary of this petition in the Federal Register, we submit the 

·following: ; · .. -. · · .:: 

This is a request for an exemption from FAR 121.311 (b) to the extent required for 

infants/children traveling on American Airlines to be able to use an FAA-approved Child 

Restraint System (CRS) in a obliquely oriented seat (not forward facing) on Boeing 777 

and Boeing 787 aircraft during all phases of flight. 

sfncerely, 

American 

Ca~~ Airlines 

· · Flight Service .. 

Managing Director Administration, Training and Procedures' · 

Ecc: Calvin R. Lett, Principal Operations Inspector DFW CMO 

Travis G .. Blower, Aviation Safety Inspector DFW CMO 

Thomas J. Rocha, Aviation Safety lnspectpr QlfW CMO, . 

Ronny G. Moon, Aviation Safety lnspe<?tO..~. DFvv.CMO .·· .. 

Hector Adler, Vice Presiaent Flight Se1Vic$' American Airline~ 

Leanne Risley, Sr. Manager Flight Service Safe~y_ and Regulatory American Airlines _.,;. 

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