2230 Stonebridge Rd West Bend, WI 53095-USA 

1.262.335.8000 Phone 1.262.335.8008 FAX 

EIN: 39-1787963 

Dear Sirs, 

Request for exemption revision 

6/10/2016 

FAA Project No.: Pending project number-FAA Chicago 

Re.: 14 CFR 25.562 and 25.785(b), Exemption revision to allow Aero Medical Products Mfg., Inc to install a 

medical/Divan-patient litter assemblies per report 006 into part 25,23,27,29 aircraft. 

Aero Medical Products Mfg., Inc hereby petitions for an exemption revision to Exemption No.10862 from 

25.562 and part of 25.785(b) of Title 14, Code of Federal Regulations ( 14 CFR) to the extent necessary to 

permit installation of a medical/Divan-patient litter assemblies, for transport of persons whose medical 

condition dictates such accommodations as well as regular passengers sitting in a side facing position as is 

already authorized by the FAA STC Report 006 Dwg 901-2 (see attached authorized drawing list) "EXHIBIT 

A". 

Specific sections of 14 CFR from which relief is sought 

Restriction on Exemption No. 10862 Docket no FAA-2013-0582 (Sept 5, 2013) needs to be removed as 

there is no basis for the restriction namely: "Occupancy is limited to non-ambulatory persons". 

What about these people? 

1. A person could just not feel good and wants to lie down. 

2. A person with a broken leg is ambulatory 

3. A person with lupus 

4. Other illness are ambulatory as well. 

5. A healthy person want to take a nap (grandpa or grandma) long day. 

6. A child with cancer 

7. Etc 

The present restriction on the exemption creates undue burden on those that are sick but ambulatory. It further 

creates restriction to American health care in a reasonable time frame. 

The Aero Medical Products Mfg Inc litter/divan aka the "Medstar" can hold a vertical force of (over 1000#) or 

say a pick up truck up while you change the oil. There is no reason to restrict it's use as a medical divan for all 

that wish to use it no matter the reason and not allow it to be used as a side facing seat just like all the other 

exempt side facing seats. 

Section 25.785(b) at amendment 25-88, requires that each seat, berth, safety belt, harness and adjacent part of 

the airplane at each station designated as occupyable during takeoff and landing must be designed so that a 

person making proper use of those facilities will not suffer serious injury in an emergency landing as a result of 

the inertia forces specified in 25.561 and 25.562. 

Section 25.562 specifies dynamic test conditions for qualification of occupant injury, as well as structural 

retention criteria. 

Extent of relief, and reason 

Aero Medical Products Mfg., Inc owns supplemental type certificates (STCs) for numerous 14 CFR part 25, 

23, 27 and 29 airplanes for litter/divan installation under report 006. The side facing three person seat was 
authorized in a Lear 35 in 1992 (see STC ST 13CH) "EXHIBIT B". The certification requirements for those 

airplanes have resulted in good service history with no adverse experience. No medical-patient loading and 

utility system installations have been shown to meet the dynamic criteria in any aircraft. 14 CFR parts 23,27, 

and 29 specifically exclude stretcher litters from the dynamic criteria. 

Aero Medical Products Mfg., Inc notes that the estimated cost of demonstrating compliance is extremely high 

considering the limited number of units for which the cost could be amortized. Since none have been shown to 

comply with the dynamic test criteria, stretchers cannot currently be used on airplanes whose type certificate 

basis includes the dynamic requirements. In this case, a person who needs to travel for essential medical care 

can either charter an airplane, at 5 to 10 times the cost of a commercial ticket, or if the cost is prohibitive, fail to 

receive the needed treatment (the consequences of which may be fatal). Another alternative would be flying an 

alternate route on an airplanes, the certification basis for which does not require dynamic testing. This would 

offer no increase in safety and may not be available. 

Why granting this request would be in the public interest; how it benefits the public as a whole 

Aero Medical Products Mfg., Inc feels that granting the petition would be in the public interest for the following 

reasons: 

• 

• 

• 

The exemption would relieve an economic burden on a segment of the traveling public already dealing 

with adversity, 

The level of safety that would be provided is an acceptable level of safety given the limited usage and 

exposure of the stretcher/divan, 

Compliance with the dynamic test requirements would be difficult at best, and very expensive, while 

returning a marginal safety benefit. In addition, 14 CFR 25.562 is written for seats and would not be 

easily applied to a litter/divan. 

Why granting the exemption would not adversely affect safety, or how the exemption would provide a 

level of safety at least equal to that provided by the rule from which exemption is sought. 

• Compliance with the dynamic test requirements would be difficult at best, and very expensive, while 

returning a marginal safety benefit. In addition, 14 CFR 25.562 is written for seats and would not be 

easily applied to a litter/divan 

Request to forego summary-notice publication in the Federal Register for public comment 

Aero Medical Products Mfg., Inc also requests that the FAA waive publication and public comment for good 

cause. 

A delay in acting on the petition would be detrimental to Aero Medical Products Mfg., Inc as well as delaying 

the deployment of lifesaving equipment. 

Additional information, views, or arguments supporting this request 

This petition is consistent with Exemption No. 6625, 6920, 7318 and 7393, which were granted for LifePort 

litter installations in Cessna 750 (Citation X), Falcon 2000, Cessna Citation 560XL and Learjet 45, respectively. 

Operation outside the United States 

This exemption is intended for operation inside and outside the US as many people travel outside the US 

because we are a Global society seeking business with the world. The BBJ aircraft is a global type aircraft. 

~~~ ~/ ~? Pful M~ Egan:XEO 

Aero Medical Products Mfg., Inc 

2230 Stonebridge Rd 

West Bend, WI 53095 

1-262-335-8000 

Cell: 1-262-305-4247 
Hnittd ,Sratv...s of :lm!rica 

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~upplcmcntel ~~pc O:crtificatc 

Aero Medica: ?roduc:s Mfg. _nc. 

-±31-± >!aple Road 

:·,res:: 3end, ~·;r 5309:5 

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AERO MEDICAL PRODuCTS M>=G_ INC. 

DRAWING LIST 

REPORT OiJo 

8/28/92 

R:;;vis1or. (E)- !/5r 1 

Tit!e Date 

composite stretcl1sr assembly 135 

comoosite stretcher assembly 

composite stretcher assarrblj 

oxy-divan construction detail 

stretcher assemoly 

ccmponer., layout 

:::orstn.:ction layout stretcher oox -:: 

drawer asserdy 

sectional views 

.::cnstruction !ayc:ut Si:r-9rd"'e~ ::o:< 

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'l.andle plate ·rstal. 

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.Jxygen asse'1lbly 2 :2r~ ... ,.s 

fa~con 6C erd plate 

s!ngle cylirder irOtCet cic~e 

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