FAA Project No.: Pending project number-FAA Chicago

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

to install a medical-patient litter assemblies per report 006 in a Gulfstream G-IV-X, G-V, 

G-VI series airplanes.

Aero Medical Products Mfg., Inc hereby petitions for an exemption 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-patient litter assemblies, for transport of persons whose 

medical condition dictates such accommodations, on Gulfstream Model G-IV-X, G-V, GVI series airplanes.

Specific sections of 14 CFR from which relief is sought

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 occupiable 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 the 

Gulfstream I, II, III, IV and for numerous 14 CFR part 25, 23, 27 and 29 airplanes. 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. 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 quite high considering the limited number of unites 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,

 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.

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

As noted above, the level of safety is acceptable given the limited usage and exposure of 

the stretcher and service history (no unsafe conditions) associated with Aero Medical 

Products Mfg., Inc stretcher installations.

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.

Aero Medical Products Mfg., Inc applied for the STC in June, 2013 and has 

commitments requiring an STC by Sept 2013. 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. In this case, the intent for the exemption is 

for non-ambulatory persons. Aero Medical Products Mfg., Inc recommends that this 

intent be covered by:

 a limitation in the Flight Manual Supplement, and

 a conspicuously located placard that states that occupancy of the stretcher litter 

during takeoff and landing is for non-ambulatory persons only.

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 

Gulfstream aircraft is a global type aircraft.

Paul M. Egan, CEO

Aero Medical Products Mfg., Inc

2230 Stonebridge Rd

West Bend, WI 53095

1-262-335-8000

Cell: 1-262-305-4247