### Exemption No. 9793B

UNITED STATES OF AMERICA



# , DEPARTMENT OF TRANSPORTATION
, 

### FEDERAL AVIATION ADMINISTRATION RENTON, WASHINGTOt 98057-3356

Inthe matter ofthe petition of THE BOEING COMPANY for anexemption from §§ 25.783(g), 25.807(a)(I), 25.809(a), and 25.813(a) of Title 14,Code ofFederal Regulations Regulatory Docket No. FAA-2008·0348

PARTIAL GRANT OF EXEMPTION Byletter BDCO·1 0·03041, dated July 20, 2010, C. ~. Thompson, Lead Project Administrator, Development Projects, The Boeing qompany, PO Box 3707, Seattle, Washington, 98124-2207, petitioned the Federal Aviation Administration (FAA) for an amendment to Exemption No. 9793A. Ifgranted, tHisamendment would permit additional relief from the requirements of §§ 25.783(g), 25.807(a)(1), 25.809(a), and 25.813(a) ofTitle 14,Code ofFederal Regulations (114 CFR). Also, Boeing requested that Limitation 16ofExemption No. 9793A be revised, to allow the optional escape slide atthe crew service door to partially block the clear Jrojected exit opening. Currently, this limitation requires a clear projected open access to ¢e crew service door. The current exemption (9793A) is apartial grant which permits ihe carriage of six non-crewmembers (commonly referred to as supernumeraries) in acorripartmcnt behind the flight deck on Boeing Model 747-8F airplanes and allows in-flightlaccess to the class Ecargo compartment bythese supernumeraries, with certain limitations. This proposed amendment would allow the crew service door to

# b9-a Type UIexit and permit alimited viewing area where evacuees would make first contact with the ground when using the crew service door. This proposed amendment would also change current Limitation No. 16to aHowthe crew service door escape slide trpartially block the opening to the exit.

### The petitioner requests relief from the following regulations: Section 25.783(g), at Amendment 25-23, each passenger entry door in the side of 

# , the fuselage must qualify as aType A, Type I, orType ITpassenger emergency exit and must meet the requirements ofSecdons 25.807 through 25.813 that apply to that type ofpassenger emergency exit. Section 25.807(a)(I), at Amendment 25M61~ provides requirements for type and location ofemergency exits. For the purposJ ofthis part, the types and locations ofexits are as follows: (1) Type I. This Ty~e must have arectangular opening of not less than 24 inches wide by 48 inches hidh, with comer radii not greater than one-third the width ofthe exit. Type Iexits must be floor-level exits. Section 25.809(a), at Amendment 25-116, each emergency exit, including each flightcrew emergency exit, must be amovable door orhatch inthe external walls ofthe fuselage, allowing an unobstructed op~ning tothe outside. In addition, 'each emergency exit must have means topermit ¥iewing ofthe conditions outside the exit when the exit is closed. Means must als:obe provided to permit viewing of the likely areas ofevacuee ground contact. The likely areas ofevacuee ground contact must be viewable during all lighting :conditions with the landing gear extended as well as in all conditions oflanding gear collapse. Section 25.813(a), at Amendment 25-46, rlquires apassageway between individual passenger areas, and leading from!each aisle to each Type Iand Type II emergency exit. These passageways must bJ unobstructed and at least 20~inches wide.

Related sections of 14 CFR Section 121.583(a) contains, inpertinent p~, a listing ofcategories ofpersons who may be carried aboard an airplane in part 121 service without complying with all the requirements ofpart 121pertaining td carriage ofpassengers. The petitioner snpports its reqnest with the fOllO~inginformation: The pertinent parts ofBoeing',s petition are quoted oelow, with minor editorial changes for clarity. The complete petition is available on-lirle at regulations_gov under docket number FAA-2008-0348.

2The extent ofrelief being sought 

# I Re!!:ulation Reauires: Relief isnecessnrv because: 14CFR25.783 (g) The crew door Main deck!Door I LH is aType A size door without any evacuation Amendment 23 and Door I LH assist meahs and thus does not meet this regulation. This is 

## , tobe considered unchanged from the 747-400F design. The configuration ofthe upper entry doors and deck 

### crewldoor does not meet all Type Iexit requirements in section , 

### thus would need ]4 CFR 2~.807 through 14CFR 25.813 allhough the fuselage cutout to be aType A, meets the fype I exit dimensions. Some 

### ofthe requirements not met lor IIexit. are covered inExemption No. 9793/9793A forthe 747-Sf; however

the ExemJtion 9793/9793A does not provide relief from this requiremeht to provide aType A, 1,or II size exit. 14eFR The crew door The crew {loorcan no longer be considered a Type Ifloor~level exit 25.807(a)(I) as a Type 1exit due to astep-up to the exit when the airplane isconfigured with inertia Amendment 67 to be a floor~ reels as th

# r only evacuation means. A previously granted Exemption level exit. No. 9735 has acknowledged this same condition on the 747-400F and

considered the ratiJw ofthe exit as aTvne III. 14eFR 25.809(a) The crew door The provided viewing window on the crew door is not capable of Amendment I16 as an viewing the evacuee ground contact area inall combinations of gear

emergency exit collapse for either evacuation means prior to the exit being opened. to have a means The configuration ofthe 747·8F airplane includes exterior bodyto view the mounted lights which will meet the requirement for lighting for both evacuee ground . 

# ,

evacuatlOl means. contact area in ,II A similar grant ofExemption No. 9696 was extended for the 767~ combinations of 300BCF biasedonthe exit porthole combined with inertia reel assist gear collapse. means, si1 person occupancy, and additional crew procedures which

will be drawn upon for the 747-8F. 14CFR25.813(a) The crew door The passageway to the exit is Jessthan 20-inches with the manually Amendment 46 as aType Iexit deployed slide installed inthe 747-8F interior configuration. As a

to have a20- customer selectable option, the 747-400F manually-deployed escape inch slide atthe crew door has been selected by amajority (5 of6) 0[747- passageway 8F airline 'customers as an additional evacuation means at that

location

. .klthough the interior configuration for the 747-8F is changed from the 747-400F, asimilar condition exist on the 747- 400F. 

# I Limitation 16 from The crew door The interior configuration ofthe 747-8F does not allow the escape Exemption 9793A escape slide be slide tobelmoved far enough aftto directly comply with the labeled with requiremert to "clear" the projected opening. However, the design instructions to and configuration ofthe 747-8F does allow the slide to be moved aft move the escape to allow outside access byrescue personnel which will be slide aft to clear demonstdted. Thus the Limitation could instead require the crew the projected door be s~own to allow access into the airplane from the outside by opening oftbe rescue personnel. Limitation 16 isto address a concern in Exemption exit 9793A thAt "the escape slide ispartially blocking the access to the

airplane J,hen the crew service door isopenedfroln the outside, which mafprevent rescue personnel from rapidly el1/ering the airplane 

## ij1 an emergency ... This concern can be addressed without fully clearing the projected door opening. There isnl similar requirement in Exemption series 1870 for this similar cohfiguration and condition on the 747-200F/400F airplanes which ha~e aproven safetYrecord.



### 3Description ofthe Issue The Model 747-SF is aderivative aircraft based onthe 747-400F. The fuselage ofthe 747-SF is 220" longer than the 747-400F. The 747-8F emergenty exits, crew door window, exterior body· mounted light for the escape slide, and the escape me~s are identical to the 747-400F with the exception that the escape slide is acustomer selectable option on the 747-SF where as itwas basic on the 747-400F. For the 747-8F, the escape slide hakbeen selected by a majority (5 of6) ofthe airline customers as the evacuation means atthe creW[door. Like the 747-400F, the 747,-8Fhas arequired flightcrflw oftwo (2) and is allowed the carriage of up to six (6) supernumeraries. Like the 747·400F and its predecessors, the 747-SF airplane flight manual (AFM) wiUlimit the airplane to eight (8) occ~pants. The eight (8) inenia reel descent devices located on the flight deck are identical inpart1number and location to the 747·400F and will be included on all 747~8F airplanes, with one for[each airplane occupant to use either through the crew door or from the flight deck overhead exit. Additionally, there are eight (8) harnesses installed basic inthe 747-8F supernumerary seating ateas, two (2) more than the 747-400F, one for each occupant to don and connect to their descent device before evacuating the airplane. The optional manually-deployed escape slide is attached to aplatform that moves fore and aft on rails inside ofthe upper deck crew door. When the escape slide isdeployed through the crew door, the forward side oftbeplatfonn is stationary and remains inthe interior creating the boundary to the passageway out the exit. The escape 'slide system also has a flexible, non· inflatable, chute hinged to the platform to assist as aguide in slide deployment. This chute also remains in the interior creating aboundary to the passageway out the exit. \¥hen the optional escape slide is installed the 20~inch passageway leadihg to the exit isnot maintained from the slide platform to the interior monument, nor isthe escape slide chute itself20+inches. The current design on the 747-8F provides the capability to move the escape slide aft providing access for rescue personnel with instructions that are affixed to the outboard side ofthe slide pack such that they can be seen when the door isopened from the outside. The ability to gain access, including the effectiveness ofthe instructions, will be;demonstrated by rescue personnel in accordance with Exemption 9793A Limitation 16. A new body-mounted exterior light was added to the V47-SF. This new light illuminates the ground contact area ofthe inertia reels, inall combin~tions ofgear collapse, before and after door opening. The existing exterior body-mounted light illuminates the ground contact area ofthe 

# , escape slide, inall combinations of gear collapse wh~n the slide is usable, before and after door opening. Both exterior lights will be installed on all ~irplanes regardless of evacuation means selected by the customer. These lights are activated 

### QI) automatically upon loss ofmain electrical power (28 VDC bus) when the system is armed, or (2) manually via the emergency light switches located on the flight deck or inthe supernumerary seating area. Statement of No Adverse Erfect on Safety The petitioner strives to provide acceptable safety conditions such that 747-8F cargo operators can safely operate their airplanes with evacuation means ~ndprocedures consistent with the current fleet. The majority (5 of6) ofthe airline customers t~at have purchased the 747-8F also operate fleets of earlier model 747 freighters, including the 747-400F. The surest, safest, and most cost effective manner ofoperating these cargo aircraft is t9 have consistent' airplane designs and cre-w/supernumerary training \vith respect to evacuatibn safety features ofthe airplane. A grant of exemption will result inconsistent operator's procedures for evacuation ofthe 747·8F with the 747--400F fleet when the escape slide isinstalled and!similar to other airplane models with only inertia reels installed, thus enhancing safety.



### 4Granting the exemption to 

### §25.783(g) atAmendment 23 for Door 1 LH and the upper deck crew door will not have an appreciable affect on safety bas~d upon the following factors which are summarized here and discussed as necessary inmore ~etail below: o Limited number oftrained supernumeraries o Specific to Door I LH, while it will be used for entry itwill not be marked with any exit signs visible from the upperdeck supernumerary seating area a Specific to the crew door, while it is sized asia Type Idoor, itwill not practically be used as an entry door due to it's location on the upper deck approximately 26 feet above the ground. a The crew door will be marked with exit signs visible from the upperdeck supernumerary seating area and have appropriate evacuation means available atthe exit. Previously the FAA recognized in Exemption No. 4808 for the 757·200PF "The intent of 14 CFR 

### 25.783(g) isto ensure that the door through which pdop!e enter an airplane is also useable as an emergency exit." "Because ofthe hetter trained, ope~ator-approved, sma/! number of 110llcrewmembers allowed in theflight deck, the FAA Y1ndsthat the entlY doorprovided in the Model 757-200PF can safety be used as an emergency exit and that the requirements that the entry door be a TypeA, lor 11is unnecessary." Although the 747-8F has a different configuration than the 757·200PF, the circumstances are similar intraining and small number ofnon-crew members. The personnel (maximum of8) aboard the'747·8F are required to be briefed by the flightcrew prior to each flight on the use ofthe exits in accordance with Exemption No. 9793/9793A. This additional level ofknowledge afforded to these occupants when compared to the nonnal passenger provides an enhancement in eV3;Cuation nonnally afforded. Door 1 LH will be used as the entry door on the 747-SF however itwill not beused as the emergency exit. It will be out ofsight and no exit signs will lead personnel to Door I LH once the supernumeraries have taken their seats in the upper deck thus itis unnecessarY to make ita useable emergency exit with evacuation means as other exits will be available, app~opriately marked, and equipped with the evacuation means (same as previous 747 Freighter rn6dels). Granting the Exemption to §25.807(a)(1) atAmendment 67 and §25.813(a) atAmendment 46 for the non-fioor-Ievel exit and less than 20-inch passageway, respectively, atthe upper deck crew door will not have an appreciable affect on safety bas~d upon the following factors, which are summarized here and discussed as necessary in more detail below: a Limited number oftrained supernumeraries (see discussion, above) a Consideration ofthe crew door rating similar to aType III exit with a 19 inch passageway being maintained o asmall step-up ofapproxImately 8 Inches 

# J Per §25 807(c)(1) atAmendment 67, apair ofType eXItswould allow 40-79 passengers, while a pair ofType III exits would be sufficient for between ~Oand 39 occupants. In combination with the flight deck overhead exit, having the 747·8F airpl~ne configured with aType I size cut out and nearly meeting the Type Ipassageway requirements, +hile only needing to provide evacuation capability for 8 occupants, the overall design isconsidered sufficiently safe. While a20-inch passageway is required for a Type IJized exit, the crew door can be considered, based on lhe number ofpassengers being evacuated, iimilar to a Type III exit. The applicable regulations, §25.813(c)(1 )(2) at Amendment 46, do

# riot specify apassageway requirement for Type III exits rather only that tlle projected opening ~ay not be obstructed and there may be no interference in opening the exit Considering the 747

## 18F crew door as similar to aType 1IIexit, with amethod of compliance associated with the projected opening by providing a 19-inch passageway atthe crew door and no obstruction inopbning the exit, is sufficiently safe for the 8 occupants. A step-up of20-inches is allowed for atype 1IIexit. The 747-8F step-up when the escape slide isnot installed is approximately 8inchcsJand there isno step-up when both the inenia reels and slide are installed. The FAA recognized asimilar condition in Exemption No. 9735 for



### 5the 747-400F "
...have a crew service door the size ofia Type I exit, but because the door has a step-up inside the airplane itis raled as a Type III exit and is available/or evacuation." Granting the exemption to §25.809(a) atAmendmenJ25-116 will not adversely affect safety based upon the following factors, which are summarized here and discussed inmore detail below; o Flight deck and supernumerary windows o Crew awareness a Manually-deployed escape slide and inertia reels o Exit height a Exterior body-moWlted lights Itisunderstood §25.809(a) atAmendment 25-116 was codified to address the potential for a crew member or supemOmerary to mistakenly open or use an emergency exit when there is an external hazard (such as a fire, water or terrain/obstacles) that isnot visible (due to lack ofmeans to view outside and/or from inadequate lighting) that could pqse an immediate threat to the occupants of the airplane, damage the evacuation means, pose a threat to personnel using the evacuation means, and/or delay the evacuation. Previous industry design practice has provided outside viewing means (windows) instaJJed on or adjacent to the passenger emergency exits in the majority ofcases. Additionally, the large flight deck windows provide ameans to view the surroWldil/g area by the flightcrew as the airplane ison approach. These windows have proven an effective means for quickly assessing conditions outside the emergency exit prior to the emergency exit being opened in order to avoid delay in opening the emergency exits and initiating the evacuation. In addition to the flight deck windows, awindow IslnstaHed in the crew door ofthe 747-8F. Additionally, the 747-8F includes three standard passenger sized windows (for the supernumeraries) on the right and left hand side ofthJ airplane aft ofthe crew door and located in the supernumerary compartment. One window (each side) is located inthe crew bunk area ofthe supernumerary compartment. 

# I
All windows provide a view ofthe surrounding area with the airplane resting on all landing gear. Once the airplane has slowed to a stop, viewing ofalliofthe likely areas of evacuee ground contact prior tothe exit being opened will not be fullypossible since they are directly beneath the aircraft when inertia reels are used. However, a view ofthe surrounding area as the airplane comes to a stop as well as the surrounding view from the flight deck and supernumerary windows once stopped provides the ability to make assessments andlappropriate evacuation decisions as follows: a In most cases, the presence ofa rue in the vicinity ofthe flight deck windows and crew door large enough to be ahazard ifthe exit i~ opened would be readily and easily recognizable bythe tlightcrew as the alrplank slows to astop. Inthese cases, the flightcrew would command evacuation frOmjthe appropriate exit.

o Recalling, the supemwneraries are required .0 bebriefed inthc use Qfthe exits, the presence of afire prwater inthe surrounding area ofthe crew door largc enough to be a hazard would likely be recognized by the su~emumeraries from windows inthe supemWllerary area, in conjunction with thefody-mounted lights as necessary, and could be communicated,to the flightcrcw when detennining which exit to utilize. Itis understood 14eFR 25.809(a) atAmendment 25jI 16is also to prevent the deployment of an escape slide into a hazard, since this deployment is in;eversible, and door re-closure is necessarily impeded by the deployed slide due to its interface with floor structure immediately inboard ofthe door sill. In the case ofthe 747-8F, the evacuation mbans ismanually-deployed after the emergency exit isopened. Ifa hazard such as fire, water, or terrain isdetected near the crew door, after the-door isopened, the door may be easily closet! again because the manually deploy passenger escape slide or inertia reels would not be irlthe way ofthe door mechanism.


### 6The location ofthe emergency exit is approximately 113.5 feet above the water line in the unplanned ditching scenario, which isworst case. Thb crew door is farenough above the water level after aditching event such that iftbis emergencY:exit were to be opened without first assessing outside conditions itcould easily and quickly be re-c1osed without consequence. Additionally the 747·8F airplane isconfigured with bpdy-mounted lights (reference Figure 5) providing the illumination in dark ofnight conditions ~oassess the surrounding area prior to emergency exit opening. After emergency exit openif).gand before evacuating through the exit, making an assessment ofsafety to evacuate can be dohe by viewing out the open exit utilizing the body-mounted exterior lights, which will fully illuminate the ground contact area ofboth evacuation means before those means are deployed. While ameans that provides viewing ofthe evacuee ground contact area for all combinations of gear collapse does not exist for the crew door when equipped with inertia reels or manuallydeployed escape slides, the airplane design provides ~nacceptable level of safety as noted above. Similar conditions were recognized and accepted by the FAA in Exemption No. 9696 forthe 767-300BCF. "We agree in this specific case with thepetilioner's rationale that in most cases the presence ofafire in the vicinity olthe fejihandjlight 'deckwindow and Door fLwould be recognizable by theflight deck crew, ... " "Because t~e assist means isan inertia reel, the evacuee has a bit more control over the landing zone ... " Similar to the inertia reels, there is also control over the deployment of the optional escape slide for the 747-8 and rationale for no adverse affect on safety for the optional slide inrelation to 

### §25.809(a) is contained herein. Limitation 16 1lisproposed that the FAA accept an adequate opening to allow access from outside the airplane atthe crew door by providing relief fTOm Limitation 

### ~6

ofExemption No. 9793A which requires in part, "Fa/"airplanes with the optional escape slide installed ai/he crew door Boeing must develop 

## , instructions/or moving the escape slide aft to clear theprojected opening a/the exitfrom outside Ih, ailp/m".

.. 

# l

Exemption 9793A noled aconcern that "the escape Slide ispartially blocking the access to the ai/plane when the crew service door isopenedfrom the outside, which mayprevent rescue persol1nelFom rapidly entering the airplane in an e~ergency." An acceptable level ofsafety can be maintained without the specific requirement to fully clear the projected opening afthe exit based on:

o providing adequate access far rescue personnel from outside the airplane o rescue personnel procedures 

# I
o maintaining all ofthe otber aspects of LimiTion 16. The exit maintains the physical structural cutout of a

### Type Iexit as well as the function ofbeing openable from the outside allowing entry into the airp;Iane. Ifthe slide has not been deployed, then the rescue personnel can move the slide pack aft by f6110wingthe instructional placards added to the outboard ofthe slide pack, thus providing an entrYway. 

# I In the nose down adverse attitudes, the 747-8F slide does not have a detent on the track for itto lock in the full open position. The force to move the ~lide is less than 30 pounds which iswithin the capability ofrescue personnel. Safety is maintained because the requirements ofLi~itation 16provide an increase insafety as compared to the 747-400F by including instructions for rescue personnel inthe type design (via placarding) inaddition to including instructions inthJ rescue and fire fighting procedures.



### 7Proposed Revision to Limitation 16 Request to Revise Limitation 16: Boeing hereby re!uests the FAA revise Limitation 16to remove the "clear opening" requirement. Boeing proposed wording. "For airplanes ",'iththe optional escape slide instaf/ed atthe crew door Boei1g must develop instructions for moving the escape slide aft toprovide an entrywav sufflcient to allow access into the airplane (or the purposes ofrescuing occupantsfrom the outside. These instructions must be added to the outboard side ofrhe escape slide assembly so that rescue personnel can read the instructions and move the escape slide out o/the way. These instructions must be demonstrated to be effective/or rescue personnel. " Statement of Public Interest The public interest will he advanced by the grant oftliis exemption as itis inthe best economic interest ofthe United States. Increased sales ofairplahes contribute to the balance~of-trade, the gross domestic product and economic health ofthe U?ited States. Marketability ofthe 747-8F is improved, leading to increased sales, by keeping the sales price and operating cost ofthe 747-8F down while providing flexibility to the airlines ina choice ofevacuation means. Purchase prices could increase due to extensive design changes associated with providing fully compliant designs for both 'evacuation means which would be necessary to allow the operational flexibility inevacuation means. Design changes likely to be necessary include: o New escape slide o Revisions to provide for a floor~level exit for operators who select only the inertia reels o Means to view the evacuee ground contact area for both the inertia reel and escape slide o Changes to the door structure and/or door mechanisms a Interior configuration changes to allow the escape slide to be moved further aft to fully clear the projected opening ofthe exit Operating costs are kept down by: o Having common training and operating procfdures with the 747 Freighter Fleet when the escape slide isinstalled while avoiding the cpst ofmaintaining different material inthe training, maintenance, dispatch and operations manuals forthe 747-8F and 747-400F. Every 747-400F delivered from Boeing wasiequipped with an escape slide installed in a similar interior configuration, awindow inthe crew door, and an exterior body-mounted light to illuminate the evacuee ground contact area ofthe escape slide. The majority (4 of6) ofthe airline customers that have pu~chased the 747-8F also operate fleets of , earlier model 747 Freighters and will have t~e escape slides installed ontheir 747-8F, same as the 747-400F. 

# I
o Common training and operating procedures to other freighter models for those airlines selecting only the inertia reels as the evacuafion means. o Having common escape slide spares with existing 747 Freighter tleets_ o Avoiding the weight and fuel penalty and sy~tem maintenance costs including any economic penalties associated with flight delays that would otherwise berealized by the required design changes as noted above in tHepurchase price impacts. o Weight and fuel benefits foroperators chooding the inertia reels as the evacuation means Lower purchase and operating costs will help maintai~j cargo shipping rates aboard freighter airplanes attheir current levels, which benefits the U{ economy as awhole. A grant ofexemption, as requested inthis petition, isJinthe best interest ofthe travelling public through introduction ofthis new product into the marketplace that has advanced the cenification basis inmany areas as compared to the 747-400F. EJabling common operating procedures for evacuation not onIymaintains purchase price and opdrating cost as noted above, bllt avoids the potential for human error, which may be introduced \~hen procedures vary for similar products. 

## 8For the reasons noted above, it isthe petitioner's opinion that the overall level ofsafety is improved by comparison to the previous 747 freighte~ models that are certified with similar configurations and evacuation systems and safety ismaintained which is inthe public's best interest. Privileges ofthis Exemption Outside the United States Per 14CFR I1.81(h), Boeing requests that the privileges ofthis exemption be extended outside the United States. This extension ofprivileges is necessary for operations based within foreign countries having bilateral agreements with the UnitedlStates accepting FAA 14CFR part 25 as their airworthiness standards for transport category aircraft. The 747-8F is intended for the global market place. Conclusion The 747-8F maintains the level ofsafety previously afforded on the 747 freighter series from an exit rating and evacuation systems standpoint. The 35 year service history ofthe 747F series has proven its safety. Granting'relieffTom §25.783(g) at Amendment 23, 

### § 25.807(a)(l) at Amendment 67, and §25.809(a) atAmendment 1]6 fpr the 747-8F model isjustified based on this exit meeting the pertinent aspects ofthe Type [exit and considering that itwill only beused by a limited number oftrained and capable occupants. Gr~nting relief from §25.809(a) at Amendment 116for the 747-8F model isjustified based on the capability ofthe airplane to provide safe evacuation means including illumination. Granting the revision to Limitation 16isjustified based onproviding adequate access by rescue personnel from outside the airplane and maintaining all ofthe other aspects ofLimitation 16. If Limitation 16isrevised the crew door will maintain ab effective opening adequate for rescue personnel to enter from outside the airplane ifnecess¥y.



### Federal Register publication, A summary ofthis petition wds published in the Federal Register on July 20, 2010 (75 FR42187). No comments were received. The FAA's analysis We have reviewed the design ofthe crew service dopr and the installation ofthe optional escape slide on the 747-8F. We agree with Boeing tpat the basic design ofthe crew service door on the 747-8F isthe same as the 747-4~OF and other earlier model 747 freighter airplanes. The baseline 747 airplane has aiitep-up of 8inches from the floor of the airplane tothe exit. Section 25.783(g) requires trat each passenger entry door in the side ofthe fuselage be aType A, Type I,orType II~assenger emergency exit. Also, §25.807 requires that all Type A and Type Iexits be floor-level and that Type IIexits not located over the wing be floor-level. Wedo not agrbe with the Boeing statement that
"
...there isno step-up when both the inertia reels an~ slide are installed." \\!hen the escape slide isinstalled and itis deployed there is atamp section from the floor ofthe airplane tothe point where the evacuee wouldjump!onto the escape slide. The ramp section makes itappear that there isnot a step-up to the exit. However, when the escape



## 9

### slide is slid aft (not deployed) there is a step-up to tlieexit. We agree with Boeing that

Exemption No. 9735 identified this issue with the c+w service door step-up and that the exit does qualify for aType IIIexit rating. HoweveI1,Exemption No. 9735 did not specifically address the issue that each passenger entry door inthe side ofthe fuselage must be aType A, Type I,orType IIfloor-level exit~ For the 747-SFand all earlier model 747 freighters, !he normal route for the flightcrew and the supernumeraries to enter the airplane isusing door 1 left located on the main deck ofthe airplane. Since the supernumeraries are trained and receive apre-flight briefing concerning the evacuation means for the exit, we agfee that it isnot necessary for the airplane entry door to be available as an emergency ~xit. Regarding Boeing's discussion on the acceptability bfthe access to the crew service door, we do not agree with the statement about the numbet ofexits required. Boeing states "a pair ofType Iexits would allow 40-79 passengers, J.,hile apair ofType 

## m exits would be sufficient forbetween 20 and 39 occupants." The r~quirements forthe type and number ofexits required forthe 747-8F are found in §25.80:7(c)(I), Amendment 25-67. For a passenger capacity of20 through 39 there must be at least one Type II and one Type III exit ineach side ofthe fuselage. For apassenger capacity of40 through 79 there must be atleast one Type Iand one Type IIIexit in each side!ofthe fuselage. The access to the crew service door is a 19-inch-wide passageway with an 8-inch step-up atthe exit. This access ismuch better than what is rbquired for aType IIIexit with less than 9 passengers. We agree that for this airplane cdnfiguration and passenger capacity this access is acceptable. We agree with Boeing that viewing the external con;:Iitionsbefore opening the crew service door is not possible fat all cases oflanding gear collapse. When using inertia reels out the crew service doo~the location where thf evacuee is likely to make contact with the ground is directly below the exit. TherefoTlt,the location isnot visible with the viewing window provided onthis exit. We agree w~tbBoeing that the design ofthe airplane and location ofthe crew service door effectively eliminates many ofthe effects
, 

### external conditions could have ifthe crew service door is opened under hazardous conditions. Also, we agree that prior tothe deploynient ofthe escape slide orinertia reels the crew service door could be closed ifthe conditiohs were not acceptable for evacuation. Concerning Limitation 16ofexemption 9793A, tha~the escape slide, when moved to the aft location, must clear the projected opening; Boeirig proposed to provide adequate access forrescue personnel to~enterthe airplane. Bdeing did not propose aminimum amount ofunobstructed opening or amethod to eval~ate what is adequate access forthe rescue personnel. Reviewing the requirement for e4t openings the minimum width is 19inches for aType IV exit. Based onthis require1ent wewould accept a 19-inch-wide passageway leading from outside the airplane to inside the airplane tothe main aisle on the upper deck ofthe airplane. A smaller passagewAy may be found acceptable bytest, however, Boeing would need to develop and the FAk. accept the test criteria.

10

### The FAA's decision

Inconsideration ofthe foregoing, Ifind that apartial grant ofexemption is inthe public interest because this design provides an acceptable l~vel of safety forthe maximum nWllberofoccupants that will be allowed on the airplane. Therefore, pursuant to the authority contained in 49 U.S.c. §§40113 and 447011,delegated to me bythe Administrator, The Boeing Company ishereby granted an amendment to Exemption No. 9793A from §§ 25.783(g), 25.807(a)(1), 25.809(a), and 25.813(a) to the extent necessary to allow type certification ofBoeing Modyl 747~8F series airplanes with provisions for the carriage ofsupernumeraries. Limitation 16has been modified and Limitation J

### 7 has been added. All other limitations 

## tram Exemption No. 9793A have been repeated below for clarity. The following limitations apply and Limitation numbers 1-6and IO~

11 must be documented inthe Limitations Section ofthe Airplane Flight Manua]:1. Amaximum ofsix supernumeraries may occupy the areajust aft ofthe flight

deck. The total maximum occupancy ofthe airplane is limited to eight persons, including the llightcrew. 2. The supernumeraries are limited tothe categories specified in §§ 121.583(a)(1) through 121.583(a)(7). 3. Main Deck Class ECargo Compartment !AccessLimitations: 

# I a. Supernumeraries are prohibited from being inthe cargo area dming taxi, take-off, and landing. The pre-flight bridfing must inform supernumeraries of this requirement. b. Access into the main deck Class E cargo compartment in~flight is allowed for only three types ofoperation. They are:



# •

•

• Carriage oflive animals requiTing care/attention during flight and



# , associated material only, no o~hercargo. The maximum number of supernumeraries allowed in tliemain deck Class Ecargo compartment is six. Cargo Qnly,no live animal re~uiring care/attention during flight. The maximum number ofsuptrnwneraries allowed in the main deck Class Ecargo compartm1entisthree. Carriage oflive animals requi·ring care/attention during flight and other cargo. The maximum n~mber ofsupernumeraries allowed in the main deck Class Ecargo dompartment is six.

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### 4. Prior to each flight, aflightcrew member must brief the supernumeraries on the following:



# •

•

•

•



# •

•

•

•

•

•

•



# •

• The use ofexits, in~luding instm~tiors to inspect.the groUl~dto determine whether asafe'landmg can be achIeved before usmg an aSsIstmeans. Location and use ofemergency equil?ment. The prohibition from being in the cargo area during taxi, take-off, and landing. The aural and visual decompression alerting system and what actions they arerequired to take. n1e visual turbulence alerting system and the requirement that persons must return to their seats. The aural and visual fire or smoke alerting system and what actions they are required to take. That access is limited to the care and handling ofanimals and cargo only. That access is limited to amaximum ofthree unless live animals requiring care/attention in-flight and associated materiaJ are being carried. That access is limited to amaximuml of six when live animals requiring care/attention in-flight are being cied. That the smoke barrier must be secured (i.e., the door or curtain must be closed) except when entering or leav'ingthe cargo compartment. That aportable oxygen bottle (with f.ull face mask attached) must be carried atall times when accessing the cargo compartment byeach person entering the cargo compartment. That smokmg isnot allowed within re cargo compartment. That the compartment must not be entered in case offire/smoke being detected inside;the Class E cargo cOlhpartment. 5. The operator must determine that each supernumerary is physically able and trained to accomplish the necessary emeigency procedures. 6. Supernumeraries Portable Oxygen:
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### a. There must be atleast one portable ox~gen unit with amask attached to it provided for each supernumerary allowed to enter the main deck Class E cargo compartment during flight. The unit mu~tprovide anindication tothe user that oxygen is flowing. b. The portable oxygen W1it must meet the performance requirements of §25.1443(a) or § 25.1443(b), orthe equipment must be shown to protect the supernumerary from hypoxia atan activity level required to return to his orher seat following arapid decompression to 25,000 feet cabin altitude.

c. During flight, the supernumerary must carry the portable oxygen unit whenever he or she is inthe Class Ecargo compartment. d. The supernumeraries must be trained in the use ofthe oxygen units. The supernumeraries must also be trained in making the determination whether oxygen is being delivered tothe dispensing units.

e. The oxygen units must be sized adequately for continuous and uninterrupted use during worst-case flight duration following decompression, ormust be of sufficient duration to allow the supernumeraries to return totheir seats where oxygen isreadily accessible for the remainder ofthe decompression. 

## f. Additionally, since the petitioner has decided to provide the same alert for both decompression and smoke/fire, the 6xygen unit must meet the protective breathing equipment (PEE) requirements1in §§ 25.1439(b)(l), (2)(i), and (4), and the equipment and system must be dtsigned to prevent any inward leakage to the inside ofthedevice and prevent an~'outward leakage causing significant increase inthe oxygen content ofthe local atmosphere (i.e., full face mask type.) 7. An automatically activated aural and vis'4aldecompression alerting system must be present and immediately recognizable inaccessible areas ofthe Class Ecargo compartment to notify supemwneraries when to don oxygen masks. Ifthere are two ormore alerts thJt asupernumerary may hear oris expected to respond to there must be andutomatic visual alert in addition to the automatic aural alert. The pre-flight briefing must include training in the sound ofthe alerting system, the meaning ofthe alerting system, and the response to the signal (i.e., procedures fot donning the masks and activating the flow of oxygen).

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### 8. Turbulence Alert: A flightcrew operated visual alerting systrm, which is recognized inaccessible areas inthe Class E cargo compartment, must be installed to indicate, during turbulence, that peisons must return to thbir seats. Appropriate procedures and limitations must be established to enlure that the flightcrew alerting systems notify the supernumeraries toret,umto their seats atthe onset of turbulence and prior to landing. The pre~flight briefing must explain this alerting system to the supernumeraries. 9. Smoke/Fire Alert: Aflightcrew activated aural and visual alerting system, which is recognized in the Class E cargo compartment, must beinstalled. This aural orvisual alerting system is to indicate that, inthe event offire or smoke inthe Class E cargo compartment, persons must return to their seats and ensure that the smoke barrier is secured (i.e., the door or curtain is closed). Appropriate procedures and limitations must be established to ensure that, at the onset ofa fire or smoke event, the flightcrew alerting systems the supernumeraries to return totheir seats and secure the smoke barrier. The pre-flight briefing must explain these alerting systems to the supermuneraries. 10. Placards: Placards are to be located inthe supernumerary area, inaconspicuous location either on or adjacent to the smoke bamell doors. The placards must indicate the following:

• Access is limited tothe care and hantlling ofanimals and cargo only.



# •

•



# •

•

• Access is limited to amaximum oft~ee unless live animals requiring care/attention in-flight and associated material are being carried. The smoke barrier must be secured (i.e., the door or cwiain must be closed) except when entering orleaving the cargo compartment. Aportable oxygen bottle (with full )ace mask attached) must be carried at all times when accessing the cargo compartment byeach person entering the cargo compartment Smoking is not allowed within the q.rgo compartment. The compartm'ent must not be enteJd incase offire/smoke being detected inside the Class Ecargo corhpartment.

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### • Do n01occupy the Class Ecargo compartment during taxi, takeoff, and landing. 11. Alerting requirements:

• Must be distinctive and effective.

• Visual alerts must be visible from all ;occupant locations and orientations, during all expected operational conditions including arapid decompression where moisture inthelair may condense.

• Aural alerts must be loud enough to beheard during all expected operational conditions including araJid decompression where the anlbient noise level will increase. 

# I
12. For the crew service door, emergency lighting must provide adequate illumination at the ground end ofthe assibtmeans, where an evacuee would normally make first contact with the ground, with the airplane in each ofthe attitudes corresponding tothe collapse ofone ormore legs ofthe landing gear and worse case center ofgravity location. This condition does n01 

### apply to the overhead hatch. 13. There must be eight inertia reels andharnesses installed onthe flight deck. No flight deck door may be installed between the supemumerary compartment and the flightdeck that would prevent acdess to the overhead hatch and eight inertia reels and harnesses. In accordanc~ with FAA-approved test plan(s), the intended inertia reels and harnesses must!be demonstrated to be a suitable assist means for the expeditious and safelevacuation ofthe maximum number oftrained occupants allowed by approved seating. This/these demonstration(s) should also address, to the satisfaction ofthe FAA, the capability oftrained occupants to utilize the intended inertia reels and harnesses to safely and expeditiously eva~uate incapacitated occupants. Additionally, this/these demonstration(s)!should also address, to the satisfaction ofthe FAA, the suitability oqthe intended devices from both high and low sill heights representative of 

## § 2.5.81O(a)(l)(iii) gear-collapse 

# , conditions includiI1gworse case center ofgravity location. 14. For all cargo ormixed cargo and live animal operations involving four or more supemumeraries, aportable syste~that protects against smoke inhalation must beprovided. A portablelsystem (e.g., smoke hood, full face mask oxygen system, etc.) that affords protection from smoke inhalation must be carried atalltimes when accessing thJ cargo compartment. Note that a single system that meets both protection from smoke inhalation and hypoxia could be used (e.g., afull face mask \.\lithl oxygen unit).

15

### 15. Flight tests must be conducted to show compliance with the provisions of §25.857 concerning the entry ofhazardofs quantities of smoke into compartments occupied by the crew orp<;Lssengers.The amount oftime that 

## , the smoke barrier is open, as aresult oftre supernumeraries evacuating the main deck cargo compartment, must be accounted forinthe testing. 16. For airplanes with the optional escape sl~deinstalled atthe crew service door, Boeing must develop instructions for sliding the escape slide aftto provide a passage from the main aisle and out oftne exit at least 19inches in width. These instructions must be added tothe outboard side ofthe escape slide assembly so rescue personnel can read the instructions and move the escape slide out ofthe way. These instructions must be demonstrated to be effective forrescue personnel. 17. For the upper deck occupancy the follo\\ring items apply:

a. The requirement of § 25.783(g) that each passenger entry door must qualify as aType A, Type I,orType IIpassenger emergency exit is exempted because the airplane entry door is onthe main deck and the main deck entry door isnot part ofthe supernumerary compartment. b.

## TIle crew service exit opening isthe siZeofaType Iexit but has an 8-inch step-up inside the airplane.

c. For the crew service door, the viewing outside through the viewing window does not meet the requirements of § 25.809(a). With the door closed itis acceptable to only be able to ~iew the general location where oc~up~ts would likely m~~efirstlcontact u~ingt.heoption.a~ escape slIde III

### normal gear condltlons and lower slHhelght condltlOl1s. After the crew service door isopen alllo.cations where occupants would likely make first contact using the' I

### optional escape slide and/or the inertia reels must bevisible from the exit opening.



## 16

### Note: The briefings and associated procedures inLimitations 7, 8, and 9 are not required ifan Airplane Flight Manual limitation isestablished to prohibit supernumeraries inthe Class Ecargo compartment during flight. Ifaccess isprohibited, placards must be revised to indicate this limitation.

Issued inRenton, Washington"on 

# OCT2 2 2010 

# Ad' J 

# <::1-;/! ~ /}R:>-k.LP( 

# /)a~
Michael 1.Kaszycki Acting Manager Transport Airplane Directorate Aircraft Certification Service

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