Exemption No. 9793B

UNITED STATES OF AMERICA ,

DEPARTMENT OF TRANSPORTATION ,

FEDERAL AVIATION ADMINISTRATION

RENTON, WASHINGTOt 98057-3356

In the matter of the petition of

THE BOEING COMPANY

for an exemption from §§ 25.783(g),

25.807(a)(I), 25.809(a), and 25.813(a) of

Title 14, Code of Federal Regulations

Regulatory Docket No. FAA-2008·0348

PARTIAL GRANT OF EXEMPTION

By letter 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. If granted, tHis amendment would permit

additional relief from the requirements of §§ 25.783(g), 25.807(a)(1), 25.809(a), and

25.813(a) of Title 14, Code of Federal Regulations (114 CFR). Also, Boeing requested

that Limitation 16 of Exemption No. 9793A be revised, to allow the optional escape slide

at the 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 a partial grant which permits ihe carriage of six non-crewmembers

(commonly referred to as supernumeraries) in a corripartmcnt behind the flight deck on

Boeing Model 747-8F airplanes and allows in-flightlaccess to the class E cargo

compartment by these supernumeraries, with certain limitations. This proposed

amendment would allow the crew service door to b9-a Type UI exit and permit a limited

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. 16 to aHow the crew service door escape slide t r partially 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 a Type A, Type I, or Type IT passenger emergency

exit and must meet the requirements ofSecdons 25.807 through 25.813 that apply

to that type of passenger emergency exit.

Section 25.807(a)(I), at Amendment 25M61~provides requirements for type and

location of emergency exits. For the purposJ of this part, the types and locations

of exits are as follows: (1) Type I. This Ty~e must have a rectangular opening of

not less than 24 inches wide by 48 inches hidh, with comer radii not greater than

one-third the width of the exit. Type I exits must be floor-level exits.

Section 25.809(a), at Amendment 25-116, each emergency exit, including each

flightcrew emergency exit, must be a movable door or hatch in the external walls

of the fuselage, allowing an unobstructed op~ning to the outside. In addition, 'each

emergency exit must have means to permit ¥iewing of the conditions outside the

exit when the exit is closed. Means must als:obe provided to permit viewing of

the likely areas of evacuee ground contact. The likely areas of evacuee ground

contact must be viewable during all lighting :conditions with the landing gear

extended as well as in all conditions of landing gear collapse.

Section 25.813(a), at Amendment 25-46, rlquires a passageway between

individual passenger areas, and leading from! each aisle to each Type I and 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, in pertinent p~, a listing of categories of persons

who may be carried aboard an airplane in part 121 service without complying with

all the requirements of part 121 pertaining td carriage of passengers.

The petitioner snpports its reqnest with the fOllO~ing information:

The pertinent parts of Boeing',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.

2
The extent of relief being sought I

Re!!:ulation Reauires: Relief is necessnrv because:

14 CFR25.783 (g) The crew door Main deck!Door I LH is a Type A size door without any evacuation

Amendment 23 and Door I LH assist meahs and thus does not meet this regulation. This is ,

to be considered unchanged from the 747-400F design. The configuration of the upper

entry doors and deck crewldoor does not meet all Type I exit requirements in section ,

thus would need ]4 CFR 2~.807 through 14 CFR 25.813 allhough the fuselage cutout

to be a Type A, meets the fype I exit dimensions. Some of the requirements not met

lor II exit. are covered in Exemption No. 9793/9793A for the 747-Sf; however

the ExemJtion 9793/9793A does not provide relief from this

requiremeht to provide a Type A, 1, or II size exit.

14 eFR The crew door The crew {loor can no longer be considered a Type I floor~level exit

25.807(a)(I) as a Type 1 exit due to a step-up to the exit when the airplane is configured with inertia

Amendment 67 to be a floor~ reels as thronly evacuation means. A previously granted Exemption

level exit. No. 9735 has acknowledged this same condition on the 747-400F and

considered the ratiJw of the exit as a Tvne III.

14 eFR 25.809(a) The crew door The provided viewing window on the crew door is not capable of

Amendment I 16 as an viewing the evacuee ground contact area in all combinations of gear

emergency exit collapse for either evacuation means prior to the exit being opened.

to have a means The configuration of the 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 of Exemption No. 9696 was extended for the 767~

combinations of 300BCF biased on the 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 Jess than 20-inches with the manually

Amendment 46 as a Type I exit deployed slide installed in the 747-8F interior configuration. As a

to have a 20- customer selectable option, the 747-400F manually-deployed escape

inch slide at the crew door has been selected by a majority (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, a similar condition exist on the 747-

400F. I

Limitation 16 from The crew door The interior configuration of the 747-8F does not allow the escape

Exemption 9793A escape slide be slide to bel moved far enough aft to directly comply with the

labeled with requiremert to "clear" the projected opening. However, the design

instructions to and configuration of the 747-8F does allow the slide to be moved aft

move the escape to allow outside access by rescue 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 of tbe rescue personnel. Limitation 16 is to address a concern in Exemption

exit 9793A thAt "the escape slide is partially blocking the access to the

airplane J,hen the crew service door is openedfroln the outside,

which maf prevent rescue personnel from rapidly el1/ering the

airplane ij1 an emergency ... This concern can be addressed without

fully clearing the projected door opening.

There is nl similar requirement in Exemption series 1870 for this

similar cohfiguration and condition on the 747-200F/400F airplanes

which ha~e a proven safetY record.

3
Description of the Issue

The Model 747-SF is a derivative aircraft based on the 747-400F. The fuselage of the 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 a customer selectable option on the 747-SF where as it was basic

on the 747-400F. For the 747-8F, the escape slide hak been selected by a majority (5 of6) of the

airline customers as the evacuation means at the creW[door.

Like the 747-400F, the 747,-8F has a required 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) wiU limit the airplane to eight (8) occ~pants. The eight (8) inenia reel descent

devices located on the flight deck are identical in part1number 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 in the 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 a platform that moves fore and aft on

rails inside of the upper deck crew door. When the escape slide is deployed through the crew

door, the forward side of tbe platfonn is stationary and remains in the 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 a guide in slide deployment. This chute also

remains in the interior creating a boundary to the passageway out the exit. \¥hen the optional

escape slide is installed the 20~inch passageway leadihg to the exit is not maintained from the slide

platform to the interior monument, nor is the 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 is opened from the outside. The ability to gain access,

including the effectiveness of the 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 of the inertia reels, in all combin~tions of gear collapse, before and after door

opening. The existing exterior body-mounted light illuminates the ground contact area of the ,

escape slide, in all 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 of main electrical

power (28 VDC bus) when the system is armed, or (2) manually via the emergency light switches

located on the flight deck or in the 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 ~nd procedures consistent with the current

fleet. The majority (5 of6) of the 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 of operating these cargo aircraft is t9 have consistent' airplane designs and

cre-w/supernumerary training \vith respect to evacuatibn safety features of the airplane. A grant of

exemption will result in consistent operator's procedures for evacuation of the 747·8F with the

747--400F fleet when the escape slide is installed and!similar to other airplane models with only

inertia reels installed, thus enhancing safety.

4
Granting the exemption to § 25.783(g) at Amendment 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 in more ~etail below:

o Limited number of trained supernumeraries

o Specific to Door I LH, while it will be used for entry it will 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 I door, it will 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 at the exit.

Previously the FAA recognized in Exemption No. 4808 for the 757·200PF "The intent of 14 CFR

25. 783(g) is to ensure that the door through which pdop!e enter an airplane is also useable as an

emergency exit." "Because of the hetter trained, ope~ator-approved, sma/! number of

110llcrewmembers allowed in the flight deck, the FAA Y1nds that the entlY door provided in the

Model 757-200PF can safety be used as an emergency exit and that the requirements that the

entry door be a Type A, lor 11 is unnecessary." Although the 747-8F has a different configuration

than the 757·200PF, the circumstances are similar in training and small number of non-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 of the exits in accordance with Exemption No.

9793/9793A. This additional level of knowledge afforded to these occupants when compared to

the nonnal passenger provides an enhancement in eV3;Cuationnonnally afforded. Door 1 LH will

be used as the entry door on the 747 -SF however it will not be used as the emergency exit. It will

be out of sight and no exit signs will lead personnel to Door I LH once the supernumeraries have

taken their seats in the upper deck thus it is unnecessarY to make it a 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) at Amendment 67 and § 25.813(a) at Amendment 46 for

the non-fioor-Ievel exit and less than 20-inch passageway, respectively, at 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 in more detail below:

a Limited number of trained supernumeraries (see discussion, above)

a Consideration of the crew door rating similar to a Type III exit with a 19 inch passageway

being maintained

o a small step-up of approxImately 8 Inches J

Per § 25 807(c)(1) at Amendment 67, a pair of Type eXIts would allow 40-79 passengers, while a

pair of Type III exits would be sufficient for between ~O and 39 occupants. In combination with

the flight deck overhead exit, having the 747·8F airpl~ne configured with a Type I size cut out and

nearly meeting the Type I passageway requirements, +hile only needing to provide evacuation

capability for 8 occupants, the overall design is considered sufficiently safe.

While a 20-inch passageway is required for a Type I Jized exit, the crew door can be considered,

based on lhe number of passengers being evacuated, iimilar to a Type III exit. The applicable

regulations, § 25.813(c)(1 )(2) at Amendment 46, do riot specify a passageway 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 74718F crew door as similar to a Type 1II exit,

with a method of compliance associated with the projected opening by providing a 19-inch

passageway at the crew door and no obstruction in opbning the exit, is sufficiently safe for the

8 occupants. A step-up of20-inches is allowed for a type 1II exit. The 747-8F step-up when the

escape slide is not installed is approximately 8 inchcsJand there is no step-up when both the inenia

reels and slide are installed. The FAA recognized a similar condition in Exemption No. 9735 for

5
the 747-400F " ...have a crew service door the size ofia Type I exit, but because the door has a

step-up inside the airplane it is raled as a Type III exit and is available/or evacuation."

Granting the exemption to § 25.809(a) at AmendmenJ25-116 will not adversely affect safety based

upon the following factors, which are summarized here and discussed in more 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

It is understood § 25.809(a) at Amendment 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 is not visible (due to lack of means 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 of cases. Additionally, the large flight

deck windows provide a means to view the surroWldil/g area by the flightcrew as the airplane is on

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, a window IslnstaHed in the crew door of the 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 of the crew door and located in

the supernumerary compartment. One window (each side) is located in the crew bunk area of the

supernumerary compartment. I

All windows provide a view of the surrounding area with the airplane resting on all landing gear.

Once the airplane has slowed to a stop, viewing of alliofthe likely areas of evacuee ground contact

prior to the exit being opened will not be fully possible since they are directly beneath the aircraft

when inertia reels are used. However, a view of the 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 of the flight deck windows and crew

door large enough to be a hazard if the exit i~opened would be readily and easily

recognizable by the tlightcrew as the alrplank slows to a stop. In these cases, the

flightcrew would command evacuation frOmjthe appropriate exit.

o Recalling, the supemwneraries are required .0 be briefed in thc use Qfthe exits, the

presence of a fire pr water in the surrounding area of the crew door largc enough to be a

hazard would likely be recognized by the su~emumeraries from windows in the

supemWllerary area, in conjunction with the fody-mounted lights as necessary, and could

be communicated,to the flightcrcw when detennining which exit to utilize.

It is understood 14 eFR 25.809(a) at Amendment 25jI 16 is 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 of the

door sill. In the case of the 747 -8F, the evacuation mbans is manually-deployed after the

emergency exit is opened. If a hazard such as fire, water, or terrain is detected near the crew door,

after the-door is opened, the door may be easily closet! again because the manually deploy

passenger escape slide or inertia reels would not be irl the way of the door mechanism.

6
The location of the emergency exit is approximately 113.5 feet above the water line in the

unplanned ditching scenario, which is worst case. Thb crew door is far enough above the water

level after a ditching event such that iftbis emergencY: exit were to be opened without first

assessing outside conditions it could easily and quickly be re-c1osed without consequence.

Additionally the 747·8F airplane is configured with bpdy-mounted lights (reference Figure 5)

providing the illumination in dark of night conditions ~o assess the surrounding area prior to

emergency exit opening. After emergency exit openif).g and before evacuating through the exit,

making an assessment of safety 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 of both

evacuation means before those means are deployed.

While a means that provides viewing of the 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 ~n acceptable level of safety as noted above.

Similar conditions were recognized and accepted by the FAA in Exemption No. 9696 for the

767-300BCF. "We agree in this specific case with the petilioner's rationale that in most cases the

presence of afire in the vicinity olthe fejihandjlight 'deck window and Door f L would be

recognizable by the flight deck crew, ... " "Because t~e assist means is an 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 in relation to § 25.809(a) is contained herein.

Limitation 16

1l is proposed that the FAA accept an adequate opening to allow access from outside the airplane

at the crew door by providing relief fTOmLimitation ~6of Exemption 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 the projected opening a/the exit from outside

Ih, ailp/m". .. l

Exemption 9793A noled a concern that "the escape Slide is partially blocking the access to the

ai/plane when the crew service door is openedfrom the outside, which may prevent rescue

persol1nelFom rapidly entering the airplane in an e~ergency." An acceptable level of safety 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 of the otber aspects of LimiTion 16.

The exit maintains the physical structural cutout of a Type I exit as well as the function of being

openable from the outside allowing entry into the airp;Iane. If the slide has not been deployed, then

the rescue personnel can move the slide pack aft by f6110wing the instructional placards added to

the outboard of the slide pack, thus providing an entrY way.

I

In the nose down adverse attitudes, the 747-8F slide does not have a detent on the track for it to

lock in the full open position. The force to move the ~lide is less than 30 pounds which is within

the capability of rescue personnel.

Safety is maintained because the requirements of Li~itation 16 provide an increase in safety as

compared to the 747-400F by including instructions for rescue personnel in the type design (via

placarding) in addition to including instructions in thJ rescue and fire fighting procedures.

7
Proposed Revision to Limitation 16

Request to Revise Limitation 16: Boeing hereby re!uests the FAA revise Limitation 16 to

remove the "clear opening" requirement. Boeing proposed wording. "For airplanes ",'ith the

optional escape slide instaf/ed at the crew door Boei1g must develop instructions for moving the

escape slide aft to provide an entrywav sufflcient to allow access into the airplane (or the

purposes of rescuing occupants from 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 it is in the best economic

interest of the United States. Increased sales ofairplahes contribute to the balance~of-trade, the

gross domestic product and economic health of the U?ited States. Marketability of the 747-8F is

improved, leading to increased sales, by keeping the sales price and operating cost of the 747-8F

down while providing flexibility to the airlines in a choice of evacuation 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 in evacuation 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 of the exit

Operating costs are kept down by:

o Having common training and operating procfdures with the 747 Freighter Fleet when the

escape slide is installed while avoiding the cpst of maintaining different material in the

training, maintenance, dispatch and operations manuals for the 747-8F and 747-400F.

Every 747-400F delivered from Boeing wasiequipped with an escape slide installed in a

similar interior configuration, a window in the crew door, and an exterior body-mounted

light to illuminate the evacuee ground contact area of the escape slide. The majority

(4 of6) of the 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 on their 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 be realized by the

required design changes as noted above in tHe purchase price impacts.

o Weight and fuel benefits for operators chooding the inertia reels as the evacuation means

Lower purchase and operating costs will help maintai~j cargo shipping rates aboard freighter

airplanes at their current levels, which benefits the U{ economy as a whole.

A grant of exemption, as requested in this petition, isJinthe best interest of the travelling public

through introduction of this new product into the marketplace that has advanced the cenification

basis in many areas as compared to the 747-400F. EJabling common operating procedures for

evacuation not onIy maintains 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.

8
For the reasons noted above, it is the petitioner's opinion that the overall level of safety is

improved by comparison to the previous 747 freighte~ models that are certified with similar

configurations and evacuation systems and safety ismaintained which is in the public's best

interest.

Privileges of this Exemption Outside the United States

Per 14 CFR I 1.81(h), Boeing requests that the privileges ofthis exemption be extended outside the

United States. This extension of privileges is necessary for operations based within foreign

countries having bilateral agreements with the UnitedlStates accepting FAA 14 CFR 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 of safety previously afforded on the 747 freighter series from an

exit rating and evacuation systems standpoint. The 35 year service history of the 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) at Amendment 1]6 fpr the 747-8F model isjustified based on this

exit meeting the pertinent aspects of the Type [exit and considering that it will only be used by a

limited number of trained and capable occupants. Gr~nting relief from § 25.809(a) at

Amendment 116 for the 747-8F model isjustified based on the capability of the airplane to provide

safe evacuation means including illumination.

Granting the revision to Limitation 16 isjustified based on providing adequate access by rescue

personnel from outside the airplane and maintaining all of the other aspects of Limitation 16. If

Limitation 16 is revised 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 of this 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 of the crew service dopr and the installation of the optional

escape slide on the 747-8F. We agree with Boeing tpat the basic design of the crew

service door on the 747-8F is the same as the 747-4~OF and other earlier model 747

freighter airplanes. The baseline 747 airplane has a iitep-up of 8 inches from the floor of

the airplane to the exit. Section 25.783(g) requires trat each passenger entry door in the

side of the fuselage be a Type A, Type I, or Type II ~assenger emergency exit. Also,

§ 25.807 requires that all Type A and Type I exits be floor-level and that Type II exits not

located over the wing be floor-level. We do not agrbe with the Boeing statement that

" ... there is no step-up when both the inertia reels an~ slide are installed." \\!hen the

escape slide is installed and it is deployed there is a tamp section from the floor of the

airplane to the point where the evacuee wouldjump!onto the escape slide. The ramp

section makes it appear that there is not a step-up to the exit. However, when the escape

9
slide is slid aft (not deployed) there is a step-up to tlie exit. 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 a Type III exit rating. HoweveI1,Exemption No. 9735 did not

specifically address the issue that each passenger entry door in the side of the fuselage

must be a Type A, Type I, or Type II floor-level exit~

For the 747 -SF and all earlier model 747 freighters, !he normal route for the flightcrew

and the supernumeraries to enter the airplane is using door 1 left located on the main deck

of the airplane. Since the supernumeraries are trained and receive a pre-flight briefing

concerning the evacuation means for the exit, we agfee that it is not 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 of exits required. Boeing states "a

pair of Type I exits would allow 40-79 passengers, J.,hile a pair of Type m exits would be

sufficient for between 20 and 39 occupants." The r~quirements for the type and number

of exits required for the 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 in each side of the fuselage. For a passenger capacity of 40 through 79 there must be

at least one Type I and one Type III exit in each side!of the fuselage.

The access to the crew service door is a 19-inch-wide passageway with an 8-inch step-up

at the exit. This access is much better than what is rbquired for a Type III exit 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;:Iitions before opening the crew

service door is not possible fat all cases of landing 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 is not visible with the

viewing window provided on this exit. We agree w~tb Boeing that the design of the

airplane and location of the crew service door effectively eliminates many of the effects

,

external conditions could have if the crew service door is opened under hazardous

conditions. Also, we agree that prior to the deploynient of the escape slide or inertia reels

the crew service door could be closed if the conditiohs were not acceptable for

evacuation.

Concerning Limitation 16 of exemption 9793A, tha~the escape slide, when moved to the

aft location, must clear the projected opening; Boeirig proposed to provide adequate

access for rescue personnel to ~enterthe airplane. Bdeing did not propose a minimum

amount of unobstructed opening or a method to eval~ate what is adequate access for the

rescue personnel. Reviewing the requirement for e4t openings the minimum width is

19 inches for a Type IV exit. Based on this require1ent we would accept a 19-inch-wide

passageway leading from outside the airplane to inside the airplane to the main aisle on

the upper deck of the airplane. A smaller passagewAy may be found acceptable by test,

however, Boeing would need to develop and the FAk. accept the test criteria.

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The FAA's decision

In consideration of the foregoing, I find that a partial grant of exemption is in the public

interest because this design provides an acceptable l~vel of safety for the maximum

nWllber of occupants that will be allowed on the airplane. Therefore, pursuant to the

authority contained in 49 U.S.c. §§ 40113 and 447011,delegated to me by the

Administrator, The Boeing Company is hereby 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 of Boeing Modyl 747~8F series airplanes with

provisions for the carriage of supernumeraries. Limitation 16 has 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

1-6 and IO~11 must be documented in the Limitations Section of the Airplane Flight

Manua]:

1. A maximum of six supernumeraries may occupy the area just aft of the flight

deck. The total maximum occupancy of the airplane is limited to eight

persons, including the llightcrew.

2. The supernumeraries are limited to the categories specified in

§§ 121.583(a)(1) through 121.583(a)(7).

3. Main Deck Class E Cargo Compartment !Access Limitations:

I

a. Supernumeraries are prohibited from being in the 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 of operation. They are:

•

•

•

Carriage oflive animals requiTing care/attention during flight and ,

associated material only, no o~her cargo. The maximum number of

supernumeraries allowed in tlie main deck Class E cargo

compartment is six.

Cargo Qnly, no live animal re~uiring care/attention during flight.

The maximum number of suptrnwneraries allowed in the main

deck Class E cargo compartm1ent is three.

Carriage of live animals requi·ring care/attention during flight and

other cargo. The maximum n~mber of supernumeraries allowed in

the main deck Class E cargo dompartment is six.

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4. Prior to each flight, a flightcrew member must brief the supernumeraries on

the following:

•

•

•

•

•

•

•

•

•

•

•

•

•

The use of exits, in~luding instm~tiors to inspect. the groUl~dto determine

whether a safe'landmg can be achIeved before usmg an aSsIst means.

Location and use of emergency 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

are required 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 of animals and cargo only.

That access is limited to a maximum of three unless live animals requiring

care/attention in-flight and associated materiaJ are being carried.

That access is limited to a maximuml 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'ing the cargo compartment.

That a portable oxygen bottle (with f.ull face mask attached) must be

carried at all times when accessing the cargo compartment by each person

entering the cargo compartment.

That smokmg is not allowed within re cargo compartment.

That the compartment must not be entered in case of fire/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 at least one portable ox~gen unit with a mask attached to it

provided for each supernumerary allowed to enter the main deck Class E cargo

compartment during flight. The unit mu~t provide an indication to the user

that oxygen is flowing.

b. The portable oxygen W1itmust meet the performance requirements of

§ 25.1443(a) or § 25.1443(b), or the equipment must be shown to protect the

supernumerary from hypoxia at an activity level required to return to his or her

seat following a rapid decompression to 25,000 feet cabin altitude.

c. During flight, the supernumerary must carry the portable oxygen unit

whenever he or she is in the Class E cargo compartment.

d. The supernumeraries must be trained in the use of the oxygen units. The

supernumeraries must also be trained in making the determination whether

oxygen is being delivered to the dispensing units.

e. The oxygen units must be sized adequately for continuous and

uninterrupted use during worst-case flight duration following decompression,

or must be of sufficient duration to allow the supernumeraries to return to their

seats where oxygen is readily accessible for the remainder of the

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 of the device and prevent an~'outward leakage causing significant

increase in the oxygen content of the local atmosphere (i.e., full face mask

type.)

7. An automatically activated aural and vis'4al decompression alerting system

must be present and immediately recognizable in accessible areas of the

Class E cargo compartment to notify supemwneraries when to don oxygen

masks. If there are two or more alerts thJt a supernumerary may hear or is

expected to respond to there must be an dutomatic visual alert in addition to

the automatic aural alert. The pre-flight briefing must include training in the

sound of the alerting system, the meaning of the 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 in accessible

areas in the 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 to ret,um to their seats at the onset of

turbulence and prior to landing. The pre~flight briefing must explain this

alerting system to the supernumeraries.

9. Smoke/Fire Alert:

A flightcrew activated aural and visual alerting system, which is recognized in

the Class E cargo compartment, must be installed. This aural or visual

alerting system is to indicate that, in the event of fire or smoke in the 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 of a

fire or smoke event, the flightcrew alerting systems the supernumeraries to

return to their 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 in the supernumerary area, in a conspicuous location

either on or adjacent to the smoke bamell doors. The placards must indicate

the following:

• Access is limited to the care and hantlling of animals and cargo only.

•

•

•

•

•

Access is limited to a maximum 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 or leaving the cargo compartment.

A portable oxygen bottle (with full )ace mask attached) must be carried at

all times when accessing the cargo compartment by each person entering

the cargo compartment

Smoking is not allowed within the q.rgo compartment.

The compartm'ent must not be enteJd in case of fire/smoke being

detected inside the Class E cargo corhpartment.

14
• Do n01 occupy the Class E cargo 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 a rapid

decompression where moisture in thelair may condense.

• Aural alerts must be loud enough to be heard during all expected

operational conditions including a raJid 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 of the assibt means, where an evacuee would

normally make first contact with the ground, with the airplane in each of the

attitudes corresponding to the collapse of one or more legs of the landing gear

and worse case center of gravity location. This condition does n01 apply to the

overhead hatch.

13. There must be eight inertia reels and harnesses installed on the 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 of the maximum number

of trained occupants allowed by approved seating. This/these

demonstration(s) should also address, to the satisfaction of the FAA, the

capability of trained 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 of the FAA, the suitability oqthe intended devices from both high

and low sill heights representative of § 2.5.81O(a)(l )(iii) gear-collapse ,

conditions includiI1g worse case center of gravity location.

14. For all cargo or mixed cargo and live animal operations involving four or

more supemumeraries, a portable syste~that protects against smoke

inhalation must be provided. A portablelsystem (e.g., smoke hood, full face

mask oxygen system, etc.) that affords protection from smoke inhalation must

be carried at all times when accessing thJ cargo compartment. Note that a

single system that meets both protection from smoke inhalation and hypoxia

could be used (e.g., a full face mask \.\lithloxygen unit).

15
15. Flight tests must be conducted to show compliance with the provisions of

§ 25.857 concerning the entry of hazardofs quantities of smoke into

compartments occupied by the crew or p<;Lssengers.The amount of time that

,

the smoke barrier is open, as a result oftre supernumeraries evacuating the

main deck cargo compartment, must be accounted for in the testing.

16. For airplanes with the optional escape sl~de installed at the crew service door,

Boeing must develop instructions for sliding the escape slide aft to provide a

passage from the main aisle and out oftne exit at least 19 inches in width.

These instructions must be added to the outboard side of the escape slide

assembly so rescue personnel can read the instructions and move the escape

slide out of the way. These instructions must be demonstrated to be effective

for rescue 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 a Type A, Type I,or Type IIpassenger emergency exit is

exempted because the airplane entry door is on the main deck and the

main deck entry door is not part of the supernumerary compartment.

b. TIle crew service exit opening is the siZe of a Type 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 it is acceptable to only be able to ~iew the general location

where oc~up~ts would likely m~~e firstlcontact u~ing t.he option.a~

escape slIde IIInormal gear condltlons and lower slH helght condltlOl1s.

After the crew service door is open alllo.cations where occupants

would likely make first contact using the'I optional escape slide and/or

the inertia reels must be visible from the exit opening.

16
Note: The briefings and associated procedures in Limitations 7, 8, and 9

are not required if an Airplane Flight Manual limitation is established to

prohibit supernumeraries in the Class E cargo compartment during flight.

If access is prohibited, placards must be revised to indicate this limitation.

Issued in Renton, Washington"on OCT 2 2 2010

Ad' J <::1-;/! ~

/}R:>-k.LP ( /)a~

Michael 1. Kaszycki

Acting Manager

Transport Airplane Directorate

Aircraft Certification Service

17