2230 Stonebridge Rd West Bend, WI 53095-USA 

1.262.335.8000 Phone 1.262.335.8008 FAX 

EIN: 39-1787963 

Dear Sirs, 

Request for exemption 

11118/2014 

FAA Project No.: Pending project number-FAA Chicago 

www.MedicaiAircraft.com 

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

medical/Divan-patient litter assemblies per report 006 in to a Boeing Business Jet. 

Aero Medical Products Mfg., Inc hereby petitions for an exemption from 25.562 and part of25.785(b) of Title 

14, Code of Federal Regulations (14 CFR) to the extent necessary to permit installation of a medical/Divanpatient litter assemblies, for transport of persons whose medical condition dictates such accommodations 

Specific sections of 14 CFR from which relief is sought 

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

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

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

the inertia forces specified in 25.561 and 25.562. 

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

retention criteria. 

Extent of relief, and reason 

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

25, 23, 27 and 29 airplanes. The certification requirements for those airplanes have resulted in good service 

history with no adverse experience. No medical-patient loading and utility system installations have been shown 

to meet the dynamic criteria in any aircraft. 14 CFR parts 23,27, and 29 specifically exclude stretcher litters 

from the dynamic criteria. 

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

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

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

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

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

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

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

offer no increase in safety and may not be available. 

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

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

reasons: 

• 

• 

• 

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

with adversity, 

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

exposure of the stretcher/divan, 

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

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

easily applied to a litter/divan. 
Why granting the exemption would not adversely affect safety, or how the exemption would provide a 

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

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

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

easily applied to a litter/divan 

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

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

cause. 

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

the deployment of lifesaving equipment. 

Additional information, views, or arguments supporting this request 

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

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

Operation outside the United States 

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

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

Paul M. Egan, CEO 

Aero Medical Products Mfg., Inc 

2230 Stonebridge Rd 

West Bend, WI 53095 

1-262-335-8000 

Cell: 1-262-305-4247