U.S. Department 

of Transportation 

Federal Aviation 

Administration 

January 29, 2015 

Mr. David A. Crotty 

Senior Certification Manager 

Jamco America, Inc. 

1018 80111 Street SW 

Everett, W A 98203 

Dear Mr. Crotty: 

Transport Airplane Directorate 

1601 Lind Avenue, S.W. 

Renton, Washington 98057-3356 

We have received your January 20, 2015 petition to amend the operational limitations in 

Exemption No. 10899. That exemption provides relief from the requirements of Title 14, Code 

ofFederal Regulations (14 CFR) 25.785(d), 25.807(c)(1), 25.807(c)(5), 25.809(£)(1), 25.813(b), 

25.857(e), 25.1447(c)(l), and 25.1447(c)(3) to allow carriage of 15 non-crewmembers 

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

Model 747-400F airplanes. 

The current petition was posted to the Department of Transportation's Federal Docket 

Management System (FDMS) in Docket No. FAA-2013-0680 where Exemption No. 10899 is 

documented. 

We have reviewed your request and disagree that Exemption No. 1870E allows access to the 

main deck Class E cargo compartment. Exemption No. 1870E does not specifically permit or 

prohibit access to the Class E cargo compartment in-flight by supernumeraries, as that was not 

part of the petition for that exemption. When we became aware that there was potential 

confusion concerning the type of equipment and approval required for allowing supernumerary 

access into Class E cargo compartments during flight, we published Special Airworthiness 

Information Bulletin (SAIB) NM-09-27 on May 12, 2009. The SAIB explained the areas of 

concern and described the additional safety provisions required by exemptions that do 

specifically allow supernumerary access in flight. I have enclosed a copy of SAIB NM-09-27 for 

reference. 

Please review Exemption No. 1870E and SAIB NM-09-27, and revise and resubmit your petition 

accordingly. 

If you have any questions or concerns regarding your petition or the petition process, please 

contact Jayson Claar by phone at 425-227-2194 or by e-mail atjayson.claar@faa.gov. 
Sincerely, 

Theresa White 

Transport Airplane Directorate 

Aircraft Certification Service 

Enclosure 

2 
FAA 

Aircraft Certification Service 

SPECIAL AIRWORTHINESS 

INFORMATION BULLETIN 

SUBJ: Equipment/Furnishings: In-flight access to Class E cargo 

compartments 

This is information only. Recommendations aren 't mandatory. 

Introduction 

SAIB: NM-09-27 

Date: May 12, 2009 

This Special Airworthiness Information Bulletin (SAIB) alerts you, owners and operators of Boeing 

747 series airplanes with a Class E cargo compartment on the main deck of the airplane that 

carry non-crewmembers (known as "supernumeraries"), of the equipment and conditions that are 

generally required on airplanes when supernumerary access into the Class E cargo compartment is 

desired during flight. 

Class E cargo compartments may be installed on, but not limited to, the following aircraft, either as 

originally delivered from the manufacturers, or on airplanes converted from passenger operations to 

freight operations after delivery that use Exemption 1870 as a basis for the approval to carry 

supernumeraries: 

Boeing 

Background 

747-100, 747-1008, 747-1 OOB SUD, 747-200B, 747-200C, 

747-200F, 747-400, 747-400F 

Title 14, Code of Federal Regulations (14 CFR) 25.857(e)), limits airplanes that have Class E cargo 

compartments to the carriage of cargo only. This limits the airplane to flight crewmembers only. 

The major reason that these airplanes are limited to flight crew only is because of the fire fighting 

method used to fight an in-flight fire. The industry standard fire fighting procedure for Class E cargo 

compartments is to shut off airflow to the cargo compartment, depressurize the airplane, and operate 

the airplane at an altitude of at least 20,000 feet. This reduces the available oxygen to a level that 

will not support the fire (oxygen starvation). Under these flight conditions the flight crewmembers 

will don oxygen until the airplane lands or the airplane altitude is below I 0,000 feet. 

The FAA has granted exemptions to permit carriage of supernumeraries on these cargo airplanes, 

when specific equipment is installed and specific conditions are met. One of the typical conditions is 

that the supernumeraries do not access the Class E cargo compartment during taxi , takeoff, flight, and 

landing, as noted by placards and/or airplane flight manual (AFM) limitations. The FAA, however, 

has also granted exemptions that do allow supernumerary access to the Class E cargo compartment 

during flight, again when specific additional requirements are met. There is at least one exemption, 

which affects numerous operators and airplanes that does not specifically prohibit or permit in-flight 

access to the Class E cargo compa1tment by supernumeraries. Exemption 1870, which is for Boeing 

747 series airplanes, is that exemption. It does not specifically permit, but does not specifically 

prohibit, access to the Class E cargo compartment in-flight by supernumeraries. The petition for 

exemption did not specifically address access to the Class E cargo compartment in flight, and 

therefore this issue was not addressed. Therefore, the exemption does not include the specific 

additional requirements that have been included in later exemptions for other airplane models where 

access was requested and granted, but with additional requirements. 
We have become aware that there may be some confusion on the part of owners and operators 

concerning what type of equipment and approval they should have for allowing supernumerary 

access into the Class E cargo compartment during flight on 747 series airplanes. 

Class E cargo compartments are usually remote from the flight deck and encompass the entire interior 

of the airplane. These Class E cargo compartments do not have the systems and equipment typically 

found in passenger compartments, e.g., automatically presented oxygen masks. 

As noted above, the industry standard fire fighting procedure for Class E cargo compartments is to 

shut off airflow to the cargo compartment, depressurize the airplane, and operate the airplane at an 

altitude of at least 20,000 feet. This will reduce the available oxygen to a level that will not support 

the fire (oxygen starvation). The flight crew dons oxygen masks and continues to use them until the 

airplane lands or the airplane altitude is below 10,000 feet. 

There are additional hazards associated with entering the cargo compartment-including cargo 

shifting, occupant injury due to contacting the cargo that does not meet the requirements for injurious 

objects in a passenger cabin, protection from decompression, and protection from smoke/fire 

conditions. 

Nonetheless, the FAA understands that some operators on some flights desire to have access to the 

Class E cargo compartment. Carriage of live animals is a frequent type of operation that requires 

access to the Class E cargo compartment in flight. However, other types of cargo (e.g., perishable or 

hazardous) also may require in-flight monitoring and may present different potential hazards. 

With the installation of, or requirement for, proper equipment, alerts, training, briefings, and 

procedures, an acceptable level of safety can be provided for the supernumeraries entering the Class 

E cargo compartment. 

The following are areas of concern that have been addressed when exemptions have allowed 

supernumeraries' access to the Class E cargo compartment in-flight. 

• Cargo compartments do not and should not have oxygen systems installed in them for the 

supernumeraries to use when in the cargo compartment because this would provide a source of 

oxygen in the cargo compattment. Since the method used to control fires in Class E cargo 

compattments is oxygen starvation, an installed oxygen system would provide a potential 

oxygen source to feed the fire. However, the supernumeraries, under some conditions such as 

decompression, need to have a supply of oxygen immediately available to them when they are 

in the cargo compartment. This can be accomplished by requiring the supernumeraries to carry 

portable oxygen units with them when entering the cargo compartment. Operators should also 

ensure that the supernumeraries are properly trained in the use of the portable equipment. 

• Cargo compartments do not have automatically presented oxygen masks which would serve to 

alert the supernumeraries that they need to don oxygen. Therefore, an alternate method of 

signaling the supernumeraries when to don the oxygen equipment should be provided. The 

signal needs to be automatic because in the event of a decompression the flight crew workload 

will be high (donning their own oxygen masks and flying the airplane). An appropriate signal 

and pre-flight briefing as to what the signal is and what the supernumeraries should do in 

response to the signal provides an acceptable level of protection. 

• Cargo compattments do not have fasten seat belt signs to alert supernumeraries to return to their 

seats and fasten their seat belt when there is turbulence. Furthermore, the cargo compartment 
does not comply with the requirements to protect occupants from injurious objects when they 

are moving about the compattment as is required for the passenger compartment. To provide an 

acceptable level of safety for the supernumeraries when they are in the cargo compartment, a 

signal needs to be provided to warn the supernumeraries of turbulence and the need for them to 

return to their seats. An appropriate signal and pre-flight briefing would provide an acceptable 

level of safety. 

• Cargo compartments are required to have automatic smoke/fire detectors installed to alert the 

flight crew of smoke/fire in the cargo compartment. After the flight crew is alerted to 

smoke/fire in the cargo compartment they should take actions associated with controlling the 

fire. These actions include shutting off airflow to the cargo compartment, depressurizing the 

airplane, and operating the airplane at an altitude of at least 20,000 feet. Cargo compartments 

do not have a way to signal the supernumeraries that there is smoke/fire in the cargo 

compartment and that they need to return to there seats. An appropriate signal and pre-flight 

briefing would provide an acceptable level of safety. 

A placard located in the supernumerary area, in a conspicuous location either on or adjacent to the 

smoke barrier, should indicate the following for access to the Class E cargo compartment. The 

pre-flight briefing should inform supernumeraries of these requirements: 

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

• Access is limited to a maximum of three supernumeraries when carrying cargo only. 

• When operation includes the carriage of large live animals that require in-flight care 

more that three supernumeraries may be carried. This type of operation includes a 

cargo of only live animal that require in-flight care, or mixed cargo including live 

animals that require in-flight care. 

• The smoke barrier should be secured (i.e., the door or curtain should be closed) except 

when entering or leaving the cargo compartment. 

• A portable oxygen bottle (with mask attached) should be carried at all times by each 

supernumerary when accessing the cargo compa1tment. 

• Smoking is not allowed within the cargo compattment. 

• The compattment should not be entered in case of fire/smoke being detected inside the 

Class E cargo compartment. 

Recommendations 

We recommend that owners and operators ensure that the systems, equipment, training, pre-flight 

briefings and procedures discussed in the areas of concern above are provided to the supernumeraries 

for all operations during which supernumeraries will be entering the Class E cargo compartment in 

flight. 

For Further Information Contact 

Jayson Claar, Aerospace Engineer, FAA, Transport Airplane Directorate, Transport Standards Staff, 

Airframe/Cabin Safety Branch, 1601 Lind Avenue SW., Renton, Washington 98057-3356; telephone 

(425) 227-2194; fax: (425) 227-1149; email: jayson.claar@faa.gov