FULBRIGHT & -.JAWORSKI L.L.P. 

A REGISTERED LIMITED LIABILITY PARTNERSHIP 

666 FIFTH AVENUE. 31ST FLOOR 

NEW YORK. NEW YORK 10103-3198 

WWW.FULBRIGHT.COM 

SGOTBETTER@FULBRIGHT.COM 

DIRECT DIAL: (212) 318-3121 

VIA HAND DELIVERY 

James FisheL Esq. 

Trial Attorney 

A viation Enforcement Ot1ice 

U.S. Department of Transportation 

1200 New Jersey Avenue SW 

Room W96-495 

Washington, DC 20590 

March 4,2010 

Re: DOT -OST -2008-0273 

Dear Mr. Fisher: 

Request of Air New Zealand Limited for 

an Equivalent Alternative Determination 

TELEPHONE: 

FACSIMILE: 

( 2 I 2) 318-3000 

(2 I 2) 3 I 8-3400 

In support of Air New Zealand's request for an equivalent alternative determination with 

respect to 14 C.F.R. 382.61, at your request, I am enclosing two copies of a DVD produced for 

Air New Zealand demonstrating twelve transfers of passengers with disabilities as well as a copy 

ufthe company's application. The DVDs were produced in PAL format. For your convenience, 

I have included two copies that r had made in-house in a U.S. compatible format. 

Enc. 

~~ Susan Gotbetter 

"'\.LS~IN • BEI-.JINC' • Dt..LLAS • DENVER. 0UBAI • HO~-JG KONG. HOUSTON. LONDON. Los ANGELES. M,NNEAPOLIS 

iviur"ICrl. i\.jEW YOF-'K • RIYADH. SAN ANTONIO. Sr LOUIS. WASHINGTON CJC 
FULBRIGHT & JAWORSKI L.L.P. 

A REGISTERED LIMITED LIABILITY PARTNERSHIP 

666 FIFTH AVENUE. 31ST FLOOR 

NEW YORK. NEW YORK 10103-3198 

WWW.FULBRIGHT.COM 

SGOTBETT ER@FULBRIGHT.COM 

DIRECT DIAL: (212) 318-3121 

VIA ELECTRONIC SUBMISSION 

Samuel Podberesky, Esq. 

TELEPHONE: 

FACSIMILE: 

March 4,2010 

Assistant General Counsel for Aviation Enforcement and Proceedings 

U.S. Department of Transportation 

1200 New Jersey Avenue SW 

Room W96-322 

Washington, DC 20590 

Re: Docket DOT-OST-2008-0273 

Request of Air New Zealand Limited for 

Equivalent Alternative Determination 

Dear Mr. Podberesky: 

(212) 318-3000 

(212) 318-3400 

Pursuant to 14 C.F .R. 382.10, Air New Zealand Limited hereby requests an equivalent 

alternative determination with respect to the requirement in 14 C.F.R. 382.61 that aircraft seats 

have movable armrests. Air New Zealand has new Business Premier and Premium Economy 

seats on order that will not have any armrests as such. 1 However, in an excess of caution, Air 

New Zealand is seeking this equivalency determination. Air New Zealand will demonstrate that 

passengers with mobility impairments can move or be moved from an aisle wheelchair to or 

from these seats without going over any obstacles. 

As shown in the attached diagrams, the seats will be configured in a herringbone pattem, 

which maximizes the number of seats accessible to passengers with disabilities: 100% of the 

aisle seats in Business Premier and 57% of the aisle seats in Premium Economy will be 

accessible to passengers with disabilities. 

In support of this application, Air New Zealand is providing the Department with 

specifications for the new seats, diagrams of the new seating configurations, written procedures 

for both self transfers and assisted transfers, and, under separate cover, a DVD demonstrating 

these transfers. 

With respect to the DVD, the filming took place in a mock-up of a cabin using prototype 

seats as production of the new Premium Economy seats and the new ottomans with removable 

I Its Economy class seats will have movable aisle armrests. 

55479515.4 AUSTIN. BEIJING. DALLAS. DENVER. DU8AI • HONG KONG. HOUSTON. LONDON. los ANGELES. M,NNEAPOLIS 

MUNICH. NEW YORK. RiYADH. SAN ANTONIO. ST LouIs. WASHINGTON DC 
Samuel Podberesky, Esq. 

March 4,2010 

Page 2 

backshell for the Business Premier seats has not begun. The modified sleep sheet used in the 

filming of the assisted transfer into and out of the Business Premier seat in the lie-flat bed 

position was created for the filming and has since been put into production. Finally, it should be 

noted that the people demonstrating the transfer techniques in the DVD are volunteers, not 

actors. Those in uniform are Air New Zealand staff, and those being transfened are a paraplegic 

volunteer and a tetraplegic volunteer. 

The techniques and equipment used m the transfer methods were created m full 

consultation with: 

• The Auckland (Otara) Spinal Unit for the development of the transfer teclmiques 

used and specialist advice on handling passengers with spinal issueslinjuries. 

• The Disability Resource Centre Auckland for consultancy on equipment and 

transfer techniques. 

• Air New Zealand Safety and Employee Wellbeing Group for providing 

ergonomic and specialist advice on equipment design, and development of 

transfer techniques and training. 

• Melrose Kiwi Concept Chairs for the design and manufacture of a new generation 

onboard aisle chair. 

Air New Zealand seeks an equivalent alternative determination covering these Business 

Premier and Premium Economy seats on new Boeing 777-300 aircraft that are to be delivered 

beginning November 2010, Boeing 787 aircraft on order, and existing Boeing 767-300 and 777-

200 aircraft that may be retrofitted. 

Air New Zealand would be happy to answer any questions or provide additional 

information concerning this request. 

SG:cg 

Enclosures: 

Respectfully submitted, 

~jfdtdfiv Susan Gotbetter 

Exhibit A - Seating Configuration of B777-319ER with Relevant Measurements 

Exhibit B - Diagram of Premium Economy Class 

Exhibit C - Diagram of Business Premier Class 

Exhibit D - Procedures for Transfers 

554795154 
Cb: 

It 

~J3:~ 

! 

Oatbd L--{j' 

Pitch 

Business Premier 

Rows 1 - 12 Not applicable as the layout is 

herringbone with all seats having 

full length access into the aisle. 

Premium Economy 36" pitch in a straight line through 

Rows 23 - 32 the cabin, although personal 

space is greater (equivalent of 39 

40" pitch) as the seats are angled 

23° to the aircraft's centreline 

Air lVeJY ZeaJand 

DeJb"ery U''E051 • J 

@--" """""".-------_. 

Relevant Measurements 

Recline Bed Length Seat Width 

Seat com.erts 22" in the seat position. 

into a full lie 79.5" 33" in the lie flat position (at 

flat bed the shoulder) 

9" n/a 20" 

EXHIBIT A 

Aisle Width 

Ranges between 35.725 and 

38.5" 25" above the floor. More 

relevant measurement however is 

at ottoman height where the width 

ranges between 16.9 and 18.255" 

20.5" 25" above the floor, but a 

more relevant measurement is 

lower down where it is 17.03" at 

its narrowest 
EXHIBIT B 

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EXHIBIT D 

Air New Zealand 

Equivalent Alternative Submission - Moveable Arm Rests 

I Background 

This document is written in support of Air New Zealand's application for an 

Equivalent Alternative determination with respect to the requirement in 14 C.F.R. 

382.61 that aircraft seats have movable armrests in order to facilitate safe and 

dignified accessibility for passengers with mobility impairment. 

Air New Zealand's Business Premier and new Premium Economy "Spaceseats" do 

not have armrests in the sense that traditional aircraft seats do, so this application 

serves to illustrate to the Department that "persons with mobility impairments using 

aisle and boarding wheelchairs can transfer horizontally into a given seat without 

being lifted over an armrest or other obstacle." 1 

All techniques discussed in this document are shown in full detail on the 

accompanying DVD. 

I Acknowledgement 

The creation of the techniques and equipment described in this document and the 

accompanying DVD have been undertaken in full consultation with (but not limited 

to): 

• The Auckland (Otara) Spinal Unit for the development of the transfer 

techniques used and specialist advice on handling passengers with spinal 

issueslinjuries. 

• The Disability Resource Centre Auckland for consultancy on equipment 

and transfer techniques. 

• Air New Zealand Safety and Employee Wellbeing Group for providing 

ergonomic and specialist advice on equipment design, and development of 

transfer techniques and training. 

• Melrose Kiwi Concept Chairs for the design and manufacture of a new 

generation onboard aisle chair. This chair has been designed and built by 

paraplegics who are frequent airline travelers and world leaders in the 

design and manufacture of specialty (e.g. tailor-made and sporting) 

wheelchairs. 

I 14 CFR Part 382 - Preamble to 382.61 on page 27652 
I Equipment 

The techniques described in this document require specialised equipment, some of 

which is "off the shelf' product, and some of which has been designed and produced 

by/for Air New Zealand in conjunction with those acknowledged above. 

Short Transfer Board (700mm) Transfer Belt 

Onboard Aisle Chair 

Modified Sleep Sheet 

Slide Sheet 

Long Transfer Board (1200mm) 
I Lean and Brace Technique 

The Lean and Brace (LAB) Technique is used with passengers who need a high 

degree of assistance in transferring between the onboard aisle chair and the aircraft 

seat. Its purpose is to shift the passenger's body weight (without lifting) to facilitate 

the fitting of the "transfer belt" and also to position the ''transfer board" and "slide 

sheet". 

This technique can be facilitated by 2 or three staff members as circumstances require. 

The following describes the LAB technique for positioning the transfer board and 

slide sheet. 

Staff member 1 supports the customer's shoulders, and leans the customer slightly 

forward to the opposite side to where the transfer board and slide sheet need to be 

positioned. The staff member should place their feet well apart for balance and lean 

against fixtures in the cabin where possible for strength and stability. 

Staff member 2 supports the customer's legs and feet, lifting the leg (if necessary) to 

allow easy access for placement of the board. 

Staff member 3 positions the transfer board and slide sheet between the seat and the 

customer's near buttock. Extreme care should be taken to ensure no damage is done to 

the customer's person and/or assistive devices such as catheters. 

Staff member 1 then returns the customer to the upright position and maintains 

support of their shoulders while staff members 2 and 3 take their positions for the 

slide transfer. 

The same technique is used when fitting the transfer belt, but only two staff members 

are required in this situation. 
I Transfer Techniques 

Customers with mobility impairment have varying degrees of disability and therefore 

require varying degrees of assistance ranging from very little (for example a 

paraplegic who can self-transfer), to a full assist (for example a tetraplegic who has no 

leg or arm control). 

Good communication with the customer will establish their needs and consequently 

explain the assistance staff will provide. 

There are essentially 12 techniques that cover the spectrum according to the degree of 

disability, and are demonstrated in the accompanying DVD as follows: 

PREMIUM ECONOMY 

SELF TRANSFER 

'"*- Aisle Chair to Seat 

'"*- Seat to Aisle Chair 

ASSISTED TRANSFER 

'"*- Aisle Chair to Seat 

'"*- Seat to Aisle Chair 

BUSINESS PREMIER 

SELF TRANSFER 

'"*- Aisle Chair to Seat 

'"*- Seat to Aisle Chair 

'"*- Aisle Chair to Lie Flat Bed 

'"*- Lie Flat Bed to Aisle Chair 

ASSISTED TRANSFER 

'"*- Aisle Chair to Seat 

'"*- Seat to Aisle Chair 

'"*- Aisle Chair to Lie Flat Bed 

'"*- Lie Flat Bed to Aisle Chair 

This document describes the techniques that require the highest level of assistance, 

i.e. the 6 assisted transfers, on the premise that the maximum requirement also (more 

than) covers those with lesser needs. The self transfer techniques are far simpler and 

are fully covered in the DVD. 
PREMIUM ECONOMY 

ASSISTED TRANSFER + Aisle Chair to Seat 

Equipment required: 

• Aisle Chair 

• Transfer Belt 

• Short Transfer Board 

• Slide Sheet 

The customer sitting in the aisle chair is positioned beside the Premium Economy seat 

lining up the back of the aisle chair with the front ofthe side panel of the seat. 

The brakes are applied, the aisle chair armrest on the side of the transfer is raised, and 

the seat belts are unfastened. 

The transfer belt is fitted using the LAB technique. 

One end of the transfer board and slide sheet are positioned between the customer's 

near buttock and the aisle chair seat using the LAB technique, and the other end of the 

board is positioned on the aircraft seat. 

Position the customer's feet towards the seat giving consideration to ensure his/her 

legs will not bump into any fixtures during the transfer. 

One staff member grips the handle of the transfer belt (on the seat side), and one holds 

the customer's shoulders. 

On the count of3, staff conduct a synchronised slide into the seat. 

Move the aisle chair away and remove the transfer board, slide sheet, and transfer belt 

using the LAB technique as required. 

Ensure the customer is comfortable and the seat belt is fastened. 

PREMIUM ECONOMY 

ASSISTED TRANSFER + Seat to Aisle Chair 

Fit the transfer belt and position one end of the transfer board and slide sheet between 

the customer's near buttock and aircraft seat using the LAB technique, and the other 

end about 200mm into the aisle. 

Position the aisle chair under the transfer board, lining up the back of the aisle chair 

with the front of the side panel of the seat. 

The brakes are applied, and the aisle chair armrest on the side of the transfer is raised. 

One staff member grips the handle of the transfer belt (on the aisle side), and one 

holds the customer's shoulders. 
Position the customer's feet towards the aisle chair giving consideration to ensure 

his/her legs will not bump into any fixtures during the transfer. 

On the count of 3, staff conduct a synchronised slide into the aisle chair. 

The aisle chair arm rest is lowered and the seat belts fastened. 

BUSINESS PREMIER 

ASSISTED TRANSFER + Aisle Chair to Seat 

Equipment required: 

• Aisle Chair 

• Transfer Belt 

• Long Transfer Board 

• Slide Sheet 

Staff prepare the seat by removing the ottoman backshell and placing the transfer 

board and slide sheet onto the seat/ottoman. 

The customer sitting in the aisle chair is positioned beside the ottoman. 

The brakes are applied, the aisle chair armrest on the side of the transfer is raised, and 

the seat belts are unfastened. 

The transfer belt is fitted using the LAB technique. 

One end of the transfer board and slide sheet are positioned between the customer's 

near buttock and the aisle chair seat using the LAB technique, and the other end is 

positioned on the aircraft seat so the board spans across the ottoman and leg space. 

One staff member grips the handle of the transfer belt (on the seat side), and one holds 

the customer's shoulders. 

On the count of3, staff conduct a synchronised slide into the seat. This will generally 

need to be done in two controlled steps to ensure the customers legs are repositioned 

during the process. 

Move the aisle chair away and remove the transfer board, slide sheet, and transfer belt 

using the LAB technique as required. 

Ensure the customer is comfortable and the seat belt is fastened. 
BUSINESS PREMIER 

ASSISTED TRANSFER '* Seat to Aisle Chair 

Equipment required: 

• Aisle Chair 

• Transfer Belt 

• Long Transfer Board 

• Slide Sheet 

Staff remove the ottoman backs hell and fit the transfer belt using the LAB technique. 

One end of the transfer board is positioned between the customer's near buttock and 

the aircraft seat using the LAB technique, and the other end is positioned about 

200mrn into the aisle with the board spanning the seat leg space and ottoman. 

The aisle chair is positioned under the transfer board (beside the ottoman) and brakes 

applied. 

The aisle chair armrest on the side of the transfer is raised. 

One staff member grips the handle of the transfer belt (on the aisle side), and one 

holds the customer's shoulders. Ifnecessary a third holds the customer's feet/legs. 

On the count of 3, staff conduct a synchronised slide into the chair. This will 

generally need to be done in two controlled steps to ensure the customers legs are 

repositioned during the process. 

Remove the transfer board and slide sheet using the LAB technique. 

The aisle chair arm rest is lowered and the seat belts fastened. 

BUSINESS PREMIER 

ASSISTED TRANSFER '* Aisle Chair to Lie Flat Bed 

Equipment required: 

• Aisle Chair 

• Transfer Belt 

• Short Transfer Board 

• Slide Sheet 

Staff prepare the bed by converting it from a seat into the lie flat position. The 

modified bedsheet is then laid out ensuring the straps are accessible on both sides. 

(The ottoman backshell should already be off and the transfer belt fitted as the 

customer will have just been transferred out of the seat.) 

The aisle chair is positioned beside the ottoman (to the side of the bed) and brakes 

applied. 
The aisle chair armrest on the side of the transfer is raised, and the seat belt is 

unfastened. 

One end of the transfer board and slide sheet are positioned between the customer's 

near buttock and the aisle chair seat using the LAB technique, and the other end is 

positioned at the centre ofthe bed. 

One staff member grips the handle of the transfer belt (on the bed side), and one holds 

the customer's shoulders. If necessary a third staff member waits to hold the customer 

after the transfer has been completed. 

On the count of3, staff conduct a synchronised slide into the centre of the bed. 

The transfer belt is removed using the LAB technique, and the customer's legs are 

raised onto the end of the bed. 

The modified sleep sheet is raised up to the customers back and the straps are arranged 

around the customer and held by a staff member in front who uses them to lower the 

customer into the lie flat position. Another staff member should provide neck and 

head support as required. 

Ensure the customer is comfortable and the bed belt is fastened. 

BUSINESS PREMIER 

ASSISTED TRANSFER '* Lie Flat Bed to Aisle Chair 

Equipment required: 

• Aisle Chair 

• Transfer Belt 

• Short Transfer Board 

• Slide Sheet 

Raise the customer's legs at the knee and sit the customer up using the straps on the 

modified sleepsheet. Another staff member should provide neck and head support as 

required. 

Swivel the customer and place his/her legs over the side of the bed. 

The transfer belt is fitted using the LAB technique. 

One end of the transfer board and slide sheet is positioned between the customer's 

near buttock and the bed using the LAB technique, and the other end is positioned 

about 200mm into the aisle (across the ottoman). 

The aisle chair is positioned under the transfer board (beside the ottoman) and brakes 

applied. 

The armrest on the side of the transfer is raised. 
One staff member grips the handle of the transfer belt (on the aisle side), and one 

holds the customer's shoulders. If necessary a third holds the customer's feet/legs. 

On the count of3, staff conduct a synchronised slide into the chair. 

Remove the transfer board and slide sheet using the LAB technique. 

The aisle chair arm rest is lowered and the seat belts fastened. 
FULBRIGHT & .JAWORSKI L.L.P. 

A REGISTERED LIMITED LIABILITY PARTNERSHIP 

666 FIFTH AVENUE. 31ST FLOOR 

NEW YORK. NEW YORK 10103-3198 

WWW.FULBRIGHT.COM 

SGOT B ETTER@FULBRIGHT.COM 

DIRECT DIAL: (212) 318-3121 

VIA ELECTRONIC SUBMISSION 

Samuel Podberesky, Esq. 

TELEPHONE: 

FACSIMILE: 

March 4, 2010 

Assistant General Counsel for Aviation Enforcement and Proceedings 

U.S. Department of Transportation 

1200 New Jersey Avenue SW 

Room W96-322 

Washington, DC 20590 

Re: Docket DOT-OST-2008-0273 

Request of Air New Zealand Limited for 

Equivalent Alternative Determination 

Dear Mr. Podberesky: 

(212) 318-3000 

(212) 318-3400 

Pursuant to 14 C.F.R. 382.10, Air New Zealand Limited hereby requests an equivalent 

alternative determination with respect to the requirement in 14 C.F.R. 382.61 that aircraft seats 

have movable armrests. Air New Zealand has new Business Premier and Premium Economy 

seats on order that will not have any armrests as such. I However, in an excess of caution, Air 

New Zealand is seeking this equivalency determination. Air New Zealand will demonstrate that 

passengers with mobility impairments can move or be moved from an aisle wheelchair to or 

from these seats without going over any obstacles. 

As shown in the attached diagrams, the seats will be configured in a herringbone pattern, 

which maximizes the number of seats accessible to passengers with disabilities: 100% of the 

aisle seats in Business Premier and 57% of the aisle seats in Premium Economy will be 

accessible to passengers with disabilities. 

In support of this application, Air New Zealand is providing the Department with 

specifications for the new seats, diagrams of the new seating configurations, written procedures 

for both self transfers and assisted transfers, and, under separate cover, a DVD demonstrating 

these transfers. 

With respect to the DVD, the filming took place in a mock-up of a cabin using prototype 

seats as production of the new Premium Economy seats and the new ottomans with removable 

I Its Economy class seats will have movable aisle armrests. 

55479515.4 

AUSTIN. BEI.JING • DALLAS. DENVER. OU8AI • HONG KONG. HOUSTON. LONDON. Los ANGELES. MINNEAPOLIS 

MUNICH. NEW YORK. RIYADH. SAN ANTONIO. ST LouIs. WASHINGTON DC 
Samuel Podberesky, Esq. 

March 4,2010 

Page 2 

backshell for the Business Premier seats has not begun. The modified sleep sheet used in the 

filming of the assisted transfer into and out of the Business Premier seat in the lie-flat bed 

position was created for the filming and has since been put into production. Finally, it should be 

noted that the people demonstrating the transfer techniques in the DVD are volunteers, not 

actors. Those in uniform are Air New Zealand staff, and those being transferred are a paraplegic 

volunteer and a tetraplegic volunteer. 

The techniques and equipment used III the transfer methods were created III full 

consultation with: 

• The Auckland (Otara) Spinal Unit for the development of the transfer teclmiques 

used and specialist advice on handling passengers with spinal issueslinjuries. 

• The Disability Resource Centre Auckland for consultancy on equipment and 

transfer techniques. 

• Air New Zealand Safety and Employee Wellbeing Group for providing 

ergonomic and specialist advice on equipment design, and development of 

transfer techniques and training. 

• Melrose Kiwi Concept Chairs for the design and manufacture of a new generation 

onboard aisle chair. 

Air New Zealand seeks an equivalent alternative determination covering these Business 

Premier and Premium Economy seats on new Boeing 777-300 aircraft that are to be delivered 

beginning November 2010, Boeing 787 aircraft on order, and existing Boeing 767-300 and 777-

200 aircraft that may be retrofitted. 

Air New Zealand would be happy to answer any questions or provide additional 

infOlmation concerning this request. 

SG:cg 

Enclosures: 

Respectfully submitted, 

~/f~ Susan Gotbetter 

Exhibit A - Seating Configuration of B777 -319ER with Relevant Measurements 

Exhibit B - Diagram of Premium Economy Class 

Exhibit C - Diagram of Business Premier Class 

Exhibit D - Procedures for Transfers 

554795 J 54 
etl: 

J~~~~~~~~~~3 

I 

Outbd 6-----r 

Pitch 

Business Premier 

Rows 1 - 12 Not applicable as the layout is 

herringbone with all seats having 

full length access into the aisle. 

Premium Economy 36" pitch in a straight line through 

Rows 23 - 32 the cabin, although personal 

space is greater (equivalent of 39 

40" pitch) as the seats are angled 

23° to the aircraft's centreline 

Air NeJ" ZeaJand 

Deli,reIY; WEOSl 

@r 

Relevant Measurements 

Recline Bed Length Seat Width 

Seat con-.erts 22" in the seat position. 

into a full lie 79.5" 33" in the lie flat position (at 

flat bed the shoulder) 

9" n/a 20" 

EXHIBIT A 

Aisle Width 

Ranges between 35.725 and 

38.5" 25" abo-.e the floor. More 

relevant measurement howe-.er is 

at ottoman height where the width 

ranges between 16.9 and 18.255" 

20.5" 25" abo-.e the floor, but a 

more relevant measurement is 

lower down where it is 17.03" at 

its narrowest 
ffiG.I'lJ.538OO7-oo3 

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EXHIBIT D 

Air New Zealand 

Equivalent Alternative Submission - Moveable Arm Rests 

I Background 

This document is written in support of Air New Zealand's application for an 

Equivalent Alternative determination with respect to the requirement in 14 C.F.R. 

382.61 that aircraft seats have movable armrests in order to facilitate safe and 

dignified accessibility for passengers with mobility impairment. 

Air New Zealand's Business Premier and new Premium Economy "Spaceseats" do 

not have armrests in the sense that traditional aircraft seats do, so this application 

serves to illustrate to the Department that "persons with mobility impairments using 

aisle and boarding wheelchairs can transfer horizontally into a given seat without 

being lifted over an armrest or other obstacle." I 

All techniques discussed in this document are shown in full detail on the 

accompanying DVD. 

I Acknowledgement 

The creation of the techniques and equipment described in this document and the 

accompanying DVD have been undertaken in full consultation with (but not limited 

to): 

• The Auckland (Otara) Spinal Unit for the development of the transfer 

techniques used and specialist advice on handling passengers with spinal 

issueslinjuries. 

• The Disability Resource Centre Auckland for consultancy on equipment 

and transfer techniques. 

• Air New Zealand Safety and Employee Wellbeing Group for providing 

ergonomic and specialist advice on equipment design, and development of 

transfer techniques and training. 

• Melrose Kiwi Concept Chairs for the design and manufacture of a new 

generation onboard aisle chair. This chair has been designed and built by 

paraplegics who are frequent airline travelers and world leaders in the 

design and manufacture of specialty (e.g. tailor-made and sporting) 

wheelchairs. 

I 14 CFR Part 382 - Preamble to 382.61 on page 27652 
I Equipment 

The teclmiques described in this document require specialised equipment, some of 

which is "off the shelf' product, and some of which has been designed and produced 

by/for Air New Zealand in conjunction with those acknowledged above. 

Short Transfer Board (700mm) Transfer Belt 

Onboard Aisle Chair 

Modified Sleep Sheet 

Slide Sheet 

Long Transfer Board (1200mm) 
I Lean and Brace Technique 

The Lean and Brace (LAB) Technique is used with passengers who need a high 

degree of assistance in transferring between the onboard aisle chair and the aircraft 

seat. Its purpose is to shift the passenger's body weight (without lifting) to facilitate 

the fitting of the "transfer belt" and also to position the "transfer board" and "slide 

sheet". 

This technique can be facilitated by 2 or three staff members as circumstances require. 

The following describes the LAB technique for positioning the transfer board and 

slide sheet. 

Staff member 1 supports the customer's shoulders, and leans the customer slightly 

forward to the opposite side to where the transfer board and slide sheet need to be 

positioned. The staff member should place their feet well apart for balance and lean 

against fixtures in the cabin where possible for strength and stability. 

Staffmember 2 supports the customer's legs and feet, lifting the leg (if necessary) to 

allow easy access for placement of the board. 

Staff member 3 positions the transfer board and slide sheet between the seat and the 

customer's near buttock. Extreme care should be taken to ensure no damage is done to 

the customer's person and/or assistive devices such as catheters. 

Staff member 1 then returns the customer to the upright position and maintains 

support of their shoulders while staff members 2 and 3 take their positions for the 

slide transfer. 

The same technique is used when fitting the transfer belt, but only two staff members 

are required in this situation. 
I Transfer Techniques 

Customers with mobility impairment have varying degrees of disability and therefore 

require varying degrees of assistance ranging from very little (for example a 

paraplegic who can self-transfer), to a full assist (for example a tetraplegic who has no 

leg or arm control). 

Good communication with the customer will establish their needs and consequently 

explain the assistance staff will provide. 

There are essentially 12 teclmiques that cover the spectrum according to the degree of 

disability, and are demonstrated in the accompanying DVD as follows: 

PREMIUM ECONOMY 

SELF TRANSFER 

'*- Aisle Chair to Seat 

'*- Seat to Aisle Chair 

ASSISTED TRANSFER 

'*- Aisle Chair to Seat 

'*- Seat to Aisle Chair 

BUSINESS PREMIER 

SELF TRANSFER 

'*- Aisle Chair to Seat 

'*- Seat to Aisle Chair 

'*- Aisle Chair to Lie Flat Bed 

'*- Lie Flat Bed to Aisle Chair 

ASSISTED TRANSFER 

'*- Aisle Chair to Seat 

'*- Seat to Aisle Chair 

'*- Aisle Chair to Lie Flat Bed 

'*- Lie Flat Bed to Aisle Chair 

This document describes the techniques that require the highest level of assistance, 

i.e. the 6 assisted transfers, on the premise that the maximum requirement also (more 

than) covers those with lesser needs. The self transfer teclmiques are far simpler and 

are fully covered in the DVD. 
PREMIUM ECONOMY 

ASSISTED TRANSFER '* Aisle Chair to Seat 

Equipment required: 

• Aisle Chair 

• Transfer Belt 

• Short Transfer Board 

• Slide Sheet 

The customer sitting in the aisle chair is positioned beside the Premium Economy seat 

lining up the back of the aisle chair with the front of the side panel of the seat. 

The brakes are applied, the aisle chair armrest on the side of the transfer is raised, and 

the seat belts are unfastened. 

The transfer belt is fitted using the LAB technique. 

One end of the transfer board and slide sheet are positioned between the customer's 

near buttock and the aisle chair seat using the LAB technique, and the other end of the 

board is positioned on the aircraft seat. 

Position the customer's feet towards the seat giving consideration to ensure his/her 

legs will not bump into any fixtures during the transfer. 

One staff member grips the handle of the transfer belt (on the seat side), and one holds 

the customer's shoulders. 

On the count on, staff conduct a synchronised slide into the seat. 

Move the aisle chair away and remove the transfer board, slide sheet, and transfer belt 

using the LAB technique as required. 

Ensure the customer is comfortable and the seat belt is fastened. 

PREMIUM ECONOMY 

ASSISTED TRANSFER '* Seat to Aisle Chair 

Fit the transfer belt and position one end of the transfer board and slide sheet between 

the customer's near buttock and aircraft seat using the LAB technique, and the other 

end about 200mm into the aisle. 

Position the aisle chair under the transfer board, lining up the back ofthe aisle chair 

with the front of the side panel of the seat. 

The brakes are applied, and the aisle chair armrest on the side of the transfer is raised. 

One staff member grips the handle ofthe transfer belt (on the aisle side), and one 

holds the customer's shoulders. 
Position the customer's feet towards the aisle chair giving consideration to ensure 

his/her legs will not bump into any fixtures during the transfer. 

On the count 00, staff conduct a synchronised slide into the aisle chair. 

The aisle chair arm rest is lowered and the seat belts fastened. 

BUSINESS PREMIER 

ASSISTED TRANSFER '* Aisle Chair to Seat 

Equipment required: 

• Aisle Chair 

• Transfer Belt 

• Long Transfer Board 

• Slide Sheet 

Staffprepare the seat by removing the ottoman backshell and placing the transfer 

board and slide sheet onto the seat/ottoman. 

The customer sitting in the aisle chair is positioned beside the ottoman. 

The brakes are applied, the aisle chair armrest on the side of the transfer is raised, and 

the seat belts are unfastened. 

The transfer belt is fitted using the LAB technique. 

One end of the transfer board and slide sheet are positioned between the customer's 

near buttock and the aisle chair seat using the LAB technique, and the other end is 

positioned on the aircraft seat so the board spans across the ottoman and leg space. 

One staff member grips the handle of the transfer belt (on the seat side), and one holds 

the customer's shoulders. 

On the count 00, staff conduct a synchronised slide into the seat. This will generally 

need to be done in two controlled steps to ensure the customers legs are repositioned 

during the process. 

Move the aisle chair away and remove the transfer board, slide sheet, and transfer belt 

using the LAB technique as required. 

Ensure the customer is comfortable and the seat belt is fastened. 
BUSINESS PREMIER 

ASSISTED TRANSFER "*- Seat to Aisle Chair 

Equipment required: 

• Aisle Chair 

• Transfer Belt 

• Long Transfer Board 

• Slide Sheet 

Staff remove the ottoman backs hell and fit the transfer belt using the LAB technique. 

One end of the transfer board is positioned between the customer's near buttock and 

the aircraft seat using the LAB technique, and the other end is positioned about 

200mm into the aisle with the board spanning the seat leg space and ottoman. 

The aisle chair is positioned under the transfer board (beside the ottoman) and brakes 

applied. 

The aisle chair armrest on the side of the transfer is raised. 

One staff member grips the handle of the transfer belt (on the aisle side), and one 

holds the customer's shoulders. If necessary a third holds the customer's feet/legs. 

On the count of 3, staff conduct a synchronised slide into the chair. This will 

generally need to be done in two controlled steps to ensure the customers legs are 

repositioned during the process. 

Remove the transfer board and slide sheet using the LAB technique. 

The aisle chair arm rest is lowered and the seat belts fastened. 

BUSINESS PREMIER 

ASSISTED TRANSFER "*- Aisle Chair to Lie Flat Bed 

Equipment required: 

• Aisle Chair 

• Transfer Belt 

• Short Transfer Board 

• Slide Sheet 

Staff prepare the bed by converting it from a seat into the lie flat position. The 

modified bedsheet is then laid out ensuring the straps are accessible on both sides. 

(The ottoman backshell should already be off and the transfer belt fitted as the 

customer will have just been transferred out of the seat.) 

The aisle chair is positioned beside the ottoman (to the side of the bed) and brakes 

applied. 
The aisle chair armrest on the side of the transfer is raised, and the seat belt is 

unfastened. 

One end of the transfer board and slide sheet are positioned between the customer's 

near buttock and the aisle chair seat using the LAB technique, and the other end is 

positioned at the centre of the bed. 

One staff member grips the handle of the transfer belt (on the bed side), and one holds 

the customer's shoulders. If necessary a third staff member waits to hold the customer 

after the transfer has been completed. 

On the count of3, staff conduct a synchronised slide into the centre of the bed. 

The transfer belt is removed using the LAB technique, and the customer's legs are 

raised onto the end of the bed. 

The modified sleepsheet is raised up to the customers back and the straps are arranged 

around the customer and held by a staff member in front who uses them to lower the 

customer into the lie flat position. Another staff member should provide neck and 

head support as required. 

Ensure the customer is comfortable and the bed belt is fastened. 

BUSINESS PREMIER 

ASSISTED TRANSFER + Lie Flat Bed to Aisle Chair 

Equipment required: 

• Aisle Chair 

• Transfer Belt 

• Short Transfer Board 

• Slide Sheet 

Raise the customer's legs at the knee and sit the customer up using the straps on the 

modified sleepsheet. Another staff member should provide neck and head support as 

required. 

Swivel the customer and place his/her legs over the side of the bed. 

The transfer belt is fitted using the LAB technique. 

One end of the transfer board and slide sheet is positioned between the customer's 

near buttock and the bed using the LAB technique, and the other end is positioned 

about 200mm into the aisle (across the ottoman). 

The aisle chair is positioned under the transfer board (beside the ottoman) and brakes 

applied. 

The armrest on the side ofthe transfer is raised. 
One staff member grips the handle of the transfer belt (on the aisle side), and one 

holds the customer's shoulders. Ifnecessary a third holds the customer's feet/legs. 

On the count of 3, staff conduct a synchronised slide into the chair. 

Remove the transfer board and slide sheet using the LAB technique. 

The aisle chair arm rest is lowered and the seat belts fastened.