AFS-15-125-E

January 23, 2015

 Exemption No. 10690D

 Regulatory Docket No. FAA-2013-0034

Ms. Stacy Bechdolt, Esq.

Director, Safety and Technical Affairs

Regional Airline Association

2025 M Street NW, Suite 800

Washington, DC 20036 

Mr. Robert Ireland

Managing Director, Engineering and Maintenance

Airlines for America

1301 Pennsylvania Avenue NW, Suite 1100

Washington, DC 20004

Mr. George Paul

Director of Technical Services

National Air Carrier Association 

1000 Wilson Boulevard, Suite 1700

Arlington, VA 22209

Dear Ms. Bechdolt:

This letter is to inform you that we have granted your petition to extend and amend Exemption

No. 10690, as amended. It explains the basis for our decision, describes its effect, and lists 

the conditions and limitations.

The Basis for Our Decision

By letter dated October 30, 2014, you petitioned the Federal Aviation Administration (FAA) 

on behalf of Regional Airline Association (RAA), Airlines for America (A4A), and National 
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Air Carrier Association (NACA) for an extension to an amendment of Exemption No. 10690, 

as amended. Specifically, the petitioners requested the following:

1. Extension of Exemption 10690 pertaining to Atropine, that expires on 

January 31, 2015.

2. The extension should allow kits to remain in the field that are short of the substances 

until normally returned for refurbishment (“grandfathering”), regardless of recovery of 

market supplies. The intent is to continue extensions for some period after supplies 

are restored to avoid a sudden need to refurbish kits off-schedule, unreasonably 

straining supply capabilities.

3. Carriers may use their own effective means to communicate that kits already in the 

field are covered by the proposed extension despite the expiration date of January 

2015 that may be apparent.

4. The extension should stipulate that it must be readily apparent that kits not containing 

Atropine are in compliance with Extension 10690 “as revised or extended,” without 

displaying the expiration date. 

5. Deletion of the requirement to carry a copy of the exemption on board the affected 

aircraft.

Your current exemption from § 121.803(c)(3) and Appendix A of Title 14, Code of Federal 

Regulations (14 CFR) allows RAA, A4A, and NACA relief from the requirement to include 

Atropine in an Emergency Medical Kit (EMK). A condition of that exemption includes a 

requirement to carry a copy of the exemption aboard the affected aircraft. 

In your petition, you indicate that there has been no change in the conditions and reasons 

relative to public interest and safety that were the basis for granting the original exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested extension and amendment to the exemption 

would not set a precedent, and any delay in acting on this petition would be detrimental to 

RAA, A4A, and NACA.

Our Decision

The FAA has determined that the justification for the issuance of Exemption No. 10690, as 

amended, remains valid with respect to the this exemption and is in the public interest. 

Therefore, under the authority provided by 49 U.S.C. §§ 106(f), 40113, and 44701, which the 

FAA Administrator has delegated to me, passenger member airlines of Regional Airline 

Association, Airlines for America, and National Air Carrier Association, and all similarly 

situated air carriers, are granted an extension of its exemption from 14 CFR § 121.803(c)(3) 
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and Appendix A of part 121, to the extent necessary to relieve its holders from the 

requirement to carry two single dose ampules of Atropine 5cc injectable, in required on-board 

EMKs when, due to the nationwide shortage discussed herein, they are unable to procure these 

items for the kits. Should the supply of single dose ampules of Atropine 5 cc injectable 

become available, exemption holders should refurbish the kits with atropine at the next 

scheduled refurbishment date. 

With regard to the request to amend the conditions and limitations, the FAA denies the 

petitioners’ request to waive the requirement to maintain a copy of the most current 

exemption with the expiration date on board the affected aircraft, because doing so would not

be in the public interest. This exemption is subject to the following conditions and 

limitations:

Conditions and Limitations

1. This exemption applies to part 119 certificate holders authorized to conduct 

part 121 passenger carrying operations.

2. A copy of this exemption must be carried on board each aircraft operating with 

emergency medical kits that do not include Atropine as required by Appendix A of 

part 121.

3. As part of the requirement under §119.43(c) to keep each of its employees and other 

persons used in its operation informed of the provisions of their operations 

specifications that apply to that employee’s or person’s duties and responsibilities, the 

certificate holders must inform crewmembers that any emergency medical kits on 

board the aircraft may not contain Atropine.

4. This exemption may be used for flights conducted outside of the United States.

The Effect of Our Decision

Our decision extends the termination date of Exemption No. 10690, as amended, to 

January 31, 2016, unless sooner superseded or rescinded. 

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service