Exemption No. 15779 

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

RENTON, WASHINGTON 98057-3356 

In the matter of the petition of 

Aero Medical Products Mfg., Inc. 

for an exemption from§§ 25.562 & 25.785(b) 

ofTitle 14, Code of Federal Regulations 

Regulatory Docket No. FAA-2016-4358 

GRANT OF EXEMPTION 

By letter dated February 15, 2016, Mr. Paul Egan, Chief Executive Officer of Aero Medical 

Products Mfg., Inc., 2230 Stonebridge Rd., West Bend, WI 53095 petitioned for exemption from 

the requirements of§§ 25.562 and 25.785(b) ofTitle 14, Code of Federal Regulations (14 CFR). 

The proposed exemption, if granted, would permit a medical stretcher installation on Gulfstream 

Aerospace LP Model Gulfstream 200 and Galaxy series airplanes. 

The petitioner requests relief from the following regulations: 

Section 25.562, requires compliance with the stmctural and occupant-protection 

requirements of§ 25.562 as adopted by Amendment 25-64. 

Section 25. 785(b ), as amended by Amendment 25-72, 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 these facilities will not suffer serious injury in an emergency landing as a result of 

the inertia forces specified in §§ 25.561 and 25.562. 

The petitioner supports their request with the following: 

This section quotes the petitioner's information. 

Aero Medical Products Mfg., Inc., hereby petitions for an exemption from 25.562 and 

part of25.785(b) ofTitle 14, Code of Federal Regulations (14 CFR) to the extent 

necessary to permit installation of medical-patient litter assemblies, for transport of 
persons whose medical condition dictates such accommodations, on Gulfstream Model 

Galaxy and G-200 series airplanes. 

Extent of relief, and reason 

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

Gulfstream I, II, III, IV and 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. 14 CFR parts 23, 27, and 29 specifically 

exclude stretcher litters from the dynamic criteria. 

Aero dical Products Mfg., Inc notes that the estimated cost of demonstrating 

compliance is quite 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 cuJTently 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 1 0 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 airplane 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 

fhe limited usage and exposure of the stretcher, 

• 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. 

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. 

Aero Medical Products Mfg., Inc applied for the STC in June, 2013 and has commitments 

requiting an STC by Sept 2013. A delay in acting on the petition would be detrimental to 

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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. In this case, the intent for the exemption is 

for non-ambulatory persons. Aero Medical Products Mfg., Inc recommends that this 

intent be covered by: 

• a limitation in the Flight Manual Supplement, and 

• a conspicuously located placard that states that occupancy of the stretcher litter 

during takeoff and landing is for non-ambulatory persons only. 

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 

Gulfstrea,m aircraft is a global type aircraft. 

Federal Register publication 

The FAA has de\:ermined that good cause exists for waiving the requirement for Federal Register 

publication for public comment because the request is identical in all material respects to 

previously granted exemptions; the exemption, if granted, would not set a precedent; and any 

delay in acting on this petition would be detrimental to Aero Medical Products Mfg., Inc. 

The FAA's analysis 

For the reasons stated by the petitioner, the FAA agrees that granting this petition is in the public 

interest. We have considered the cost implications and the overall benefits resulting from the use 

of a medical stretcher. The FAA agrees that demonstrating compliance with the requirements of 

§ 25.562 would be difficult, if not impossible, and applying the existing pass/fail criteria to these 

installations is questionable. The need for medically fragile people to receive necessary and 

potentially life-saving medical attention outweighs the increase in the level of safety gained by 

requiring medical stretchers to meet dynamic testing requirements. Also, this exemption would 

pe1mit the transp ortation of medically fragile people, from countries Jacking the medical 

expe1tise or equipment to address a certain medical condition, to a country with more advanced 

medical expertise and facilities. 

The FAA agrees that stretchers for medical use were not considered in the context of the 

dynamic-test requirements of§ 25.562 when that regulation was developed. Occupancy of other 

be1ths during takeoff and landing for ambulatory persons was not considered feasible under the 

conditions of§ 25.562; and for the purposes of compliance, stretchers are considered "berths." 
The FAA acknowledges that part 25 differs from other aircraft regulatory standards in this 

regard. 

With respect to the overall level of safety, the FAA notes that full compliance with the 

requirements of§ 25.561 will be required for the medical stretcher. This is consistent with the 

standards for all seats prior to the adoption of§ 25.562. Thus, as noted by the petitioner, an 

alternative to this exemption would be to seek transportation on an airplane that does not require 

dynamic testing as part of its certification basis (i.e., an airplane with an earlier certification 

basis). While this alternative is a viable option, the FAA does not consider this a desirable 

approach. Airplanes certificated with § 25.562 included in their certification basis have 

incorporated many safety advances not found on earlier-model airplanes. It would be 

counterproductive to restrict this type of transportation to those earlier models. 

The FAA also notes that the petition requests that an STC be issued by September2013. In a 

conversation with Mr. Egan, he clarified the en·or, stating that an STC amendment is needed by 

March 2016. 

The FAA's decision 

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

Therefore, pursuant to the authority contained in 49 U.S.C. 40113 and 44701, delegated to me by 

the Administrator, Aero Medical Products Mfg., Inc., is granted an exemption from the 

requirements of 14 CFR 25.562 and 25. 785(b) to the extent necessary to allow installation of a 

medical stretcher on Gulfstream Aerospace LP Model Gulfstream 200 and Galaxy series 

airplanes. The OP.erating limitations section of the airplane flight manual supplement must state 

that occupancy t f the stretcher berth is limited to non-ambulatory persons. In addition, the I 

following text o:· equivalent text must be stated on a placard conspicuously located near the 

stretcher berth( c;,: 

Occupancy is limited to non-ambulatory persons. 

Issued in Rento~1 , Washington, on MAR 2 5 2016 

~1~ Michael Kaszycki 

Acting Manager, Transpo11 Airplane Directorate 

Aircraft Certification Service 

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