Exe mption 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 exemptio n from§§ 25.5 62 & 25.785(b) ofTitle 14 , Code of Federa l Regulations Regu lato ry Docket No. FAA-2016-4358

GRANT OF EXEMPTI ON

B y letter dated February 15 , 2 016, Mr. Paul Egan , Chief Executive Officer of Aero Medical Products Mf g., In c., 2230 Stonebrid ge Rd. , West Bend, WI 53095 petitioned fo r exemption from th e requirements of§§ 25.562 and 25.785(b) ofTitl e 14, Code of Federa l Regul atio n s (14 CFR). T he proposed exemption , if granted , would perm it a medi cal s tretcher in stall ation on Gulfstream Ae rospace LP Mode l G ulf stream 200 and Gal axy seri es a irplanes. The petitioner reque s ts relief from the following regulations: Section 25.562 , requires compliance with the stmctural and occupant-protection requireme nt s of§ 25.562 as adopted by Amendmen t 25-64. Section 25.785(b ) , as amend ed by Amendment 25

- 72, requires th at each seat, berth, safety belt , harness , and ad j acent part of the airplane at eac h stat ion designated as occup iable durin g takeoff and landing must be designed so that a person making pr oper u se of these fac ili t ies will not suffer serious injury in an emergency land in g as a result of the inertia forces spec ified in §§ 25.561 and 25.562. The petitioner s upports their request with th e following: This section quotes the petitioner 's information. Aero Medical Products Mfg. , Inc. , hereby p eti t ions for an exemption from 25.562 and part of25.785(b) of T itle 14 , Code of Federal Regulations ( 14 CFR) to the extent necessary to p ermi t install ation of medical- p atie nt litter assemblies, for transport ofpersons 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 CF R part 25 , 23,27 and 29 airplanes. The certification requirements for those airplanes have resulted in good service his to ry with no adverse experience. No medical-patient loading and utility system installations hav e been shown to meet th e dynamic criteria. 14 CFR parts 23 , 27, and 29 specifically exclude stretcher litters fro m the dynamic criteria. Aero**dical** Product s Mf g . , Inc notes that the estimated cost of demonstrating compliance is quite hi gh considering the limited number of units for which the cost could be amortized. Since none have bee n shown to comply with the dynamic tes t criteria, stretcher s cannot cuJTently be used on airplanes whose t ype certificate basis includes the dynamic requirements. In this case , a person who needs to travel fo r essential medical care can eith er 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 b e fatal). Another alternative would be flying an alternate route on an airplane the certificat ion 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 Ae ro Medical Products Mfg., Inc feels t hat granting the petition wou ld be in the public interes t for the fo llo w ing reasons:

• The exemp tion would relieve an economic burden on a segment of the traveling public already dealing with adversity ,
• T he leve l of safety that would be provided is an acceptable level of safety given f he limited usage and exposure of t he stretcher ,
• Compliance with the dynamic test requirements wo uld be difficult at best , and very expensive , whi le returning a marginal safety benefit. In add ition , 14 CFR 2 5

. 562 is written for seats and would not be easily applied to a li tte r. 

### Request to forego s ummary-notice publication in the Federal Register for public comment Aero Med ical Prod uct s Mfg. , Inc al so requests that the FAA waiv e publicat io n a nd public comment fo r goo d caus e. Aero Medical Products Mfg. , Inc applied for the STC in J une, 2013 and has commitments requiting an STC by Sept 2013. A delay in acting on the petition would be detrimental to

2I Aero Med ica l Products Mfg., Inc as well as delaying the deployment of li fesav ing equ ipment. 

### Additional inform atio n, views, or arguments supporting this request This petition is co n s istent w ith Exe mption No. 6625, 6920, 7318 and 7393 , which were granted for LifePort litter installations in Cessna 750 (C itation X), Falcon 2000 , Cessna Citati on 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 inte nt be covered by:

• a lim itat ion in the Fli ght Manual Supplement , and

• a conspicuously located placard that states that occupancy of the stretcher litter during takeoff and landing i s for non-ambulatory persons only. 

### Operation outside the United States T hi s exemptio n is intend e d for operation inside and outside the US as many people travel outs ide the US because we are a G lobal society seek i ng business with th e world. The Gulfstrea,m aircraft is a g lobal type aircraft. Federa l R egiste r 

### publication Th e FAA has de\: ermined that good cause exists for waiv i ng the requirement for Federal R egister publication fo r public comment because the request i s identical in a ll material respec ts to previous l y granted exemptions; th e exe mption , if granted, would not set a precedent; and any de l ay in acting on this petiti on would be detrimental to Aero Medical Products Mfg. , Inc. 

### The FAA's analysis For the reason s stated by the petitioner , the FAA agrees t hat granti ng this petition is i n the publ i c in terest. We have cons i dered the cost implications and the overall benefi ts resu lting from the use of a medical stretcher

. The FAA agrees that demon strating compliance with the requirements of 

### § 25.562 would be difficult, if not impossib le, and applying the ex isting pass/fai l c ri teria to these installations is questionable. T he need for medically fragile people to receive necessary and potentially lif e-saving medical attention outweighs the increase in the level of safety gained by requiring medical stretc h ers to meet dynamic testing requirements. Also , thi s exemption would pe1mit the trans p ortation of medically fragile people, from countries Jacking the med i cal expe 1ti se or equipment to address a certain medical condition , to a country with more advance d medica l experti se and faci litie s. The FAA agrees that stretchers for medical use were not considered in the context of the dynamic-test re q uirements of§ 25.562 whe n that regu lation was developed. Occupancy of other be 1 ths during takeoff and landing for amb ul atory persons was not considered feasible under the conditions of§ 25.562; and for the purposes of comp li ance , stretchers are cons idered " berths

. "The FAA acknowledges th at part 25 differs from other aircraft regulatory s tandards in this re g ard. With respect to the overa ll level of safety , the FAA notes that full compliance with the requireme nts of§ 25 .561 will be r equired for the med ical stretcher. Thi s is consistent with the standards for all seats prior to the adoption of§ 25.562. Thus, as noted by the petitioner, an alternative to thi s exemption would be to seek transportation on a n ai rplan e that does not require dynamic testing as part of its certification basis ( i.e. , an airplane with an earlier certification basis). While thi s alternative is a viab le option , the FAA does not consider this a desirable approac h. A irp lanes cert i ficated wi th § 25.562 included in their certification basis have incorporated many safety advances not found on earli er-mode l airplane s . I t would be cou nterpro duc tive to restrict this type of transportation to those earlier models. The FAA also note s that the petition request s that an STC be issued by September2013

. In a conversation with Mr. Egan, he clarified th e en·or, stating that an STC amendment is needed by March 2016. The 

### FAA's decis ion In consideration of th e foregoing, I find that a g rant 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 Product s Mfg. , Inc. , is granted an exemption fro m the requirements of 14 CFR 25.562 and 25

.785(b) to the extent necessary to allow install ation of a med ical stretcher on Gulfstr eam Aerospace LP Model Gulfstream 200 and Galaxy series airplanes. The OP.erating limitations section of the airplane flight manual s upplement must state that occupanc y t f th e s tre tcher berth is limited to non-ambulatory person s. In add ition , the I following text o:· equivalent text must be stated on a placard conspicuou s ly located near the s tretcher berth(c;, : Occupancy is limited to non - ambulatory p ersons. Issued in

### Rento~1**,** Washington, on 

## MAR 2 5 2016

# ~1~ Michael Ka szycki Acting Manager, T rans po11 Airplane Dir ecto rate A ircraft Certification Se r v ice



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