“Petition for Exemption” in order to use a Crelling-Model 27 

(Houdini) Harness

I am writing to request an exemption from 14 CFR §§ 121.311(b) and 135.128(a) to the 

extent required for Miss Mia Fong to be able to use a Crelling-Model 27 (Houdini) Harness

as a restraint system during all phases of flight while aboard an aircraft. In addition, if my

petition is granted, I request that any U.S. air carrier operating under part 121 or part 135

while Mia is aboard its aircraft is granted an exemption from 14 CFR § 121.311(b) and (c) or 

135.128(a) and (b), as appropriate, to the extent necessary to allow Mia to use a CrellingModel 27 (Houdini) Harness as a restraint system during all phases of flight while aboard an 

aircraft in operations under either 121 or 135. We plan to fly on part 121 operators and also 

plan to take a helicopter tour under part 135.

I believe the pertinent sections from 14 CFR from which we seek relief are Section 121.311 

Seats, safety belts, and shoulder harnesses and Section 135.128 Use of Safety Belts and child 

restraint systems.

My daughter is 10 years old, weighs 48 pounds and is 52 inches tall. My daughter’s physical 

condition is as follows: Mia has cerebral palsy and is designated as a spastic quadriplegic. 

She does not have control of her trunk and is unable to sit without supports. She also does not 

walk so she uses a wheelchair for mobility and that and her chairs at home are equipped with 

lateral supports and a chest harness. As a result of her physical condition, she needs the 

support and security provided by the Crelling-Model 27 (Houdini) Harness. Furthermore, 

because of her disability, Mia is not able to communicate in any form – verbal or sign 

language – and is therefore incapable of literal compliance with the regulation. I am also 

submitting the following contact information: Mrs Janice Fong, 1 Fair View, Dalton in 

Furness, Cumbria LA15 8RZ, United Kingdom – janice@cowlinginsurance.co.uk

I understand that the regulation is written to create a high level of safety for each individual 

passenger by ensuring that they are securely restrained in their seats during all phases of 

flight. The regulation also ensures that an individual does not cause harm to other passengers 

on the airplane by being thrown into them during turbulent or emergency conditions.

I propose that Mia be allowed to occupy a Crelling-Model 27 (Houdini) Harness, which will 

be securely strapped around a passenger seat with two straps. Mia will then be secured with 

the front straps of the Crelling-Model 27 (Houdini) Harness. Although Mia will use the 

Crelling-Model 27 (Houdini) Harness to provide safety, security and upper body support, 

the aircraft seat belt will also be used as the primary method of restraint. The Crelling-Model 

27 (Houdini) Harness will not block any passenger’s view of the “Fasten Seat Belt” sign, 

“No Smoking” sign or any required exit sign. It will also be placed in such a manner that its 

location will not restrict access to, or use of, any required emergency exit, or of the aisle in 

the passenger compartment.

The Crelling-Model 27 (Houdini) Harness is used to offer postural support, a certain degree 

of restraint, as well as assistance in seating the occupant in an upright sitting position. The 

Crelling-Model 27 (Houdini) Harness is designed for the use of persons with physical 

disabilities where extra support and positioning is required during travel. The harness

consists of a full body harness which is fitted horizontally around the seat back with two 

horizontal fixing straps. 
This proposal will satisfy the intended purpose of the regulations by ensuring that Mia is 

securely restrained by the aircraft seat belt, but is also provided additional safety, security and 

support by the Crelling-Model 27 (Houdini) Harness internal restraints. This ensures a high 

level of safety for Mia and a high level of safety for the other passengers and crew on the 

airplane. In fact, in Mia’s case, safety is greatly enhanced by the extra support and security 

that the Crelling-Model 27 (Houdini) Harness will provide during the entire flight.

Enhancing safety for Mia is in the public interest. In addition, the public interest is also 

served by the fact that the use of the Crelling-Model 27 (Houdini) Harness allows her to use 

commercial air transportation. Without the support and security of this specially designed 

restraint system, she would be unable to fly commercially.

I also believe that, with certain limitations established by the FAA in a grant to this petition, 

there can be an equivalent level of safety to that provided by the affected regulation. 

As stated previously, the Crelling-Model 27 (Houdini) Harness will be securely strapped 

around the passenger seat with two straps. I understand that with the additional weight of 

Mia attached to the seatback, the seatback may move forward more quickly in an accident 

scenario. I also understand that this might cause a higher Head Injury Criteria (HIC) load for 

the person seated in the seat behind the passenger using the Crelling-Model 27 (Houdini) 

Harness (because the seatback moving forward more quickly would mean that it would not 

be there to attenuate the energy from the impact of the person seated behind the person using 

the Crelling-Model 27 (Houdini) Harness. 

In order to achieve an equivalent level of safety as that provided by the affected regulation, I 

propose that the FAA establish a limitation in a grant to this petition that Mia only sits in a 

passenger seat with no passenger seated behind her. Therefore, no unsafe condition would 

exist for a passenger seated behind Mia whilst she is using the Crelling-Model 27 (Houdini) 

Harness. 

I also propose that all operations under the exemption be conducted with at least one of Mia’s 

parents or a caregiver accompanying her. In addition, I propose that Mia’s parent or caregiver 

be required to carry a copy of the exemption with them during the flight and to advise the 

operator about the contents of the exemption at least 48 hours before the date of each flight.

I also request that the processing of this petition not be delayed for publication and comment 

in the Federal Register. We want to travel on 19 July 2015. If you take the time to put this in 

the Federal Register, it will delay the process and we may not be able to travel in this 

timeframe.

If it is necessary to put a summary in the Federal Register, I submit the following:

This is a request for an exemption from 14 CFR § 121.311(b) and (c), as well as §135.128(a) 

and (b), to the extent required for a person to use a Crelling-Model 27 (Houdini) Harness on 

an aircraft. Due to physical challenges, without the support and security of the CrellingModel 27 (Houdini) Harness, this person would be unable to fly. In this case, the safety of 

this person is greatly enhanced by the extra support and security that the Crelling-Model 27 

(Houdini) Harness will provide for her during the flight