Exemption No. 10380 

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 20591 

 

In the matter of the petition of 

 

CONTINENTAL AIRLINES, INC. Regulatory Docket No. FAA-2011-0617

 

for an exemption from § 121.317(d) 

of Title 14, Code of 

Federal Regulations 

 

PARTIAL GRANT OF EXEMPTION 

 By letter dated June 6, 2011, Mr. David Pohlmeyer, Manager Quality Assurance, 

Continental Airlines, Inc. (CALA), 1600 Smith Street, Houston, Texas 77002, petitioned the 

Federal Aviation Administration (FAA) on behalf of Continental for an exemption from 

§ 121.317(d) of Title 14, Code of Federal Regulations (14 CFR). The proposed exemption, if 

granted, would allow CALA to operate all of its Boeing Model 787 aircraft without there 

being affixed to each forward bulkhead or partition and each passenger seat back, a placard 

that reads "Fasten Seat Belt While Seated.” CALA has petitioned for the FAA to approve the 

use of symbolic representation placards in lieu of text for all CALA Boeing Model 787 

aircraft. 

The petitioner requests relief from the following regulation:

Section 121.317(d) prescribes, in pertinent part, that no person may operate a 

passenger-carrying airplane under that part unless at least one legible sign or placard 

that reads “Fasten Seat Belt While Seated” is visible from each passenger seat. 

The petitioner supports its request with the following information:

The petitioner states that the FAA has granted usage of a symbolic placard in lieu of text in 

compliance with § 25.791(e) where it states: 

 

AFS-11-343-E 

Symbols that clearly express the intent of the sign or placard may be used in lieu of 

letters. 
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Pursuant to the precedent established by granting the usage of symbolic placards in 

compliance with § 25.791, and in the spirit of keeping in compliance with the requirements of 

§ 121.317, CALA requests that the FAA extend approval of the usage of symbolic placards in 

lieu of text for all Boeing Model 787 aircraft. 

CALA believes that this petition for exemption is in the public interest to provide service to 

domestic and international destinations utilizing the Boeing 787 series aircraft. Failure to 

grant this exemption would require extensive modification at aircraft delivery and delay 

entering the aircraft into passenger service. 

CALA states that the level of safety could be increased due to the use of a seated passenger 

symbol being understood by more than English-speaking passengers. Additionally, this longrange aircraft will be primarily used internationally rather than on domestic flights. 

A summary of the petition was published in the Federal Register on June 29, 2011. 

(76FR38265). No comments were received. 

The FAA’s analysis is as follows:

The FAA finds that the points raised by CALA support a partial grant to allow CALA to 

operate its airplanes without there being affixed to each forward bulkhead and each passenger 

seat back a sign or placard that reads “Fasten Seat Belt While Seated.” We find that it is in the 

public interest in this instance to replace placards using text with placards using symbols in 

order to communicate better with a diverse and international traveling public. 

Unexpected in-flight turbulence continues to be the leading cause of in-flight injury to 

occupants of the aircraft cabin. Further, there is a regulatory requirement for seatbelt 

compliance (§ 121.317) and adherence to crewmember instructions (§ 91.11). The FAA also 

recognizes that several other part 121 certificate holders are encountering difficulties gaining 

passenger compliance with seatbelt signs and crewmember instructions. 

The purpose of the fasten seatbelt while seated placard required by § 121.317(d) is to 

reinforce crewmember instructions to passengers when: 

1. the seatbelt sign is off and the airplane encounters unexpected turbulence; 

2. or assumes an unusual altitude, such as during an evasive maneuver; or 

3. in cases of a malfunction in the flight control system. 

CALA’s equivalent level of safety argument is supported by research data from a Civil 

Aeromedical Institute (CAMI) study. The research indicates that it has become common 

practice to use symbols in lieu of text when constructing placards and signage, particularly in 

international usage. The language found in § 25.791 noted above clearly acknowledges that 

fact and contemplates the use of symbolic placards onboard aircraft. Further, G.A. McLean, 

PhD, researcher and author of the CAMI study titled “Comprehension of Safety Briefing Card 
3

Pictorials and Pictograms,” was asked to comment on this request for exemption. In his 

response he has stated: 

Regarding symbolic signs and placards, and in consultation with our international 

regulatory partners, it has been discussed and agreed that placement of symbolic signs 

and placards in aircraft on which international (non-English-speaking) passenger 

populations fly could improve global understanding of the message, and thus safety. 

While it appears that passengers may need extra education or experience with regard 

to some symbolic signs and placards, the seat belt symbol is not one of them. Thus, we 

concur with its use, as well as the targeted use of other well-comprehended symbols. 

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, Continental Airlines, Inc., is granted an exemption from 

14 CFR § 121.317(d) to the extent necessary to allow CALA to operate all of its Boeing 

Model 787 aircraft using symbolic representation placards affixed to each forward bulkhead 

or partition and each passenger seat back in lieu of text placards reading “Fasten Seat Belt 

While Seated,” subject to the conditions and limitations listed below. 

Conditions and Limitations 

1. The symbolic placards on the Boeing 787 aircraft will be included in the initial 

conformity inspection and maintained in the condition that was present during aircraft 

delivery. 

2. Strict compliance with § 121.571(a)(2) will be reemphasized to each crewmember 

serving on any airplane to be operated under this exemption prior to introduction of 

the Boeing 787 aircraft into air carrier service. Thus, after each takeoff, immediately 

before or immediately after turning the seatbelt sign off, an announcement shall be 

made that passengers should keep their seatbelts fastened, while seated, even when the 

seatbelt sign is off. 

3. The briefing shall include a statement that the Federal Aviation Regulations require 

passenger compliance with lighted passenger information signs, placards, and 

crewmember instructions concerning the use of safety belts. 

4. Cabin crewmembers will use alternate methods to alert special passengers; such as, 

the elderly, non-English speaking, deaf or hearing impaired, those with limited 

mobility, and those traveling with small children. CALA cabin safety procedures will 

include the use of visual aids; such as, seatbelt extenders or briefing cards, pointing to 

seatbelt signs and symbolic placards combined with oral announcements during 

seatbelt compliance checks. 
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5. Crewmembers will include a caution to passengers that they should not attempt to 

open overhead bins when the seatbelt sign is illuminated in the seatbelt announcement. 

6. Cabin crewmembers will include additional announcements that passenger risk is 

increased when long lines form around the lavatory as needed. 

This exemption terminates on October 31, 2013, unless sooner superseded or rescinded. 

Issued in Washington, D.C., on October, 28, 2011. 

/s/ 

John M. Allen 

Director, Flight Standards Service .