Enclosure 1) to BDCO-10-03270 Page 1 of 7 

Data in support of Boeing’s Petition for a Partial Exemption from 14 CFR Part 

25 Section 25.853(d) Smoke Density and Heat Release Requirements for Ensolite 

Energy Absorbing Foam Padding on Business Class Side-Facing Seats with 

Inflatable Lap Belts Installed on Air New Zealand Model 777-300ER Series 

Airplanes.

References

(a) Special Conditions No. 25-295-SC: Boeing Model 777 Series Airplanes; 

Side-Facing Single-Occupant Seats Equipped with Inflatable Lap belts 

(b) Transport Airplane Cabin Interiors Crashworthiness Handbook AC25-17A 

Para 81(b)(5) 

(c) Special Conditions No. 25-187A-SC: Boeing Model 777 Series Airplanes; 

Seats With Inflatable Lap belts 

(d) Special Conditions No. 25-367-SC, Boeing Model 777 Series Airplanes; 

Seats With Non-Traditional, Large, Non-Metallic Panels 

(e) Boeing letter, B-7673-RA-11825: Delethalization of Partitions and other 

Vertical Surfaces, dated November 28, 1978 (FAA concurrence indicated) 

(copy enclosed) 

Introduction

The Air New Zealand Model 777-300ER series airplanes program includes the 

installation and certification of Contour ‘USC2’ model side-facing Business 

Class passenger seats with Inflatable restraints. Although this will be the first 

installation of this seat model on a Boeing Model 777-300ER airplane, a similar 

seat model ‘F11800 Series’ has been previously certified by the FAA for the 

reference (a) and (c) Special Conditions. The seat partitions surrounding these 

side-facing seats incorporate energy absorbing foam padding. The first Air New 

Zealand 777-300ER airplane with the USC2 seats, ANZ WE051, is scheduled to 

enter into service in November 2010. 

By this letter, Boeing petitions for exemption from the requirements of 14 CFR 

25.853(d) Amdt. 25-83 and paragraph 1 of the reference (d) Special Conditions 

to the extent that these apply to the application of energy absorbing materials 

required by 14 CFR 25.785 and references (a) and (b). Energy absorbing foams 

such as those listed in reference (b) for the purpose of meeting 14 CFR 

25.785(b),(d)(2),(k), are not capable of meeting the flammability requirements of 

14 CFR 25.853(d) and the proposed exemption, if granted, would permit 

installation of energy absorbing material, such as one-inch of Ensolite (Type 

AH, AHC, IV3, HHC 

or HH), Klegecell or Airex 4070 on Boeing Model 777-300ER series airplanes. 

To support certification for the Air New Zealand Model 777-300ER airplanes, 

the exemption is needed on or before October 13, 2010. 
Enclosure 1) to BDCO-10-03270 Page 2 of 7 

Justification for Exemption from 14 CFR 25.853(d)

Air New Zealand 777 Business Class seats (Figures 1, 2, 3) include partitions 

both forward and aft of each passenger seat place. The edges of these partition 

walls may be struck during an emergency landing or turbulence (e.g. Figure 4). 

During an emergency landing, for threshold loads below 6.5g, the inflatable 

restraints will not deploy and seated passengers may strike the top edge of the 

partition wall in front of them. For loads of 6.5g and above, the inflatable 

restraints activate to cushion forward impact. However, contact with the inflated 

airbag produces a rebound resulting in seated occupants contacting the vertical 

portion of the partition wall aft of the passenger as shown in dynamic test video 

and figure (4). Although most of the energy is mitigated by the initial reaction 

with the airbag, the remaining movement of the occupant must be addressed. 

During turbulence, passengers may contact the partition wall edges either while 

seated, or in the event of a fall while navigating through the cabin. To protect 

passengers from injuries resulting from contact with seat partition wall edges, the 

Business Class seats incorporate padding on these wall edges. The padding 

consists of Ensolite, an energy absorbing foam recommended in AC25-17A for 

this express purpose, encapsulated within a leather cover. 

The small concentrations of this edge-capping material compared to the total 

surface area of materials used in the interior (edge-capping is 0.01% of total 

interior surface area) have no appreciable effect on the overall fire safety of the 

passenger cabin. In addition, the edge-capping material itself meets the 

requirements of 14 CFR 25.853(a) and all materials adjacent to the edge-capping 

will meet the requirements of 14 CFR 25.853(a) and either 14 CFR 25.853(d) or 

the reference (d) Special Conditions, where appropriate, reducing the possibility 

of propagation should the seat partition wall be involved in a fire. The use of 

Ensolite edge-capping utilized on panels associated with side-facing seats goes 

back 5 years in production at Boeing, and Boeing has knowledge of previous 

similar use in airplane modification programs. The Ensolite padding in question, 

while not complying with the requirements of 14 CFR 25.853(d), has been added 

to address the reference (a) Special Conditions and delethalization (per 14 CFR 

25.785 and AC 25-17A). The padding has been present as a means of mitigating 

personal injury and meeting the intent of 14 CFR 25.785 on airplanes since 1978 

as evidenced by the reference (e) Boeing letter and subsequent incorporation in 

AC 25-17 (released in 1991). 

Statement of No Adverse Effect to Safety

Granting of this petition as proposed for the configuration of passenger seats on 

the Boeing Model 777-300ER series airplane will not adversely affect aviation 

safety. The small concentrations of this edge-capping material, compared to the 

total surface area of materials used in the interior, have no appreciable effect on 

the overall fire safety of the passenger cabin. In addition, the edge-capping 

material itself meets the requirements of 14 CFR 25.853(a) and all materials 

adjacent to the edge-capping will meet the requirements of 14 CFR 25.853(a) 

and either 14 CFR 25.853(d) or the reference (d) Special Conditions, where 

appropriate, reducing the possibility of propagation should the seat partition wall 

be involved in a fire. 
Enclosure 1) to BDCO-10-03270 Page 3 of 7 

Statement of Public Interest

Granting of this petition is in the public interest because it provides for the 

installation of an injury-preventing device that will be useful during all phases of 

flight, including takeoff, taxi, landing, turbulence, conditions encountered during 

normal flight and emergency landing events. The material fully complies with 

14 CFR 25.853(a) and will not propagate a fire. Additionally, it will add to the 

survivability of a post crash fire due to its ability to mitigate personal injury in a 

crash event and aid in an occupant’s ability to safely evacuate the aircraft. 

In addition, due to the fact that energy absorbing material has been accepted by 

the FAA for delethalization and has been in use for at least two decades for that 

usage, the Boeing Company requests that the FAA find good cause under 14 

CFR 11.87 and waive the need for the public process described in 14 CFR 11.85. 

Petition

By this letter, Boeing petitions for exemption from 14 CFR 25.853(d) Amdt. 25-83 

and paragraph 1 of the reference (d) Special Conditions for “Seats with NonTraditional, Large, Non-Metallic Panels”, limited to the application of energy 

absorbing materials required by references (a) and (b). This exemption, if 

granted, would apply to the Boeing Model 777-300ER series airplanes. 

The Boeing Company requests that this exemption, if granted, be capable of 

being exercised outside the United States. Initially, as previously mentioned, this 

petition will be utilized on a Boeing 777-300ER to be registered for service 

under the auspices of the New Zealand Civil Aviation Authority. Other 

applications are expected in the future on airplanes to be manufactured by 

Boeing and registered under foreign authorities in addition to the United States 

Federal Aviation Authority. 

Summary to Publish in the Federal Register

Boeing petitions the FAA for exemption of the heat release and smoke density 

testing requirement of Title 14 Code of Federal Regulations (14 CFR) Section 

25.853(d) on an interior cabin component, energy absorbing padding, installed 

on the edges of Business Class passenger seat partition walls on the Boeing 

Model 777-300ER series airplane. The padding is used as a means to reduce the 

potential for head injury in the event of an emergency landing or turbulence, and 

in order to show compliance to 14 CFR 25.785(b), (d)(2) and (k). Side-facing 

Business Class seats with inflatable lap belts are a novel and unusual design 

feature on passenger seats and are subject to the reference (a) and (c) Special 

Conditions. In addition to the protection provided by the occupant inflatable 

restraints, these special conditions require protection for the case where the 

restraints are not designed to inflate. During events less than 6.5g (before the 

airbag deploys), a seated occupant’s head may contact the top surface of the 

partition wall in front of them. The pad provides a means to prevent possible 

injury. 

During emergency landing events between 6.5g to 16g, where the airbag is 

designed to deploy, the passenger may deflect off the inflated bag and contact the 

vertical portion of the partition wall behind them. An energy absorbing foam 

edge-capping pad has been added to the partition wall design to address this 
Enclosure 1) to BDCO-10-03270 Page 4 of 7 

possible secondary injury situation. The edge-capping pad is made of Ensolite 

wrapped in leather and is included in the partition design to address headstrike 

and occupant injury scenarios as allowed by the guidance of AC25-17A Para. 

81(b)(5). 

14 CFR 25.785 requires that occupants be protected from head injury by either 

the elimination of any injurious object within the striking radius of the head, or 

by padding. Traditionally, this has required a setback from any bulkhead or other 

rigid interior feature or, where not practical, specified types of padding. 

The 25-295-SC special conditions for Side- Facing Single-Occupant Seats 

Equipped With Inflatable Lapbelts, paragraph (b) includes: 

“Body-to-Wall/Furnishing Contact: Under the load condition defined in Sec. 

25.562(b)(2), the seat must be installed immediately aft of a structure such as an 

interior wall or furnishing that will support the pelvis, upper arm, chest, and 

head of an occupant seated next to the structure. A conservative representation 

of the structure and its stiffness must be included in the tests. It is recommended, 

but not required, that the contact surface of this structure be covered with at 

least two inches of energy absorbing protective padding (foam or equivalent), 

such as Ensolite.” 

Also Advisory Circular, AC25-17A, Section 25.785 Seats, Berths, Safety Belts, 

and Harnesses, 81(b)(5) Paragraph (c)(2), provides: 

“...Surfaces within the 35-inch arc may be padded with energy absorbing 

material, such as one-inch of either Ensolite (Type AH, AHC, IV3, HHC or HH), 

Klegecell or Airex 4070. ” 

Boeing believes that the appropriate method to address the fire properties of 

energy absorbing foam, as described above, is a compliance finding limited to 

the self-extinguishing requirements of 14 CFR 25.853(a). Boeing requests grant 

of the exemption as it will add to the survivability of a post crash due to its 

ability to mitigate personal injury in a crash event and aid in an occupant’s 

ability to safely evacuate the aircraft.
Enclosure 1) to BDCO-10-03270 Page 5 of 7 

Figures

Figure 1 – Business Class Cabin Layout 

Figure 2 – Contour Business Class Seating Layout
Enclosure 1) to BDCO-10-03270 Page 6 of 7 

Figure 3 – Partition Walls in perspective with Associated Seats LeftHand, Rear-Facing Surface - Right-Hand, Forward-Facing Surface 

 

Figure 4 – Occupant Safety Test Showing Contact with Partition Wall
Enclosure 1) to BDCO-10-03270 Page 7 of 7 

Name and Address of the Petitioner 

The Boeing Company 

C/o Dave Marcrander 

PO Box 3707 M/C 03-85 

Seattle, WA 98103-2207