15 January 2015

To: US Department of Transportation 

 Federal Aviation Administration 

Subject: Petition for exemption – 737-700BDSF - Special Freighter Modification - 

Provisions for Safety of Supernumeraries 

1) Introduction 

IAI has requested to certify (STC) a major modification of a Model 737-700 Series 

aircraft from passenger to a Bedek Special Freighter (BDSF) configuration. The program 

is being certified by the CAAI, then by the FAA via a validation process. The project has 

been assigned the FAA project number ST12406SE-T. 

IAI is requesting to be granted an exemption from meeting certain requirements, 

pertaining to the following:

• Carriage of two non-crewmembers (supernumeraries), in a dedicated 

supernumerary compartment in addition to the existing flight deck occupancy 

of two flight crewmembers, and two observers.

• Access of supernumeraries into the Class E compartment in flight for the 

purpose of attending to the cargo.

• Use of non-presenting oxygen masks in the supernumerary compartment and 

use of portable oxygen bottle by persons entering the Class E cargo 

compartment in lieu of self-presenting oxygen masks.

• Relief from the requirement for hand holds for persons entering Class E cargo 

compartment

• Relief from requirement for assist space at floor level exit. 

The exemption is requested for B737-700 aircraft modified to special freighter under an 

IAI STC. The configuration of the modified airplane as related to the carriage of 

supernumeraries and the requested exemptions are identical to the configuration of the 

IAI 737-300/-400 special freighters and exemptions which were previously granted to it 

by the FAA (Ref Exemptions 8335 and 8335B for B737-300 and 9792 for B737-400). 

a. FAR 25 Affected Sections 

Section 25.785(j), at Amendment 25-88 Seats, berths, safety belts, and harnesses, 

requires in pertinent part, that that there be a firm handhold, handgrip, or rail along each 

aisle to enable persons to steady themselves while using the aisles in moderately rough 

air. 

A I R C R A F T D I V I S I O N

I S R A E L A E R O S P A C E I N D U S T R I E S L T D

B e d e k A v i a t i o n G r o u p
Section 25.813(b), at Amendment 25-128 Emergency Exit Access, requires, in pertinent 

part, that adequate space to allow crewmember(s) to assist in the evacuation of 

passengers must be provided. 

Section 25.857(e), at Amendment 25-93 Cargo Compartment classification, requires, in 

pertinent part, that when a Class E cargo compartment is installed on the airplane, the 

airplane be used for carriage of cargo only. 

Section 25.1447(c)(1), at Amendment 25-116 Equipment Standards for Oxygen 

Dispensing Units, requires, in pertinent part, that oxygen-dispensing units must be 

automatically presented to the occupants before the cabin altitude exceeds 15000 feet. 

The total number of dispensing units and outlets must exceed the number of seats by at 

least 10 percent. The extra units must be uniformly distributed throughout the cabin as 

practicable, and there must be two oxygen masks in each lavatory. 

b. Related Sections of the FAR

Section 121.583(a) Carriage of persons without compliance with the passenger-carrying 

requirements of this part contains, in pertinent part, a listing of categories of the people 

who may be carried aboard an airplane in part 121 services without complying with the 

requirements of part 121 to carriage of passengers. 

 

2) Description of the converted airplane configuration 

General

The Boeing B737-700 is a transport category airplane. The converted 737-700BDSF will 

have an all-cargo main deck configuration. A new 9g rigid cargo/smoke barrier located 

aft of doors 1L and 1R, separates the Class E main deck cargo compartment from the 

supernumerary compartment (See Fig.1). The existing flight deck accommodation for 

pilot, co-pilot and two observer seats are retained from the type certified aircraft 

providing for a flight deck maximum occupancy of four persons. Two (2) additional noncrewmembers (supernumeraries) are seated in the supernumerary compartment on the 

original existing aft facing flight attendant seats, which are mounted on the aft wall of the 

forward lavatory near door 1L. 

Supernumerary seats

The type certified aft facing cabin attendant seats and their restraint harness are retained 

unchanged from the type certified aircraft. Life vest and their stowage provisions are also 

retained unchanged for the use of the supernumeraries. 
Figure 1 

737-700BDSF Layout 

LIFE VESTS 

FLSAHLIGHT 

PORTABLE OXYGEN 

FULL FACE MASK

LIFE RAFTS STOWAGE 

(PROVISIONS) 

PORTABLE 

ELT 

FIRE EXTINGUISHER 

PBE
Emergency exits arrangement and emergency evacuation 

The existing original aircraft emergency egress means doors 1L and 1R are not affected 

by the modification to freighter and are retained with their slides, markings, accessibility 

and illumination. These doors provide the emergency exits for the supernumeraries in 

compliance with the regulations, except for the lack of assist space aft of door 1L due to 

the installation of the rigid barrier closely aft of the door. 

Flight deck exits and evacuation are not affected by the conversion to freighter.

Following an emergency landing, an evacuation alert signal will be given to the

supernumeraries through an existing attendant evacuation signaling system.

PA system and Intercom 

The existing Public Address (PA) system is retained in the supernumerary area. The 

existing forward attendant station intercom is retained. 

Oxygen equipment 

The conversion to freighter requires the capability to depressurize the airplane in order to 

extinguish a fire in the class E compartment and to cruise at an altitude of 25000 feet until 

a landing is possible. 

In order to provide oxygen for the airplane occupants for the required duration the 

following equipment is provided: 

For the two occupants in the supernumerary area, two oxygen bottles with two masks that 

are permanently connected to the bottles are installed within reach of the seated 

supernumeraries. The oxygen bottles are sized for the maximum required flight duration. 

An illuminated "Use Oxygen" sign is installed in direct view of the seated 

supernumeraries. Illumination of the sign, combined with an audible warning signal over 

the PA, will be operated automatically in case of loss of cabin pressure or manually by 

the flight crew at cabin altitude above 15000 feet, to alert the supernumeraries. 

Due to the close proximity of the galley area to the supernumerary seat PSU, there is no 

need for an additional oxygen source at the galley. A lighted “Return to Seat” sign shall 

be installed at the galley area, activated automatically and manually simultaneously with 

the “Use Oxygen” signal. 

Lavatory compartment self-presenting oxygen masks dispenser is retained in the type 

certified configuration. 

Oxygen supply to any person entering Class E cargo compartment is provided by an 11 

cubic feet portable oxygen bottle with full face mask, which must be carried by the 

person entering the compartment at all times. Persons in the cargo compartment will be 

warned to use oxygen and return to seat through a cargo compartment alert system. 

Smoking is not permitted in the compartment. Appropriate instruction placards are 

installed on the cargo compartment and lavatory entry doors. 

The flight deck oxygen system, as certified in the original aircraft for the four flight deck 

occupants, is sufficient for the required flight duration and is not affected by the 

conversion to freighter. 
Cargo compartment alert system 

A flight deck operated switch shall activate a visual alert system flashing alternate 

compartment lights for the duration of 20 seconds to indicate to any person within the 

compartment that immediate return to seat is required. The system shall be activated by 

the flight crew to warn persons in the cargo compartment of a need to return to seat due 

to a smoke alert or an imminent turbulence. 

An aural and visual alert system consisting of horns and flashing of alternate 

compartment lights will be automatically activated in case of loss of cabin pressure at 

cabin altitude above 15000 feet, and in case of activation of the decompression mode or 

manually by the flight crew, to alert any person in the class E compartment to don oxygen 

mask and return to seat. 

Appropriate instruction placards are installed at the cargo compartment entry door. 

Lavatory Compartment 

The forward lavatory compartment is retained unchanged from the type certified aircraft 

including the self-presenting oxygen mask and "Return to Seat" sign. 

Crew Galley 

G1 galley unit is retained from the type certified aircraft. 

An illuminated "Return to Seat" sign is installed on the face of the galley. The galley is 

located in close proximity to the oxygen bottle and the supernumerary seats. A fire 

extinguisher and a PBE are installed on the rigid barrier adjacent to the galley. 

Cargo Compartment Access Door 

An entry slide door in the 9g barrier provides access to the main deck Class E cargo 

compartment from the supernumerary compartment. The door and barrier shall be 

designed to prevent smoke penetration into occupied areas. The door must be closed at all 

times except for entry and exit. Entry into the compartment is prohibited during taxi, 

takeoff and landing or in case of fire within the compartment. A placard on the door 

provides the operating instructions and limitations accordingly. 

Flight Manual Limitations 

The Airplane Fight Manual Supplement shall include all the limitations and instructions 

related to the carriage of supernumeraries and their entry into the class E compartment in 

flight including instructions for their pre-flight briefing by the crew. 
3) Requested exemption 

Exemption from the abovementioned Sections is sought to the following extent: 

Section 25.785(j): An exemption is requested from the requirement for a firm hand hold, 

hand grip or hand rail for persons entering the cargo compartment in flight. As the 

compartment is a large open space it is impractical to provide hand hold for a person 

entering the compartment. Instead, an equivalent safety is provided by the alert system 

that is available for the flight deck crew to warn persons in the cargo compartment of 

imminent turbulence and of the need to return to their seats and by their physical 

capability and training. 

Section 25.813(b): An exemption is requested from requirement for assist space adjacent 

to exit door. Assist space is not needed since supernumerary persons are capable of 

performing autonomous evacuation of the aircraft and there is no cabin crew on board to 

provide assistance. 

Section 25.857(e): Relief is sought to permit carriage of four (4) non-crew persons (Two 

observers and two supernumeraries) in addition to the two flight crewmembers, on an allfreighter airplane, which has a class E cargo compartment. 

Section 25.1447(c)(1): An exemption is requested to allow usage of non self presenting 

oxygen dispensing units in the supernumerary compartment. The self-presenting masks 

alert passengers to use the oxygen and put the masks within easy reach. An equivalent 

safety is provided by having oxygen bottles with connected masks installed within reach 

of the seated occupant of the supernumerary compartment and by an automatic and 

manual alert system illuminating an ordinance sign with an audio alert signal to instruct 

the person to don the oxygen mask in case of drop of cabin pressure. 

An exemption is requested to allow usage of non self presenting oxygen dispensing units 

in the class E compartment. An equivalent level of safety is provided by having a 

portable oxygen bottle with a full face mask carried by each person entering the Class E 

cargo compartment at all times and by an automatic and manual audio and visual alert 

system alerting the person to don the oxygen mask. 

 

4) Supporting Arguments 

Exemption from cargo only provisions of Section 25.857(e) has been previously granted 

to IAI for cargo conversions of B767-200SF, B747-200/-300SF , B737-300SF/RB/QC 

and B737-400SF aircraft. 

1. The cargo operators need for their missions a number of support personnel, 

necessary for the safe handling of the cargo in the process of loading/offloading and 

for in-flight attendance of the cargo. Such personnel are obviously needed both at 

departure and destination of a cargo flight. It is important that the cargo handlers are 
present upon airplane arrival, particularly if perishable goods or live animals are 

carried. The most efficient way to assure their attendance at destination airport is to 

transport them aboard the cargo flight. 

2. Among their various missions, the cargo operator may have to carry particular kinds 

of goods, such as live animals, hazardous materials, valuable or perishable cargo. 

Such types of cargo cannot be left unattended, even for the duration of a flight, and 

the presence of personnel qualified in their handling is necessary on the airplane on 

which they are carried. Safety and efficiency of the operation will therefore be 

enhanced. 

3. Cargo operators also need to have qualified personnel necessary for operation and 

maintenance purposes at various locations. They will optimize their missions if they 

are permitted to carry their personnel aboard their cargo flights, thus saving travel by 

regular passenger flights. 

4. The categories of the supernumerary persons for which this exemption is requested 

are as defined on FAR Section 121.583(a), they are trained as to the autonomous use 

oxygen masks, emergency equipment and emergency exit operation. 

It will also be required that the operator allows access to the supernumerary seats 

only to persons trained in the necessary emergency procedures. These persons must 

be physically capable of using the rope descent means and will not need assistance 

by a crewmember. The non-crewmembers shall be briefed preflight about the 

emergency procedures by the flight crew. The necessary instructions shall be 

incorporated in the Airplane Flight Manual. 

5) Supporting arguments for the additional sections affected 

The airplane reconfiguration for carriage of cargo does not enable providing assist space 

adjacent to the exits as required by Section 25.813(b). The use of assist space adjacent 

to the emergency exits is not necessary, however, as the considered categories of 

personnel will be trained for operation of main exit doors and for autonomous

evacuation. 

The exemption from Section 25.785(j) requirement to provide a handhold is justified by 

providing means that enable flight deck crew to warn persons in the main deck of 

imminent turbulence, signaling them of the need to return to their seats and fasten seat 

belts. Appropriate instruction placards will be installed at the entrance to the main deck 

cargo compartment and the requirement for pre-flight briefing of the supernumeraries in 

this respect will be added to the AFM Supplement. 

The requirements of Section 25.1447(c)(1) to have automatic presentation of oxygen 

dispensing units before the cabin pressure altitude exceeds 15000 feet are compensated 

by the fact that the supernumeraries will have knowledge of equipment location and use 

and by their seating in direct view of the "Use Oxygen" instruction sign. This signal, 

combined with the training and briefing provided to the supernumeraries is considered 

equivalent to the dropping masks of a passenger airplane. 
Masks shall be accessible to seated occupants of 5'2" to 6'3" stature. The quantity of 

oxygen is sufficient for the maximum duration of the flight including an intended 

decompression for suppression of cargo fire. 

A portable oxygen bottle with full face mask must be carried by each person entering the 

Class E cargo compartment at all times. An automatic and manual aural and visual alert 

system is provided to instruct the person to don the oxygen mask in case of drop of cabin 

pressure. 

Public Interest 

Granting the requested exemption will be in the public interest, as by allowing the 

carriage of the supernumerary persons aboard the cargo flights the operators will be able 

to optimize the safety conditions of the cargo operation and to make the operation more 

efficient. 

Improving the utility of the airplanes reduces the total number of airplanes and affects 

the environment and the airports congestion. 

David Gat 

Acting Director, Certification 

Aircraft Division 

Bedek Group 

Israel Aerospace Industry