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Federal Aviation Administration
Washington, DC

MMEL Policy Letter (PL) 132, Revision 0, GC

Date:                                    05/03/2021

To:                                        Manager, Aircraft Evaluation Division (AFS-100)
All Aircraft Evaluation Group Managers

From:                                    Manager, Air Transportation Division (AFS-200)

Reply to Attn of:                  Manager, New Program Implementation Branch (AFS-240)

MMEL GLOBAL CHANGE (GC)

This GC is an approved addendum to all existing Master Minimum Equipment List (MMEL) documents. Operators may seek use of the specific relief contained in this Policy Letter (PL) by revising their minimum equipment list (MEL). In doing so, each applicable sample proviso must be copied verbatim in the operator’s MEL. Approval of a revised MEL is gained using established procedures, through the assigned Principal Operations Inspector (POI). This GC expires 05/03/2025.

SUBJECT:                 Portable Emergency Equipment

MMEL CODE:                    25 (Equipment/Furnishings), 26 (Fire Protection), and 35 (Oxygen)

REFERENCE:                     Portable Protective Breathing Equipment (PBE):

                                             PL-43, Revision 3, Crewmember Portable Protective Breathing Equipment (PBE), dated December 4, 2017.

                                             14 CFR part 25, § 25.1439.

                                             14 CFR part 29, § 29.1439.

                                             14 CFR part 121, § 121.337.

                                             Megaphones:

                                             PL-47, Revision 2, Megaphone MMEL Requirements, dated October 17, 2011.

                                             14 CFR part 91, § 91.513.

                                             14 CFR part 121, §  121.207.

                                             14 CFR part 121, § 121.309.

                                             Emergency Medical Equipment:

                                             PL-73, Revision 5, MMEL Relief for Emergency Medical Equipment, dated June 15, 2011.

                                             14 CFR part 91, § 91.513.

                                             14 CFR part 121, § 121.803.

                                             14 CFR part 121, Appendix A.

                                             14 CFR part 125, § 125.207.

                                             14 CFR part 135, § 135.177.

                                             Portable Fire Extinguishers:

                                             PL-75, Revision 1, Portable Fire Extinguisher, dated August 15, 1997.

                                             14 CFR part 23, § 23.2325.

                                             14 CFR part 25, § 25.851.

                                             14 CFR part 29, § 29.851.

                                             14 CFR part 91, § 91.513.

                                             14 CFR part 121, § 121.309.

                                             14 CFR part 125, § 125.119.

                                             14 CFR part 135, § 135.155.

                                             Portable Oxygen Bottles or Units:

                                             14 CFR part 91, § 91.211.

                                             14 CFR part 121, §§ 121.327, 121.329, 121.331, and 121.333.

                                             14 CFR part 125, § 125.219.

                                             14 CFR part 135, § 135.157.

                                             Flashlights or Flashlight Holders:

                                             14 CFR part 91, § 91.503.

                                             14 CFR part 121, §§ 121.310 and 121.549.

                                             14 CFR part 125, § 125.209.

                                             14 CFR part 135, §§ 135.159, 135.167, and 135.178.

PURPOSE:

The purpose of this PL is to combine the existing PLs as specified in the Reference section into one new PL (PL‑132), in order to establish standard MMEL relief for flight deck/cabin emergency equipment, including (but not limited to): portable fire extinguishers, portable oxygen bottles or units, emergency medical equipment, portable Protective Breathing Equipment (PBE), flashlights or flashlight holders and megaphones. In addition, a new sub-item for tamper seals has been added for application, if needed. This PL is designated as a GC due to current MEL relief that could cause adverse conditions and result in a loose item becoming a projectile in the aircraft.

This PL combines PLs 43, 47, 73, and 75 regarding emergency equipment. This approved PL will allow the archiving of the noted PLs.

REVISION HISTORY:

PL-43:

Revision 3: Clarifies PL-43 by adding “Portable” preceding “Protective Breathing Equipment.” Also clarifies proviso adding “14” preceding “CFR,” and adds conditions a), b), and c). Adds note advising operators that inoperative PBE unit(s) are subject to dangerous goods shipping and handling requirements if removed from certified location, or are removed from the aircraft. If inoperative PBE unit(s) is removed from certified location, or removed from the aircraft, they are considered “in commerce” and Title 49 of the Code of Federal Regulations (49 CFR) part 175 dangerous goods regulations apply.

Revision 2: Added relief for PBE removed and the requirement to remove or obscure the PBE location placard.

Revision 1: Updated PL-43 to current PL standards. The requirement for portable PBE units for use by crewmembers in combating an in-flight fire became effective January 31, 1990. Airline operators can procure PBE units from several different manufacturers. One distributor, the Puritan-Bennett Aero Systems Company, has informed operators who purchased their crewmember PBE units that a new determination has been made on the serviceability of these units. Based on their test, the vacuum pouch of a Puritan-Bennett PBE unit may be punctured for up to 7 days without degradation of the moisture‑sensitive chemical in the atmosphere‑regenerating system. Previous guidance from the company was to replace any unit, in which the vacuum pouch had been punctured, at the first opportunity not to exceed 48 hours.

PL-47:

Revision 2: Adds requirement to remove or obscure the megaphone placard.

Revision 1: Reformatted PL-47 and changed Repair Category C to D with no change to policy.

Revision 0: Megaphones are required by Title 14 of the Code of Federal Regulations (14 CFR) part 121, § 121.309(f) for passenger-carrying operations. The number required is one (1) for airplanes with a seating capacity of more than 60 and less than 100 passengers, and two (2) for airplanes with a seating capacity of more than 99 passengers. MMEL relief for inoperative or missing megaphones can therefore only be applied for units that are carried in excess of the regulatory requirement. Combi-type operations require a megaphone, the quantity corresponding to the number of passenger seats installed. The regulation does not extend the megaphone requirement to all-cargo type operations.

PL-73:

Revision 5: Reduces the number of cycles/flights to one cycle/flight for incomplete, missing, or inoperative Emergency Medical Kits (EMK), First Aid Kits (FAK), and Automated External Defibrillators (AED).

Revision 4: Provided limited dispatch authority for EMKs, FAKs, and/or AEDs that do not meet minimum FAA requirements.

Revision 3: Provided clarification that equipment in excess of the CFRs associated with emergency medical equipment can be missing or inoperative.

Revision 2: Expanded previous MMEL relief for FAKs to include relief for all emergency medical equipment.

Revision 1: Reformatted PL-73 with no change to policy. Emergency medical equipment is required by 14 CFR, which set forth the required number of EMKs, FAKs, and AEDs.

Revision 0: In order to support operational issues associated with the use of emergency medical equipment, operators may elect to have additional equipment installed associated with 14 CFR-required equipment. Examples of associated equipment includes additional items in the EMK, FAK, or AEDs; kit seals; sharps container; infection control kit; etc. In response to the Aviation Medical Assistance Act of 1998, the FAA issued a Final Rule (FR), Emergency Medical Equipment, dated April 12, 2001. The FR requires that air carrier operators carry AEDs on passenger-carrying aircraft and augment current EMKs. The FR required operators to comply by April 12, 2004. After diversion due to an in-flight medical event, replacement and replenishment of the emergency medical equipment may be hindered by factors beyond the operator’s control. This situation has the potential to expose a large number of passengers to more risk at the diversion airport than there would be if the aircraft was dispatched in accordance with the MMEL.

PL-75:

Revision 1: Reformats PL-75 with no change to policy. Hand fire extinguisher requirements for crew, passenger, cargo, and galley compartments are specified by the CFRs. The number of required fire extinguishers in the passenger compartment is dependent on the seating capacity of the aircraft. MMEL relief for inoperative or missing fire extinguishers can therefore only be applied for units that are carried in excess of the regulatory requirement. Further, fire extinguishers that are in excess of the regulatory requirement that are inoperative must be tagged inoperative, removed from the installed location, and placed out of sight so it cannot be mistaken for a functional unit. Since the MMEL relief is for units in excess of the CFRs, a Category D repair interval is specified.

DISCUSSION:

PL-132:

Revision 0: Comprehensive PL to address all flight deck and cabin portable emergency equipment items, including fire extinguishers, oxygen bottles, emergency flashlights, megaphones, and cabin emergency equipment. This revision incorporates current PL-43, PL-47, PL-73, and PL-75. Concurrent with the publication of this revision, these four PLs will be archived.

POLICY:

ATA 25 Megaphones (Formerly PL-47):

To ensure that the requirements set forth in the 14 CFR are met, the Flight Operations Policy Board (FOPB) has determined that the number of megaphones required by regulation must be installed and fully functional. Megaphones in excess of the number required may be granted relief.

ATA 25 Emergency Medical Equipment (Formerly PL-73):

This PL authorizes continued operation for a maximum of one flight to a location where emergency medical equipment repairs or replacements can be made. Emergency equipment in excess of the number required may be granted relief.

ATA 25 Portable Flashlights:

A flashlight that does not operate, does not properly indicate serviceability, or does not test properly is considered inoperative. Where 14 CFR requires that crewmembers have an operative flashlight, it is required to be readily available.

ATA 26 Portable Fire Extinguishers (Formerly PL-75):

A portable fire extinguisher that has been discharged or indicates low pressure is considered inoperative. It is, therefore, necessary to require all portable fire extinguishers, required by the CFRs, to be operative. Portable fire extinguishers in excess of those required by CFR may be granted relief.

ATA 35 Portable Breathing Equipment (Formerly PL-43):

A punctured PBE seal may reveal damage to other than the regenerating system, such as a torn hood or broken face plate. Any time a PBE seal is broken, the PBE unit is considered inoperative. It is, therefore, necessary to require all crewmember PBE units, required by the CFRs, to be operative. Crewmember PBE units in excess of those required by CFRs may be granted relief.

ATA 35 Portable Oxygen Bottles or Units:

A portable oxygen bottle or unit that has been used or has a damaged/missing mask or hose is considered inoperative. It is, therefore, necessary to require all portable oxygen bottles or units, required by the CFRs, to be operative. Oxygen bottles or units in excess of those required by CFRs may be granted relief.

The following standard MMEL proviso and repair category is adopted to provide standardization among all MMELs.

AIRCRAFT:

(Insert aircraft make and model)

TABLE KEY

1.    REPAIR CATEGORY

2.    NO. INSTALLED

3.    NO. REQUIRED FOR DISPATCH

4.    REMARKS OR EXCEPTIONS

 

25. Equipment/Furnishings

 

 

 

 

 

 

Sequence No.

Item

1

2

3

4

Change Bar

25-XX

Portable Flashlights/
Flashlight Holders

C

-

-

May be inoperative or removed provided:

a)   Crewmember assigned to the affected position has an equivalent operative flashlight readily available,

b)   Inoperative flashlight remains in a certified location or is removed from the aircraft, and

c)   Location placarding is removed or obscured.

 

 

 

D

-

-

Any in excess of those required by 14 CFR may be inoperative or removed provided:

a)   Inoperative flashlight remains in a certified location until removed from the aircraft at the next suitable maintenance facility, and

b)   Location placarding is removed or obscured.

 

***

Tamper Seals or Tags

C

-

-

(O) May be inoperative, damaged, or missing provided proper installation and operation is verified at each preflight.

 

25-XX

Megaphones

D

-

-

Any in excess of those required by 14 CFR may be inoperative or removed provided:

a)   Inoperative megaphone remains in a certified location until removed from the aircraft at the next suitable maintenance facility,

b)   Location placarding is removed or obscured, and

c)   Required distribution is maintained.

 

***

Tamper Seals or Tags

C

-

-

(O) May be inoperative, damaged, or missing provided proper installation and operation is verified at each preflight.

 

 

AIRCRAFT:

(Insert aircraft make and model)

TABLE KEY

1.    REPAIR CATEGORY

2.    NO. INSTALLED

3.    NO. REQUIRED FOR DISPATCH

4.    REMARKS OR EXCEPTIONS

 

25. Equipment/Furnishings

 

 

 

 

 

 

Sequence No.

Item

1

2

3

4

Change Bar

25-XX

Automated External Defibrillator (AED) and/or Associated Equipment

A

-

0

(O) May be incomplete, inoperative, or removed provided:

a)   AED is labeled or placarded in a manner that will identify it as a unit that cannot be mistaken for a fully serviceable unit,

b)   Location placarding is removed or obscured, and

c)   Repairs or replacements are made within one flight.

NOTE: Medical equipment installed in the aircraft as part of an Emergency Medical Service (EMS) operation is not considered part of the normal complement of equipment. No MMEL relief applies to that equipment and 14 CFR maintenance and inspection requirements do not apply.

 

 

 

D

-

-

Any in excess of those required by 14 CFR may be incomplete, inoperative, or removed.

 

***

Tamper Seals or Tags

C

-

-

(O) May be inoperative, damaged, or missing provided proper servicing is verified at each preflight.

 

25-XX

Emergency Medical Kit (EMK) and/or Associated Equipment

A

-

0

(O) May be incomplete or removed provided:

a)   EMK is labeled or placarded in a manner that will identify it as a unit that cannot be mistaken for a fully serviceable unit,

b)   Location placarding is removed or obscured, and

c)   Repairs or replacements are made within one flight.

NOTE: Medical equipment installed in the aircraft as part of an EMS operation is not considered part of the normal complement of equipment. No MMEL relief applies to that equipment and 14 CFR maintenance and inspection requirements do not apply.

 

 

 

 

 

 

(Continued)

 

 

AIRCRAFT:

(Insert aircraft make and model)

TABLE KEY

1.    REPAIR CATEGORY

2.    NO. INSTALLED

3.    NO. REQUIRED FOR DISPATCH

4.    REMARKS OR EXCEPTIONS

 

25. Equipment/Furnishings

 

 

 

 

 

 

Sequence No.

Item

1

2

3

4

Change Bar

25-XX

Emergency Medical Kit (EMK) and/or Associated Equipment
(Cont’d)

D

-

-

Any in excess of those required by 14 CFR may be incomplete or removed.

 

***

Tamper Seals or Tags

C

-

-

(O) May be inoperative, damaged, or missing provided proper EMK servicing is verified at each preflight.

 

25-XX

First Aid Kit (FAK) and/or Associated Equipment

A

-

-

(O) If more than one is required by 14 CFR, only one of the required FAKs may be incomplete or removed provided:

a)   The FAK is labeled or placarded in a manner that will identify it as a unit that cannot be mistaken for a fully serviceable unit,

b)   Location placarding is removed or obscured, and

c)   Repairs or replacements are made within one flight.

NOTE: Medical equipment installed in the aircraft as part of an EMS operation is not considered part of the normal complement of equipment. No MMEL relief applies to that equipment and 14 CFR maintenance and inspection requirements do not apply.

 

 

 

D

-

-

Any in excess of those required by 14 CFR may be incomplete or removed.

 

***

Tamper Seals or Tags

C

-

-

(O) May be inoperative, damaged, or missing provided proper FAK servicing is verified at each preflight.

 

 

AIRCRAFT:

(Insert aircraft make and model)

TABLE KEY

1.    REPAIR CATEGORY

2.    NO. INSTALLED

3.    NO. REQUIRED FOR DISPATCH

4.    REMARKS OR EXCEPTIONS

 

26. Fire Protection

 

 

 

 

 

 

Sequence No.

Item

1

2

3

4

Change Bar

26-XX

Portable Fire Extinguishers

D

-

-

Any in excess of those required by 14 CFR may be inoperative or removed provided:

a)   Inoperative fire extinguisher remains in a certified location until removed from the aircraft at the next suitable maintenance facility,

b)   Location placarding is removed or obscured, and

c)   Required distribution is maintained.

NOTE: Inoperative fire extinguishers, removed from a certified location or removed from the aircraft, are subject to 49 CFR dangerous goods regulations.

 

***

Tamper Seals or Tags

C

-

-

(O) May be inoperative, damaged, or missing provided proper installation and servicing is verified at each preflight.

 

 

AIRCRAFT:

(Insert aircraft make and model)

TABLE KEY

1.    REPAIR CATEGORY

2.    NO. INSTALLED

3.    NO. REQUIRED FOR DISPATCH

4.    REMARKS OR EXCEPTIONS

 

35. Oxygen

 

 

 

 

 

 

Sequence No.

Item

1

2

3

4

Change Bar

35-XX

Portable Protective Breathing Equipment (PBE)

D

-

-

Any in excess of those required by 14 CFR may be inoperative or removed provided:

a)   Inoperative PBE remains in a certified location until removed from the aircraft at the next suitable maintenance facility,

b)   Location placarding is removed or obscured, and

c)   Required distribution is maintained.

NOTE: Inoperative PBEs, removed from a certified location or removed from the aircraft, are subject to 49 CFR dangerous goods regulations.

 

***

Tamper Seals or Tags

C

-

-

(O) May be inoperative, damaged, or missing provided proper installation and servicing is verified at each preflight.

 

35-XX

Portable Oxygen Bottles or Units (Including Masks and Hoses)

D

-

-

Any in excess of those required by 14 CFR may be inoperative or removed provided:

a)   An inoperative or not properly serviced portable oxygen bottle/unit remains in a certified location until removed or serviced at the next suitable maintenance facility,

b)   Location placarding is removed or obscured, and

c)   Required distribution is maintained.

NOTE 1: Inoperative portable oxygen bottles or units, removed from a certified location or removed from the aircraft, are subject to 49 CFR dangerous goods regulations.

(Continued)

 

 

AIRCRAFT:

(Insert aircraft make and model)

TABLE KEY

1.    REPAIR CATEGORY

2.    NO. INSTALLED

3.    NO. REQUIRED FOR DISPATCH

4.    REMARKS OR EXCEPTIONS

 

35. Oxygen

 

 

 

 

 

 

Sequence No.

Item

1

2

3

4

Change Bar

35-XX

Portable Oxygen Bottles or Units (Including Masks and Hoses)
(Cont’d)

 

 

 

NOTE 2: Medical equipment installed in the aircraft as part of an EMS operation is not considered part of the normal complement of equipment. No MMEL relief applies to that equipment and 14 CFR maintenance and inspection requirements do not apply.

 

***

Tamper Seals or Tags

C

-

-

(O) May be inoperative, damaged, or missing provided proper installation and servicing is verified at each preflight.

 

Each Flight Operations Evaluation Board (FOEB) Chair should review the specific aircraft configuration(s) and apply this policy to affected MMELs through the normal FOEB process.

ORIGINAL SIGNED by

/s/ Thomas F. Malone

Manager, Air Transportation Division