Memorandum

U.S. Department
of Transportation

Federal Aviation
Administration

Subject: INFORMATION : Policy Statement on Exit Bands Date: April
2, 2003

From: Manager, Transport Airplane Directorate, Aircraft Certification
Service, ANM-100 Reply to Attn. of: ANM-03-115-04

To: See Distribution Regulatory Reference: § 25.811(f), AC 20-47



Summary

The purpose of this memorandum is to provide Federal Aviation
Administration (FAA) certification policy on colored exit bands
required by § 25.811(f)(1) and (2).

Current Regulatory and Advisory Material

Section 25.811(f)(1) and (2) states the following:

(f) Each emergency exit that is required to be openable from the
outside, and its means of opening, must be marked on the outside of
the airplane. In addition, the following apply:

1. The outside marking for each passenger emergency exit in the side
of the fuselage must include a 2-inch colored band outlining the
exit.
2. Each outside marking including the band, must have color contrast
to be readily distinguishable from the surrounding fuselage surface.
The contrast must be such that if the reflectance of the darker color
is 15 percent or less, the reflectance of the lighter color must be
at least 45 percent. " Reflectance" is the ratio of the luminous flux
reflected by a body to the luminous flux it receives. When the
reflectance of the darker color is greater than 15 percent, at least
a 30-percent difference between its reflectance and the reflectance
of the lighter color must be provided.
Advisory Circular 20-47, dated February 8, 1966, states the
following:
Questions have been raised as to whether the colored band must be on
the fuselage structure surrounding the opening or whether it can be
on the exit adjacent to the edge. A two-inch colored band outlining
the exit is considered to comply with applicable regulations whether
the band is on the edge of the exit itself, on the fuselage
surrounding the exit, or partially on both.

Policy

The FAA has been asked if compliance with § 25.811(f)(1) and (2) can
be found with the lower section of a 2-inch colored band located a
few inches above the base of an exit. Metal door sills are often
installed on the fuselage below floor-level exits to provide
protection from impacts with loading equipment. If the band is
located on the bottom edge of an exit, its color must be compared
with the door sill color to determine compliance with § 25.811(f)(2).
This requirement can result in a color scheme which is not desired by
the operator. Note that painting the door sill is not considered a
viable option since impacts with loading equipment cause the paint to
scratch and wear away quickly. If the band is located a few inches
above the base of the exit, its color is compared with the door color
below the band instead of the metal door sill. This results in more
color options for operators to choose from in determining a desired
color scheme.

The purpose of these bands is to assist rescue personnel in
recognizing exits in the side of the fuselage. Section 25.811(f)(1)
requires that a 2-inch color band outline each passenger emergency
exit in the side of the fuselage. Advisory Circular 20-47, paragraph
4b, indicates that a color band outlining an exit is considered to
comply with applicable regulations whether the band is on the edge of
the exit itself, on the fuselage surrounding the exit, or partially
on both. Although this guidance indicates acceptance of bands located
on the edge of the exit itself, the FAA considers that a band could
be located a small distance away from the exit's edge and still be
considered to "outline" the exit as required by § 25.811(f)(1). The
FAA finds that for floor-level exits the size of a Type II exit or
larger, compliance can be found with the top and side sections of a
band located a maximum of 2 inches away from the exit's edge and the
bottom section of a band located between 2 inches below and 3 inches
above the exit's edge. Attachment 1 is a figure that demonstrates
these boundaries. The bottom section of the band is allowed to be
farther away from the exit's edge than the other sides of the band to
be consistent with past practices for exits with a door sill
installed at their base. Although the band is not required to be on
the edge of the exit, it must be parallel to the exit's edge.

Effect of Policy

The general policy stated in this document does not constitute a new
regulation or create what the courts refer to as a "binding norm."
The office that implements policy should follow this policy when
applicable to the specific project. Whenever an applicant's proposed
method of compliance is outside this established policy, it must be
coordinated with the policy issuing office, e.g., through the issue
paper process or equivalent.

Applicants should expect that the certificating officials will
consider this information when making findings of compliance relevant
to new certificate actions. Also, as with all advisory material, this
policy statement identifies one means, but not the only means, of
compliance.

/s/ Ali Bahrami for

Vi L. Lipski



Attachment 1
Acceptable Color Band Locations for an Exit the Size of a Type II

Exit or Larger