Narrative:

A group of FAA inspectors from dallas met our aircraft at love field during a quick turn and had a copy of an far 25 regulation stating something to the effect that there will be at least 1 exit on each side of the aircraft and it will be unobstructed. Our light transport (and all others) have these exits but in cargo operations the one in the starboard aft area is generally obstructed by cargo. Far 135 requires us to only have at least 1 regular or emergency exit available with no passenger on board which was our situation. Our FSDO in columbus, oh, approves our light transport cargo interiors and our loading methods. However, the dallas FSDO states that our interiors have been erroneously approved and are illegal. We loaded our jet and consequently bumped a significant amount of freight to satisfy the unobstructed rear exit requirement of this particular FSDO. Something needs to be done about these multiple far interpretations as our company and many others fly all over the us, and it seems every FSDO has a different set of regulations. Supplemental information from acn 109251: during the ramp check the FAA inspector, stated that even in cargo carrying operations the normal and emergency exit must be unobstructed, and not as stated in part 135, where the emergency exit is only required for passenger carrying operations. We then proceeded to load the airplane so as not to obstruct the emergency exit. We were told that if we obstruction the emergency exit we would get a letter of intent to violate.

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Original NASA ASRS Text

Title: INTERP OF FEDERAL AVIATION REG 135 PT 87 (C-4 AND C-7). BAGGAGE OR CARGO LOADING. CARGO ONLY OPERATION.

Narrative: A GROUP OF FAA INSPECTORS FROM DALLAS MET OUR ACFT AT LOVE FIELD DURING A QUICK TURN AND HAD A COPY OF AN FAR 25 REG STATING SOMETHING TO THE EFFECT THAT THERE WILL BE AT LEAST 1 EXIT ON EACH SIDE OF THE ACFT AND IT WILL BE UNOBSTRUCTED. OUR LTT (AND ALL OTHERS) HAVE THESE EXITS BUT IN CARGO OPS THE ONE IN THE STARBOARD AFT AREA IS GENERALLY OBSTRUCTED BY CARGO. FAR 135 REQUIRES US TO ONLY HAVE AT LEAST 1 REGULAR OR EMER EXIT AVAILABLE WITH NO PAX ON BOARD WHICH WAS OUR SITUATION. OUR FSDO IN COLUMBUS, OH, APPROVES OUR LTT CARGO INTERIORS AND OUR LOADING METHODS. HOWEVER, THE DALLAS FSDO STATES THAT OUR INTERIORS HAVE BEEN ERRONEOUSLY APPROVED AND ARE ILLEGAL. WE LOADED OUR JET AND CONSEQUENTLY BUMPED A SIGNIFICANT AMOUNT OF FREIGHT TO SATISFY THE UNOBSTRUCTED REAR EXIT REQUIREMENT OF THIS PARTICULAR FSDO. SOMETHING NEEDS TO BE DONE ABOUT THESE MULTIPLE FAR INTERPRETATIONS AS OUR COMPANY AND MANY OTHERS FLY ALL OVER THE U.S., AND IT SEEMS EVERY FSDO HAS A DIFFERENT SET OF REGS. SUPPLEMENTAL INFO FROM ACN 109251: DURING THE RAMP CHK THE FAA INSPECTOR, STATED THAT EVEN IN CARGO CARRYING OPS THE NORMAL AND EMER EXIT MUST BE UNOBSTRUCTED, AND NOT AS STATED IN PART 135, WHERE THE EMER EXIT IS ONLY REQUIRED FOR PAX CARRYING OPS. WE THEN PROCEEDED TO LOAD THE AIRPLANE SO AS NOT TO OBSTRUCT THE EMER EXIT. WE WERE TOLD THAT IF WE OBSTRUCTION THE EMER EXIT WE WOULD GET A LETTER OF INTENT TO VIOLATE.

Data retrieved from NASA's ASRS site as of August 2007 and automatically converted to unabbreviated mixed upper/lowercase text. This report is for informational purposes with no guarantee of accuracy. See NASA's ASRS site for official report.