A Dispatcher noted that the supplemental life rafts were removed from B737-800 over water aircraft and as a consequence when the aircraft have more than 160 souls on board FAR 121.339A is violated because not enough raft space is provided.

Narrative

The company has removed supplemental rafts from all B737-800 with seating capacity of 160 seats. The raft capacity of these aircraft is 168. With a full passenger load (160) and a minimum crew complement (2+4=6) the total number of occupants would be 166. There is no method that the company had to account for lap children. There is the potential that a FAR violation (FAR 121.339A (2)) would occur if a flight departed with a full passenger complement and more than two lap children or a higher than a minimum crew. Attachments FAR 121.339 -- Emergency equipment for extended over-water operations. a) Except where the Administrator; by amending the operations specifications of the certificate holder; requires the carriage of all or any specific items of the equipment listed below for any over-water operation; or upon application of the certificate holder; the Administrator allows deviation for a particular extended over-water operation; no person may operate an airplane in extended over-water operations without having on the airplane the following equipment: 1) A life preserver with an approved survivor locator light; for each occupant of the airplane. 2) Enough life rafts (each equipped with an approved survivor light) of a rated capacity and buoyancy to accommodate the occupants of the airplane. Unless excess rafts of enough capacity are provided; the buoyancy and seating capacity beyond the rated capacity of the rafts must accommodate all occupants of the airplane in the event of a loss of one raft of the largest rated capacity.