september 2011page 1seats technical center [email protected] industry priorities for the...

Seats Technical Center [email protected] 2011 page 1

Industry Priorities for the Next TSO-C127 Revision

September 9, 2011Industry & FAA WorkshopTA Wilson Event Center

Seattle, Washington


TSO-C127 Industry TSO-C127(b) Strategy Timeline

Industry meeting in Washington DC

April 8, 2011

FAA David Hempe Letter

May 27, 2011

Discussion with FAA in Washington DC

Aug 28, 2011

FAA Matrix shared with Industry at SAE meeting Letter

May 23, 2011

Industry Response Letter

June 7, 2011

Industry/FAA meeting in Seattle

Sep 9, 2011


Issues Previously Discussed between Industry & FAA• Priority 1 - Seat Heat Release Special Conditions

• Priority 2 - Delethalization of Features

• Priority 3 - Delethalization of Features from the Occupant's Own Seat

• Priority 4 - Wire Routing and Flammability Approval for Items in

TSO Type Design

• Priority 5 - Life Preserver Stowage Requirements

• Priority 6 - Compliance of Under Seat Baggage Restraint

Shared with the FAA on April 8, 2011


Priority 1 - Seat Heat Release Special Conditions•Evaluation of the seat for HRSC is

independent of the aircraft interior•Compliance activity should be re-usable

for each installer – the TSO facilitates this

• Important that the TSO support

– Collection of valid data– Determination that the HRSC are

met for that seat design (similar to 25.853(a) and (c)

– Installation limitations address any issues that are beyond the TSO

•Question – does a guidance document need to be in place for the TSO to reference?– Industry standardization activity in

2010 can serve as minimum performance standard (MPS) criteria Shared with the FAA on April 8, 2011


Priority 1 - Seat Heat Release Special Conditions

Shared with the FAA & Industry on September 9, 2011


Priority 2 - Delethalization of Features

•Occupant Strikes to a Monument– Guidance exists for delethalization of

the seat back facing an occupant within the head strike zone (AC 25-17A) • FAA policy PS-AIR100-2003-ARP5526

provides seat manufacturers and installers with guidance for making determinations of compliance to the TSO MPS as well as Part 25. (AS8049, as well as 14 CFR 25.785 and 25.601)

• Utilization of current guidance FAA Policy Memo ANM-03-115-31 standardizes the delethalization analysis for components within the striking radius of an occupant’s head.

•Incorporation of inflatable systems special conditions into TSO-C127b would allow installers to utilizes TSO collected data without redundant review.


tme2504

The special conditions are installation applicant specific. However, if we identified special conditions that were not specific to a particular installation and they became MPS under the TSO, the installer would not have to review further for thos aspects. The installation specific aspects could benefit from the ability of the TSOA holder to report valid testing data. It would have to be the installer's responsibility to ensure that the parameters of the test were pre-identified such that further review would be mitigated.


Priority 2 - Delethalization of Features

• FAA intends to include delethalization requirements of SAE ARP 5526A in the next revision to TSO-C127

• FAA will evaluate use of FAA policy memo ANM-03-115-31 as called out in ARP-5526B– Coordination/consensus between Transport, Rotorcraft,

and Small Airplane Directorates may be required• Industry appreciates FAA intent to address this in the

FY012 TSO revision

Summary of Correspondence Between FAA & Industry May 27 & June 7, 2011


Priority 3 - Delethalization of Seat Features - continued

• Delethalization of seat features from an occupant’s own Seat (14 CFR 25.785(b)(d)(k))– AC 25-17A guidance could be updated to include

items on an occupant’s own seat and, if followed, TSOA would indicate that no further review is needed.

– An acceptable means to evaluate compliance for features on an occupant’s own seat could be:•Features, including cocktail tables, that fall into the hatched area shown are acceptable.

•Features encroaching into the headstrike zone less than or equal to 1.0”, as measured from the inside surface of the armrest, are acceptable for seat widths of 21” or greater, as measured between the inside surface of each armrest.

•Features encroaching into the headstrike zone and not exceeding a height of 37” above the seat track are acceptable.

•Features encroaching into the headstrike zone more than 3.0”, as measured from the inside surface of the armrest, are not covered by this MOC and compliance must be shown by other means.



Priority 3 - Delethalization of Features from the Occupant's Own Seat

• Industry requests the TSO recognize that an inspection for sharp edges and corners provides adequate substantiation for delethalization of items on an occupant’s own seat

• Industry notes this level of evaluation has traditionally been used for TSO and installation evaluations across industry for years.

• Industry recognizes that potential future designs may be so unique that further substantiation may be required prior to installation. TSO applications for such designs should note that further evaluation is required.

• Industry requests this be addressed in the FY012 TSO revision

• The FAA will request the SAE Seat Committee develop a standard for evaluating seat delethalization including non-traditional seat designs.



Priority 4 - Wire Routing and Flammability Approval for Electrical Items in TSO Type Design

•TSO should cover Wire Routing and Wire Flammability for electrical components integrated for which design and quality is clearly controlled by the TSO manufacturer

• Minimum Performance Standards (MPS) criteria can be covered by:– ARINC 628 Part 5 provides

guidelines for Part Selection, Wire Design, Wire and Equipment Installation, Documentation

– SAE AS8049A and ARP5526 - Provide further design guidelines



Priority 4 - Wire Routing and Flammability Approval for Items in TSO

Type Design• Wire Routing Electrical Items

– Standards exist for wire routing requirements. – FAA coordination with the Directorates is needed to

determine if these requirements can be easily and appropriately integrated into the FY012 TSO-C127 revision or will require more time and must wait for a future revision.

• Wire Insulation Flammability– Wire flammability requirements are well known and will

be included in the next revision of TSO-C127 for the appropriate seat types.

• Industry supports the inclusion of both wire routing and wire flammability under the TSO in FY 2012



Priority 5 - Life Preserver Stowage Requirements•Life Preserver design and certification is completely

contained within the seat design.•Life preservers or their storage locations must be

designed so that tampering is evident. 14 CFR 25.795(c)(3)(iii); AC 25.795-8

•Each life preserver must be within easy reach of each seated occupant 14 CFR 25.1411(f)

– Although life vest retrievability is already a part of the TSO MPS, installers often have difficulty with the practical usefulness of that approval when certifying airplane interiors.

– FAA CAMI DOT/FAA/AM-03/9 Report and guidelines need to be recognized and utilized into compliance findings.

•SAE ARP 5526(B) contains sufficient guidance that installers could use the TSO approval along with a well written Installation Instructions and Limitations (IIL) document, without any further substantiation for installation.

•AC 25.795-8 contains sufficient guidance to serve as a TSO MPS. Seats with TSO approval would not require any further substantiation for ensuring tamper evident design.



Priority 5 - Life Preserver Stowage Requirements

• Life Preserver Retrievability– FAA intends to evaluate whether to use a modified version of

ARP 5526a or utilize the requirement in ARP 5526b.– FAA intends to address this issue in the FY012 TSO revision.

• Life Preserver Tamper Evidence– There is currently no industry standard for this requirement.

• AC 25.795-B highlights one acceptable method for transport category airplanes. The FAA will request that the SAE Seat Committee develop an industry standard document for life preserver tamper evidence.

• Coordination across the FAA Directorates would be required prior to potential incorporation of the resultant standard into the TSO.

• For these reasons, integration of life preserver tamper evidence requirements into the next revision of TSO-C127 is not likely but will be considered for a future revision.



Priority 6 - Compliance of Under-seat Baggage Restraint

•The FAA has issued Policy that allows the TSO holders to use ARP5526 guidance to meet TSO MPS. (PS-AIR100-2003-ARP5526) – We recommend that the FAA adopts

the latest revision of the ARP5526 (Rev. B or C) for the new revision of TSO-C127

– By doing this, the installer would be able to use the TSO to show compliance to 25.787 for the baggage restraints as installed in the airplane.



Priority 6 - Compliance of Under Seat Baggage Restraint

• At this time, the draft revision of TSO-C127 partially uses section 3.7 of ARP 5526A as an optional requirement for the step load.

• In addition, the draft revision allows for the use of weights to simulate under-seat baggage loads during dynamic tests. The FAA intends to evaluate the use of section 3.7 of ARP 5526B as a requirement in the next draft of TSO-C127.

• Industry supports inclusion of these actions in the FY012 TSO revision.


september 2011page 1seats technical center [email protected] industry priorities for the...

Documents