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PlaneTorque Australia Pty Ltd Professional Aeronautical Consulting & Auditing Services ABN 23 104 977 942

PlaneTorque June 2008

elcome to the fifth issue of PlaneTorque. This month we take a look at the tricky area of ensuring continued conformance of seats, seat belts, harnesses and other trim such as carpets and side walls. An area I have only recently become quite familiar with as a result of my CASA IoA CoA activities. Not all of the following comments apply to Light Sport Aircraft.

Seats, Seat Belts, Harnesses & the like. Why all the fuss when you get them repaired? irstly a small legend to clarify abbreviations used: a) b) c) d) e) f) g) h) i) j)

AAC = Airworthiness Advisory Circular AIAA = Aerospace Industries Association of America, Inc., AS = Aerospace Standard E/O Engineering Order NAS = National Aerospace Standard OEM = Original Equipment Manufacturer SB = Service Bulletin SAE = Society of Automotive Engineers, Inc. STC = Supplemental Type Certificate TSO = Technical Standard Order. FAA in this case

et’s start with a list of the potential offending items. a) b) c) d) e)

Seats themselves Seat belts Seat harnesses Cargo nets Carpet & trim

hat are the design specifications that need to be considered? a) Seats – TSO C39b & C39c

b) Seat belts & harnesses – TSO C22g or SAE AS 8043; TSO C100b; C114, C167 and there well may be more. c) Cargo nets – TSO C90c or AIAA NAS 3610 d) Carpet, trim & seat covers – Burn Tests ow let’s list the type of things we can do with these items (Well aside from doing nothing!): a) Replace with like new item. b) Replace with a new alternative item. c) Replace with a used item. d) Repair existing item. hat are the rules covering this type of activity? Well put plainly the item must at all times conform to original design specifications unless covered by another acceptable design change (ie: STC; SB or E/O etc.). Actually its no different to the aircraft as a whole. So let’s look at how each item is affected by the maintenance we can perform on them. eplace with an OEM approved product. Bit of a no-brainer really. Just make sure the item come with an acceptable release document and is installed correctly (Including certifications). eplace with a new alternative item. Same as for above accept the item might be approved via an STC; SB or E/O. eplace with a used like item (Same part number). A common event and as long as the item is inspected and found fully serviceable, its just a Page 1 of 2

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paperwork exercise. Ie: Removed serviceable from VH-XXX.

Now the tricky option. REPAIRS he common tasks performed on these type of items over and above inspections and minor repairs are structural repairs and refurbishment. Again I would suggest that structural repairs are well understood by most LAME’s with respect to how to go about doing them and the required certifications and release documents. However the same is not always quite so true for refurbishment. The following lists in brief the matters we must consider when refurbishing any of these items: a) Does the OEM allow his product to be repaired or refurbished by any entity outside his own? Some OEM’s explicitly do not (Refer the example below of a seat belt data plate – Photo 1). I started to try and research this important aspect but of those OEM web sites I visited none explicitly forbid repairs by others. However I suspect that if tested in court some might get a tad protective. My advice would be, if in doubt ask and as a minimum ensure the repairs are covered by appropriate E/O’s. b) Do the materials used conform to acceptable burn tests and are burn test results part of the release documentation? Where do you find burn test data? FAR 23.853 & FAR 25.853. CASA AAC 1-114 c) When installing trim how is it attached? Careful where you allow screw holes to be


PlaneTorque Australia Pty Ltd Professional Aeronautical Consulting & Auditing Services ABN 23 104 977 942

PlaneTorque June 2008

d)

e)

f)

g)

h)

drilled. I have personally seen some quite dangerous results from unsupervised non-aviation trained staff. Do the repairs conform to the required technical specification and is this noted on the data plate? Is there a data plate on each element of the assembly? Is the data plate complete in all other respects? Again take a look at the good but incomplete data plate below in photo 1. What’s missing? In the case of seats you need to be particularly careful. For example has the seats basic design been changed as a result of say using a different consistency padding material or cover. Has the replacement carpet or seat cover material come from the one roll? If not has each piece been ID’d back to its appropriate release document and burn test certificate?

Photo 2 – A very average seat belt data plate. Also not on each element of the seat belt halves.

Photo 3 – A new seat belt assembly where the OEM has opted to stamp the data onto each buckle in the set.

Where-What-When?

Photo 4 – A repaired seat belt with an OK data plate.

Answers in next months issue. Last months was a Russian medium lift helicopter I came across in New Zealand in April 2008. I think it’s a Mil-8T

Photo 1 – A cloth seat belt data plate with missing key data. Nice data plate design but it lacks finish. OEM name removed by me

PTA have just released an alternate noncomplex aircraft maintenance log book. ONLY A$35 Fully compliant with CAO 100.5. Save over A$120 when compared to CASA version. Buy one this month and get a FREE recreational aircraft MR form.

the case because you have not ensured the aircraft remains in conformance with its type design. Scenario: Aircraft crashes, seat belts or seat fail, carpet burns too quickly, people are hurt/killed their legal team pin the cause on your nonconforming repairs. And of course your insurance company might not be inclined to cough up either as you have it would seem deliberately taken short cuts and not complied with the law of the land (Check your policy wording!). Does this sound a tad far fetched? Trust me its not.

What The!

Data plate examples.

Advert.

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Useful Links

In conclusion. hat is the down side of ignoring all this B.S. and just doing your own thing? Well at the start of the cycle you may get a cross in a box rather than a tick at the CoA inspection. Delays cost money. Indeed its a show stopper in certain circumstances. Later, in court, following that bad accident where our lawyer mates are chewing your butt off, you might find they win Page 2 of 2

The following links are the most common but there are of course others. All are hyperlinked. 1. Australian Technical Standard Orders http://www.casa.gov.au/airworth/atso

2. USA Technical Standard Orders then go to the TSO section http://www.faa.gov/regulations_policies/

3. USA Special Chemicals http://www.specialchem4polymers.com/tc/FlameRetardants/index.aspx?id=9364

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Contact Info: Tel.: 08 93774669 FAX: 08 93774521 Mob.: 040 0377 054 E-mail: alan.jupp@ptaaus.com.au www: www.ptaaus.com.au


Iss05-Jun08