Federal Aviation European Aviation Administration Safety Agency FAA/ EASA Briefing Koito Seat ADs 1
Federal Aviation European Aviation Administration Safety Agency Agenda 09: 30 Introductions/ logistics 09: 45 Background and Summary NPRM/ PAD Cologne/ Singapore Meetings 10: 00 FAA/ EASA activities since Oct. Industry meetings 10: 30 Differences between the proposals and the final ADs 11: 00 Break 11: 15 Provision by provision explanation of requirements/ ramifications EASA/ FAA AD differences and ramifications Compliance data 12: 00 Discussion of seat grouping 12: 30 Koito Presentation Q & A. 2
Federal Aviation European Aviation Administration Safety Agency Background/ Summary Background • Towards the end of 2009, EASA/ FAA became aware of allegations that the Koito seat company had been falsifying Certification test results, and had not controlled production conformity, for an appreciable period. • TC holders (Airbus, Boeing) and JCAB progressively added confirmation to these allegations 1stQ. 2010. • Initiatives started by TC holders and EASA/ FAA to determine scale of the issue. 3
Federal Aviation European Aviation Administration Safety Agency Background/ Summary It became clear that unsafe conditions existed and thus mandatory action was needed. EASA and FAA coordinated on an AD framework. Regulatory system differences however, prevented 100% alignment. 4
Federal Aviation European Aviation Administration Safety Agency Background/ Summary FAA NPRM published on 24 Sept 2010 EASA PAD published on 22 Sept 2010 Industry briefing sessions held • October 14, Cologne • October 21, Singapore 5
Federal Aviation European Aviation Administration Safety Agency Industry Meetings Based on the unusual circumstances surrounding the proposed ADs, EASA and FAA took the unusual step of holding industry meetings during the comment period Meetings primarily listening sessions for EASA/ FAA, but also chance to explain proposals further 6
Federal Aviation European Aviation Administration Safety Agency Industry Meetings Approximately 150 people attended the two industry meetings Numerous concerns and issues were raised EASA and FAA took all these comments into account when finalizing the ADs In particular the time between publication and effective date addressed several of the stated concerns 7
Federal Aviation European Aviation Administration Safety Agency FAA/ EASA activities since October 2010 Industry meetings 8
Federal Aviation European Aviation Administration Safety Agency Actions Since the Industry Meetings EASA/ FAA reviewed JCAB/ Koito confidence testing of selected seat models. EASA/ FAA reviewed JCAB/ Koito reports on tear-down inspection conducted on in- service seats. EASA, FAA, JCAB, Airbus, Boeing met at Koito to review confidence testing conducted by Koito under JCAB oversight. 9
Federal Aviation European Aviation Administration Safety Agency Actions Since the Industry Meetings Airbus and Boeing refined criteria to establish seat clusters and carry out assessments that are acceptable to EASA/ FAA. FAA intends to publish information on Boeing clusters, in a Special Airworthiness Information Bulletin. EASA intends to publish information on Airbus/ Boeing clusters in a Safety Information Bulletin. 10
Federal Aviation European Aviation Administration Safety Agency Comments on the Proposals Thirty + commenters More than 150 comments Comments covered wide range of issues 11
Federal Aviation European Aviation Administration Safety Agency Comments on the Proposals Common Themes • Withdraw AD • Extend comment period • Lengthen compliance times • Accept all Koito confidence tests All comments reviewed; substantive comments addressed in the final FAA AD. EASA comment/ response document addressed every comment. 12
Federal Aviation European Aviation Administration Safety Agency Differences between the proposals and the final ADs 13
Federal Aviation European Aviation Administration Safety Agency Differences Proposals & Final ADs Sharp Edges • Deleted requirement to show that original certification testing did not exhibit sharp edges. • Added Pass Fail structural testing criterion. – “The generation of sharp edges or injurious surfaces during the structural testing performed to comply with this AD may also be considered failure criteria.” – That is, if sharp edges are generated during static testing seats must be removed within two years. If sharp edges are generated during dynamic testing, but static testing is then successfully performed, seats may remain in service for six years 14
Federal Aviation European Aviation Administration Safety Agency Differences Proposals & Final ADs Allowance of new test articles 25.561 compliance • Static testing can be conducted on new build test articles, without the need to assess the conformity of the in-service fleet with the approved design. This position is based on the negligible effect on the static test results of potential non-conformities of Koito seats. 15
Federal Aviation European Aviation Administration Safety Agency Differences Proposals & Final ADs Conformity of in-service seats used for testing • Confirm aspects of in-service seats, when in- service seats are tested. – matching part number to test plan – noting general condition – revisions/ modification – date of manufacture. 16
Federal Aviation European Aviation Administration Safety Agency Differences Proposals & Final ADs Allowance of new test articles 25.562 compliance • FAA AD: conformity of in-service seats to new build seats to use for dynamic test. • EASA has the same position as the FAA, although the EASA AD does not explicitly mention this option. The use of new-built test articles will be allowed, provided that conformity of the in-service seats to the approved design can be demonstrated. 17
Federal Aviation European Aviation Administration Safety Agency Differences Proposals & Final ADs Added Clarification and Guidance through Notes: • Clarification of certification basis of TSO determines level of AD test. (FAA AD) • Clarification of the relevant aircraft certification basis. (EASA AD) • Koito interface load reports may be acceptable for the determination of compliance required by the AD. 18
Federal Aviation European Aviation Administration Safety Agency Differences Proposals & Final ADs Added Clarification and Guidance through Notes: • FAA NPRM rule did not address non-TSO, TSO- C39, TSO-C39a and TSO-C127 seats. Intend to supersede this AD to capture all seats produced by Koito Industries, Ltd. 19
Federal Aviation European Aviation Administration Safety Agency Differences Proposals & Final ADs Allow certain cabin reconfigurations. • Re-arrangement of the existing installed seats is acceptable following the same installation instructions and limitations as the original certification. (e.g., if the original seat installation limitations allowed 32” to 34” pitch, the new layout shall be pitched within that range). 20
Federal Aviation European Aviation Administration Safety Agency Differences Proposals & Final ADs 25.853(c) testing of seat cushions • Limited to seat bottom cushion and seat back cushion, i.e., not headrests, footrests etc. • Allow the use of new build samples for oil burner test, provided that it is shown that the in-service cushions consist of foams/ covers which were supplied to Koito and marked by a different production organisation approved by EASA and/ or FAA. 21
Federal Aviation European Aviation Administration Safety Agency Differences Proposals & Final ADs 25.853(c) testing of seat cushions • Test reports issued by any qualified design organization acceptable to the Agency, including Koito under JCAB supervision, except, • Tests performed in the Koito seat cushion oil burner test facility after 23rd May 2011 may also be acceptable. 22
Federal Aviation European Aviation Administration Safety Agency Differences Proposals & Final ADs Seat cushion replacement • FAA removed restrictive AC 25.562-1B requirement for TSO-C39 seats. • Compliance to 25.562(c)(2) not required for TSO-C127 cushions. – TSO-C127 seat and cushion placarded to show that seat cushion/ seating system may not comply to 25.562(c)(2). 23
Federal Aviation European Aviation Administration Safety Agency Differences Proposals & Final ADs Seat cushion replacement • EASA removed requirement to install replacement cushions having SRP location consistent with the original cushions for seats installed on aeroplanes required to meet CS/ JAR/ FAR 25.562. – replacement cushions must have consistent seat bottom geometry, stiffness and density (measured according to accepted industry standards) as compared with the cushions they replace. – Compliance to 25.562(c)(2) is not required 24
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