Aircraft Upholstery Fabric. US

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Magman

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Magman
The Cessna ( now Textron ) 170A is certificated under CAR 3 regs. Replacement of interior fabric must meet original design specs regarding flame retardants. However; CAA/FAA never developed requirements in this area for CAR 3 aircraft. My understanding is that using materials meeting a national standard is sufficient.

Auto upholstery fabric?

Compliance with the Burn Cert requirements of FAR 23 is not required in the US.

I know folks that did their own Burn Tests with surprising results.

There are times this can get ugly.
 
Tagging for updates.

I'm curious about this as well as I'd like to recover my front seats.

@NealRomeoGolf just had his seats recovered and re-foamed, and sent samples of his material for burn tests.
 
CAR 3 indeed just calls for fire resistant material without providing any requirement to test it. If you want you can send what you want to use out to be tested, but it's not required.
 
I read enough justification from multiple aviation writers about burn certs being required that I did it. Didn't cost all that much and now I have proof in my logbook. My leather came from a car interior vendor but they didn't provide any data to comply with FAR 23.
 
The official burn test is cheap, easy, and seemingly less stringent than what most had done at home (they use a small lab burner) - they're looking to ensure that the materials don't continue to burn after the flame source is taken away. You'll find that most automotive materials just pass this test - flame resistant additives are quite expensive.

IMO it's a good idea - gives you time to get out.
 
Magman said:
However; CAA/FAA never developed requirements in this area for CAR 3 aircraft. My understanding is that using materials meeting a national standard is sufficient.
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There are regulatory requirements for CAR 3 and Part 23 non-commuter aircraft interiors just not a separate published burn test standard like the Part 25 burn cert. There is FAA guidance out there on how to meet the CAR3/Part 23 requirements. However, I found its much simpler just to buy Part 25 cert materials with a document and be done with it. Plus as mentioned above, this is to protect your but from not burning in the seat which usually convinced my customers to go the Part 25 route. The local upholster I used had material venders who could provide burn certs if needed and the cost difference between the different fabrics/materials was minimal in most cases. But there were times when a color or texture was not available in the Part 25 cert offerings so any ASTM flash or fire resistant tested material was acceptable for CAR3 or Part 23 non-commuter applications as you noted in your post about a national standard. In addition to all this, a pilot could replace the interior upholstery under Part 43 preventive mx provided no primary structure, controls, etc were not disassembled or the weight change between old and new materials doesn't exceed a 1 lb difference.
 
The situation here is 2 guys in the auto business doing “I’ll paint your car if you’ll do my aircraft interior” or similar. My guess is it does limit material selection.

My belief is auto fabric has had some standard for the last 50 years.

Any recommendations for a Burn Test lab? There is someone I know that made some type of test apparatus also.

I’ve been through a couple poor FAA presentations on this topic. It seemed to just muddy the water. ie “ If you modify the installation in any way you have to upgrade to Part 23 Standards. Adding a button or pocket would be a modification”. Maybe 2 buttons requires Part 25 ?

My understanding is the retardant properties degrades with time and cleaning techniques. So retaining old original material may be counterproductive.
 
Magman said:
The situation here is 2 guys in the auto business doing “I’ll paint your car if you’ll do my aircraft interior” or similar. My guess is it does limit material selection.
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I would have the aircraft owner buy the materials separate to ensure he gets the proper material or ensure the upholstery guy provides certificates with the material he gets. Been there done this in the past.
Magman said:
My belief is auto fabric has had some standard for the last 50 years.
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Some auto materials have ASTM test papers and some don't. We once used some ASTM corduroy material for a Staggerwing interior that came with ASTM flash and flame resistance documents which doesn't require any further approvals so long as the aircraft is CAR3 or Part 23 non-commuter.
Magman said:
Any recommendations for a Burn Test lab?
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I've only used Skandia in IL. But I haven't needed to use them for any Part 91 aircraft as I always ensured materials had a Part 25 cert or an ASTM doc.
Magman said:
There is someone I know that made some type of test apparatus also.
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FYI: There is an FAA handook that shows how to make test cabinets for each required test.
Magman said:
If you modify the installation in any way you have to upgrade to Part 23 Standards.
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Not that I've seen or heard of. Part 43 covers modifications and Part 23 is new aircraft certification so don't know of any connection when it comes to interior mods?? As I mentioned above, for simplicity I always recommend using Part 25 cert materials but there is no requirement to upgrade regardless of the modification that I am aware of.
 
I had the Comanche done at an auto upholstery shop.

My stance on the whole burn thing is, if the cockpit is on fire, I'm probably on fire, and I don't think burn resistant seating is going to do much since I would have to burn first before the seat would.
 
Personal Safety is only PART of the issue.

There was a fatal with a 152 several years ago. The Insurance Co. declined coverage as “ Unapproved Components “ were in the aircraft and therefore it was
Not Airworthy as it no longer met the Type Cert .

The component referred to was a carpet and it had no bearing on the accident.
“ Further investigation revealed” that the carpet was made by Airtex. They do not identify individual components of a kit. I believed they relented.


I couldn’t make this stuff up. Dominic is the fiction writer!
 
EdFred said:
My stance on the whole burn thing is, if the cockpit is on fire, I'm probably on fire, and I don't think burn resistant seating is going to do much since I would have to burn first before the seat would.
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Possibly. But the main difference between materials with a burn certificate and those materials without is how it burns. You'll find non-tested materials tend to flash at very low temps and simple ignition sources. So instead of smelling something burning which gives you time to land, the cockpit will flash over before you know it. Regardless, the one who gets "burned" more on improper interior materials is the unsuspecting APIA signing off an inspection or the future buyer who's prebuy check missed the fact the interior carpets and curtains are from Walmart.
 
I have a related question; hope this isn't too much of a drift but I could use some wise POA advice (yeah, I know that's quite a gamble).

My plane is over 50 years old. I have no idea whether the fabrics still meet flame retardance requirements. No doubt over five decades numerous contaminants have soaked into the carpets and upholstery.

I've seen a variety of flame retardant chemicals and sprays for sale on line and I'm beginning to think it might be wise to "refresh" the fabrics in my plane, but I don't know what problems there may be with these products. If, for example, some of them outgas a chemical that attacks plexiglass, that would be a problem (just a made-up example).

Are there any concerns with these chemicals? Any that are recommended? Any to avoid?
 
I had an auto upholstery place do my plane. Mine was their first but they went on to do a few others. Amusingly their name was Hartzell (not relation) Auto Upholstery.
They had no problem sourcing Part23 fabrics even though the Navion like your 170 doesn't strictly require it.
 
From FAA Order 8900:

VOLUME 4 AIRCRAFT EQUIPMENT AND OPERATIONAL AUTHORIZATIONS
CHAPTER 14 GENERAL OPERATING AND FLIGHT RULES—MAINTENANCE ISSUES
Section 14 Flammability Testing of Interior Materials Used in Repairs and Alterations
4-14-14-1 OBJECTIVE. This section provides guidance to aviation safety inspectors (ASI) regarding flammability testing of materials used in repairs and alterations of aircraft interiors.
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4-14-14-3 GENERAL. The primary audience for this guidance is Flight Standards District Office (FSDO), certificate management office (CMO), International Field Office (IFO), and Office of Safety Standards (OSS) personnel who are responsible for certificate management, oversight, and policy. Inspector responsibility is limited to normal surveillance activity to ensure compliance with regulatory policy.
4-14-14-5 BACKGROUND.
A. Flammability Testing. Flammability testing is necessary for repairs and alterations to interior materials and components if required in the aircraft certification basis and/or the operating rule. The Type Certificate Data Sheet (TCDS) (or aircraft specification) for the specific aircraft identifies the certification basis. This generally includes materials used in crew, passenger, and cargo compartment interiors, and other materials identified in the certification basis. Title 14 of the Code of Federal Regulations (14 CFR) part 43, § 43.13(b)requires, in part, that each person maintaining or altering aircraft shall do that work in such a manner and use materials of such a quality that the condition of the aircraft will be at least equal to its original or properly altered condition with respect to qualities affecting airworthiness. The person authorized by § 43.7 to approve an aircraft for return to service after repair or alteration is responsible for determining that the materials used are suitable and meet applicable requirements.
B. Maintenance. Flammability testing of material specimens is not maintenance. Flammability testing is comparable to chemical and physical destructive testing of other material specimens used in aircraft repairs and alterations (e.g., aluminum and steel), which is also not considered maintenance. As such, flammability testing is not work performed on the material to return it to “at least its original or properly altered condition.” A flammability test determines whether a material or component meets the regulatory requirements of the aircraft airworthiness standards, so it may be used as part of a design, repair, or alteration. Flammability testing is not maintenance in accordance with part 43, and authorizing a repair station to perform these tests under 14 CFR part 145 is not appropriate.
C. Approval. The Federal Aviation Administration (FAA) does not approve or certificate flammability test facilities.

4-14-14-9 GUIDANCE.
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A. Authorization. The regulations set forth test procedures, but do not state who has authorization to perform the tests or collect the data. Any person who can perform the testing to the requirements of the applicable airworthiness standard may accomplish flammability testing. The FAA will not approve or certificate persons to perform flammability testing. A responsible Aircraft Certification Service office, DER, or ODA must approve test data as part of the approved technical data required to support a major repair or major alteration. As with any maintenance or alteration, the person who approves the aircraft for return to service is responsible for doing that work in such a manner and using materials of such a quality that the aircraft worked on will be at least equal to its original or properly altered condition.
B. Material Specimen Tests. Material specimen tests may not be representative of the material configuration installed in the aircraft, and may not be sufficient to determine that the complete repair or alteration meets all requirements. For example, the flammability characteristics of a seat or interior panel material alone may be different from the material as installed on the part with foam, insulation, adhesive, etc. Consult the applicable regulation for test criteria for showing compliance to the rule.
C. Ratings and Capabilities. The FAA will not authorize limited ratings for flammability testing, and repair stations must not add flammability testing to the capabilities lists.
D. Field Approval. ASIs should not field approve flammability test data for materials.
4-14-14-11 FLAMMABILITY TEST DOCUMENTATION. The following are methods for approval of flammability test data:
A. Data for Major Repairs and Alterations. Test data for major repairs and alterations must receive approval by one or a combination of the following alternatives:
1) DERs use FAA Form 8110-3, Statement of Compliance with Airworthiness Standards, only to approve flammability test data associated with specific certification projects (design approvals), major repairs, and major alterations. This form is not for quality assurance or material certification.
2) Appropriately authorized ODAs use FAA Form 8100-9, Statement of Compliance with Airworthiness Standards, to approve flammability test data for major repairs or major alterations only for a specified product (by make, model, and serial number).
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3) A letter from a responsible Aircraft Certification Service office approves specific flammability test data.
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B. Approval for Return to Service. The Authorized Release Certificate, FAA Form 8130-3, Airworthiness Approval Tag, is for approval for return to service of products and parts, not material testing or certification. A flammability test is not work performed on the material to return it to “at least its original or properly altered condition” in accordance with the current edition of FAA Order8130.21, Procedures for Completion and Use of the Authorized Release Certificate, FAA Form 8130-3, Airworthiness Approval Tag.
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C. Acceptable Data for Minor Repairs or Alterations.When a repair or alteration is not major and does not require FAA approved technical data, the flammability testing documentation should be acceptable to the FAA and meet the requirements of the person approving the aircraft for return to service. The documentation should provide evidence that the tests complied with FAA standards and include the test results necessary to show compliance. For minor repairs and alterations, test data that shows compliance with the aircraft’s certification basis is acceptable without the responsible Aircraft Certification Service office, DER, or ODA findings or approvals. Certification of Conformance statements (or similar) may not be adequate. The test data must include specifics such as burn length, flame time, burn rate, glow time, etc., as required by the regulations.
D. Data Approval Considerations. Data development should include an evaluation of the entire interior repair or alteration to determine the type of data approval required. The FAA does not allow piecemeal or a series of “minor” determinations in order to circumvent the requirement for approved data for the overall repair or alteration.
E. Aircraft Records. The owner/operator is not required to keep flammability test data for minor repairs and minor alterations in the aircraft records after approval for return to service by an authorized person.




 
I was unable to find fees at Skandia site. Any idea?

The previous post seems to imply ANY PERSON can perform the tests?

Also the Owner/ Operator does not have to even keep records?

As Bell stated; this really sucks for the Tech.

Maybe I should take an interior pic at Annual and have Owner do as PM later?
 
Half Fast said:
I have no idea whether the fabrics still meet flame retardance requirements.
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In general, you'll find materials manufactured to a flame-resistant standard retain their resistant qualities through their entire lifespan regardless of age. This is why there are no time-limits or airworthiness limitations on this item of certification. However, if a material is manufactured but gets its flame-resistance from an exterior application of a spray product, etc. then there are time issues to be concerned about. Hence the importance of using the proper materials.
Half Fast said:
I've seen a variety of flame retardant chemicals and sprays for sale on line and I'm beginning to think it might be wise to "refresh" the fabrics in my plane,
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There are a number of options available. For example, there are various Part 135 requirements that require the annual reapplication of fire retardant coatings on interior materials like cargo nets, etc. We used different products, some that even met the Part 25 burn tests but I don't recall their name or brand. If this is something you are thinking about I would drop a mail to Skandia or any other flame test company and see if they have any recommendations. Or look to aviation supply companies for options. The sprays I used caused zero issues with the aircraft.

Magman said:
As Bell stated; this really sucks for the Tech.
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It only sucks if you don't know about it. If you're the one signing the annual for your two auto business buddies, tell them they need burn documents for the materials or you're moving on. Simple. However, you almost have to go out of your way not to get a burn certificate nowadays.
 
I'm reminded of the Apollo 1 disaster. If I remember correctly, they completely reconsidered the flammability of the components in the cockpit after the accident, because while not the cause, rapid spread of flames enabled by seat and other materials was a contributing factor.

In an engine fire situation, it's not likely to matter. But in the event of an electrical fire or other cause of sparking, it may. Especially when the spread of a small fire is enabled by flammable materials around it. Just like in the Apollo 1 disaster, in these situations, seconds count.

What a horrifying way to go though :(
 
Thanks for the reply!


Bell206 said:
In general, you'll find materials manufactured to a flame-resistant standard retain their resistant qualities through their entire lifespan regardless of age
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Well, for example, my plane's floorboards are plywood covered with carpet. I assume the plywood was treated 50 years ago, but over the years it's been stained and colored by greases and oils from the plane. Maybe the plywood is still flame retardant, but who really knows? I'm not really interested in putting a torch to it to find out. ;)

A $20 spray bottle or two seems like cheap insurance as long as it doesn't cause other problems, which leads to....



Bell206 said:
The sprays I used caused zero issues with the aircraft.
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I looked at a product Spruce sells called "Inspecta-Shield." Spruce's website has a note that says, "Note: Inspecta-Shield is corrosive to aluminum and other metals. If it comes in contact with metals be sure to wipe off metal and clean thoroughly." I read the manufacturer's data and didn't see any mention of this. I assume they mean it causes corrosion if the spray gets on metal and NOT that treated fabrics cause a problem if they come in contact, but I'm not sure.
 
Magman said:
I was unable to find fees at Skandia site. Any idea?

The previous post seems to imply ANY PERSON can perform the tests?

Also the Owner/ Operator does not have to even keep records?

As Bell stated; this really sucks for the Tech.

Maybe I should take an interior pic at Annual and have Owner do as PM later?
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My certs from Skandia were $85.10 per fabric. I had 2 colors so I had two fabrics.
 
Baked Potato said:
I'm reminded of the Apollo 1 disaster. If I remember correctly, they completely reconsidered the flammability of the components in the cockpit after the accident, because while not the cause, rapid spread of flames enabled by seat and other materials was a contributing factor.

In an engine fire situation, it's not likely to matter. But in the event of an electrical fire or other cause of sparking, it may. Especially when the spread of a small fire is enabled by flammable materials around it. Just like in the Apollo 1 disaster, in these situations, seconds count.

What a horrifying way to go though :(
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NASA also learned not to use pure oxygen instead of air.
 
Half Fast said:
I assume the plywood was treated 50 years ago
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I doubt the plywood was included as it is more structure than furnishing.
Half Fast said:
"Inspecta-Shield."
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Dont know that product but the stuff we used was sprayed all over aluminum interior areas with issues but we had corrosion promblems simply flying around and over the GOM. I'd look around some more or call the vendor direct.
 
Half Fast said:
NASA also learned not to use pure oxygen instead of air.
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pure oxygen at 14 psi. ---> normally nonflammable materials can become extremely flammable.

pure oxygen at 5 psi is ok (at least that's my understanding).
 
Half Fast said:
Well, if it's not treated, it'll sure burn! Seems pointless to ensure you've put flame retardant carpet on top of firewood. :)
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Well it depends on how you look at it. They dont treat the dope and fabric or other wooden structure in the cockpit area on older aircraft like Stearmans. It wasnt until pilots wanted the comforts of home in their aircraft like carpeting and cushy seats that fire protection even had to be looked at.;)
 
Half Fast said:
Well, if it's not treated, it'll sure burn!
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I replaced my floorboards recently and tossed one in the fire pit. Holy moly! Varnished plywood dried for 45 years burns like crazy. We're going to cut the rest of the boards into strips as fire starter wood. And varnish makes nasty black smoke.
 
I’ve never seen a cow burst into flames. I think I’m good with my interior.
 
Timbeck2 said:
I would use synthetic leather. It looks and feels like real, it wears better and doesn’t require any special treatment.
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FWIW: I think the original Naugahyde brand material is best for any aircraft or marine applications. For durability there are few equals. Most 135 ops use this with fabric covers, if needed.

And for those who are purists you could even raise a modest herd of Naugas... and collect your own material just like Uniroyal does.:rolleyes:
 
As to burn cert., IIRC AC43.13 outlines the procedure, and the specs on the burn cabinet. It's really very simple, even a caveman can do it.
I used leather, and treated carpet in my airplane.
 
I used Kurt to test a firewall blanket for me. I think it was $99 for a test. I would recommend him.
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Sent from my iPhone using Tapatalk Pro
 
My IA says that boats have similar requirements, and most marine upholstery shops routinely provide burn certs for their materials. Probably not a big help if you live in the plains or desert, but here in Florida you can't swing a dead cat without hitting a boat upholstery shop.
 
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