Legalities on DIY interior

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JC150

Pre-takeoff checklist
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JC150
I am redoing the interior to my Piper Arrow III, and planning on putting in all new plastic pieces, soundproofing, carpet, sidewalls, and seats. I saw other threads on here about DIY interiors, but I couldn't find how I should log it in the logbooks. Is this something an A&P needs to do or would this fall under "preventative maintenance"? I'm just curious if its even legal for me to change out the interior...
 
Can't speak to the legalities or logbook requirements. But I highly suggest you have the aircraft weighed when your done to properly update the W&B.
 
Yup, preventive maint because interior is not structural. Part 43 appendix A. But make sure you get burn tags for all the materials, which go in the log book with the phrase..."replaced (list items), see burn certification letters attached" or something like that. I'll dig out mine later today and post them here.
 
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gstegall said:
I would check with an IA or your local fsdo.
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Overkill. Any A&P knows the answer. If they don't, tsk tsk tsk.

This is a teaching moment. Go read Part 43, Appendix A. Very enlightening and fodder for innumerous discussions here.
 
Run a search on here with my user name and upholstry. I posted a thing on it.
 
here are somethings that I've posted before.....

Depends on when it was certified....and what it was certified under. Older aircraft certified before 1970's were certified under CAR 3 vs part 23.

"Flame resistance" is not a requirement under CAR 3.

If you need to meet the burn resistance requirements of part 23... I have discovered several products that meet FAR 25.853 (a) & (b) and another product that meets FAR 25.853 appendix F a(1) (i). These products are flame retardant penetrants that can be directly applied to the fabric. I believe either of these products would exceed the "flame resistance" FAR 23.853 requirement for part 91 operations.

If you need to perform the treatments....I have two quart bottles of the flame retardant I will sell for half price of what I paid. ($35 for both +S&H)

Check the TCDS (Type Certificate Data Sheets) for your model aircraft (can be found at the FAA website FAA.Gov)....it will tell you what it was certified under.
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SECTION 4. CABIN INTERIOR

9-60. GENERAL. Only materials that are flash-resistant should be used in cabin interiors. The requirements related to fire protection qualities of cabin interior materials are specified in CAR 3.388, fire precautions or 14 CFR part 23, section 23.853 compartment interiors.

9-61. CAR-3 AIRCRAFT INTERIOR. The requirement for an interior of a CAR-3 aircraft that is used only in 14 CFR, part 91 operations, where smoking is not permitted, is that the materials shall be flash-resistant. (Reference CAR-3.388.)


a. For compartments in CAR-3 aircraft where smoking is permitted, the wall and ceiling linings, the covering of all upholstering, floors, and furnishings shall be flame-resistant. Such compartments should be equipped with an adequate number of self-contained ash trays. All other compartments shall be placarded against smoking. (Refer to CAR-3.388.)


(1) If fabric is bought in bulk to refurbish the interior, seats, and ceiling liners for a CAR-3 aircraft used in part 91 operations, a manufacturer's statement, declaring that the material meets the American Society for Testing and Materials (ASTM) or similar national standard for either flash resistance or flame resistance, would be acceptable, but only for a CAR-3 aircraft installation. (Refer to 14 CFR part 43, section 43.13(a).) A manufacturer's statement is acceptable due to neither the Civil Aeronautics Administration (CAA) nor the Federal Aviation Administration (FAA) having published an FAA fire standard for either flash or flame resistance for interior materials for CAR-3 aircraft. Since the FAA would accept and recognize a national standard, the mechanic would reference the manufacturer's statement and the national standard that the material meets in the aircraft's maintenance records.

(2) If an annual inspection is performed on a CAR-3 aircraft with a new interior and there is no mention of a manufacturer's statement that the fabric is flash or flame resistant as applicable, the possibility exists that the fabric is an unapproved part. The mechanic should take the necessary steps to ensure that the fabric meets or exceeds the ASTM or national standards. (Refer to 14 CFR part 23, appendix F.)

(3) If an FAA-approved STC interior kit is installed in a CAR-3 aircraft, and the material and fabric in the kit are PMA or TSO approved, the mechanic should include the STC number in block 8 of FAA Form 337.
b. It is recommended that for all CAR-3 interiors to use only fabric and materials that meets the more stringent requirements of part 23, appendix F.
9-62. PART 23 AIRCRAFT INTERIOR. Materials used in part 23 aircraft interiors must meet the requirements of section 23.853, and the burn test requirements called out in part 23, appendix F.


a. If the fabric is bought in bulk to refurbish a part 23 aircraft then the fabric must meet the part 23 burn requirements. A burn test would have to be done on samples of the material and fabrics by an approved and rated FAA Repair Station. That FAA Repair Station would certify that all the material and fabrics meet part 23, appendix F requirements. The mechanic would include that repair station's statement in the aircraft's records.

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b. If STC-approved interior kit with either PMA or TSO-approved materials for a part 23 aircraft is bought, the mechanic would only have to reference the STC number on FAA Form 337 and the aircraft's records. part 23, appendix F would not be required.

c. If an annual inspection is to be performed on a part 23 aircraft in which a new interior was installed, but the aircraft's records do not reflect that a burn test was performed on the interior's materials and fabric by an FAA Approved Repair Station, or there is no mention of an STC or FAA Form 337 in the aircraft records, then a burn test that meets, part 23, appendix F must be accomplished before the aircraft is approved for return to service.
9-63. SOURCE OF INFORMATION. If information regarding the original or properly altered fire protection qualities of certain cabin interior materials is not available, requests for this information should be made to the aircraft manufacturer or the local FAA regional office, specifying the model aircraft and the aircraft manufacturer. The date the aircraft was manufactured or the serial number, and the 14 CFR part under which the aircraft is operated (i.e., CAR-3, 14 CFR part 91, or part 121, etc.).

9-64. UPHOLSTERY AND/OR BELTS. Upholstery and/or belts that have been washed may lose some or all of their fire-resistant qualities. Unless the soap is completely removed from the cloth, the strength of the material may be significantly reduced. Consult the manufacturer to determine how to maintain the fire-resistant qualities.
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If one replaces damaged interior plastics with good plastics from an identical salvage aircraft, is any paperwork required?
 
If I want to apply adhesive to hold down a piece of existing carpeting/floor covering, do I need to worry about flammability? Any paperwork?
 
gprellwitz said:
If I want to apply adhesive to hold down a piece of existing carpeting/floor covering, do I need to worry about flammability? Any paperwork?
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The answer for me is no and no. I'm not suggesting that is correct, just how I do things of this nature.
 
gprellwitz said:
If I want to apply adhesive to hold down a piece of existing carpeting/floor covering, do I need to worry about flammability? Any paperwork?
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3M has FAA-blessed adhesives. But let's get realistic...the amount of adhesive you're going to use is really quite small compared to the size of the carpet, etc. However, there are options to adhesives so that you can remove the carpet for cleaning (both the carpet and the floor) as well as check for corrosion and crud during inspections. Personally, I like 4-6 velcro strips to hold down carpet in the front of the cabin.
 
About CAR 3 - just because it's no required (e.g. shoulder harnesses, etc) due to age, there's no reason not to conform to current safety regs.
 
murphey said:
About CAR 3 - just because it's no required (e.g. shoulder harnesses, etc) due to age, there's no reason not to conform to current safety regs.
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Sure there is. Making something safe is one thing. Producing paperwork is another. If no paperwork is required then I'm not going to bother to produce any.
 
I have no idea if it's true or not, but I was told by an aviation upholstery shop once, that if a material meets CalDot's automotive standards then it meets the FAA's requirements.

Does anybody know?
 
timwinters said:
I have no idea if it's true or not, but I was told by an aviation upholstery shop once, that if a material meets CalDot's automotive standards then it meets the FAA's requirements.

Does anybody know?
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as a practical matter, yes. It's the burn cert paperwork that comes into play. Part23 you need it. CAR3 you don't.
 
Send the material and a $40 dollar check to Skandia and if all goes well, you get your "burn cert"
 
JHW said:
Sure there is. Making something safe is one thing. Producing paperwork is another. If no paperwork is required then I'm not going to bother to produce any.
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Jeff - your Down Under rules are not the same as the US FAA rules. As for US Rules & paperwork, if the materials are already FAA blessed with a burn cert, the only "paperwork" is a 1 sentence log entry and I quote

" As per 14 CFR 43 Part 1, replaced back bulkhead, left & right side panels and both front seats and rear bench seats with Airtex products, burn certificates in 3-ring binder with sales receipt # xxxx."

The sales receipt is important because it has the colors, material type and product numbers for the next owner if they need to replace something.
 
Lkrautheim said:
Send the material and a $40 dollar check to Skandia and if all goes well, you get your "burn cert"
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Or check if there are companies that do a burn cert in your local area. You can watch and see how it works.
 
murphey said:
Jeff - your Down Under rules are not the same as the US FAA rules. As for US Rules & paperwork, if the materials are already FAA blessed with a burn cert, the only "paperwork" is a 1 sentence log entry and I quote

" As per 14 CFR 43 Part 1, replaced back bulkhead, left & right side panels and both front seats and rear bench seats with Airtex products, burn certificates in 3-ring binder with sales receipt # xxxx."

The sales receipt is important because it has the colors, material type and product numbers for the next owner if they need to replace something.
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My airplanes live in illinois and kansas. I've replaced the interiors in all of them with materials bought from a local auto upholstery place.
 
murphey said:
Yup, preventive maint because interior is not structural. Part 43 appendix A.
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That's pretty much true -- here's the exact language from the regulation:
(11) Repairing upholstery and decorative furnishings of the cabin, cockpit, or balloon basket interior when the repairing does not require disassembly of any primary structure or operating system or interfere with an operating system or affect the primary structure of the aircraft.
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But make sure you get burn tags for all the materials, which go in the log book with the phrase..."replaced (list items), see burn certification letters attached" or something like that. I'll dig out mine later today and post them here.
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Greg Amy wrote a great article in AvWeb covering the proper way to do this.
 
cowman said:
If one replaces damaged interior plastics with good plastics from an identical salvage aircraft, is any paperwork required?
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It would certainly have to be logged, including some statement about where the parts came from.
 
and most automotive grade materials meet DOT standards of "flame resistance"....so, burn certs are not needed for CAR 3 aircraft if the proper materials are used and documented.
 
Checkout_my_Six said:
and most automotive grade materials meet DOT standards of "flame resistance"....so, burn certs are not needed for CAR 3 aircraft if the proper materials are used and documented.
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I always bought my material from Airtex Interiors and requested the burn certs with the invoice. Filed it in the log books. While not required I figured somewhere down the road it may help the next owner if ever questioned.
 
This thread has been helpful for me. I've been wanting to replace my interior for a while but didn't want to pay what some aviation shops wanted for the work. I talked to a local automotive upholstery place today and was given a very good quote for leather seats. I'll also need to replace the carpet, which shouldn't be much extra since there isn't a lot to begin with. In addition, I want to replace the plastic panels in the plane -- I don't think they can do that. I'll have to look into that one a bit more.
 
LevelWing said:
This thread has been helpful for me. I've been wanting to replace my interior for a while but didn't want to pay what some aviation shops wanted for the work. I talked to a local automotive upholstery place today and was given a very good quote for leather seats. I'll also need to replace the carpet, which shouldn't be much extra since there isn't a lot to begin with. In addition, I want to replace the plastic panels in the plane -- I don't think they can do that. I'll have to look into that one a bit more.
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Order the plastic panels and have someone help you. They will require fitting and trimming to get a good fit and look. There are a few aftermarket plastic trim places on the internet.
 
RotorAndWing said:
I always bought my material from Airtex Interiors and requested the burn certs with the invoice. Filed it in the log books. While not required I figured somewhere down the road it may help the next owner if ever questioned.
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yes....it does help....specially if you have to teach your FSDO a thing or two about CAR 3 vs pt 23 vs pt 25 "flammability resistance" standards.....:mad2:


Baltimore FSDO....cough....cough.....:rolleyes:
 
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Checkout_my_Six said:
yes....it does help....specially if you have to teach your FSDO a thing or two about CAR 3 vs pt 23 vs pt 25 "flammability resistance" standards.....:mad2:


Baltimore FSDO....cough....cough.....:rolleyes:
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I avoid the Baltimore FSDO like the plague.
 
RotorAndWing said:
Order the plastic panels and have someone help you. They will require fitting and trimming to get a good fit and look. There are a few aftermarket plastic trim places on the internet.
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Or, another option, which was done in my plane, if the plastic panels are still relatively intact, then simply wrap them with material that matches the seats and reinstall.

Depending on the location of course.

Mine look great.
 
LevelWing said:
This thread has been helpful for me. I've been wanting to replace my interior for a while but didn't want to pay what some aviation shops wanted for the work. I talked to a local automotive upholstery place today and was given a very good quote for leather seats. I'll also need to replace the carpet, which shouldn't be much extra since there isn't a lot to begin with. In addition, I want to replace the plastic panels in the plane -- I don't think they can do that. I'll have to look into that one a bit more.
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You'll probably get a better product too. Most aviation shops can't stich a straight line to save their lives.
 
RotorAndWing said:
Order the plastic panels and have someone help you. They will require fitting and trimming to get a good fit and look. There are a few aftermarket plastic trim places on the internet.
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Some of it is plastic, but I think I may want some cloth to go on top of it on the sides, near the arm rest. I haven't quite figured it out yet. I don't mind the fitting and trimming, especially if it saves money over an aviation interior shop.

timwinters said:
Or, another option, which was done in my plane, if the plastic panels are still relatively intact, then simply wrap them with material that matches the seats and reinstall.

Depending on the location of course.

Mine look great.
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Do you have any pictures?
 
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