What are the rules about replacing/redoing seats in certificated aircraft?

C

CowboyPilot

Guest
Howdy,

I'm giving some thought to redoing the seats in my 1967 172 Skyhawk. Some time back, we had the interior completely--as in done by real professionals and not by me--redone on our Cardinal. It is our primary long XC machine and it's primarily just me and my wife or a business partner in it with me. I wanted it damn comfortable for these aging, aching bones and it worked.

It also knocked hell out of my pocketbook.

The Skyhawk is my "daily driver" that I use to hopscotch around Texas visiting with old cronies and pursuing the $100 enchilada. I'd like to re-do the seats to make them considerably more comfortable than they are at present, maybe put in a console, color TV, mini-fridge, foot-massager, fax machine, shiatsu neck massager. . .

Just the seats and maybe a small console.

Question is, can I do this myself--have the seats built by an interior (not necessarily an aviation interior guy) person and then install them myself so long as the aircraft logbook notes this work AND the fabric is certified FAA-approved?

Thanks.

-JD
 
I looked into this a while ago, and seem to recall that, so long as the materials are appropriately-certified (either by testing data and certification supplied by the manufacturer, or by having a sample of material tested and certified), and the seat removal and re-installation are signed-off by an A&P, you are good to go.

Now, speaking of flame certification, let's see if: (1) I was right; and, if not, (2) I am flame-proof.

I had looked into it because I know a very good auto upholstery craftsman, and was going to see about getting him hooked up with an A&P shop I know... never happened...yet.
 
SCCutler said:
I looked into this a while ago, and seem to recall that, so long as the materials are appropriately-certified (either by testing data and certification supplied by the manufacturer, or by having a sample of material tested and certified), and the seat removal and re-installation are signed-off by an A&P, you are good to go.

Now, speaking of flame certification, let's see if: (1) I was right; and, if not, (2) I am flame-proof.

I had looked into it because I know a very good auto upholstery craftsman, and was going to see about getting him hooked up with an A&P shop I know... never happened...yet.
Click to expand...

Hey Spike,

Kinda what I was thinking too and pretty much same situation I'm in. I know a guy that does incredible automotive interiors and custom-builds seats ergonomically. Won't go into the details of our "well, we're thinking about this deal" because the Pro-Rata Police would come jackbooting up to my hangar and kick in the door.

Just wondering what the legality and/or the loopholes were/are.

Regards.

-JD
 
JD, I will try to track down the fruits of my previous research labor (no promises, I am not known as the most-organized blade on the saw), if found, they are yours. But I am quite certain that it can be done.
 
SCCutler said:
JD, I will try to track down the fruits of my previous research labor (no promises, I am not known as the most-organized blade on the saw), if found, they are yours. But I am quite certain that it can be done.
Click to expand...

Gracias.

And if it's too big of a pain in the butt, I might have to look up and see what the regs say about installing one of those inflatable rubber donuts in the left seat. . .

Regards.

-JD
 
My feeling would be that if you are only replacing fabric and cushions, then you only have to worry about the fire-resistance regs (you might still need a 337 signed off, I think, but it would be pretty trivial to do).

However, if you're thinking of touching anything like a frame, seatbelt, or seat pan, then you'll need to do much calculating or load testing to prove that you haven't affected the seats' abillity to withstand both maneuvering and emergency landing loads. You probably don't want to go down that route as it'll cost a fortune.

Chris
 
cwyckham said:
However, if you're thinking of touching anything like a frame, seatbelt, or seat pan, then you'll need to do much calculating or load testing to prove that you haven't affected the seats' abillity to withstand both maneuvering and emergency landing loads. You probably don't want to go down that route as it'll cost a fortune.

Chris
Click to expand...

Went down that road in the Cardinal last year.

That's why I think I need to install one of those rubber donuts (flame proof and load-bearing, of course) in the left-seat of my Skyhawk.

It's also why I'll never buy nor own another certificated aircraft ever again once I get rid of these and get the two experimentals built.

Regards.

-JD
 
There is no requirements for fire proof or fire retarded materials in aircraft operated in part 91.

there is for aircraft operated in part 135 and above

see FAR
25.853 Compartment interiors.

but that does not apply to us
 
NC19143 said:
There is no requirements for fire proof or fire retarded materials in aircraft operated in part 91.

there is for aircraft operated in part 135 and above

see FAR
25.853 Compartment interiors.

but that does not apply to us
Click to expand...

Actually, the 172 (up to model P, which I assume this one is lower than, given the year) is CAR 3 up to ammendment 3-12.

§ 3.388 Fire precautions—

[(a) Cabin interiors. Only materials which are flash resistant shall be used. In compartments where smoking is to be permitted, the wall and ceiling linings, the covering of all upholstering, floors, and furnishings shall be flame-resistant. Such compartments shall be equipped with an adequate number of self contained ash trays. All other compartments shall be placarded against smoking.
Click to expand...

The definition of Flash and Flame resistant from section 3.1 is

(3) Flame-resistant. Flame-resistant material means material which will not support combustion to the point of propagating, beyond safe limits, a flame after the removal of the ignition source.

(4) Flash-resistant. Flash-resistant material means material which will not burn violently when ignited.

Click to expand...
 
JD, I had my seats done at a local auto shop that does lots of airplane seats around here. He had a selection of fabrics with airplane cert paperwork that he could order.

Mine were nothing special, kept the same "hard" foam, just a new layer of thin foam, fabric seat surface and vinyl sides, picture attached. Cost me very little and got rid of the 1969 originals.

Unfortunately, I was over there at his shop a couple days ago and he mentioned that the 2 places he gets approved fabric and foam from are having some problems right now, and there isn't much out there. He said all they have in stock at the moment are the really ugly ones that are left over, and they don't expect to build much more inventory for another 6 months or so.
 
You may want to consider Airtex Interiors' seat kits (www.airtexinteriors.com). Seat kits for a 172 start at $825. The materials in the kit meet the FAR requirements. All you have to fiddle with is the installation

Bruce
 
cameronbm said:
You may want to consider Airtex Interiors' seat kits (www.airtexinteriors.com). Seat kits for a 172 start at $825. The materials in the kit meet the FAR requirements. All you have to fiddle with is the installation

Bruce
Click to expand...
that's ok, but you pay twice the price and still have to do a lot of the work
 
I've sat in a seat by Oregon Aero and was amazed at the comfort. Their website www.oregonaero.com isn't working at the moment, but I'm sure they can do C172 seats with their eyes closed.
 
From my point of view you have to know what certification your aircraft was certified to. It is either part 23 or CAR-3, for the interior flammability for your Cessna. You can find the certification basic by checking the type certificate data sheet (3A12) for your Cessna. The certification is below:

Certification basis

Models 172 through 172P
Part 3 of the Civil Air Regulations effective November 1, 1949, as amended by 3-1 through 3-12. In addition, effective S/N 17271035 and on, FAR 23.1559 effective March 1, 1978. FAR 36 dated December 1, 1969, plus Amendments 36-1 through 36-5 for Model 172N; FAR 36 dated December 1, 1969, plus Amendments 36-1 through 36-12 for Model 172P through 172Q. In addition, effective S/N 17276260 and on, FAR 23.1545(a), Amendment 23-23 dated December 1, 1978.

Based on the above I assume you have a Part 3 (CAR-3) aircraft so your seat materials only have to meet the CAR-3 requirement. With means the seat covering and not the stuffing has to be flame resistant. This goes for all the interior materials.

The Federal Aviation Administration (FAA) has promulgated several regulations on flammability standards for aircraft and their components. The regulations applicable to aircraft cabins are in Federal Aviation Regulations (FAR) Sections 23.853, 25.853, and 29.853. These sections are similar in content but different as to the type of aircraft involved. The specific requirements for testing products to demonstrate compliance with the applicable FAR section are included as an appendix within the appropriate FAR part.

Generally speaking, cabin contents that are permanently attached to the aircraft are required to meet flammability testing standards. The wall coverings and cabin seats are two types of products that are required to meet the standards. Carry–on items and certain passenger convenience items are not covered by the regulations. Blankets, pillows, pillowcases, headrest covers, and tray covers are not covered by the FAA's flammability standards for cabin interiors.

Guidance material on the subject of flammability testing is available in Advisory Circular (AC) 25.853–1, Flammability Requirements for Aircraft Seat Cushions, and may be obtained from the FAA Advisory Circular System.

The rules you will have to meet are:

§ 21.303 Replacement and modification parts.
Material substitution

§ 43.13 Performance rules (general).
(b) Each person maintaining or altering, or performing preventive maintenance, shall do that work in such a manner and use materials of such a quality, that the condition of the aircraft, airframe, aircraft engine, propeller, or appliance worked on will be at least equal to its original or properly altered condition (with regard to aerodynamic function, structural strength, resistance to vibration and deterioration, and other qualities affecting airworthiness).

If you replace your seat covering with the same material it’s no problem. However many owners want something that looks better and wears better. This is where FAR 43.13(b) kicks in if its better than the original its an alteration and requires a FAA Form 337. This is a simple to thing to have accomplished at your local FSDO.

As far as the burn certification is concerned you can purchase material and have a sample set to Douglas or Scandia for the burn certification tests. We are only talking about $40.00 or so the last ones I did.

Who can install it? Anyone under the supervision of a mechanic, I have gone to the local automotive shop and watched and made the maintenance record entry in accordance with FAR 43.9.

Can you install the material? Yes, in accordance with 43.3 and have it returned to service under 43.5 by a proper certificate person.

Stache
 
Stache said:
With means the seat covering and not the stuffing has to be flame resistant.
Click to expand...

Could this be one of those times where we might chose to use common sense to overrule a regulation of lesser standards?

What about leather? Some say it is universally accepted to always pass the testing and as such can be considered to be always permissible without testing.
In some ways that seems reasonable, "yeah -leather is leather", but....
 
Let'sgoflying! said:
Could this be one of those times where we might chose to use common sense to overrule a regulation of lesser standards?

What about leather? Some say it is universally accepted to always pass the testing and as such can be considered to be always permissible without testing.
In some ways that seems reasonable, "yeah -leather is leather", but....
Click to expand...

why skirt a rule that's so easy to comply with? just save a 1 ft sq piece of the leather and send it off to get tested, $30 or so and you've got your piece of paper
 
JohnR said:
I've sat in a seat by Oregon Aero and was amazed at the comfort. Their website www.oregonaero.com isn't working at the moment, but I'm sure they can do C172 seats with their eyes closed.
Click to expand...

I called them about doing mine. You just ship them the whole seat and they redo it. As I recall I was looking at the $800-$1000 range depending and how fancy of foam and covering I wanted.
 
JHW said:
why skirt a rule that's so easy to comply with? just save a 1 ft sq piece of the leather and send it off to get tested, $30 or so and you've got your piece of paper
Click to expand...

no disagreement here -but the question remains, if you test that piece of leather, is it good for all cow hides? Does Brangus burn like a bonfire, while Ayrshire is asbestos? :D
 
Any one notice this?

§ 3.388 Fire precautions—

[(a) Cabin interiors. Only materials which are flash resistant shall be used. In compartments where smoking is to be permitted, the wall and ceiling linings, the covering of all upholstering, floors, and furnishings shall be flame-resistant. Such compartments shall be equipped with an adequate number of self contained ash trays. All other compartments shall be placarded against smoking.

Do you plan to smoke in your aircraft?

post a placard saying "NO SMOKING" you are good to go cotton.
 
Last edited:
Stache said:
From my point of view you have to know what certification your aircraft was certified to. It is either part 23 or CAR-3, for the interior flammability for your Cessna. You can find the certification basic by checking the type certificate data sheet (3A12) for your Cessna. The certification is below:

Certification basis

Models 172 through 172P
Part 3 of the Civil Air Regulations effective November 1, 1949, as amended by 3-1 through 3-12. In addition, effective S/N 17271035 and on, FAR 23.1559 effective March 1, 1978. FAR 36 dated December 1, 1969, plus Amendments 36-1 through 36-5 for Model 172N; FAR 36 dated December 1, 1969, plus Amendments 36-1 through 36-12 for Model 172P through 172Q. In addition, effective S/N 17276260 and on, FAR 23.1545(a), Amendment 23-23 dated December 1, 1978.

Based on the above I assume you have a Part 3 (CAR-3) aircraft so your seat materials only have to meet the CAR-3 requirement. With means the seat covering and not the stuffing has to be flame resistant. This goes for all the interior materials.

The Federal Aviation Administration (FAA) has promulgated several regulations on flammability standards for aircraft and their components. The regulations applicable to aircraft cabins are in Federal Aviation Regulations (FAR) Sections 23.853, 25.853, and 29.853. These sections are similar in content but different as to the type of aircraft involved. The specific requirements for testing products to demonstrate compliance with the applicable FAR section are included as an appendix within the appropriate FAR part.

Generally speaking, cabin contents that are permanently attached to the aircraft are required to meet flammability testing standards. The wall coverings and cabin seats are two types of products that are required to meet the standards. Carry–on items and certain passenger convenience items are not covered by the regulations. Blankets, pillows, pillowcases, headrest covers, and tray covers are not covered by the FAA's flammability standards for cabin interiors.

Guidance material on the subject of flammability testing is available in Advisory Circular (AC) 25.853–1, Flammability Requirements for Aircraft Seat Cushions, and may be obtained from the FAA Advisory Circular System.

The rules you will have to meet are:

§ 21.303 Replacement and modification parts.
Material substitution

§ 43.13 Performance rules (general).
(b) Each person maintaining or altering, or performing preventive maintenance, shall do that work in such a manner and use materials of such a quality, that the condition of the aircraft, airframe, aircraft engine, propeller, or appliance worked on will be at least equal to its original or properly altered condition (with regard to aerodynamic function, structural strength, resistance to vibration and deterioration, and other qualities affecting airworthiness).

If you replace your seat covering with the same material it’s no problem. However many owners want something that looks better and wears better. This is where FAR 43.13(b) kicks in if its better than the original its an alteration and requires a FAA Form 337. This is a simple to thing to have accomplished at your local FSDO.

As far as the burn certification is concerned you can purchase material and have a sample set to Douglas or Scandia for the burn certification tests. We are only talking about $40.00 or so the last ones I did.

Who can install it? Anyone under the supervision of a mechanic, I have gone to the local automotive shop and watched and made the maintenance record entry in accordance with FAR 43.9.

Can you install the material? Yes, in accordance with 43.3 and have it returned to service under 43.5 by a proper certificate person.

Stache
Click to expand...

This I agree with;

"Based on the above I assume you have a Part 3 (CAR-3) aircraft so your seat materials only have to meet the CAR-3 requirement."

this I dis-agree with;

"With means the seat covering and not the stuffing has to be flame resistant. This goes for all the interior materials"

Because the rule reads:

§ 3.388 Fire precautions—

[(a) Cabin interiors. Only materials which are flash resistant shall be used. In compartments where smoking is to be permitted, the wall and ceiling linings, the covering of all upholstering, floors, and furnishings shall be flame-resistant. Such compartments shall be equipped with an adequate number of self contained ash trays. All other compartments shall be placarded against smoking.
 
NC19143 said:
Any one notice this?

§ 3.388 Fire precautions—

[(a) Cabin interiors. Only materials which are flash resistant shall be used. In compartments where smoking is to be permitted, the wall and ceiling linings, the covering of all upholstering, floors, and furnishings shall be flame-resistant. Such compartments shall be equipped with an adequate number of self contained ash trays. All other compartments shall be placarded against smoking.

Do you plan to smoke in your aircraft?

post a placard saying "NO SMOKING" you are good to go cotton.
Click to expand...

I believe you are misreading the rule. Notice the period after "shall be used." Only materials which are flash resistant shall be used for any cabin interior period. However, if you want to smoke in your aircraft, you must comply with extra rules, including making certain things flame resistant (which is better than flash resistant). My earlier post has the definitions of flame and flash resistance.

Chris
 
cwyckham said:
I believe you are misreading the rule. Chris
Click to expand...

Well that wouldn't be the first time, But I wonder how many aircraft out there are operating with out the ashtrays they entered service with, and having no "NO SMOKING " sign.

Ever see an aircraft with the ash trays converted to IC jacks.? did you notice a "NO SMOKING " sign?

Next question would be, is a recovering of the interior a major alteration or minor maintenance?

Removal and replacement with a like item has always been a log book entry, does a fabric change constitute a major modification?

see far
Appendix A Major Alterations, Major Repairs, and Preventive Maintenance

(a) Major alterations

(1) Airframe major alterations. Alterations of the following parts and alterations of the following types, when not listed in the aircraft specifications issued by the FAA, are airframe major alterations:

(i) Wings.

(ii) Tail surfaces.

(iii) Fuselage.

(iv) Engine mounts.

(v) Control system.

(vi) Landing gear.

(vii) Hull or floats.

(viii) Elements of an airframe including spars, ribs, fittings, shock absorbers, bracing, cowling, fairings, and balance weights.

(ix) Hydraulic and electrical actuating system of components.

(x) Rotor blades.

(xi) Changes to the empty weight or empty balance which result in an increase in the maximum certificated weight or center of gravity limits of the aircraft.

(xii) Changes to the basic design of the fuel, oil, cooling, heating, cabin pressurization, electrical, hydraulic, de-icing, or exhaust systems.

(xiii) Changes to the wing or to fixed or movable control surfaces which affect flutter and vibration characteristics.

Is seat fabric there?
 
JD:

Oregon Aero seats are fantastic. Might be a nice selling point when you go "off the grid" and get rid of the Wichita built aluminum. By the way, are you going the RV10 route?

Jay
 
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