Fire Retardant Interiors
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Fire Retardant Interiors
I'm looking for a CARs reference addressing the requirement for fire retardant material in private aircraft. 523.853 addresses new aircraft requirements but is there not a regulation that stipulates that any retrofit or repair materials used in an interior must meet the same standard?
Is there a difference between Commercial and Private use aircraft? Anyone been more successful at tracking this through the miasma of TC regs?
Is there a difference between Commercial and Private use aircraft? Anyone been more successful at tracking this through the miasma of TC regs?
Just because you're paranoid doesn't mean they're not after you!
Re: Fire Retardant Interiors
The whole 52X.XXX standards are design standards for all aircraft regardless of how they are used. If you're installing an interior, you have to meet the requirements of the type design of your aircraft, commercial or private. You could be installing some interior that's been STC'd but there's no way TCCA would approve materials in a passenger compartment that do not meet the requirements of 52X.853.Blakey wrote:I'm looking for a CARs reference addressing the requirement for fire retardant material in private aircraft. 523.853 addresses new aircraft requirements but is there not a regulation that stipulates that any retrofit or repair materials used in an interior must meet the same standard?
Is there a difference between Commercial and Private use aircraft? Anyone been more successful at tracking this through the miasma of TC regs?
Re: Fire Retardant Interiors
Not sure that's correct. It states that all aircraft must have shoulder restraints but there is no need to install them in grandfathered aircraft. It's a good idea and they would really like you to but you can just replace the old lap belts if you wish. Whatever is on the type certificate is the required standard. I have always been told that interiors were different but can't find a reference.
Just because you're paranoid doesn't mean they're not after you!
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Re: Fire Retardant Interiors
Interiors are the same as the rest of the airplane. . If your airplane was type certified under civil air regulation part 3 revision xx, that is what you're interior has to meet in terms of standards.. but if your airplane was certified under Canadian aviation regulation 5xx, then you have to meet those regulations. . That's why a lot of older airplanes don't have shoulder harnesses, or cht gauges, etc..
Re: Fire Retardant Interiors
Start with the type certificate for your airplane. It contains the certification basis for your particular aircraft model. Then refer to CAR 605 and the standards in 625 for additional operational requirements for all aircraft. CAR 523 at various amendments is the basic certification basis for some models but certainly not all. What type of aircraft are we talking about?
P.S. Type design is not the same as type certificate or basis of certification. See CAR 100 and look up the definition and you can use the term accurately.
P.S. Type design is not the same as type certificate or basis of certification. See CAR 100 and look up the definition and you can use the term accurately.
Re: Fire Retardant Interiors
Any materials you could purchase now for interior "repair" would be either of:
New OEM for that aircraft, with certs, go ahead and use them (but likely not available for older aircraft),
Or, STC'd for your aircraft, go ahead and use them,
Or, not specified for your aircraft, but accompanied with 2x.853 burn certs. Probably you can use them, but it depends upon the certification basis of the aircraft, and the type of burn test which has been passed (horizontal vs vertical most commonly). I doubt that a TC inspector will press you hard if you do the repair with vertical test compliant material. Occasionally, a "horizontal" burn test would not be good enough for a newer aircraft, but rare.
Or, not accompanied with any burn certs, you cannot legally use them for the repair.
Interiors are an unfortunate gap in the "made parts" repair of aircraft, as I know very skilled and diligent interior repair shops which TC has shut down for lack of proper approvals for the work and materials. But, they were selling the interior work with no maintenance release.
Refer to AC43.13, 9-61 and 9-62. If you have material which meets the requirements of that section of AC43.13, you can use them in the repair, as AC43.13 is "specified data, which AWM 571.06(2) (a) says is required for a "major repair". Indeed, an interior repair is not even "major" when considered in the context of AWM 571, Appendix A,
https://www.tc.gc.ca/eng/civilaviation/ ... a-1893.htm
So, extra points of you print that off, and fill it out for the project. You're extra covered. If in doubt, a completed copy of this appendix, with respect to work accomplished, the major/minor decision made, and data chosen will be a good defense of TC asks about the work later. These are regulatory tools for your use...
New OEM for that aircraft, with certs, go ahead and use them (but likely not available for older aircraft),
Or, STC'd for your aircraft, go ahead and use them,
Or, not specified for your aircraft, but accompanied with 2x.853 burn certs. Probably you can use them, but it depends upon the certification basis of the aircraft, and the type of burn test which has been passed (horizontal vs vertical most commonly). I doubt that a TC inspector will press you hard if you do the repair with vertical test compliant material. Occasionally, a "horizontal" burn test would not be good enough for a newer aircraft, but rare.
Or, not accompanied with any burn certs, you cannot legally use them for the repair.
Interiors are an unfortunate gap in the "made parts" repair of aircraft, as I know very skilled and diligent interior repair shops which TC has shut down for lack of proper approvals for the work and materials. But, they were selling the interior work with no maintenance release.
Refer to AC43.13, 9-61 and 9-62. If you have material which meets the requirements of that section of AC43.13, you can use them in the repair, as AC43.13 is "specified data, which AWM 571.06(2) (a) says is required for a "major repair". Indeed, an interior repair is not even "major" when considered in the context of AWM 571, Appendix A,
https://www.tc.gc.ca/eng/civilaviation/ ... a-1893.htm
So, extra points of you print that off, and fill it out for the project. You're extra covered. If in doubt, a completed copy of this appendix, with respect to work accomplished, the major/minor decision made, and data chosen will be a good defense of TC asks about the work later. These are regulatory tools for your use...
Re: Fire Retardant Interiors
Careful. Using AC 43.13 as "specified data" has a few caveats.Refer to AC43.13, 9-61 and 9-62. If you have material which meets the requirements of that section of AC43.13, you can use them in the repair, as AC43.13 is "specified data, which AWM 571.06(2) (a) says is required for a "major repair".
(d) FAA Advisory Circulars AC 43.13-1 and AC 43.13-2, subject to the following conditions:
(i) the aircraft is a small aircraft, and the alteration does not affect dynamic components, rotor blades, structure that is subject to pressurization loads, or the primary structure of a rotorcraft;
(ii) the alteration does not affect an existing limitation (including the information contained on mandatory placards) or change any data contained in the approved sections of the Aircraft Flight Manual, or equivalent;
(iii) the data are appropriate to the product being altered, and are directly applicable to the alteration being made; and,
(iv) the data are not contrary to the aircraft manufacturer’s data.(données specifies)
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Re: Fire Retardant Interiors
Is interior replacement a major mod?
I would think maintaining the original standards would be acceptable. For that refer to the type certificate.
There are a few articles that can be found on the subject.
I would think maintaining the original standards would be acceptable. For that refer to the type certificate.
There are a few articles that can be found on the subject.
Re: Fire Retardant Interiors
How would you go about doing that? Can an AME use the type certificate to replace the interior? Is there an intermediate step?torquey401 wrote:Is interior replacement a major mod?
I would think maintaining the original standards would be acceptable. For that refer to the type certificate.
There are a few articles that can be found on the subject.
Re: Fire Retardant Interiors
Your reference to the required data is found in AWM 571(.06). It will require you to determine of the mod/repair is "major", which is done by reference to AWM 571, Appendix A. Once you know "major" / "Minor", and refer to 571.06, you'll know the type of data you require.
The Type Certificate will specify the certification basis for the aircraft, which is important, and somewhat useful. The certification basis will tell you which flammability standard must be met.
However, the nuance difference between the flammability standards for light aircraft of varied cert basis will be of little difference to you, as you cannot buy interior materials with much variation in flammability compliance statements. If there is a statement about flammability characteristics relative to aviation standards for an interior material, it probably will not align well with the design requirements specified in the TCDS cert basis.
It's not like where the aircraft maintenance manual, or AC43.15 tell you to use 2024-T3 aluminum, and you have a "Form 1" for your metal saying that it is 2024-T3. Approach this with caution, knowing that if you have to defend this to TC, you'd better be able to articulate hope relative to the regs.
The Type Certificate will specify the certification basis for the aircraft, which is important, and somewhat useful. The certification basis will tell you which flammability standard must be met.
However, the nuance difference between the flammability standards for light aircraft of varied cert basis will be of little difference to you, as you cannot buy interior materials with much variation in flammability compliance statements. If there is a statement about flammability characteristics relative to aviation standards for an interior material, it probably will not align well with the design requirements specified in the TCDS cert basis.
It's not like where the aircraft maintenance manual, or AC43.15 tell you to use 2024-T3 aluminum, and you have a "Form 1" for your metal saying that it is 2024-T3. Approach this with caution, knowing that if you have to defend this to TC, you'd better be able to articulate hope relative to the regs.
Re: Fire Retardant Interiors
PilotDAR, you know how it's done and I know how it's done. I was hoping to hear from torquey401. I would be interested to know what he/she was implying. Like where you would go to shop for such materials and who has the authority to declare the suitability of that material. (etc)
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Re: Fire Retardant Interiors
The relevant section from AC43.13-1B is attached. Seems pretty straightforward. Refer to the TCDS for the aircraft model certification basis (CAR3 vs FAR23). If you want to be safe as to what to use, use the higher standard material (FAR23). There are a few options as to where to buy. http://www.aircraftinteriors.ca/ http://www.airtexinteriors.com/index.php.
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- AC43.13-1B Chp9 Sec 4.pdf
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Re: Fire Retardant Interiors
Excellent. Your original post had a couple of holes in it.