Do Interiors need 8130?

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AskBob
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Do Interiors need 8130?

Is carpet, foam or sink installed to a corporate jet needs to have a copy of

8130-3 before installation, is C of C enough for traceability?

 

Thanks

Received by email from Norman

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n14ky
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You don't necessarily need an 8130-3 for the materials, but you will need an 8110-3 to show that the compartment interior matrix meets the burn standards of 25.853

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, 27.853, 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. Such products as (blankets, pillows, pillowcases, headrest covers, and tray covers) are not covered by the FAA's flammability standards for cabin interiors. Therefore, these listed products are not required to undergo flammability testing at this time.

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.

A flammability test should come with an FAA for 8130-3 to show compliance along with the burn certification sheets.

Norman (not verified)
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Hi Bob, is this a requirements to a maintenance organisation outside United States or only in US?

Norman (not verified)
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Where can i get 8110-3, from the supplier? How to prepare compartment interior matrix?

This requirement is only for U.S. registered aircraft even if they are outside of the U.S. All foreign repair stations or maintenance facilities must still meet the U.S. requirements on N-number aircraft or it would invalidate the airworthiness certificate. There is a statement on the airworthiness certificate about be valid.

FAA Form 8130-3 is issued by the manufacture for new parts and by U.S. certificated repair stations with the proper ratings. You could also have a DAR with the proper function codes sign an 8130-3 as well.

Anonymous (not verified)
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"generally speaking", if it is a CAR 3 aircraft, the interior components must only meet the requirements that were established at original certification, CAR 3. This is the minimum requirement. It would certainly be prudent to meet the more stringent part 23 requirements.

Anonymous (not verified)
Anonymous's picture

The 8110 is provided by the lab certifying the interior products. Keep in mind that just buying all the components certified (just an example: padding, underlayment, adhesive and carpet) may not be good enough. You may have to have the built up composite burn tested as it is to be installed, as in all glued together. Veneer on a wall panel might be another good example. You can buy veneer with a burn cert, but if it is to be adhered to the panel, then a test panel may have to be built up to represent the finished installation of veneer, adhesive and base panel and burn tested accordingly.

My advice, call someone such as Skandia labs and talk to them. They are very knowledgeable and can help you out with anything. They only certify to the latest reg's (Parts 23 and 25), so it will be overkill on an older aircraft, but they can help you figure out what you need to do.

As follow-up you can send a sample to Skandia labs to have a burn test performed. As an example if you purchase sheep skin seat covers say from COSTCO for your 4-seat aircraft buy an extra one and send it to Skandia lab for testing. If it passes it will come back with the required burn certification results that will apply to the other in the batch you purchased. They should all be from the same batch material.

Just as a reminder if your aircraft is a CAR-3 and not part 23 the burn certification is very different. Under CAR-3 only the outside material is fire resistant. Under part 23 the outer and inner materials are required to be burn resistance as a unit. (Reference AC 23-2 and AC 25.10)

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, 27.853, 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.

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.

As stated above the lay up has to pass the burn tests including glues, tread, and other material. This is why it is important to go to a certificated repair station that holds the proper rating to have interior work accomplished.

Some times aircraft owners will go to the local automotive upholstery shop. These shops do not know or care about burn certifications and may use the wrong material. I have seen this way to many times so steer away from automotive upholstery shops unless they are supervised by an mechanic with proper knowledge of materials.

skybob5
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I work at a Repair Station that refurbishes interiors. As for sheepskins, if they are the pull-on version, then they are "loose equipment" and not affected with logbook entries, weight and balance concerns, etc. .
When we do pull-on sheepskin seat covers, I always include the burn certs because we have certs on all materials we use. Skandia Labs are a very good resource for all burn cert questions.
I cut an 8130-3 for each seat that we refurb stating what we did to the seat frame, what type of cushions were used, original or new, types of seat fabric or leather, sewn-in padding, sheepskins and then state the burn certs that they were certified with. Skandia does an all-inclusive certification that works quite nicely. Then I add in the restraints, whether new, rewebbed, or original, if original, I add in the date of mfg. Then the customer gets a copy of all certifications and an original 8130-3 for the seat.
As for getting a sheepskin from Costco, I'd be surprised if it would pass the burns. Properly treated sheepskins are very expensive!

Anonymous (not verified)
Anonymous's picture

I work in a repair station for interiors also. We are at a stand still in finding the CMM for an MU-2B. Our PMI is requesting that we provide some form of data that we are in compliance with for the custom design? We have recently read about submitting into the log entry that it can be described as an "owner produced part". Can you provide any insight as to how an "OPP" works?

AskBob
AskBob's picture

At NBAA a few years ago I met a gentleman starting a business around OPP. I have not researched the validity of his claims and it may not match your interior needs but he has a lot of data on how OPP work.
http://makeyourownaircraftparts.com/

n14ky
n14ky's picture

Owner produced parts still need to comply with the original cert basis and the TC or STC. The only thing that OPP does for you is it relaxes the QA requirements for the production of the part. The installer is still required to verify that the part meets type design and is in condition for safe flight. If the OPP is different in any way from the original, you now have an alteration, so is the alteration Major or Minor? A minor alteration only needs to be designed to acceptable data, a major alteration has to have approved data.

As custom interiors, that usually falls into the major alteration category and may fall into the major change in type design that would require an STC. Most cabin class aftermarket interiors are approved via STC.

The definition of “Owner Produced Part,” is in CFR 21.303(b) (2), this is a certification rule.

One has to be careful with owner-produced parts; the following would tend to indicate that a person produced a part:
• The owner provided the manufacturer with design or performance data from which to manufacture the part. (This may occur, for instance, where a person provided a part to the manufacture and ask that a part be duplicated.)
• The owner provided the manufacturer with materials from which to manufacture the part.
• The owner provided the manufacturer with fabrication processes or assembly methods to be used in the manufacture of the part.
• The owner provided the manufacturer with quality control procedures to be used in the manufacture of the part.
• The owner supervised the manufacturer of the part.

If the above can be met then the owner could produce their own part. One of the major concerns is the quality control procedures without them you cannot make the part.

Since this is about interiors you have to check the TCDS to see what the certification basic of the aircraft is CAR or FAR/CFR. The requirements are different from being fire resistant top layer of material to all the material under FAR/CAR being fire resistant.

As other have stated you have to have the specification from the manufacture or you may have to have you interior field approved by your local FAA office.

I would like to bring to the discussion is installing slipcovers or any material over the seats and just making a record entry. If the installation is temporary in nature and can be removed after every flight, it may be okay. However, if the slipcovers is installed in a manner where they are not designed to be removed I can see where the FAA may consider this an alteration and request to see the data indicating the certification basic for installing it. For this reason as stated by others interiors is usually done on a STC for larger aircraft. On GA aircraft, it is normally done by field approval.

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. The products like (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.

Interiors have become a major concern at accident sites and if the aircraft does not meet type design it may invalid the owner insurance coverage as well as open up issues for the owner about his aircraft being airworthy at the time of the incident or accident. This may be the only time the FAA will get a close look at the aircraft records and they will read every entry. Just because there is an record entry may not make the aircraft airworthy.

n14ky
n14ky's picture

To go even one step further, the foam in the seat, and the seat structure are specifically designed to meet the crashworthiness requrements. On older aircraft (CAR3 and before) this isn't a big issue, but for newer aircraft, like the current Cessna production 172, 182, 206, the foam material is designed to absorb the impact and extrude through the holes in the seat pan. Make a repair to the seat pan or change the foam density, you may have rendered the aircraft unairworthy as it may no longer meets type design for crashworthy standards.

bob.pasch
bob.pasch's picture

Interesting thought Dave. I hadn't thought of that but you're right... (did I just say you're right in print? :)

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