koito ad - easa + faa briefing (presentation) · • faa ad: conformity of in-service seats to new...

Federal AviationAdministration

European AviationSafety Agency

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FAA/EASA Briefing

Koito Seat ADs



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Agenda 09:30 Introductions/logistics 09:45 Background and Summary NPRM/PAD Cologne/Singapore Meetings 10:00 FAA/EASA activities since Oct. Industry meetings 10:30 Differences between the proposals and the final ADs 11:00 Break 11:15 Provision by provision explanation of

requirements/ ramifications EASA/FAA AD differences and ramifications Compliance data 12:00 Discussion of seat grouping 12:30 Koito Presentation Q & A.



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Background/SummaryBackground

• Towards the end of 2009, EASA/FAA became aware of allegations that the Koito seat company had been falsifying Certification test results, and had not controlled production conformity, for an appreciable period.

• TC holders (Airbus, Boeing) and JCAB progressively added confirmation to these allegations 1stQ. 2010.

• Initiatives started by TC holders and EASA/FAA to determine scale of the issue.



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Background/Summary It became clear that unsafe conditions

existed and thus mandatory action was needed.

EASA and FAA coordinated on an AD framework.

Regulatory system differences however, prevented 100% alignment.



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Background/SummaryFAA NPRM published on 24 Sept 2010EASA PAD published on 22 Sept 2010 Industry briefing sessions held

• October 14, Cologne• October 21, Singapore



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Industry MeetingsBased on the unusual circumstances

surrounding the proposed ADs, EASA and FAA took the unusual step of holding industry meetings during the comment period

Meetings primarily listening sessions for EASA/FAA, but also chance to explain proposals further



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Industry MeetingsApproximately 150 people attended the

two industry meetingsNumerous concerns and issues were

raisedEASA and FAA took all these comments

into account when finalizing the ADs In particular the time between publication

and effective date addressed several of the stated concerns



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FAA/EASA activities since October 2010 Industry meetings



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Actions Since the Industry Meetings

EASA/FAA reviewed JCAB/Koito confidence testing of selected seat models.

EASA/FAA reviewed JCAB/Koito reports on tear-down inspection conducted on in-service seats.

EASA, FAA, JCAB, Airbus, Boeing met at Koito to review confidence testing conducted by Koito under JCAB oversight.



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Actions Since the Industry Meetings

Airbus and Boeing refined criteria to establish seat clusters and carry out assessments that are acceptable to EASA/FAA.

FAA intends to publish information on Boeing clusters, in a Special Airworthiness Information Bulletin.

EASA intends to publish information on Airbus/Boeing clusters in a Safety Information Bulletin.



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Comments on the ProposalsThirty + commentersMore than 150 commentsComments covered wide range of issues



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Comments on the ProposalsCommon Themes

• Withdraw AD• Extend comment period• Lengthen compliance times• Accept all Koito confidence tests

All comments reviewed; substantive comments addressed in the final FAA AD.

EASA comment/response document addressed every comment.



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Differences between the proposals and the final ADs



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Differences Proposals & Final ADsSharp Edges

• Deleted requirement to show that original certification testing did not exhibit sharp edges.

• Added Pass Fail structural testing criterion.– “The generation of sharp edges or injurious surfaces

during the structural testing performed to comply with this AD may also be considered failure criteria.”

– That is, if sharp edges are generated during static testing seats must be removed within two years. If sharp edges are generated during dynamic testing, but static testing is then successfully performed, seats may remain in service for six years



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Differences Proposals & Final ADsAllowance of new test articles 25.561

compliance• Static testing can be conducted on new build

test articles, without the need to assess the conformity of the in-service fleet with the approved design. This position is based on the negligible effect on the static test results of potential non-conformities of Koito seats.



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Differences Proposals & Final ADsConformity of in-service seats used for

testing• Confirm aspects of in-service seats, when in-

service seats are tested.– matching part number to test plan– noting general condition– revisions/modification– date of manufacture.



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Differences Proposals & Final ADsAllowance of new test articles 25.562

compliance• FAA AD: conformity of in-service seats to new

build seats to use for dynamic test.• EASA has the same position as the FAA,

although the EASA AD does not explicitly mention this option. The use of new-built test articles will be allowed, provided that conformity of the in-service seats to the approved design can be demonstrated.



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Differences Proposals & Final ADsAdded Clarification and Guidance through

Notes:• Clarification of certification basis of TSO

determines level of AD test. (FAA AD)• Clarification of the relevant aircraft certification

basis. (EASA AD)• Koito interface load reports may be acceptable

for the determination of compliance required by the AD.



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Differences Proposals & Final ADsAdded Clarification and Guidance through

Notes:• FAA NPRM rule did not address non-TSO, TSO-

C39, TSO-C39a and TSO-C127 seats. Intend to supersede this AD to capture all seats produced by Koito Industries, Ltd.



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Differences Proposals & Final ADsAllow certain cabin reconfigurations.

• Re-arrangement of the existing installed seats is acceptable following the same installation instructions and limitations as the original certification. (e.g., if the original seat installation limitations allowed 32” to 34” pitch, the new layout shall be pitched within that range).



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Differences Proposals & Final ADs25.853(c) testing of seat cushions

• Limited to seat bottom cushion and seat back cushion, i.e., not headrests, footrests etc.

• Allow the use of new build samples for oil burner test, provided that it is shown that the in-service cushions consist of foams/ covers which were supplied to Koito and marked by a different production organisation approved by EASA and/or FAA.



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Differences Proposals & Final ADs25.853(c) testing of seat cushions

• Test reports issued by any qualified design organization acceptable to the Agency, including Koito under JCAB supervision, except,

• Tests performed in the Koito seat cushion oil burner test facility after 23rd May 2011 may also be acceptable.



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Differences Proposals & Final ADsSeat cushion replacement

• FAA removed restrictive AC 25.562-1B requirement for TSO-C39 seats.

• Compliance to 25.562(c)(2) not required for TSO-C127 cushions. – TSO-C127 seat and cushion placarded to show that

seat cushion/seating system may not comply to 25.562(c)(2).



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Differences Proposals & Final ADsSeat cushion replacement

• EASA removed requirement to install replacement cushions having SRP location consistent with the original cushions for seats installed on aeroplanes required to meet CS/JAR/FAR 25.562. – replacement cushions must have consistent seat

bottom geometry, stiffness and density (measured according to accepted industry standards) as compared with the cushions they replace.

– Compliance to 25.562(c)(2) is not required



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Differences Proposals & Final ADsSpare seats/components

• FAA - New seats with same part number may be installed to replace in-service seats removed for testing.

• EASA - “New seats/components and seats/components removed from service may be installed as direct spares for the same part number seats or components.”



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Differences Proposals & Final ADsCompliance Times

• FAA NPRM compliance time intent of 2, 3, 6 years was ambiguous due to wording on the lead-in paragraph. AD written to remove any ambiguity regarding the phased 2, 3, 6 year compliance from effective date of rule.



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Provision by provision explanation of

requirements/ramificationsAD comparison



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Showing of AD ComplianceEASA/FAA intend to issue a SIB/SAIB to

deliver information on seat clustering.SIB/SAIB has no legal status, i.e. does not

compel any action, but would support a means to show compliance with the requirements of the AD.

The SIB/SAIB will be revised if test results are made available, and if clusters are refined further.



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Showing of AD ComplianceEach Koito seats will have to be covered

by an (A)MOC in order to be allowed to remain in service more than 2 years.

Any entity (TC holders, Koito Industries, airlines, other) can apply for an AMOC.

The (A)MOC can cover static and/or dynamic strength requirements of the AD.



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Showing of AD Compliance The (A)MOC will be approved according

to the following procedure:1. An application is submitted to EASA/FAA2. A test plan is submitted to EASA/FAA 3. The test plan is approved by EASA/FAA4. Test results are submitted to EASA/FAA5. The appropriate correction time is

determined.6. The (A)MOC is approved.



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Showing of AD Compliance The content of the SIB/SAIB can be

referenced to skip steps 2, 3 and 4 if compliance is shown by similarity in accordance with agreed groupings.

All approved (A)MOCs will specify the action to be performed in order to comply with the AD, i.e. list of seat part numbers to be removed within the correction time.



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Showing of AD Compliance The following actions will have to be

taken in order to allow seat cushions installed on Koito seats to remain in service more than 3 years:1. A test plan is submitted to EASA/FAA 2. The test plan is approved by EASA/FAA3. Test results are submitted to EASA/FAA4. A letter is issued by EASA/FAA



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Steps to ComplyBefore 2 years: determine whether seat

meets 25.561• Directly through static test (in-service or new

production seat)• Indirectly through dynamic test• By similarity to critical seat in the cluster



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back/bottom cushion meet 25.853(c)• Directly through tests using actual in service

materials• Directly through tests using new build

samples, provided that it is shown that the in-service cushions consist of foams/ covers supplied by production organisation approved by EASA and/or FAA.

• By substituting a different complying bottom/back cushion pair



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meets 25.562(b)(2)/(c)(7) • Directly through dynamic test• By similarity to critical seat in the cluster

EASA ONLY, Before 10 years: full re-certification of the seats



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Detailed Test Issues

• Acceptable 25.561 compliance method– Successful dynamic testing conducted on new build

test articles– Unsuccessful dynamic testing conducted on new build

test articles or in-service seats, – Failure cannot be in the seat– Failure must occur after the seat has demonstrated

substantive load carrying capability



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Detailed Test Issues

• 25.562 compliance test failure– Seat to be removed from service within 6 years– Compliance with 25.561 within 2 years still required– Data may be usable for 25.561 under limited

conditions (see previous slide)

• 25.853(c) compliance failure– Redesign of seat cushion acceptable without total

requalification of seat



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Seat Clusters (Groupings)



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Seat ClustersKoito had defined 17 unique seat clusters

representing 150+ seat modelsEASA/FAA determined that these clusters

did not constitute seat Families as defined in AC 25.562-1B

Airbus and Boeing reviewed design data to develop refined seat clusters that are acceptable to EASA/FAA



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Seat ClustersExample

• 1 cluster 7 plus “families” • 15 seat models dozens of p/n, both TSO-C39

and TSO-C127 (or equivalent)• 10 to 14 critical seats to test

Industry encouraged to work together to pool resources and work together to find compliance to the AD.

FAA/EASA intend to publish results of cluster exercise, possibly in a SAIB/SIB



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Example Seat Cluster

Seat Model No. Seat TSO Aircraft Model identified seat part number for test ARS-674 - Std Row TSO-C127a 777-200/-300ER Similarity to ARS-710 - Std Row ARS-710 - Std Row TSO-C127a 747-400/777-300 83269B15257-403 ARS-815 TSO-C127a 777-200 Similarity to ARS-710 - Std Row Y21B73 TSO-C127a 777-300ER Similarity to ARS-710 - Std Row



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Koito Presentation



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Q&A

koito ad - easa + faa briefing (presentation) · • faa ad: conformity of in-service seats to new...

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