Federal Aviation Administration Memorandum Date: OCT 0.4 2010 To Al Aircraft Certification Offices From: David W. Hempe, Manager, Aa Enginting Divison, AIR 100 ECPM Prepared by: Jan Risheim, Technical Programs Branch, AIR-120 Memo No: AIR100-2010-120-002 Subject: Clarification of T'80-C127a and TSO C39e Flammability Requirements ‘As part of recent investigation regarding a manufacturer of TSO-approved seats, the PAA discovered there was confusion regarding the flammability requirements identified in TSO-C127a, Rotorcraft, Transport Airplane, and Normal and Utility Airplane Seating Systems and TSO-C39e, 9g Transport Airplane Seats Cerified by State Testing. Both TSO-C121a and TSO-C39e reference Society of Automotive Engineers (SAE) Aerospace Standard 8049 revision A (AS8D49A) asthe base performance document for the TSO. Paragraph 3.4.1 of the AS8049A reads as follows: 3.4.1 The cushion system, covering and upholstery and all other exposed material lused in the seat shall have sel-extinguishing properties as specified in the ‘applicable Federal Regulations A literal reading of AS8049A would require that all materials inthe seat meet the vertical ‘burn test requirement idemttied in Tile 14 of the Code of Federal Regulations (14 CFR) parts 23 and 25, Appendix F. The airworthiness regulations themselves do not require this. The FAA asked the SAE SEAT Committee for confirmation on the intent of AS8049A, paragraph 3.4.1. The SAE SEAT Committee promptly responded as follows:‘The tos “exposed al mates" and “setexingishing" end”. al ober exposed materials sodin paseergereeas.."'s only tore to oxiand the appeabc farabityrequrements n S41GeR'21855, 25453, 27859 and 29.853 regulations to oer materle used on ra sea The ‘ent anguage n Sechon 3. nearby bmi he requirements oy eatin categorie or {eat standards sssoceted wi "selhexingulsting properties, “Te ment 0 AS 8049 (Rowisions A as) i that he language nc 2.885, 25883, 27.853 and 23.855 be appledo all materiale where malarial proper, size an ‘quant woul nt create or propagate a cabn re ono around he sea “Theretore ll defines materi categories aswel as means of complance established in he applicable ars of 14 CFR 28883 (Type C Genoa Aviation). 25883 (Type A Transpo, 27.859(Type B Normal Rotererat) ans 29.859 (Type B Transpert Rotel eoninves to be Sasslactry lr meeting the specs language m Socton 3.41 ofthe SAE document ASSOS® AB 5. With the understanding thatthe intent of AS8049A is to prevent the use of materials that ‘would create or propagate a cabin fire, the FAA has assessed the effect of this clarification and finds that compliance with paragraph 3.4.1 of ASBO49A as described above is acceptable in meeting the requirements of 1'SO-C39¢ and TSO-C127a that reference paragraph 3.4.1 of ASSO49A. ‘The SAE SEAT Committe plans to modify this section inthe next release of ASBO49 (revision C) to correct the wording. The FAA will also revise the applicable wording in the next releare of TSO-C127 and TSO-C39. Ifyou have any questions please contact Jan Risheim (AIR-120) at 425-227-2209,