Retarding Fire Hazard in Interior Fabrics
Technicians must know the rules for their own protection
By John Boyce
The installation of interior fabrics is really no different to the installation of any other component in an aircraft; you have to be aware of the rules and follow them because, as with any other installation, it is the A&P technician who signs off on it and is ultimately responsible for how it functions.
Ethel Dawson, general manager of AccuFleet International, an aircraft interior flammability testing facility in Houston, is careful when answering a question about what she would say to technicians concerning fabric installation.
"Number one," Dawson says, "is to be familiar with FAA requirements for interior compartment materials for that type aircraft (that you are working on). Be very cautious about the materials applied and the treatments done. Always be concerned with re-certification of the material, if needed."
Put another way by Fred M. Walker, owner of Walker Aircraft Interiors in San Antonio, "What the mechanic has to know is that everything they put into that airplane has to be certified. If they do not have the paperwork indicating what fabric it is, who it came from, what (flammability) testing has been done on it; they cannot install it, legally. If the airplane crashes and burns, the mechanic is the one with his signature on there. He definitely wants to make sure the materials are approved (by the FAA)."
Asked where an A&P's liability lies after he returns an aircraft to service with upholstery modifications, Bill O'Brien, the FAA's national resource specialist, says the A&Ps have to meet the performance rules in FAR Part 43.13 and they have the "same liability as if he replaced a standard part. The job must meet type design or properly altered condition for safe operation."
Parts that count
Because most data shows that a substantial percentage of aircraft accident deaths result from fire and smoke inhalation, plus asphyxiation from toxic gasses released during a fire, much of the concern associated with aircraft interiors is the flammability of the materials used in them.
The FAA's rules governing flammability and flammability testing of materials in compartment interiors are mainly contained in Parts 23.853 and 25.853, and Advisory Circular AC25-853-1 for fireblocking and AC23-2 for Part 23 testing.
Generally speaking, the distinction between Part 23 and Part 25 has to do with size and use. Part 23 regulations pertain to smaller "normal utility" aircraft that weigh below 12,500 pounds. Part 25 pertains to transport category aircraft.
There is overlap, but Part 121 (airline operations) and Part 135 (on-demand, charter operations) aircraft fall under Part 25 rules, while Part 91 (corporate, personal-use operations) aircraft fall under Part 23 rules. There are some Civil Air Regulations (CAR) rules involved, but if you follow FAR Parts 23 and 25 rules you will be meeting or exceeding the civil rules pertaining to flammability.
All materials for compartment interiors must be self-extinguishing — either because they are inherently flame retardant, or they have been treated in some manner with a non-corrosive fire retardant. In the case of seat cushions in transport category aircraft, they must be composed of fireproof materials or be fire blocked and completely encapsulated with a material such as Kevlar,® keeping the cushion material — usually polyurethane foam — totally protected from heat and flame. The fireblocking rule addresses cabin passenger seat foam. Foams which are used in other areas of the aircraft must at least meet the minimum requirements for flammability. There is no requirement to fire block seat cushions in non-transport category aircraft; however, they too must at least meet the minimum requirements for flammability.
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