Interior confusion

Airplanes are just like people; they have personalities, likes and dislikes, and as they get older they begin to fray a bit at the edges.

Now let's look at the material/fabric fire protection requirements for CAR-3 Certificated Aircraft.

These aircraft simultaneously make up both the oldest and majority of aircraft found in the U.S. aviation fleet. These are the Beech, Cessna, and Piper aircraft from days of our youth. The 10-year-old kids who hung on the airport fence in the late 1950s are now in their fifties and they are buying these older aircraft and revitalizing them in high hopes of recapturing their four decade old dream.

CAR-3 aircraft that are used for Part 91 operations, with interiors where smoking is not permitted, the interior materials shall be flash-resistant (Ref: CAR-3, Section 3.388). In CAR 3 aircraft interiors where smoking is permitted, the wall and ceiling linings, the covering of all upholstering, floors, and furnishings shall be flame-resistant (Ref: CAR-3, Section 3.388).

When a mechanic buys material in bulk to refurbish the interior, seats, and ceiling liners for a CAR-3 aircraft used in Part 91 operations, a manufacturer's statement declaring that the material meets the American Society for Testing and Materials (ASTM) or similar national standard for either flash resistance or flame resistance for the applicable installation would be acceptable. A manufacturer's statement is acceptable due to the fact that neither the old Civil Aeronautics Administration (CAA) or the Federal Aviation Administration (FAA) has not published an FAA fire standard for either flash or flame resistance for interior materials for CAR-3 aircraft. The FAA accepts and recognizes a national standard, so the mechanic who bought the fabric/material in bulk should reference the manufacturer's statement and the national standard that the fabric/material meets in the aircraft's maintenance records.

If no "standards" statement is made in the aircraft's logs, then the IA will have a problem at the aircraft's next annual inspection. He is looking at a new interior that may or may not meet CAR-3 requirements. In other words, he may have an "unapproved interior" and the fabric might have the flame resistance of a box of matches. So if the IA can't chase down the mechanic who installed the interior and get the necessary "standards" statement in the logbook, then the only other alternative he has, in order to solve this problem, is to have a laboratory check and certify that the fabric meets the ASTM or any other nationally-recognized flash or flame-resistant standard or do a burn test in accordance with Part 23, Appendix F.

A suggestion. To avoid mucking around with the flash/flame/burn federal requirements when you buy interior fabric/material in bulk for CAR-3 aircraft, the best way to satisfy the regulations is to have an appropriated FAA repair station perform and sign off a Part 23 burn test. If your fabric passes Appendix F requirements, then it exceeds the CAR-3, Section 3.88 requirements and you can tell your customers that they are better protected in case of an accident.

What about the fire protection for FAR -23/25 certificated aircraft interiors? Requirements for interiors for Part 23/25 are straightforward, none of this flash and flame duel CAR-3 standards. If you buy in bulk, the fabric and materials must meet Part 23, Appendix F or Part 25, Appendix F burn test requirements. The applicable Appendix F test must be performed by an FAA Repair Station who will certify that all materials and fabrics meet the regulation. This statement must be made part of the aircraft's maintenance records. If you buy interior fabric or materials that will be used on both Part 23 and Part 25 aircraft be sure that the repair station certifies that the material/fabric meets both Part 23 and Part 25 requirements.

If a CAR 3, Part 23, or Part 25 aircraft has an interior installed under a STC, then the new interior is considered a major alteration and the STC number must be noted on Block 8 of the FAA Form 337 and in the aircraft's maintenance records. It is not necessary to state in the aircraft's maintenance logbooks that the interior meets burn requirements of Appendix F of either Part 23 or Part 25. The fact that the STC is FAA-approved data satisfies the burn test requirement. Also, don't forget that under the new law passed by Congress in October of 1996, the owner of the aircraft must have a letter from the STC holder that authorizes the owner to install the STC.

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