Appendix 2
b. These factors pertain only to how adding the electronic components should be evaluated for its effect on meeting the TSO for a previously TSO-approved seat. The evaluation must also cover the approval for installation into the aircraft.
12. How are dynamically-tested seats (e.g, TSO-C127 16g seats) affected by adding electronic components? In addition to the structural concerns for statically tested seats, adding electronic components to a dynamically tested seat can also affect the seat's response to the dynamic test pulse. Changes to the mass and og of the seat from adding electronic components are difficult to predict and typically require dynamic testing to evaluate. Adding electronic components will also affect the results of a HIC test, if a head strike on the electronic components occurs. Lumbar loads can be affected by addition of an electronic component below the seat. For seats with electronic components that were successfully dynamically tested for HIC, small changes to component stiffness or mass can have big effects on HIC results. This is one example why it is important for electronic component approval holders to control all changes
13. Can a seat TSOA applicant/holder use the non-TSO functions policy with electronic components? No. Our current policy does not allow the method for accepting data for non- TSO functions for seat TSOs. We expect that future internal FAA policy will clarify and expand how we view the use of non-TSO functions data acceptance for all TSOS. Until then we adhere to current policy.
Note: In general, the Non-TSO function policy does not apply to, and can't be used by, LODA applicants/holders unless specifically allowed per the applicable bilateral. Review the bilateral agreement of the country of the foreign manufacturer for more information.
14. Can an air carrier buy a seat modified with electronic components directly from a seat manufacturer? The air carrier can only buy the seat modified with the electronic components from the PAH of the modified seat. The seat may be shipped from a supplier to the customer if the supplier has been granted direct ship authority from the PAH of the modified seat.
a. For the methods described in paragraphs 7.a (seat approved under TC but not TSO approved) or 7.c (electronic components not defined in TSO design) of this AC, the PAH is the PC or PMA holder.
b. For the method described in paragraph 7.b (electronic components defined in TSO design) of this AC, the PAH is the TSO approval holder. However, it must be understood that the seat manufacturer has only a regulatory responsibility to ensure that the seat with the IFE meets the TSO, not the STC that approved the IFE for installation into the aircraft.
15. What's the difference between the "seat modifier" and the "electronic components assembler"? The seat modifier holds the approval to produce the seat modified with electronic components. They have total responsibility for production control of the seat with electronic components. The electronic components assembler performs the physical work of installing the electronic components into the seat. Sometimes the modifier and assembler are the same. Other times the modifier contracts the physical installation of electronic components to a supplier A2-4
Appendix 2 (electronic components assembler). In the example in FAQ 3 above, Precision Interiors is the seat modifier and Welbilt Seats is the electronic components assembler.
16. Why does this AC supersede previous policy?
a. In previous policies, we stated that electronic components could be listed on the TSO drawings or supporting documents, like the installation instructions and limitations, even when the TSO applicant/holder did not control the design and manufacture of the electronic components.
b. As we explain in paragraph 7.c (electronic components not defined in TSO design), when the TSO applicant/holder does not control the electronic components, they must not list electronic components on the TSO drawings or any other documents that are part of the TSO approval except as provided for test article components.
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