Missing Burn Certificate for my A/C Interior - Replacement/Solution Sought
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Missing Burn Certificate for my A/C Interior - Replacement/Solution Sought
Amazing you think you know it all, when you go to purchase a used aircraft. Looked at everything I thought, but I never got the Burn Certificate for the seats that the previous owner had re-upholstered. Now I wish to change onto the N-Reg and don't have anything to show the DAR. 
The seats don't look original Cessna, so I'll hardly be able to swing that. The previous owner cant remember who or where did the seats.
Has anyone come up against this problem? Can I get the fabric tested somehow? Or can a burn cert be found somewhere.... Owners who buy an A/C seeking to go onto the N reg take note, don't make the same oversight.
Irish
The seats don't look original Cessna, so I'll hardly be able to swing that. The previous owner cant remember who or where did the seats.Has anyone come up against this problem? Can I get the fabric tested somehow? Or can a burn cert be found somewhere.... Owners who buy an A/C seeking to go onto the N reg take note, don't make the same oversight.
Irish
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Irish
The guy who did the seat covers for my aircraft gets his fabrics tested and produced the documentation for my inspection.
I am sure that he gets the fabric tested to order, PM me and I will put you in touch with him, this would all be under UK approval but I would think that would work for the FAA.
I am sure that he gets the fabric tested to order, PM me and I will put you in touch with him, this would all be under UK approval but I would think that would work for the FAA.
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Are we talking cloth or leather?
Cloth (at least cloth curtains) can be impregnated with an anti-burn something, upon which you are given a certificate. This was good enough for a commercial buildings insurance and license-to-use. Companies can also spray that stuff onto things that are hard to remove and put in a washing machine (aircraft seats for instance). In case of the building I was managing at that time, the stuff they put on (and thus the certificate) was good for five years, after which a reapply was needed and a new certificate issued.
One night we accidently left a skylight window open and somebody tried to set the curtains on fire. Needless to say, it didn't work - we only had some scorch marks which the insurance covered. Even one of our volunteers, a fire chief, was impressed.
So, instead of going to great lengths in getting a new burn certificate, or getting your existing upholstery tested (but where would they take the sample from) you might just consider getting them burn-treated once more.
Oh, and the requirement for burn certificates, impregnation of cloth and things is typically not that it cannot burn at all anymore, but only that the burning stops within a certain time or distance as soon as the ignition source is taken away. Or even just that the flame front doesn't propagate at more than a certain speed, giving you ample time to evacuate. So don't think about testing in-situ by putting a propane burner against your interior. (On the bright side - that will require a new interior and you now know what to ask for from the upholsterer, do you?)
Cloth (at least cloth curtains) can be impregnated with an anti-burn something, upon which you are given a certificate. This was good enough for a commercial buildings insurance and license-to-use. Companies can also spray that stuff onto things that are hard to remove and put in a washing machine (aircraft seats for instance). In case of the building I was managing at that time, the stuff they put on (and thus the certificate) was good for five years, after which a reapply was needed and a new certificate issued.
One night we accidently left a skylight window open and somebody tried to set the curtains on fire. Needless to say, it didn't work - we only had some scorch marks which the insurance covered. Even one of our volunteers, a fire chief, was impressed.
So, instead of going to great lengths in getting a new burn certificate, or getting your existing upholstery tested (but where would they take the sample from) you might just consider getting them burn-treated once more.
Oh, and the requirement for burn certificates, impregnation of cloth and things is typically not that it cannot burn at all anymore, but only that the burning stops within a certain time or distance as soon as the ignition source is taken away. Or even just that the flame front doesn't propagate at more than a certain speed, giving you ample time to evacuate. So don't think about testing in-situ by putting a propane burner against your interior. (On the bright side - that will require a new interior and you now know what to ask for from the upholsterer, do you?)
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When we had our aircraft re upholstered, we looked at costs. It was cheaper to use leather rather than the approved cloth materials. This is because the cloth has to be non flammable and not give off toxic fumes. Leather doesn't suffer either of these problems.
From memory the reupholstering was in our maintenance records with all the details of who did it and what was used, your logbooks should show this.
If its not in your records perhaps someone has reupholstered your aircraft 'unofficially' and perhaps used the wrong material.
ZA
From memory the reupholstering was in our maintenance records with all the details of who did it and what was used, your logbooks should show this.
If its not in your records perhaps someone has reupholstered your aircraft 'unofficially' and perhaps used the wrong material.
ZA
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Its leather alright - but not sure if an aftermarket treatment will satisfy the DAR. I would of thought that leather is leather and given its not cloth that we wouldnt have a sticking point with the DAR. Seems not. Will have to go down the road of getting it tested unless I find a better plan 
Irish
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Have you spoken to an aircraft upholsterer? As you say leather is leather and doesn't burn or give off toxic gas. The seat foam etc may need to be tested. An aircraft upholsterer would know.
ZA
ZA
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Irish,
leather, vinyl, or fabric is the important question here.
If the original Cessna material was replaced with leather without changing anything else about the seat (foam), you might have a chance of making this work for the inspector. I've never heard of leather which does not pass the burn standards. It's worth the discussion with him.
The burn standards which are being called up are specific to aircraft, and based upon sucessful testing. Many fabrics (wool in particular) pass, and special treatments are sometimes used to make the fabric meet the standard, but this is not a well liked method, as the properties of the treatment are known to deteriorate over time, and the effect is lost. The test consists of burning (under very controlled conditions - by an accredited lab) three sapmles of the material, whose size is generally 3" by 12", though there can be some give on the size. The test in Canada costs about $400, and is pass or fail (you pay either way)
If the seats are vinyl, it might be possible to read manufacturer's information from the inside of the vinyl, it's often printed there. With a photo of that information, it might be possible to determine what the product is, and get the certification for that material from the manufacturer.
If you have fabric seats (or vinyl with no ID), it might be possible trim enough fron under the seats to get test samples, and do the burn test. If the inspector is being sticky, it's probably your only solution. If this is not an easy do, it'll be cheaper to have the seats redone with certified material than fight it.
PM me if you can't find a solution...
Pilot DAR
leather, vinyl, or fabric is the important question here.
If the original Cessna material was replaced with leather without changing anything else about the seat (foam), you might have a chance of making this work for the inspector. I've never heard of leather which does not pass the burn standards. It's worth the discussion with him.
The burn standards which are being called up are specific to aircraft, and based upon sucessful testing. Many fabrics (wool in particular) pass, and special treatments are sometimes used to make the fabric meet the standard, but this is not a well liked method, as the properties of the treatment are known to deteriorate over time, and the effect is lost. The test consists of burning (under very controlled conditions - by an accredited lab) three sapmles of the material, whose size is generally 3" by 12", though there can be some give on the size. The test in Canada costs about $400, and is pass or fail (you pay either way)
If the seats are vinyl, it might be possible to read manufacturer's information from the inside of the vinyl, it's often printed there. With a photo of that information, it might be possible to determine what the product is, and get the certification for that material from the manufacturer.
If you have fabric seats (or vinyl with no ID), it might be possible trim enough fron under the seats to get test samples, and do the burn test. If the inspector is being sticky, it's probably your only solution. If this is not an easy do, it'll be cheaper to have the seats redone with certified material than fight it.
PM me if you can't find a solution...
Pilot DAR
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Presuming you are talking a lightie, the burn standard should be a horizontal bunsen test.
Basic leather should pass this .. however the dyes etc sometimes are a problem.
Commercial treatments often don't pass the FAR Appendix tests so an aftermarket treatment without a burn test probably won't cut the mustard with the DAR.
Basic leather should pass this .. however the dyes etc sometimes are a problem.
Commercial treatments often don't pass the FAR Appendix tests so an aftermarket treatment without a burn test probably won't cut the mustard with the DAR.
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Found this crowd on the interweb who do CAA Burn testing and can do it for £32 in a few days.
TFT (Ilkley) Ltd.
The Sidings Business Park, SKIPTON, North Yorkshire, BD23 ITB 1
Phone or Fax 01756 792525
Only thing was I has to carefully remove the leather seat back pocket as a sample for them to burn and see if its up to scratch. Suppose a seat pocket is a small price to pay as opposed to facing an recover....
Will post progress
TFT (Ilkley) Ltd.
The Sidings Business Park, SKIPTON, North Yorkshire, BD23 ITB 1
Phone or Fax 01756 792525
Only thing was I has to carefully remove the leather seat back pocket as a sample for them to burn and see if its up to scratch. Suppose a seat pocket is a small price to pay as opposed to facing an recover....
Will post progress
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Irish,
Be sure that the testing company is acceptable to the CAA (ask the CAA not the company). Perhaps the CAA certifies them, I don't know your system. Then, you will have to tell them which standard you wan the test to (depends upon certification basis of the aircraft - I can figure it out for you if you need help). No point in failing a test which is more demanding than that which is required, when you would otherwise have passed. f it is an older aircraft, it is probably a CAR 3 cert basis, which will be much less demanding.
Be careful what you ask for, because you might get it!
Good luck,
Pilot DAR
Be sure that the testing company is acceptable to the CAA (ask the CAA not the company). Perhaps the CAA certifies them, I don't know your system. Then, you will have to tell them which standard you wan the test to (depends upon certification basis of the aircraft - I can figure it out for you if you need help). No point in failing a test which is more demanding than that which is required, when you would otherwise have passed. f it is an older aircraft, it is probably a CAR 3 cert basis, which will be much less demanding.
Be careful what you ask for, because you might get it!
Good luck,
Pilot DAR
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One CAA surveyor I spoke to said that he'd walked around an airfield and spotted several aircraft with new upholstery and hoped that the owner/operators had got modification approval (minor mod) for the change. Be aware be very aware!!!
I believe for new material you would need a Form 8 from the supplier to prove fire resistance. And, I suppose it brings into question, do upholsters need to be approved in by the CAA in someway?.
I believe for new material you would need a Form 8 from the supplier to prove fire resistance. And, I suppose it brings into question, do upholsters need to be approved in by the CAA in someway?.
Moderator
There are three things you can do to an aircraft: Maintenance, where you unbolt something, and bolt the same thing back on, Repair/replacement where you bolt on a different one of the same thing, in place of the damaged one you removed, or Modification, where you put something different in place of what you removed.
With few execptions, modifications require design approval. This could be an STC you bought from the holder, or an approval you sought for yourself, through your authority's system for that.
If you are replacing upholstry with original replacement parts from the original airframe manufacturer, it's a repair, and no approval is required. Other than that, it's probably a modification, and a modification approval is required. I know of several aircraft upholstery shops which were shut down, because they chose to not obtain design approval for interiors they did on small aircraft, even though the work was excellent. (and would have been easily approvable, had the sought approval)
Caution, when having such work done!
Pilot DAR
With few execptions, modifications require design approval. This could be an STC you bought from the holder, or an approval you sought for yourself, through your authority's system for that.
If you are replacing upholstry with original replacement parts from the original airframe manufacturer, it's a repair, and no approval is required. Other than that, it's probably a modification, and a modification approval is required. I know of several aircraft upholstery shops which were shut down, because they chose to not obtain design approval for interiors they did on small aircraft, even though the work was excellent. (and would have been easily approvable, had the sought approval)
Caution, when having such work done!
Pilot DAR
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Just as another thought on this subject:
I've looked at my IPC and type certificate and nowhere can I see the type of material used to cover the original seats etc specified. So, why do you have to prove that the material used to reupholster your seats has to comply with any 'burn' requirements?
In the UK there was a GRN (?) that required this but not sure if it the same for the US.
I've looked at my IPC and type certificate and nowhere can I see the type of material used to cover the original seats etc specified. So, why do you have to prove that the material used to reupholster your seats has to comply with any 'burn' requirements?
In the UK there was a GRN (?) that required this but not sure if it the same for the US.
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If you are replacing upholstry with original replacement parts from the original airframe manufacturer, it's a repair, and no approval is required. Other than that, it's probably a modification, and a modification approval is required. I know of several aircraft upholstery shops which were shut down, because they chose to not obtain design approval for interiors they did on small aircraft, even though the work was excellent. (and would have been easily approvable, had the sought approval)
Moderator
I've looked at my IPC and type certificate and nowhere can I see the type of material used to cover the original seats etc specified. So, why do you have to prove that the material used to reupholster your seats has to comply with any 'burn' requirements?
Once you install a product which is not identified in the IPC, approved or "specified" data is required for a design change. In some cases, AC43.13-1B would be appropriate specified data, but not for interior repairs, they would require an approval.
Repair vs replacement is simple: If you are installing a part listed in the IPC for that aircraft, and you have a certificate of airworthiness (in the format appropriate for an individual part) for that part, you are replacing. If you are installing something not listed in the IPC, or something for which you do not have a C of A, you are repairing and probably modifying too - approval required.
And.... Beware of TSO. The fact the an item is TSO'd (tire for example) does not approve it for intallation on a particular aircraft. It still must be specifically approved for installation on that aircraft by IPC or STC. Why, you ask? Tire example: 6.00-6, 4 ply is a main wheel tire for many light aircraft. 6.00-6, 8 ply is a nose wheel tire for a much heavier and faster aircraft. Either would fit in the position of the other, but neither would be approved or safe in the reversed application.
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Pilot DAR
I think we agree! I've just gone through a nightmare trying to get the Authorities to understand the difference between repair v replacement and it has only taken 2 years:-)
I think we agree! I've just gone through a nightmare trying to get the Authorities to understand the difference between repair v replacement and it has only taken 2 years:-)
burn tests
From my experience you'll need testing to FAR 25.853 / CS 25.853
(FAR for FAA, CS for EASA)
Airline services in manchester can do this but it may cost a few £££ for a one off test, they do testing for airline seats of multiple qty's normally.
The old CAA burn test house approvals are now req'd to bE per AQAS
standards under EASA.
cheers
(FAR for FAA, CS for EASA)
Airline services in manchester can do this but it may cost a few £££ for a one off test, they do testing for airline seats of multiple qty's normally.
The old CAA burn test house approvals are now req'd to bE per AQAS
standards under EASA.
cheers
