Gaining Approval Of Seats With Integrated Electronic Components

02/09/11 AC 21-49 Appendix I Rgure 1. One Process for ntegra1:ing Bedronic Components in Seats Previously Approved IJnderTSO (for example tFE in a TSOA seat) Applicant gels STC for design 3AlfOY3l of seat wifh changes to indudelFE STC holder gels PMA to manuf3cture seat modified with IFE PMA holder contracts seat manufacturer ffSOA holder) lo be a Sl.l)l)Her to PMA ootder for TSO-approved seat and to assemble IFE in seat per STC approved deSign TSOAholder d"sassemblesl TSOA holder builds TSOAholder reassembles sea to seat to conlbnn to app(ieSTSO i1teg elFE to TSO.approved design.

maJU19S oonfonn lo S TC-approved design Supp er OoesstJP¢ier (TSOA holder) (f SOA holder) ships seat with JFE to N h ave direct ship aulhority YES their customer from PMA holder?

(PMA holder) TSOA holder ships PMA holder ships se with IFE to seat with IFE to the PMA holder's theiraJStomer customer Note: Although this example shows an article approved via a TSOA, it would also work for an appliance approved under a LODA except for using a PMA. For non-U.S. manufacturers, a PMA can t be issued. An appropriate production approval per the bilaterals for the modified seat must be obtained (see FAQ I) .

Al-1 02/09/11 AC21 -49 Appendix2 FREQUENTLY ASKED QUESTIONS 1. How do I get a design approval and production approval ifl am a non-U.S.

manufacturer of a seat or electronic component?

a. Design approval. Wherever this AC uses the term "TSO approved seat" it applies to seats manufactured in the U.S. and approved to a TSOA, and to seats manufactured outside the U.S. and approved to a LODA. In either case, the seats can be changed to include electronic components under the U.S. type certification process or under a non-U.S. certification process that is then validated by us in accordance with the applicable bilateral agreement.

b. Production approval. The production approval of the seat, individual electronic components, and seat with electronic components must be obtained in accordance with the applicable bilateral agreement. Typically the bilateral agreement will specify that the civil aviation authority of the country of manufacture will approve and oversee a production quality control system that ensures the exported parts will conform to an approved design and are in a condition for safe operation. The use of the term production approval holder (PAH) in this document in cludes non-U.S. manufacturers in that they must have an approved production quality control system per the bilateral. Use of the specific terms production certificate (PC) and parts manufacturer approval (PMA) apply to U.S. manufacturers only.

2. Who can change the TSO-approved seat design to include an electronic component?

a. Either the TSO-approval holder or another person, per 14 CFR § 21.611. The TSO approval holder can change the seat design to include electronic components, if they control the design and manufacturing quality of the entire article, including the electronic components to the extent of meeting the TSO requirements as generally outlined in Table 1. See paragraph 7.b (electronic components defined in TSO design) of this AC.

b. According to 14 CFR § 21. 611 (c), a person other than a manufacturer can change the seat design to include an electronic component by obtaining a TC, ATC, or STC for the electronic components approval.

3. Who is the seat modifier? This is the entity that we approved to produce the seat with the design changes that include the electronic components. Often the modifier is the same entity to whom we granted the approval for the design change. Other times, the modifier may be using a previous design approval (using the approved data by a licensing agreement) that we issued to someone else to gain a production approval for the seat with electronic components.

EXllmple: We issued an STC to Expert Engineering to install an JFE system (integrated in a TSO-approv ed Welbilt Seat) into a Boeing 767-300. Expert Engineering licenses their STC and associated data to Precision Interiors, who in turn obtains a PMA to produce the seat with JFE. Precision Interiors contracts Welbilt Seats, in a supplier capacity, to assemble the JFE into the seat. Precision Interiors is the modifier because they hold the production approval. The design and installation approval is the STC issued to Expert Engineering.

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02/09/11 AC 21 - 49 Appendix 2 4. What are the seat modifier's responsibilities? The seat modifier is responsible to manufacture the seat with electronic components conforming to an approved design of the seat and electronic components. They must ensure all their suppliers are controlled under the seat modifier's approved quality control system or FIS. They must ensure the seat with electronic components is properly marked with a modification placard.

5. When is a modification placard required? The method in paragraph 7 .c (electronic components not defined in TSO design) of this. AC requires a modification placard. We require a modification placard any time a TSO-approved article is changed by someone other than the TSO approval holder. The method in paragraph 7.a (seat approved under TC but not TSO approved) of this AC doesn't require a modification placard. The method in paragraph 7.b (electronic components defined in TSO design) of this AC doesn't require a modification placard unless a person other than the TSO approval holder makes a change to the seat after it has left the TSO holder's quality control system.

6. What must be listed on the modification placard? See paragraph 11 of this AC for marking requirements.

Example: In FAQ 3 above, the modification placard should list Precision Interiors as the modifier, and list the STC number issued to Expert Engineering as the means of design approval. Precision Interiors is the modifier even when Welbilt Seats holds a TSO approval for the original seat without electronics, and Precision Interiors has contracted Welbilt to install the JFE into the TSO-approved seats. This is because Precision Interiors holds the production approval for the seat with the JFE.

7. What does it mean to " ... control the design and/or quality of the electronic component"? When controlling the design, the approval holder directs every aspect of the electronic component that can affect compliance to the applicable requirements, and that can affect conformity. Further, the holder ensures that the electronic component is in a condition for safe operation. Control includes all changes to those aspects as well. Approval holders are responsible to make sure that all the parts, components, subassemblies and assembly services they get from suppliers comply with applicable requirements.

Example: A seat manufacturer, Perfection Seats, includes the JFE in their TSO design as explained in paragraph 7.b (electronic components defined in TSO design) of this AC. Perfection Seats contracts Ultimate Video Concepts to provide JFE for integration in their seats, for which Perfection Seats is getting TSO approval. The JFE must meet the TSO performance standards for the items listed in paragraph 8 of this AC. Flammability is one example.

Perfection Seats is responsible for ensuring the original design of Ultimate Video Concepts' JFE meets the flammability requirements in the TSO.

Perfection Seats is also responsible for ensuring all design changes made by Ultimate Video Concepts to the JFE continue to meet the flammability requirements in the TSO. From our perspective, we issue the approval to A2-2

02/09/11 AC 21-49 Appendix 2 Perfection Seats, not Ultimate Video Concepts. Perfection Seats is responsible for ensuring the JFE meets the TSO.

8. Does the electronic component design approval affect the seat TSO approval?

Sometimes. It's important that the person seeking approval of the electronic component design determines that the seat with the electronic component continues to meet the seat TSO. This person must also ensure that the associated installation limitations remain valid or are properly evaluated and revised. If this isn't done~ the TSO approval is no longer valid and th ey must obliterate the TSO number listed on the TSO label. It also means that if the basis for installing the seat was the fact it was TSO-approved, and this is no longer true, then the applicant for installation approval will now have to reevaluate the basis for showing compliance to 14 CFR.

9. If I'm a seat TSO approval applicant/holder, can I list the electronic component on my seat TSO drawings?

a. Yes, but only if you control the design and manufacturing quality (production) of the electronic components as explained in paragraph 7.b (electronic components defined in TSO design) of this AC. When the TSO approval applicant/holder doesn't control the electronic component, it can't be list ed except when the electronic component is used as a test article and strictly defined. This can be accomplished by listing the drawing number including revision level of the electronic component. Because design changes made to the electronic component after the revision level were not evaluated during original TSO testing, they are not approved and require additional evaluation and a separate approval. Everything listed on a TSO drawing is the responsibility of the TSO approval applicant/holder to control for design and production to meet the TSO. This is true for all TSO articles (not just seats) that have extra functions or features not required by the TSO. An electronic compo nent is no different.

b. Per Table 1, it is also possible for a seat TSO approval holder to control some electronic components like footrest actuator motors, reading lights, and control units to meeting the TSO and not control other electronic components like IFE to meeting the TSO. In this case, the footrest motor, reading light and control unit are listed on the TSO approved drawings, but the IFE is not listed on the TSO approved drawings.

10. Do the seats have to have a TSO approval? No. As explained in paragraph 7.a (seat approved under TC but not TSO approved) of this AC, a TSO-approved seat is not mandatory.

11. How are statically-tested seats (e.g., TSO-C39 9g seats) affected by adding electronic components?

a. Adding an electronic component to a seat approved to TSO-C39 primarily affects its strength and flammability. The entity seeking electronic component design approval must evaluate the seat for the addition of the electronic component to determine how the seat reacts to the higher load, the change in center of gravity (cg), and so forth.

A2-3 02/09/11 AC 2 1-49 Appendix2 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-C12716g 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 cg 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 made by their suppliers.

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 da ta 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 P AH of the modified seat. The seat may be shipped from a supplier to the customer if the supplier has been granted direct ship autho ri ty from the P AH of the modified seat.

a. For the methods described in paragraphs 7.a (seat approved under TC but not T SO approved) or 7 .c (electronic components not defined in TSO design) of this AC, the P AH 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 SIC 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

02/09/11 AC 21-49 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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