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Part 23 burn test certifications

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AOP

In Remembrance 2023
Joined
Jun 29, 2010
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Mount Hairy, MD
I have been going back and forth with the maker of the L-4 seat cushions I found about the requirement for burn tests on all airplane upholstery. He evidently had no heartburn making me a set, but when orders started coming in from all over, he started getting a little antsy about making lots of cushions for lots of airplanes.

I used to answer questions at AOPA, and we always told people that loose seat cushions that were not permanent installations were not required to have the same material certs under Part 23. However, there was nothing on paper that I could show this guy to assuage his anxiety.

It is a well known aphorism that says when dealing with the FAA, it is often better not to ask, because you may not like the answer. Which translates to something that sounds a lot like "It is easier to get forgiveness than permission", which we all know to be absolutely false, because the FAA does not forgive. What it means is that if you get a written answer to a question, it then becomes official precedent, and not something that they could look the other way on.

Well, on the basis of my experience at AOPA and what I had been told there, and had heard being told to innumerable pilots innumerable times, I called the Baltimore FSDO and spoke to a Maintenance Inspector. Dave Carey was his name, a very personable guy on the phone, too. I wanted to know that since this could not be the first time that this had come up, there must be something written down that I could show the maker. He said that it was true, that loose cushions, throw pillows, lumbar supports and seat liners that taxi drivers often use are not required to be certificated for burn tests, but that there was nothing he could find written down. He did, however invite the maker to call him directly.

So anyway, that is as official as we are likely to get.
 

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