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New Draft FAA Guidance: Non-TSO Functions in Seats

The FAA has published new draft guidance for public comment.  The policy statement clarifies the non-TSO function language in TSO C127B, which was added in 2014.  Non-TSO functions are those that go beyond the minimum standards of the seat TSO, like reading lights or in-flight-entertainment.

The draft policy explains that non-TSO functions in aircraft seats should be declared, in order to signal to the installer that the substantiation and design control for the added functionality may need to be addressed by a separate design approval, because it may not have been an FAA-approved design element in the TSO design approval.  It also provides additional guidance on what functions are non-TSO functions.

Comments are due to the FAA by July 20, 2015.

You can email comments to: robert.a.rouza@faa.gov

Comments can also be delivered by mail or hand to:
Federal Aviation Administration
Design, Manufacturing & Airworthiness Division
Systems & Equipment Standards Branch, AIR-130
470 L’Enfant Plaza, SW, Ste. 4102
Washington, DC 20024

Please send a copy of your comments to MARPA, so that the Trade Association’s response can support your concerns.  Please also let the Association know if this is guidance that is important to your business.

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About Jason Dickstein

Mr. Dickstein is the President of the Washington Aviation Group, a Washington, DC-based aviation law firm. He represents several aviation trade associations, including the Aviation Suppliers Association, the Aircraft Electronics Association, the Aircraft Fleet Recycling Association and the Modification and Replacement Parts Association.

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