SAE - ARP6448A
(R) Gaining Approval for Seats with Integrated Electronics in Accordance with AC 21-49 Section 7.b
|Publication Date:||1 October 2021|
This SAE Aerospace Recommended Practice (ARP) provides a framework for establishing methods and stakeholder responsibilities to ensure that seats with integrated electronic components (e.g., actuation system, reading light, inflatable restraint, inflight entertainment equipment, etc.) meet the seat TSO minimum performance standard. These agreements will allow seat suppliers to build and ship TSO-approved seats with integrated electronic components. The document presents the roles and accountabilities of the electronics manufacturer (EM), the seat supplier, and the TC/ATC/STC applicant/holder in the context of AC 21-49 Section 7.b ("Type Certification Using TSO-Approved Seat with Electronic Components Defined in TSO Design"). This document applies to all FAA seat TSOs C39( ), C127( ), etc.
The document defines the roles and responsibilities of each party involved in the procurement of electronics, their integration on a TSO-approved seat, and the seat's installation on an aircraft. Requirements for design and quality control and the methods for communicating design and change data between electronics manufacturers (EM) and seat suppliers are defined such that standardization is possible across the industry to ensure continued airworthiness of TSO-approved seats with integrated electronic components. This document primarily focuses on correspondence between the seat supplier and the electronics manufacturer.
Appendix A: Presents key characteristics of electronic components and guidance on how changes are classified per the requirements of Table 1 of AC 21-49.
Appendix B: Provides an outline of a typical data approval process and the change management process between electronics manufactures and seat suppliers.
Appendix C: While the responsibility rests solely with the seat supplier to ensure all TSO attributes identified in Table 1 of AC 21-49 are acceptable, Appendix C has been included to outline the process for delegating EMs authorization to assess the impact of changes on their equipment with respect to seat TSO attributes. This authorization will allow the classification of the change and the appropriate administration of the change by the electronics manufacturer via seat supplier delegation.
Appendix D: Given the mix of business arrangements that can exist in the seat, in-flight, and aircraft procurement lifecycle (buyer furnished equipment, supplier furnished equipment, customer furnished equipment), there is discussion on the potential need for separate agreements between the EMs and seat suppliers to ensure binding flow down of design and quality control requirements. As such, a working together agreement (WTA) template is provided as Appendix D.
Regulatory and Business
Model It is important to recognize that industry and the FAA have different needs when it comes to getting a seat with electronic components approved for use in an aircraft. The FAA looks at certification strictly from a regulatory point of view and to whom they issue the various approvals. The FAA makes the approval holder responsible for ensuring all aspects under that approval are met, regardless of how industry establishes the business arrangements.
For seats covered under TSOA, there are two approvals: the seat TSOA and the installation approval (TC/STC/ATC). The TSOA holder will continue to review and approve changes as long as the seats with integrated electronic components are in the field. The installation approval holder may close their installation project after the last aircraft delivers and cannot review any proposed changes under that closed project. In these cases, a third party TC/STC/ATC holder/applicant may be contracted to review and approve changes to electronic components for the aspects of the change that affect AC 21-49 Section 9 requirements.
For industry, regulatory obligations under each approval have to be met while having some flexibility for establishing business agreements and delegations such that said obligations can be achieved efficiently. This document defines the responsibilities from both a regulatory perspective and a business perspective.