SAE - ARP6448
Gaining Approval for Seats with Integrated Electronics in Accordance with AC21-49 Section 7.b
|Publication Date:||1 June 2012|
This document provides an industry-recommended
The approval for the integration of the electronics will fall, in part or in full, under the type design authority of the Seat Installer rather than the Seat Supplier shipping the integrated seat. The defined responsibilities, areas of authority and accountability of each party, as well as necessary communication protocols, must ensure configuration management, design control and quality control. These definitions, controls and protocols are agreed (thru normal commercial agreements and binding contracts) and adhered to by all parties ensuring all parts in the supply chain remain approved (e.g. certified and conformed). This document primarily focuses on the relationship between the Seat Supplier and the Electronics Manufacturer.
Table A1 of Appendix A of this document contains information which details the key characteristics of electronic components derived from the Change Impact Analysis characteristics identified in AS9016 (see Reference), tailored to the specific needs of AC 21-49, that require review to ensure proper compliance with the TSO requirements per Table 1 of AC21-49.
Additionally, Appendix B has been included to outline a typical data approval and change management process tailored specifically for ensuring proper communication links are established between all parties.
There are many different ways to ensure design and quality control procedures are in place to meet AC21-49 Section 7.b requirements through the established process identified in this document. While the responsibility rests solely with the Seat Supplier to ensure all TSO attributes identified in Table 1 of AC21-49 are acceptable, Appendix C has been included to outline the process for authorization of Electronics Manufacturers to assess the impact of changes in their equipment on the TSO attributes. This authorization will allow the classification of the change and the appropriate handling of the implementation of the change.
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 holds the approval holder responsible for ensuring all aspects under that approval are met, regardless of how industry establishes the business arrangements. For industry, we have to meet regulatory obligations under each approval, but have the flexibility of establishing business agreements to achieve those obligations. This document will define the responsibilities from both a regulatory perspective and a business perspective. Without commitment to establish and maintain these business agreements, success will not be achieved in meeting regulatory responsibilities.
There are many different ways a seat with electronic components can be approved for use in an aircraft. However, the guidance that follows is based on one acceptable model that has widespread use and involves multiple entities - including Seat Installers, Seat Suppliers, and Electronics Manufacturers as defined below.
Seat Supplier: A party that attains a TSO approval for the seat with integrated electronic components. A TSO approval can be either a TSO authorization (TSOA) or letter of TSO design approval (LODA).
Seat Installer: A party that attains a TC (or STC) for the installation and activation of the seat with integrated electronic components in the aircraft. The TC/STC approval covers the seat's installation into the aircraft and the installation and activation of the electronic components. In some instances the Seat Installer responsibilities may be divided or shared between a Physical Seat Installer and an Electronic System Activator, as defined in Section 3 of this document. A Physical Seat Installer attains approval for seat's physical installation into the aircraft, only without activating the seat's electronic components. The electronic system activator attains approval for the activation of electronic components.
Electronics Manufacturer: A party that supplies electronic components to be used in the installation and collaborates with both the Seat Supplier and the Seat Installer. The Electronics Manufacturer may be a production approval holder.