+-------+------------------------------+-------------------------------+
|       | **DISPOSITION OF PUBLIC      |                               |
|       | COMMENTS ON DRAFT POLICY     |                               |
|       | STATEMENT ANM-115-05-10,     |                               |
|       | POLICY STATEMENT ON AN       |                               |
|       | ACCEPTABLE METHOD OF         |                               |
|       | COMPLIANCE WITH § 25.562 FOR |                               |
|       | REPLACING RESTRAINT SYSTEMS  |                               |
|       | ON FORWARD AND AFT FACING    |                               |
|       | SEATS**                      |                               |
+-------+------------------------------+-------------------------------+
| Comm  | Comment                      | Disposition                   |
| enter |                              |                               |
+-------+------------------------------+-------------------------------+
| Mike  | I would like to congratulate | N/A                           |
| Ol    | the FAA on publishing the    |                               |
| eson, | proposed Memorandum          |                               |
| Presi | ANM-115-05-10 for replacing  |                               |
| dent, | restraint systems on         |                               |
| O     | aircraft seats. This is a    |                               |
| leson | giant step forward for the   |                               |
| Tec   | aviation industry in         |                               |
| hnolo | reducing the dynamic         |                               |
| gies, | certification costs for      |                               |
| Inc.  | aircraft seating. Having     |                               |
|       | personally coordinated the   |                               |
|       | certification activity       |                               |
|       | between the applicant (a     |                               |
|       | restraint system             |                               |
|       | manufacturer who developed   |                               |
|       | the methodology) and the     |                               |
|       | FAA, I am fully aware of the |                               |
|       | positive impact that this    |                               |
|       | proposed policy will have on |                               |
|       | the industry.                |                               |
|       |                              |                               |
|       | I would like to further      |                               |
|       | state that that this         |                               |
|       | methodology and acceptance   |                               |
|       | criteria have been used with |                               |
|       | successful results on a few  |                               |
|       | programs to date. Having     |                               |
|       | conducted the required       |                               |
|       | testing and witnessed same   |                               |
|       | as a § 25.562 DER for the    |                               |
|       | FAA, I can say that the      |                               |
|       | criteria are stringent       |                               |
|       | enough to show adequate      |                               |
|       | comparison of restraint      |                               |
|       | systems and their            |                               |
|       | performance. I am proud to   |                               |
|       | have been part of the        |                               |
|       | coordinated efforts of       |                               |
|       | various FAA regional         |                               |
|       | offices, CAMI, FAA TAD and   |                               |
|       | the restraint system         |                               |
|       | manufacture to create such a |                               |
|       | beneficial policy.           |                               |
+-------+------------------------------+-------------------------------+
| Mark  | The proposed policy has been | N/A                           |
| Ba    | assessed and is supported.   |                               |
| thie, |                              |                               |
|       |                              |                               |
| Air   |                              |                               |
| worth |                              |                               |
| iness |                              |                               |
| Stan  |                              |                               |
| dards |                              |                               |
| Br    |                              |                               |
| anch, |                              |                               |
|       |                              |                               |
| Civil |                              |                               |
| Avi   |                              |                               |
| ation |                              |                               |
| S     |                              |                               |
| afety |                              |                               |
| Auth  |                              |                               |
| ority |                              |                               |
| Aust  |                              |                               |
| ralia |                              |                               |
+-------+------------------------------+-------------------------------+
| Mark  | Whilst it is appreciated     | The proposed policy memo has  |
| Ba    | that this is a policy        | been given to the Small       |
| thie, | generated by the Transport   | Airplane and Rotorcraft       |
|       | Airplane Directorate for     | Directorates so that they can |
| Air   | Transport Category aircraft  | assess its applicability to   |
| worth | using research based on 16g  | parts 23, 27 and 29. CASA's   |
| iness | dynamic tests, CASA would    | comment has also been         |
| Stan  | like to encourage the        | provided to these             |
| dards | expansion of this policy, or | organizations. The Small      |
| Br    | alternatively generate new   | Airplane and Rotorcraft       |
| anch, | policies, to encompass       | Directorates will issue       |
|       | replacement methods for      | separate policy if it is      |
| Civil | restraint systems of Normal, | determined to be acceptable   |
| Avi   | Utility and Acrobatic        | for demonstrating compliance  |
| ation | categories (Part 23) and     | with parts 23, 27 and/or 29.  |
| S     | Rotorcraft categories (Parts |                               |
| afety | 27 & 29).                    |                               |
| Auth  |                              |                               |
| ority | CASA encourages all research |                               |
| Aust  | and policies that endeavour  |                               |
| ralia | to lower costs to the        |                               |
|       | aviation industry whilst     |                               |
|       | maintaining the required     |                               |
|       | level of aviation safety.    |                               |
+-------+------------------------------+-------------------------------+
| Tom   | I would like to comment in   | The FAA considers that the    |
| K     | favor of this policy         | proposed criteria (+/- 6%     |
| nott, | statement regarding          | peak restraint loads, +/-1    |
|       | replacement restraint        | inch maximum ATD head         |
| Ne    | systems. Like the Policy     | excursion, etc.) will result  |
| enah, | Statement on seat bottom     | in the level of protection    |
| WI    | cushions, this will provide  | established in part 25.       |
|       | much-needed clarification on |                               |
|       | the requirements for the     |                               |
|       | refurbishment of aircraft    |                               |
|       | interiors, and hopefully     |                               |
|       | this will lead to aircraft   |                               |
|       | that maintain their original |                               |
|       | level of occupant            |                               |
|       | protection.                  |                               |
+-------+------------------------------+-------------------------------+
| Tom   | One improvement would be to  | Draft Advisory Circular (AC)  |
| K     | add a statement that         | 25.562-1X provides guidance   |
| nott, | replacing a restraint system | on this issue and a more      |
|       | with one of the same type    | complete list of seat and     |
| Ne    | from the same manufacturer,  | restraint system changes that |
| enah, | differing only in webbing    | do not require analysis to    |
| WI    | color and/or metal plating,  | certify. This draft AC is     |
|       | is a minor change.           | expected to be issued         |
|       |                              | relatively soon. Since it     |
|       |                              | provides guidance on this     |
|       |                              | issue and since the focus of  |
|       |                              | this memo is specifically to  |
|       |                              | provide a component method    |
|       |                              | for replacing restraint       |
|       |                              | systems, the general guidance |
|       |                              | on this specific issue has    |
|       |                              | not been repeated in this     |
|       |                              | memo.                         |
+-------+------------------------------+-------------------------------+
| Tom   | A minor shortcoming is there | The introductory paragraph    |
| K     | is no reminder that the      | states that the purpose of    |
| nott, | restraint system is part of  | this memo is to provide a     |
|       | the TSO\'d (or TC\'d or      | method of compliance with     |
| Ne    | STC\'d) article. The         | § 25.562 for replacing        |
| enah, | discussion about the         | restraint systems on          |
| WI    | TSO-C22g and TSO-C114 also   | previously                    |
|       | could lead to the same       | [approved]{.underline} seats. |
|       | confusion.                   | In other words, the original  |
|       |                              | seat and restraint system has |
|       |                              | been approved in a Type       |
|       |                              | Certificate (TC), Amended TC, |
|       |                              | Supplemental Type Certificate |
|       |                              | (STC), Amended STC or TSO     |
|       |                              | program. The memo does not    |
|       |                              | mention that the seat has a   |
|       |                              | TSO, because a TSO is not     |
|       |                              | required to certify the seat  |
|       |                              | and restraint system to part  |
|       |                              | 25. It is also understood by  |
|       |                              | the words of the introductory |
|       |                              | paragraph, and the memo as a  |
|       |                              | whole, that the restraint     |
|       |                              | system is part of the seat.   |
+-------+------------------------------+-------------------------------+
| Tom   | Though the test method       | N/A                           |
| K     | proposed will definitely     |                               |
| nott, | lower certification costs    |                               |
|       | while maintaining the        |                               |
| Ne    | certificated level of        |                               |
| enah, | safety, I believe that       |                               |
| WI    | lower-cost static tests      |                               |
|       | could also be used to        |                               |
|       | substantiate the replacement |                               |
|       | of restraint systems. The    |                               |
|       | key factor is the elasticity |                               |
|       | of the webbing, that is, how |                               |
|       | much load is transferred     |                               |
|       | into the seat structure.     |                               |
|       | This is covered by the +/-   |                               |
|       | 6% in peak restraint load.   |                               |
|       | As far as occupant           |                               |
|       | displacement, the amount of  |                               |
|       | \"open\" webbing (not        |                               |
|       | doubled over near the        |                               |
|       | attachments, or absent at    |                               |
|       | the hardware) is not enough  |                               |
|       | to cause drastic changes in  |                               |
|       | occupant excursion. In one   |                               |
|       | STC project I worked on, a   |                               |
|       | static test of two very      |                               |
|       | different webbing            |                               |
|       | specifications led to a      |                               |
|       | calculated difference of     |                               |
|       | only 3/8 inch in head path,  |                               |
|       | much less than the +/- 1.0   |                               |
|       | inch limit in the proposed   |                               |
|       | policy. I am sure that as    |                               |
|       | data is collected using the  |                               |
|       | proposed policy, this will   |                               |
|       | become apparent.             |                               |
|       |                              |                               |
|       | Thank you for a very useful  |                               |
|       | Policy Statement.            |                               |
+-------+------------------------------+-------------------------------+
| GAMA  | The draft policy proposed    | The acceptability of this     |
|       | that the peak restraint      | method is based on it         |
|       | loads acceptance criteria to | providing a means to          |
|       | be within +/- 6% between the | demonstrate that a proposed   |
|       | replacement and certificated | restraint is                  |
|       | restraint system. As noted   | [equivalent]{.underline} to a |
|       | in the policy statement, the | certificated restraint. A     |
|       | basis of the acceptable      | replacement restraint that    |
|       | criteria appears to have     | performs                      |
|       | been derived from variances  | [equivalently]{.underline} to |
|       | in restraint loads that      | a certificated restraint will |
|       | occur in tests conducted in  | not change the performance of |
|       | accordance with § 25.562(b)  | the seat and can be installed |
|       | of same part number seats.   | on the seat without it        |
|       | However, the FAA has not     | resulting in a non-compliance |
|       | published any of the data    | with §§ 25.562 or             |
|       | for review nor has the FAA   | 25.785(b),(d). Installation   |
|       | made it available to the     | of a non-equivalent           |
|       | GAMA 16 G Seat committee to  | replacement restraint could   |
|       | assess. Without access to    | result in the seat not        |
|       | such data, the 16G committee | remaining attached to the     |
|       | members are in no position   | floor, the occupant injury    |
|       | to make a proper judgment on | criteria of § 25.562(c) being |
|       | the validity of the          | exceeded, etc. during the     |
|       | acceptance criteria.         | dynamic conditions of         |
|       | However, such variances are  | § 25.562(b). (Note that       |
|       | not considered typical based | another method may be         |
|       | on industry experience with  | acceptable which demonstrates |
|       | dynamic tests. For example,  | that a replacement restraint  |
|       | one applicant in the past    | is equivalent to [or better   |
|       | has justified a broader      | than]{.underline} a           |
|       | variance of +/-10% as a      | certificated restraint, but   |
|       | comparison of restraint      | that consideration is outside |
|       | loads based on their         | of the scope of investigation |
|       | experience with seat dynamic | for this proposed method.)    |
|       | testing and discussions held |                               |
|       | with FAA CAMI in 2000. The   | A test conducted in           |
|       | +/-10% range was accepted by | accordance with § 25.562(b)   |
|       | the FAA on a certification   | with same part number seats   |
|       | program using a similar      | and restraint systems         |
|       | restraint replacement        | installed side-by-side on a   |
|       | policy. Industry requests    | common dynamic test sled will |
|       | that FAA considers a range   | typically not produce         |
|       | of +/-10% as reasonable      | identical peak loads in the   |
|       | acceptance criteria for      | restraints. Some variance in  |
|       | restraint load comparison.   | load data will occur due to   |
|       | We will provide test data,   | factors such as               |
|       | if requested, to support our | anthropomorphic test dummy    |
|       | position and would welcome   | (ATD) positioning, design     |
|       | further discussion on this   | tolerances, etc. As such, the |
|       | issue.                       | FAA considers that it is      |
|       |                              | acceptable for this           |
|       |                              | comparison method to include  |
|       |                              | criteria with a performance   |
|       |                              | range for determining if a    |
|       |                              | replacement restraint is      |
|       |                              | equivalent to a certificated  |
|       |                              | restraint. However, the       |
|       |                              | acceptable range should not   |
|       |                              | be too large because the      |
|       |                              | acceptability of this method  |
|       |                              | is based on its criteria only |
|       |                              | allowing replacement of       |
|       |                              | [equivalent]{.underline}      |
|       |                              | restraints.                   |
|       |                              |                               |
|       |                              | A supplemental type           |
|       |                              | certificate applicant first   |
|       |                              | proposed to use the +/- 6%    |
|       |                              | criterion. The FAA determined |
|       |                              | that this criterion was       |
|       |                              | acceptable for their project  |
|       |                              | based on their proprietary    |
|       |                              | data and some FAA data. This  |
|       |                              | applicant conducted multiple  |
|       |                              | programs using that criteria  |
|       |                              | and found that proposed       |
|       |                              | restraints can be designed    |
|       |                              | within that range. Since the  |
|       |                              | criteria is achievable, it    |
|       |                              | should not be expanded to +/- |
|       |                              | 10% which would allow greater |
|       |                              | dissimilarity between         |
|       |                              | restraints and conflict with  |
|       |                              | the basis of this method of   |
|       |                              | compliance, that is, to show  |
|       |                              | that the restraints are       |
|       |                              | equivalent.                   |
|       |                              |                               |
|       |                              | The FAA considered the amount |
|       |                              | of variance that can occur in |
|       |                              | restraint load data, but did  |
|       |                              | not based the +/- 6%          |
|       |                              | criterion on the largest      |
|       |                              | variance that can occur. The  |
|       |                              | amount of variance in dynamic |
|       |                              | test data is dependant on the |
|       |                              | amount of care taken in       |
|       |                              | setting up the test and       |
|       |                              | obtaining the data. For the   |
|       |                              | reasons explained above, the  |
|       |                              | FAA considers +/- 6% most     |
|       |                              | appropriate for this method.  |
|       |                              |                               |
|       |                              | The FAA Transport Standards   |
|       |                              | Staff contacted the applicant |
|       |                              | that used the +/-10%          |
|       |                              | criterion on a certification  |
|       |                              | program. The applicant        |
|       |                              | indicated that the criterion  |
|       |                              | was not used based on FAA     |
|       |                              | policy, but was used based on |
|       |                              | it being documented in a test |
|       |                              | plan that was coordinated     |
|       |                              | with their local Aircraft     |
|       |                              | Certification Office. FAA     |
|       |                              | policy has not been published |
|       |                              | allowing the use of the +/-   |
|       |                              | 10% criterion.                |
|       |                              |                               |
|       |                              | The FAA contacted GAMA about  |
|       |                              | data they could provide       |
|       |                              | regarding the amount of       |
|       |                              | variance that can occur in    |
|       |                              | peak restraint loads. A GAMA  |
|       |                              | 16G Seat Committee team       |
|       |                              | leader requested industry     |
|       |                              | members to provide data from  |
|       |                              | rigid seat tests comparing    |
|       |                              | same part number restraints.  |
|       |                              | These industry members did    |
|       |                              | not provide any data.         |
|       |                              | Regardless, the FAA considers |
|       |                              | +/- 6% most appropriate for   |
|       |                              | this method for the reasons   |
|       |                              | explained above.              |
+-------+------------------------------+-------------------------------+
| GAMA  | Industry proposes that       | As explained above, this      |
|       | restraint segments that are  | method is used to demonstrate |
|       | directly attached to the     | that a proposed restraint     |
|       | fuselage structure (i.e. not | system is                     |
|       | attached to the seat) should | [equivalent]{.underline} to a |
|       | not be required to meet the  | certificated restraint        |
|       | peak restraint load          | system, and therefore may be  |
|       | criteria. The rational of    | substituted onto the          |
|       | requiring the peak restraint | certificated seat. The peak   |
|       | loads to be within limits is | restraint load criterion is   |
|       | to ensure that the seat is   | used to make this comparison. |
|       | not subjected to higher      | The commenters proposal would |
|       | loads with the new restraint | not evaluate the equivalency  |
|       | system. When some segments   | of the restraints or          |
|       | of restraints (such as       | demonstrate that the change   |
|       | shoulder harness) are        | would comply with § 25.562.   |
|       | directly attached to the     | This proposal has not been    |
|       | fuselage structure, the      | accepted.                     |
|       | loads transferred to the     |                               |
|       | seat are through the segment |                               |
|       | of restraints that are       |                               |
|       | directly attached to the     |                               |
|       | seat. Therefore, the only    |                               |
|       | valid peak restraint load    |                               |
|       | comparison should be limited |                               |
|       | to the portions of restraint |                               |
|       | systems that are attached to |                               |
|       | the seat.                    |                               |
+-------+------------------------------+-------------------------------+
| GAMA  | The draft policy proposed    | As explained in the response  |
|       | that the difference between  | to GAMA's first comment, the  |
|       | the replacement and          | acceptability of this method  |
|       | certificated restraint       | is based on the pass/fail     |
|       | system should not exceed +/- | criteria ensuring that a      |
|       | 1.0 inch for ATD maximum     | replacement restraint will    |
|       | head excursion. Industry     | perform                       |
|       | members have seen variations | [equivalently]{.underline} to |
|       | in dynamic testing such as   | a previously certificated     |
|       | initial belt placement on    | restraint. The +/- 1 inch     |
|       | the ATD, initial restraint   | criterion is used to          |
|       | tension, leg articulation    | determine this equivalency.   |
|       | (foot drags on floor), ATD   | The limits of this criterion  |
|       | positioning, etc. that have  | were determined in a similar  |
|       | affected the maximum ATD     | manner as the peak restraint  |
|       | head excursion by greater    | load criterion and has been   |
|       | than one inch on same seat   | determined to be achievable.  |
|       | tests. Industry proposes     |                               |
|       | that the head excursion      | The scope of this method is   |
|       | criteria be imposed based on | limited to demonstrating      |
|       | the installation of the seat | equivalency of restraint      |
|       | and the potential of         | systems. Another method may   |
|       | headstrike. For example, if  | be acceptable which           |
|       | the seat installation is     | demonstrates that a           |
|       | clearly free from any        | replacement restraint is      |
|       | headstrike potential due to  | equivalent to [or better      |
|       | large seat offsets, the      | than]{.underline} a           |
|       | maximum head excursion need  | certificated restraint, but   |
|       | not apply. In addition, a    | that consideration is outside |
|       | shorter headpath produced by | of the scope of investigation |
|       | the replacement restraint    | for this proposed method. The |
|       | should be acceptable (even   | FAA considers that the        |
|       | if it falls below the --1.0  | proposal, or a modification   |
|       | inch tolerance) if a proper  | of the proposal, is an        |
|       | analysis of the headpath     | appropriate suggestion for    |
|       | shows that it is reduces or  | consideration in a separate   |
|       | eliminates head contact.     | policy memo or issue paper.   |
|       |                              | Some areas that would need to |
|       |                              | be investigated are as        |
|       |                              | follows:                      |
|       |                              |                               |
|       |                              | -   The actual head path      |
|       |                              |     produced with a           |
|       |                              |     replacement restraint can |
|       |                              |     not be determined from    |
|       |                              |     the rigid seat comparison |
|       |                              |     test.                     |
|       |                              |                               |
|       |                              | -   A lap safety belt that    |
|       |                              |     produces a significantly  |
|       |                              |     greater headpath may      |
|       |                              |     perform differently in    |
|       |                              |     terms of its ability to   |
|       |                              |     remain on an occupant's   |
|       |                              |     pelvis during the impact. |
|       |                              |     Additionally, this        |
|       |                              |     evaluation would need to  |
|       |                              |     be considered for its     |
|       |                              |     installation on the       |
|       |                              |     actual seat, not the      |
|       |                              |     rigid seat fixture.       |
|       |                              |                               |
|       |                              | -   A replacement restraint   |
|       |                              |     that produces a shorter   |
|       |                              |     head path and still       |
|       |                              |     allows head contact will  |
|       |                              |     affect other parameters   |
|       |                              |     that are critical in      |
|       |                              |     determining compliance    |
|       |                              |     with § 25.562, such as    |
|       |                              |     ATD head                  |
|       |                              |     velocity/acceleration and |
|       |                              |     HIC.                      |
|       |                              |                               |
|       |                              | This is not intended to be a  |
|       |                              | complete list of issues that  |
|       |                              | would need to be              |
|       |                              | investigated.                 |
+-------+------------------------------+-------------------------------+
| GAMA  | The inclusion of seat        | The intent of this method of  |
|       | cushions in the test setup   | compliance is to demonstrate  |
|       | adds an additional variable  | that a replacement restraint  |
|       | to the testing that does not | system will perform           |
|       | appear to be necessary when  | equivalently to a             |
|       | the test is making a         | certificated restraint system |
|       | side-by-side comparison of   | when it is installed on the   |
|       | the restraint system         | certificated seat. The FAA    |
|       | performance. Elimination of  | studied the effects of        |
|       | as many variables as         | allowing rigid seat fixtures  |
|       | possible will lead to a more | to be used in lieu of actual  |
|       | direct and clear comparison  | seats to produce valid data,  |
|       | method between the           | and as a result, the proposed |
|       | performance to the           | method was established. The   |
|       | replacement and certificated | commenter is proposing that   |
|       | restraint system. Therefore, | an additional variable be     |
|       | industry proposes that the   | introduced to this method,    |
|       | seat cushions be eliminated  | i.e., to also allow testing   |
|       | from the test setup and      | without representative seat   |
|       | require that the ATD's       | cushions. The effects of a    |
|       | seating position during the  | seat bottom cushion on ATD    |
|       | test, in reference to the    | movement and headpath is not  |
|       | SRP, be similar to the       | clearly understood at this    |
|       | production seat.             | time, but could be            |
|       |                              | significant. Data to          |
|       |                              | determine the effects of      |
|       |                              | eliminating cushions from the |
|       |                              | rigid seat should be          |
|       |                              | generated before              |
|       |                              | incorporating the proposed    |
|       |                              | change into the method. As a  |
|       |                              | result, the proposed change   |
|       |                              | will not be incorporated at   |
|       |                              | this time. If the proposed    |
|       |                              | change is found acceptable at |
|       |                              | a later time, this policy     |
|       |                              | memo can be revised then or   |
|       |                              | the proposed change can be    |
|       |                              | approved for use in an issue  |
|       |                              | paper.                        |
+-------+------------------------------+-------------------------------+
| GAMA  | The current draft policy     | The FAA agrees that the total |
|       | requires that for torso      | load reacted by a restraint   |
|       | restraint systems,           | is greater during a test      |
|       | individual segments of the   | using a rigid seat than when  |
|       | belts be statically tested   | using the actual seat.        |
|       | to failure and that the peak | However, the ATD responds     |
|       | loads should be within +/-   | differently when a rigid seat |
|       | 6% or greater than the       | is used in lieu of the actual |
|       | certificated restraint       | seat. This different ATD      |
|       | system. The policy states    | response produces a different |
|       | that the requirement to      | load distribution between the |
|       | statically test each         | individual segments of torso  |
|       | individual segment is based  | restraint systems (e.g.,      |
|       | on FAA's data that the       | pelvic restraint portion,     |
|       | individual segments of a     | upper torso restraint         |
|       | torso restraint system can   | portion.) The FAA has learned |
|       | be subjected to              | from analyzing proprietary    |
|       | significantly lower dynamic  | data that in some cases,      |
|       | load during test using a     | individual segments of a      |
|       | rigid fixture versus a test  | torso restraint system can be |
|       | using a certificated seat.   | subjected to a significantly  |
|       | Without access to FAA's      | lower dynamic load because of |
|       | data, we do not know whether | the difference in load        |
|       | the conclusion was based on  | distribution. Because the     |
|       | rigid tests at a             | rigid seat dynamic test may   |
|       | significantly lower G level  | not load all segments to the  |
|       | than the G level of the      | same or greater level than    |
|       | certificated seat. Contrary  | would occur in the actual     |
|       | to FAA's assertion,          | seat test, the static test to |
|       | industry's experience has    | failure is needed to ensure   |
|       | always showed that when      | compliance with § 25.562.     |
|       | tested at the same G levels, |                               |
|       | the rigid seat restraint     | The FAA does not currently    |
|       | loads are higher than the    | have data for determining a   |
|       | actual seat. The rigid seat  | minimum strength criterion    |
|       | has no energy attenuation    | for a restraint that would    |
|       | capability and therefore,    | ensure that it would not fail |
|       | the restraint has to react   | during § 25.562 testing. If   |
|       | the occupant load            | future research determines a  |
|       | exclusively, resulting in    | valid minimum strength value, |
|       | higher restraint loads.      | this memo could be revised or |
|       | Dynamic testing of the       | an issue paper approved to    |
|       | restraint system, whether it | accept restraints that meet   |
|       | is performed on a rigid or   | that minimum strength in lieu |
|       | actual seat, is more         | of the current static         |
|       | representative and realistic | comparative test criterion.   |
|       | measure of compliance than   |                               |
|       | static tests of individual   |                               |
|       | segments. AS 8043 already    |                               |
|       | has established minimum      |                               |
|       | strength requirements that   |                               |
|       | is typically higher than     |                               |
|       | what is recorded in dynamic  |                               |
|       | tests. Industry recommends   |                               |
|       | that the policy be revised   |                               |
|       | to only require that the     |                               |
|       | proposed restraint system    |                               |
|       | meet TSO C-114 requirements  |                               |
|       | in-lieu of static test, and  |                               |
|       | that the dynamic rigid seat  |                               |
|       | test should be sufficient.   |                               |
+-------+------------------------------+-------------------------------+
| GAMA  | On Page 3 (Additional        | Yes, the policy memo is       |
|       | Acceptance Criteria for      | correct. This alternate       |
|       | Torso Restraint Systems,     | procedure can be used when    |
|       | last para.), the policy      | the applicant has data for    |
|       | states that "As an           | the restraint loads reacted   |
|       | alternative to statically    | by the certificated restraint |
|       | testing...", does the peak   | segments in their             |
|       | load of the proposed         | certification testing. These  |
|       | restraint segment have to be | loads represent the maximum   |
|       | ≥ the certificated segment?  | loads demonstrated to not     |
|       | A tolerance range, as used   | result in a restraint failure |
|       | elsewhere, is appropriate.   | and a noncompliance with      |
|       |                              | § 25.562. Hence, restraint    |
|       |                              | segments that can react those |
|       |                              | loads are strong enough to    |
|       |                              | comply with § 25.562;         |
|       |                              | however, restraint segments   |
|       |                              | of any less strength may not  |
|       |                              | comply with § 25.562.         |
+-------+------------------------------+-------------------------------+
| GAMA  | On Page 5, last paragraph:   | Concur. The memo has been     |
|       | Industry recommends a minor  | revised.                      |
|       | wording change to read as    |                               |
|       | follows for better           |                               |
|       | clarification "Replacing the |                               |
|       | restraint on a TSO-C127 seat |                               |
|       | is considered a minor change |                               |
|       | [to the TSO]{.underline}     |                               |
|       | when made by the original    |                               |
|       | seat TSO approval holder.    |                               |
+-------+------------------------------+-------------------------------+
| GAMA  | Industry recommends that the | The FAA has determined that   |
|       | FAA conduct a thorough       | there are no discrepancy      |
|       | review of draft AC25.562-1B  | between this policy and the   |
|       | to ensure that the proposed  | draft AC.                     |
|       | policy on restraint system   |                               |
|       | replacement is compatible    |                               |
|       | with the draft AC25.562-1B.  |                               |
|       | In the event that there is a |                               |
|       | conflict, we request that    |                               |
|       | the FAA notify the GAMA 16 G |                               |
|       | committee members of the     |                               |
|       | nature of the discrepancy    |                               |
|       | and proposed action prior to |                               |
|       | the final publication of     |                               |
|       | this policy.                 |                               |
+-------+------------------------------+-------------------------------+
| GAMA  | Industry recommends the      | The policy memo explains in   |
|       | final policy include some    | the section "Effect of        |
|       | flexibility in the use of    | Policy" that it identifies    |
|       | sound engineering judgment   | one means, but not the only   |
|       | and rational to determine    | means, of compliance. It also |
|       | the applicability of the     | states that, "whenever an     |
|       | proposed acceptance criteria | applicant's proposed method   |
|       | or test methods. In reality, | of compliance is outside this |
|       | not all certification        | established policy, it must   |
|       | programs are the same and    | be coordinated with the       |
|       | some seat/restraint system   | policy issuing office, for    |
|       | designs or installations may | example, through the issue    |
|       | have different margins of    | paper process or equivalent." |
|       | safety. Industry believes    | This promotes standardization |
|       | that even though the content | that is not obtained from     |
|       | of this proposed policy      | coordination with just one    |
|       | should be relied upon as the | Aircraft Certification        |
|       | core guidance, ultimately,   | Office. Use of the            |
|       | the FAA should allow the     | coordination procedure in the |
|       | applicant to discuss the     | "Effect of Policy" paragraph  |
|       | relevance of each proposed   | does allow some flexibility   |
|       | criteria (acceptance         | while retaining an            |
|       | criteria or test methods)    | appropriate level of          |
|       | with the local FAA ACO       | standardization. The FAA      |
|       | counterpart in the           | considers that the proposed   |
|       | development of a final       | policy should not be revised. |
|       | compliance document.         |                               |
+-------+------------------------------+-------------------------------+
| GAMA  | Industry recommends that     | The proposed policy memo has  |
|       | this draft policy be         | been given to the Small       |
|       | coordinated with the FAA     | Airplane and Rotorcraft       |
|       | Small Airplane and           | Directorates so that they can |
|       | Rotorcraft Directorates for  | assess its applicability to   |
|       | Part 23, 27 and 29           | parts 23, 27 and 29. The      |
|       | applications. We believe     | Small Airplane and Rotorcraft |
|       | that this policy should also | Directorates will issue       |
|       | be applicable for other      | separate policy if it is      |
|       | certification categories.    | determine to be acceptable    |
|       |                              | for demonstrating compliance  |
|       |                              | with parts 23, 27 and/or 29.  |
+-------+------------------------------+-------------------------------+
| GAMA  | As previously stated,        | This method of compliance was |
|       | industry members of the 16G  | developed by working with an  |
|       | Seat Committee could not     | STC applicant. Proprietary    |
|       | perform a thorough review of | data generated by this        |
|       | the draft policy, as the FAA | applicant may only be         |
|       | conducted research used to   | provided based on their       |
|       | develop this method of       | permission. The FAA and       |
|       | compliance has not been made | another applicant jointly     |
|       | accessible. Industry         | generated data from four      |
|       | requests that the FAA make   | rigid seat tests which were   |
|       | public in some fashion the   | considered. The FAA does not  |
|       | research data, analysis,     | typically release this type   |
|       | assumptions, and conclusions | of data without permission    |
|       | used in the formulation of   | from the applicant. SAE       |
|       | this policy.                 | report 1999-01-1609 "A Lumbar |
|       |                              | Spine Modification to the     |
|       |                              | Hybrid III ATD For Aircraft   |
|       |                              | Seat Test" contains data from |
|       |                              | repeated rigid seat tests     |
|       |                              | that were used. The policy    |
|       |                              | memo and the FAA responses to |
|       |                              | public comments in this       |
|       |                              | document explain the basis    |
|       |                              | for accepting the performance |
|       |                              | criteria.                     |
+-------+------------------------------+-------------------------------+
| H.    | On Page3 \"Acceptance        | See the FAA response to the   |
| Fuji  | Criteria\" of draft          | first GAMA comment. It        |
| wara, | Memorandum, there is a       | explains that the purpose of  |
|       | following                    | this method is to demonstrate |
| Sp    |                              | that a replacement restraint  |
| ecial | sentence:                    | is [equivalent]{.underline}   |
| Assi  |                              | to a certificated restraint.  |
| stant | \"The Points of maximum ATD  | It also explains the reasons  |
| to    | head excursion should be     | criteria with a performance   |
| the   | with ±1.0 inch each other\"  | range (+/- 1 inch, etc.) has  |
| Dire  |                              | been found acceptable for     |
| ctor, | However, we think that ±1.0  | determining restraint         |
|       | inch difference influence    | equivalency with this         |
| Air   | Head Injury Criterion (HIC). | comparison method.            |
| worth | In case original data        |                               |
| iness | approved by TSO is near the  | Response to Question 1:       |
| Divi  | limits,                      | Replacement restraints that   |
| sion, |                              | meet the +/- 1 inch           |
|       | it may be possible to exceed | criterion, in addition to the |
| E     | the limits of HIC which is   | other criteria, are           |
| ngine | prescribed in FAR            | considered to be equivalent   |
| ering |                              | to the certificated           |
| D     | 25.562.                      | restraint. As an equivalent   |
| epart |                              | restraint, it is considered   |
| ment, | Question 1: In case the      | to provide the same level of  |
|       | limits of HIC, which is      | HIC protection as the         |
| Civil | prescribed in FAR 25.562,    | certificated restraint. For   |
| Avi   |                              | installation where the        |
| ation | are exceeded, does it pass   | certificated restraint        |
| Bu    | or fail the tests?           | results in compliance with    |
| reau, |                              | the HIC requirement,          |
|       | Question 2: We are not sure  | installation of the           |
| Min   | of the reasons to decide     | equivalent replacement        |
| istry | \"±1.0 inch\". Please tell   | restraint is also compliant   |
| of    | us the reason.               | with the HIC requirement      |
| Land, |                              | without further showing.      |
| Infr  |                              |                               |
| astru |                              | Response to Question 2: The   |
| cture |                              | FAA reviewed SAE report       |
| and   |                              | 1999-01-1609 "A Lumbar Spine  |
| Trans |                              | Modification to the Hybrid    |
| port, |                              | III ATD For Aircraft Seat     |
| Japan |                              | Tests," Table 3 and other     |
|       |                              | data generated with an        |
|       |                              | applicant that showed data    |
|       |                              | scatter of approximately +/-  |
|       |                              | 0.5 inches in a carefully     |
|       |                              | controlled environment. The   |
|       |                              | FAA considered that other     |
|       |                              | seats tested in this same     |
|       |                              | controlled environment, and   |
|       |                              | even more so in a typical     |
|       |                              | certification test            |
|       |                              | environment, could result in  |
|       |                              | larger variances. The +/- 1   |
|       |                              | inch criterion was determined |
|       |                              | to be appropriate because it  |
|       |                              | minimized the range to        |
|       |                              | provide a valid measure of    |
|       |                              | restraint equivalency, but is |
|       |                              | considered broad enough to be |
|       |                              | achievable in actual          |
|       |                              | certification tests.          |
+-------+------------------------------+-------------------------------+