> U.S. Department\
> of Transportation![](media/image1.wmf){width="0.48333333333333334in"
> height="0.4798611111111111in"}

Federal Aviation\
Administration

+----+----------------------------------------+---+-----+---------------+
| Su | [INFORMATION]{.underline}: New Policy  |   | Da  | # Nove        |
| bj | on the Stowage, Retention, and         |   | te: | mber 21, 2002 |
| ec | Breakaway of Deployable Individual     |   |     |               |
| t: | Video Systems (IVS) Installed in       |   |     |               |
|    | Transport Airplane Seats               |   |     |               |
+----+----------------------------------------+---+-----+---------------+
|    |                                        |   |     |               |
+----+----------------------------------------+---+-----+---------------+
| F  | Acting Manager, Transport Airplane     |   | Re  | 02-115-21     |
| ro | Directorate, Aircraft Certification    |   | ply |               |
| m: | Service, ANM-100                       |   | to  |               |
|    |                                        |   | At  |               |
|    |                                        |   | tn. |               |
|    |                                        |   | of: |               |
+----+----------------------------------------+---+-----+---------------+
|    |                                        |   |     |               |
+----+----------------------------------------+---+-----+---------------+
| T  | See Distribution                       |   | R   | § 25.789      |
| o: |                                        |   | egu |               |
|    |                                        |   | lat |               |
|    |                                        |   | ory |               |
|    |                                        |   | R   |               |
|    |                                        |   | efe |               |
|    |                                        |   | ren |               |
|    |                                        |   | ce: |               |
+----+----------------------------------------+---+-----+---------------+
|    |                                        |   |     |               |
+----+----------------------------------------+---+-----+---------------+

This memorandum is issued as a supplement to memorandum 01-115-32, dated
May 30, 2001, which discussed the use of industry standards in the seat
certification process and, in particular, qualification of video systems
mounted on seats. The intent of that memo was to reduce the regulatory
burden on industry by simplifying the certification process for video
abuse load testing of video systems deployed from passenger seats. This
memorandum will serve to further simplify the certification process by
acknowledging the acceptability of test data generated by the seat
suppliers pertaining to the retention of video components. This
acknowledgment is limited to video components installed by the seat
supplier on seats that they manufacture and for which TSO approval, to
TSO C39 (latest change) or TSO C127 (latest change), is obtained.

Additionally, this policy statement provides information and guidance
regarding acceptable means, but not the only means, of showing
compliance with 14 CFR §§ 25.789, 25.785, and 25.813 for certifying
retention, breakaway, and stowage of in-seat video systems (IVS)
components installed on seats. Deployable IVS typically consist of, but
are not limited to, a seat video display, a deployment mechanism, a
video and power cable, and an armrest/console.

> Three subject areas still need clarification for these seat mounted
> video components. They are: retention of seat mounted video
> components, use of a breakaway feature, and stowage. The following
> guidance addresses the method of compliance, test processes and
> pass/fail criteria for these components.
>
> **[RETENTION]{.underline}**
>
> **Regulations**: § 25.789(a) -- "*Means must be provided to prevent
> each item of mass (that is part of the airplane type design) in a
> passenger or crew compartment or galley from becoming a hazard by
> shifting under the appropriate maximum load factors corresponding*
>
> *to the specified flight and ground load conditions, and to the
> emergency landing conditions of § 25.561(b.)*"
>
> **Method of Compliance**: Deployable in-seat video components should
> be designed so that they remain in the stowed position for the load
> conditions applicable to the appropriate
>
> airplane model in which they are installed. When the component stowage
> incorporate a latching mechanism, it should be equipped with a
> distinct visual, audible or tactile indicator which indicates proper
> engagement of the latch to the person stowing the equipment.
>
> **Acceptable Test Procedure (for forward deploying video
> components)**: The IVS components should be stowed in a manner that
> ensures proper engagement of the latching mechanism. Test records
> should document the distinct visual, audible or tactile indication of
> proper latch engagement. The required test load is calculated by
> adding the weight of the components and the deployment mechanism
> (i.e., video display, cable) and then multiplying this combined weight
> by a 9.0 load factor. Using a hand held load indicator or equivalent,
> apply a forward load that is equal to or greater than the calculated
> required test load to the seat components approximately 2 inches from
> the component edge and hold for 3 seconds. The edge to be tested is
> the edge that is farthest from the arm pivot point for a component
> that has a pivot located on the armrest console. This is intended to
> address video components that are stowed in the forward vertical face
> of an armrest and that pivot forward and upward when deployed. For
> other types of forward deploying systems, apply the required forward
> load through the approximate center-of-gravity (CG) of the component
> and the deployment mechanism. Test records should document the applied
> force needed to substantiate the means of retention of the IVS.
>
> **Acceptable Test Procedure (for upward deploying video components):**
> When the IVS installation incorporates a latching mechanism the IVS
> components should be stowed in a manner that ensures proper engagement
> of the latching mechanism. Test records should document the distinct
> visual, audible or tactile indication of proper engagement if
> applicable. When calculating the appropriate upward test load,
> consider the § 25.561(b) loads and the flight, gust, and ground loads
> for the appropriate airplane model. The required load can be
> calculated by adding the weight of the components (i.e., video
> display, cable) and deployment mechanism and then multiplying this
> combined weight by the appropriate load factor. Using a hand held load
> indicator or equivalent, apply the appropriate upward load that is
> equal to or greater than the calculated required test load to the
> component approximately 2 inches from the component edge and hold for
> 3 seconds. The edge to be tested is the edge that is farthest from the
> arm pivot point for the component that has a pivot located on the
> armrest console. For other types of upward deploying systems, apply
> the required forward load through the approximate CG of the component
> and deployment mechanism. When attaching the strap to a monitor, it
> may be necessary to cut a hole in the armrest cap/cover. Test records
> should document the applied force needed to substantiate the means of
> retention of the IVS.
>
> **Pass/Fail Criteria (for upward or forward deploying video
> components)**: The IVS component must remain in the stowed position
> under the 9.0g forward load or the applicable upward load (the greater
> of 3.0g upward load of § 25.561(b)(3)(i) or the vertical inflight load
> of the airplane in which the seat is to be installed), as dictated by
> the system's design.
>
> **[USE OF A BREAKAWAY FEATURE]{.underline}**
>
> **Regulation**: § 25.785(k) - "*Each projecting object that would
> injure persons seated or moving about the airplane in normal flight
> must be padded*."
>
> **Method of Compliance**: Two acceptable methods for minimizing the
> injury potential of IVS components are by incorporating padding and/or
> a breakaway/swivel feature to the component design. When the component
> uses a breakaway/swivel feature to minimize injury potential, the seat
> supplier must provide justification that the breakaway load value
> being used will not present a potential injury hazard in itself. The
> seat component deployment mechanism need not be padded on a surface,
> if it can be shown that when a load is applied to this surface, a
> breakaway/swivel condition would result. A load not exceeding 10
> pounds should be applied to a component surface to initiate a
> breakaway/swivel condition, in order to minimize potential injury.
>
> **Acceptable Test Procedure**: Fully deploy the IVS component. Using a
> hand held load indicator or equivalent; apply a forward load to the
> component approximately 2 inches from the edge to initiate the
> breakaway/swivel feature. The referenced component edge is the edge
> farthest from the pivot point to initiate the breakaway/swivel
> feature. Measure and document the force required to initiate the
> breakaway/swivel feature for the seat video component being tested.
>
> **Pass/Fail Criterion**: The measured force must not exceed 10 lbs.
>
> **[STOWAGE]{.underline}**
>
> **Regulation**: § 25.813 Emergency Exit Access. "*Each required
> emergency exit must be accessible to the passengers and located where
> it will afford an effective means of evacuation."*
>
> **Method of Compliance**: The IVS component, if it deploys for normal
> use, should be capable of being restowed using nominal force.
>
> **Acceptable Test Procedure (for forward deploying video
> components)**: Using a hand held load indicator or equivalent; apply a
> forward (or aft) load to the deployed component approximately 2 inches
> from the edge to cause rotation/swivel to its pre-stowage position.
> Measure and document the force required to rotate/swivel the video
> display. Apply a forward (or aft) load to the arm to rotate it to the
> stowage position. Measure and document the force required to rotate
> the arm. Some designs may require additional rotations and
> translations to complete the stowage of the component. Apply, measure,
> and document the necessary loads in the appropriate directions to
> complete the stowage of the seat video component being tested.
>
> **Acceptable Test Procedure (for upward deploying video components):**
> Using a hand held load indicator or equivalent; apply a load to the
> deployed component approximately 2 inches from the edge to cause
> rotation to its pre-stowage position. Measure and document the force
> required to rotate the component. Apply a load to the arm to rotate or
> push the arm into the stowage position, depending on the design.
> Measure and document the force required to rotate or push the arm.
> Some designs may require additional rotations and translations to
> complete the stowage of the component. Apply, measure, and document
> the necessary loads in the appropriate directions to complete the
> stowage, including latching, of the seat video component being tested.
>
> **Pass/Fail Criterion**: The forces measured independently must not
> exceed 35 lbs. in any direction.
>
> A statement from the seat manufacturer that the IVS components
> installed in the seat remained attached and stowed when subjected to
> the emergency landing loads of § 25.561 and to the specified flight
> and ground load conditions for the specific aircraft into which the
> seats will be installed, should be sufficient. This may be a specific
> statement or encompassed in a more general statement. An example of
> the latter is as follows: The seat installer (e.g., an airplane
> manufacturer) includes the text from § 25.789 in its seat interface
> requirements document (or equivalent) that all seat suppliers must
> meet, and specifically requires that all deployable IVS items remain
> stowed. The purpose of that document is to ensure that the seat will
> meet the requirements of the interface with the airplane. The seat
> supplier, upon delivery of the seats, should provide a statement to
> the installer that all of the requirements of the interface document
> have been met.
>
> On the other hand, if it is the seat installer who actually installs
> the IVS components, such as the video equipment, into the seats
> provided by the seat supplier, then analysis or additional testing
> with additional FAA oversight per FAA Order 8110.4B will be required
> in order to demonstrate FAR part 25 compliance for the modified seats.
>
> Finally, this guidance material covers compliance for cabin safety
> issues only. All other applicable certification regulations still
> apply.
>
> **Effect of Policy**
>
> The general policy stated in this document does not constitute a new
> regulation or create what the courts refer to as a "binding norm." The
> office that implements policy should follow this policy when
> applicable to the specific project. Whenever an applicant's proposed
> method of compliance is outside this established policy, it must be
> coordinated with the policy issuing office, e.g., through the issue
> paper process or equivalent.
>
> Applicants should expect that the certificating officials will
> consider this information when making findings of compliance relevant
> to new certificate actions. Also, as with all advisory material, this
> policy statement identifies one means, but not the only means, of
> compliance.
>
> Any questions may be directed to Alan Sinclair, ANM-115, at (425)
> 227-2195.
>
> /s/
>
> Ali Bahrami

+-------+--------------------------------+----------------------------+
|       | **DISPOSITION OF PUBLIC        |                            |
|       | COMMENTS ON DRAFT POLICY       |                            |
|       | STATEMENT 02-115-21, RETENTION |                            |
|       | OF ITEMS OF MASS INSTALLED IN  |                            |
|       | TRANSPORT AIPRLANE SEATS**     |                            |
+=======+================================+============================+
| **C   | **Comment**                    | **Disposition**            |
| ommen |                                |                            |
| ter** |                                |                            |
+-------+--------------------------------+----------------------------+
| Air   | Page 2, section \"RETENTION\"  | The sentences have been    |
| Tran  | revise as shown: \"When the    | revised.                   |
| sport | component stowage incorporate  |                            |
| A     | a latching mechanism it should |                            |
| ssoci | be equipped with a distinct    |                            |
| ation | visual, audible and/or tactile |                            |
| (ATA) | indicator...\" and \"Test      |                            |
|       | records should document the    |                            |
|       | distinct visual, audible       |                            |
|       | and/or tactile indication...\" |                            |
+-------+--------------------------------+----------------------------+
| ATA   | Page 3, section \"USE OF A     | Do not concur, the         |
|       | BREAKAWAY FEATURE\" Comment:   | breakaway feature and the  |
|       | If IVS is stowed for takeoff   | padding is to protect the  |
|       | and landing there should be no | occupants (passenger and   |
|       | requirement for a breakaway    | crew) while moving about   |
|       | feature or padding. The IVS    | the cabin during normal    |
|       | would be no more of an injury  | flight and during          |
|       | hazard than other stowable     | turbulence.                |
|       | items in the cabin.            |                            |
+-------+--------------------------------+----------------------------+
| Civil | The term \"breakaway/swivel\"  | The definition of          |
| Avi   | should be defined to ensure    | \"breakaway/swivel\" has   |
| ation | that correct interpretation of | been added.                |
| Auth  | \"breakaway\" is understood.   |                            |
| ority |                                |                            |
| of    |                                |                            |
| the   |                                |                            |
| U     |                                |                            |
| nited |                                |                            |
| Ki    |                                |                            |
| ngdom |                                |                            |
| (CAA  |                                |                            |
| UK)   |                                |                            |
+-------+--------------------------------+----------------------------+
| CAA   | Page 2, the section            | The sentence has been      |
| UK    | \"Acceptable Test Procedure    | revise as follows: \"When  |
|       | (for upward deploying video    | the IVS installation       |
|       | components):\" The statement   | incorporates a latching    |
|       | that \" The IVS components     | mechanism the IVS          |
|       | should be stowed in a manner   | components should be       |
|       | that ensures proper engagement | stowed in a manner that    |
|       | of the latching mechanism.\"   | ensures proper engagement  |
|       | Assumes that all IVS           | of the latching            |
|       | components have a latching     | mechanism.\"               |
|       | mechanism.\"                   |                            |
+-------+--------------------------------+----------------------------+
| CAA   | Page 2, section \"RETENTION\"  | The sentence was revise as |
| UK    | It is not clear what is the    | follows: \" When the       |
|       | purpose of the following \"... | component stowage          |
|       | the distinct visual and/or     | incorporate a latching     |
|       | audible indicator of proper    | mechanism it should be     |
|       | latch engagement.\"            | equipped with a distinct   |
|       |                                | visual, audible and/or     |
|       |                                | tactile indicator which    |
|       |                                | indicates proper           |
|       |                                | engagement of the latch to |
|       |                                | the person stowing the     |
|       |                                | equipment.\"               |
+-------+--------------------------------+----------------------------+
| Matsu | In the paragraphs describing   | While we concur with the   |
| shita | \"Acceptable Test Procedures\" | statement this test        |
| Avi   | on retention of items of mass: | condition is consider to   |
| onics | Ref. 25.789(a). The memorandum | represent the worst case   |
| S     | draft states \"Using a hand    | and is intended to account |
| ystem | held load indicator or         | for variations in the      |
| Corp. | equivalent, apply a forward    | system design and to       |
|       | (or upward) load that is equal | provide a standardize test |
| (MAS) | to or greater than the         | criteria.                  |
| via   | calculated required test load  |                            |
| the   | to the seat components         |                            |
| ATA   | approximately 2 inches from    |                            |
|       | the component edge\...\"       |                            |
|       |                                |                            |
|       | Applying the required test     |                            |
|       | load \"approximately 2 inches  |                            |
|       | from the component edge\" is   |                            |
|       | not representative of the      |                            |
|       | actual forces involved. The    |                            |
|       | test load should actually be   |                            |
|       | applied at the center of       |                            |
|       | gravity of the rotational mass |                            |
|       | (i.e., monitor, cable and      |                            |
|       | components of the deployment   |                            |
|       | mechanism that rotate with the |                            |
|       | monitor) when the              |                            |
|       | Monitor/Deployment Arm is in   |                            |
|       | the stowed position.           |                            |
+-------+--------------------------------+----------------------------+
| B     | Page 1, Subject: Change the    | Concur, title was revised  |
| oeing | title of the policy to: "New   |                            |
|       | Policy on Stowage, Retention,  |                            |
|       | and Breakaway of Deployable    |                            |
|       | Individual Video Systems (IVS) |                            |
|       | Installed in Transport         |                            |
|       | Airplane Seats"                |                            |
+-------+--------------------------------+----------------------------+
| B     | Page 1, paragraph 1: Just      | Concur, statement has been |
| oeing | before the last sentence in    | added.                     |
|       | the first paragraph, add the   |                            |
|       | following: "This policy        |                            |
|       | statement provides information |                            |
|       | and guidance regarding         |                            |
|       | acceptable means, but not the  |                            |
|       | only means, of showing         |                            |
|       | compliance with 14 CFR §§      |                            |
|       | 25.789, 25.785, and 25.813 for |                            |
|       | certifying retention,          |                            |
|       | breakaway, and stowage of IVS  |                            |
|       | components installed on        |                            |
|       | seats."                        |                            |
+-------+--------------------------------+----------------------------+
| B     | Page 1, paragraph 1: Change    | The paragraph was revised  |
| oeing | the second to last sentence to | as follows to address this |
|       | read as follow: "This          | concern: \"This memorandum |
|       | memorandum will serve to       | will serve to further      |
|       | further simplify the           | simplify the certification |
|       | certification process          | process by acknowledging   |
|       | pertaining to the stowage,     | the acceptability of test  |
|       | retention, and breakaway of    | data generated by the seat |
|       | deployable video systems on    | suppliers pertaining to    |
|       | seats for suppliers that have  | the retention of video     |
|       | an approved quality control    | components. This           |
|       | system on file with the FAA in | acknowledgment is limited  |
|       | accordance with 14 CFR §21.605 | to video components        |
|       | (a) (3)."                      | installed by the seat      |
|       |                                | supplier on seats that     |
|       |                                | they manufacture and for   |
|       |                                | which TSO approval, to TSO |
|       |                                | C39 (latest change) or TSO |
|       |                                | C127 (latest change), is   |
|       |                                | obtained.\"                |
+-------+--------------------------------+----------------------------+
| B     | Page 1, paragraph 1: Change    | The sentence was revised   |
| oeing | the last to read as follows:   | as follows: \" Deployable  |
|       | "Deployable in-seat video      | in-seat video systems      |
|       | systems (IVS) typically        | (IVS) typically consist    |
|       | consist of a seat video        | of, but are not limited    |
|       | display, a deployment          | to, a seat video display,  |
|       | mechanism, a video and power   | a deployment mechanism, a  |
|       | cable, and an                  | video and power cable, and |
|       | armrest/console."              | an armrest/console.\"      |
+-------+--------------------------------+----------------------------+
| B     | Page 1, paragraph 3: Change    | The paragraph 1 on page    |
| oeing | the text of this paragraph to  | 1was revised to address    |
|       | read as follows: "If the       | this concern.              |
|       | policy stated here is followed |                            |
|       | and the Pass/Fail criteria are |                            |
|       | met, then this type of         |                            |
|       | installation, when done in     |                            |
|       | conjunction with an            |                            |
|       | FAA-approved quality system,   |                            |
|       | could be considered a minor    |                            |
|       | change and can be considered   |                            |
|       | approved as described in       |                            |
|       | §21.95."                       |                            |
+-------+--------------------------------+----------------------------+
| B     | Page 2, first full paragraph   | Do not concur. The         |
| oeing | entitled, "Acceptable Test     | requirement is structured  |
|       | Procedure (for forward         | to take into account       |
|       | deploying video components)":  | various types of           |
|       | Delete the sentence that       | installation.              |
|       | states, "The edge to be tested |                            |
|       | is the edge that is farthest   |                            |
|       | from the arm pivot point for   |                            |
|       | the component that has a pivot |                            |
|       | located on the armrest         |                            |
|       | console."                      |                            |
+-------+--------------------------------+----------------------------+
| B     | Page 2, first full paragraph:  | Do not concur, see         |
| oeing | Change the second sentence     | previous comment.          |
|       | from the end to read as        |                            |
|       | follows: \"Apply the required  |                            |
|       | ... "                          |                            |
+-------+--------------------------------+----------------------------+
| B     | Page 2, first full paragraph:  | The sentence was revised   |
| oeing | Change the last sentence to    | as follows: \"Test records |
|       | read as follows: "Test records | should document the        |
|       | should document the applied    | applied force needed to    |
|       | force that substantiates the   | substantiate the means of  |
|       | latching mechanism on the IVS. | retention of the IVS.\"    |
|       | These test records shall be    |                            |
|       | maintained by the supplier."   | The change on page 4,      |
|       |                                | covers the data retention  |
|       |                                | issue. \""A statement from |
|       |                                | the seat manufacturer that |
|       |                                | the IVS components         |
|       |                                | installed in the seat      |
|       |                                | remained attached and      |
|       |                                | stowed when subjected (1)  |
|       |                                | to the emergency landing   |
|       |                                | loads of §25.561 and (2)   |
|       |                                | to the specified flight    |
|       |                                | and ground load conditions |
|       |                                | for the specific aircraft  |
|       |                                | into which the seats will  |
|       |                                | be installed, should be    |
|       |                                | sufficient."               |
+-------+--------------------------------+----------------------------+
| B     | Page 2, paragraphs 2 and 3     | Revised the first sentence |
| oeing | (concerning acceptable test    | of paragraph 3 as follows: |
|       | procedures for upward          | \"When the IVS             |
|       | deploying video components and | installation incorporates  |
|       | pass/fail criteria): These     | a latching mechanism the   |
|       | paragraphs should be revised   | IVS components should...\" |
|       | to indicate that the new       |                            |
|       | policy statement does NOT      |                            |
|       | address upward deploying video |                            |
|       | systems that do not have a     |                            |
|       | latch (reference FAA letter    |                            |
|       | 98-120S-368, dated August 21,  |                            |
|       | 1998). While this method of    |                            |
|       | compliance requires an         |                            |
|       | installation-level review, if  |                            |
|       | this method is to be used, the |                            |
|       | seat/IVS at the component      |                            |
|       | level needs to be designed to  |                            |
|       | meet the requirement and can   |                            |
|       | be covered in this policy.     |                            |
+-------+--------------------------------+----------------------------+
| B     | Page 3, paragraph 1 (Use of    | Issue paper are by design  |
| oeing | Breakaway Feature - Method of  | project specific. The      |
|       | Compliance): Revise this       | change to Page 1,          |
|       | paragraph to include a third   | paragraph 1: "This policy  |
|       | method of compliance that was  | statement provides         |
|       | approved by Issue Paper CI-20  | information and guidance   |
|       | (reference letter 100S-01-12,  | regarding acceptable       |
|       | dated January 25, 2001).       | means, but not the only    |
|       |                                | means, of showing          |
|       |                                | compliance with 14 CFR §§  |
|       |                                | 25.789, 25.785, and 25.813 |
|       |                                | for certifying retention,  |
|       |                                | breakaway, and stowage of  |
|       |                                | IVS components installed   |
|       |                                | on seats." Should be       |
|       |                                | adequate to address any    |
|       |                                | additional methods of      |
|       |                                | compliance that the        |
|       |                                | applicants may wish to     |
|       |                                | use.                       |
+-------+--------------------------------+----------------------------+
| B     | Page 3, paragraph 6 (Stowage - | Concur sentence has been   |
| oeing | Acceptable Test Procedure):    | revised.                   |
|       | Change the last sentence of    |                            |
|       | this paragraph to read as      |                            |
|       | follows: "... necessary loads  |                            |
|       | in the appropriate directions  |                            |
|       | to complete the stowage,       |                            |
|       | including latching, of the ... |                            |
|       | "                              |                            |
+-------+--------------------------------+----------------------------+
| B     | [Page 4, second full           | The sentence was revised.  |
| oeing | paragraph]{.underline}: Change |                            |
|       | the first sentence to read as  | NOTE: The results should   |
|       | follows: "A statement from the | be documented and be made  |
|       | seat manufacturer that the IVS | available to the FAA upon  |
|       | components installed in the    | request. As always, it is  |
|       | seat remained attached and     | the responsibility of the  |
|       | stowed when subjected (1) to   | installer to ensure that   |
|       | the emergency landing loads of | the installation is in     |
|       | §25.561 and (2) to the         | compliance.                |
|       | specified flight and ground    |                            |
|       | load conditions for the        |                            |
|       | specific aircraft into which   |                            |
|       | the seats will be installed,   |                            |
|       | should be sufficient."         |                            |
+-------+--------------------------------+----------------------------+
| B     | [Page 4, paragraph             | The paragraph 1 on page    |
| oeing | 3]{.underline}: Change the     | 1was revised to address    |
|       | text to read as follows: "By   | this concern.              |
|       | the same token, this policy    |                            |
|       | applies if the seat installer  |                            |
|       | physically installs the IVS    |                            |
|       | components, such as the video  |                            |
|       | equipment, into the seats      |                            |
|       | provided by the seat supplier, |                            |
|       | if the installer has an        |                            |
|       | FAA-approved quality system on |                            |
|       | file."                         |                            |
+-------+--------------------------------+----------------------------+