> U.S. Department\
> of Transportation
>
> **Federal Aviation\
> Administration**
>
> ![](media/image1.png){width="6.305555555555555in"
> height="0.16597222222222222in"}

+----+----------------------------------------+---+-----+----------------+
| Su | # [INFORMATION]{.underline             |   | Da  | November 21,   |
| bj | }: Policy Statement on Corded Electric |   | te: | 2002           |
| ec | al Devices Used in the Passenger Cabin |   |     |                |
| t: |                                        |   |     |                |
+----+----------------------------------------+---+-----+----------------+
|    |                                        |   |     |                |
+----+----------------------------------------+---+-----+----------------+
| F  | Acting Manager, Transport Airplane     |   | Re  | 02-115-20      |
| ro | Directorate, Aircraft Certification    |   | ply |                |
| m: | Service, ANM-100                       |   | to  |                |
|    |                                        |   | At  |                |
|    |                                        |   | tn. |                |
|    |                                        |   | of: |                |
+----+----------------------------------------+---+-----+----------------+
|    |                                        |   |     |                |
+----+----------------------------------------+---+-----+----------------+
| T  | See Distribution                       |   | R   | §§ 25.601,     |
| o: |                                        |   | egu | 25.813(a) and  |
|    |                                        |   | lat | (c), 25.815,   |
|    |                                        |   | ory | AC 25‑17,      |
|    |                                        |   | R   | Policy         |
|    |                                        |   | efe | Memorandums    |
|    |                                        |   | ren | dated Nov. 25, |
|    |                                        |   | ce: | 1994, and      |
|    |                                        |   |     | April 8, 1995  |
+----+----------------------------------------+---+-----+----------------+
|    |                                        |   |     |                |
+----+----------------------------------------+---+-----+----------------+

> The purpose of this memorandum is to consolidate and clarify Federal
> Aviation Administration (FAA) certification policy with respect to
> addressing potential hazards associated with the installation of
> corded electrical devices used in the passenger cabin. Examples of
> corded electrical devices are telephone handsets and video system
> controllers. This guidance supersedes the previously published
> guidance, reference memorandums dated November 25, 1994, and April 8,
> 1995.

## Current Regulatory and Advisory Material

> Section 25.601 requires that the airplane not have design features or
> details that experience has shown to be hazardous or unreliable.
>
> Section 25.813(a) requires an unobstructed passageway leading from the
> main aisle to each Type A, Type B, Type C, Type I or Type II emergency
> exits and between individual passenger areas and, if two or more main
> aisles are provided, unobstructed cross-aisles between main aisles.
>
> Section 25.813(c) requires access from the nearest aisle to each Type
> III or Type IV exit and, for airplanes that have a passenger seating
> configuration of 60 or more, an unobstructed passageway that leads to
> these exits.
>
> Section 25.815 specifies required passenger aisle widths. Advisory
> Circular (AC) 25-17, paragraph 441b(2) states, in pertinent part, "The
> effect of the protuberance on evacuation of the airplane should be
> considered when determining if it may or may not protrude into the
> required aisle width."

The Transport Airplane Directorate (TAD) issued the November 25, 1994,
policy memorandum entitled "Certification of Telephone Units in Seat
Backs or on Partitions Intended for Use by Passengers in the Seat Rows
Immediately Adjacent to the Seats" in response to comments from parties
involved with the production and installation of air telephones in the
backs of seats installed on transport category airplanes. The parties

> expressed concern that different manufacturers were being held to
> different criteria in order to get their systems certificated. In an
> effort to ensure that a "level playing field" existed for all
> applicants, the TAD obtained information from various aircraft
> certification offices and other FAA organizations and issued the
> November 25, 1994, policy memorandum. That policy memorandum
> identified the following criteria to be considered in regard to the
> electrical device's cord:

a\. The cord length should be limited so as not to allow the corded
device to be passed to anyone sitting across the passenger aisle from
the seatback with the unit installed, or to be used by anyone sitting in
the seat row behind the user's seat row. Conduct an evaluation to ensure
that an unstowed cord does not become a hazard which can entrap or snag
limbs or clothing during an emergency evacuation.

> b\. Placards should be installed which state what action is to be
> taken if a cord fails to retract properly, and, as applicable, how to
> activate the retraction mechanism when a cord clutch system is
> installed.
>
> c\. Corded devices should not be installed on or in the surface of any
> seat or partition bordering the passageway to any emergency exit.
>
> The FAA received a significant numbers of responses to portions of the
> guidance provided in the November 25, 1994, memorandum. As a result
> the TAD issued an additional FAA policy memorandum, dated April 8,
> 1995, entitled "Follow-up to November 25, 1994, Memorandum on the
> Certification of Telephone Units." This memorandum provided the option
> of requiring corded devices to be stowed for taxi,
>
> takeoff and landing or, alternatively, of meeting all the criteria of
> the November 25, 1994, memorandum. The April 8, 1995, memorandum
> rescinded certain aspects of the November 25, 1994, memorandum
> provided that the phone system was restricted from use during taxi,
> takeoff and landing.
>
> This guidance was intended to be used only temporarily until new
> guidance could be developed. The issues were referred to a Society of
> Automotive Engineers (SAE) S‑9 Committee which was to develop
> industry-wide standards. The FAA would then consider the industry
> standard for adoption into official guidance. If new guidance was not
> so developed, the FAA would issue new guidance with an implementation
> goal of February 1997. The SAE S‑9 Committee eventually developed a
> draft document containing general recommendations. But the document
> did not provide information that could be translated into a guidance
> document, and was never approved by the Aerospace Council.

In addition to the policy related to cords, policy was also provided on
head strike considerations (applicable to units installed in seat backs
and intended for use by passengers seated in the row aft) and
placarding. Those issues will be addressed later in this memorandum.

> **The New Policy**
>
> The policy contained herein is intended to provide the applicant with
> various certification options, which will require little or no
> on-aircraft evaluation of cord devices, provided that these devices
> meet certain basic criteria. This policy is applicable to typical
> commercial air carrier passenger configurations, i.e., 14 CFR part 121
> and part 135 operations.
>
> The cordreels used for corded device installations must be of
> sufficient quality and design that they reliably retract. The
> reliability of the cord reels should be established by the
> manufacturer, e.g., lifecycle testing, or analysis supported by
> testing. The data or analysis with supporting data should be made
> available upon request. The constant tension cordreel should be tested
> to show that it can be extended and retracted for its service life
> without a degradation in its performance. In addition to the extension
> testing, the ratcheting cordreel should also be tested to show that
> the ratcheting mechanism will perform reliably for its projected
> service life. The same basic philosophy applies to coiled cords as
> well.
>
> The following guidelines apply: (See process flow chart below.)
>
> a\. If the device is not intended for use during taxi, takeoff and
> landing (TT&L), and is restricted accordingly, e.g., by appropriate
> placarding, then no cord length and no cord loop evaluations are
> required.
>
> b\. If the device is intended for use during TT&L, and it has a
> constant tension cord, then no cord length and no cord loop
> evaluations are required.
>
> c\. If the device is intended for use during TT&L, and it does not
> have a constant tension cord and it is not installed on an aisle,
> cross aisle or exit row, then no cord loop and length evaluation is
> required.
>
> d\. If, however, the device is intended for use during TT&L, and does
> not have a constant tension cord, and is installed on an aisle
> armrest, a cross aisle armrest or aisle side seatback or in an exit
> row, then cord loop and length evaluations must be made to ensure that
> the corded device will not interfere with passenger emergency egress.
> These devices may include breakaway capabilities in the cord
> connections, or frangibility in the cord itself, that can act as
> compensating features during the evaluation.

The following cord loop and length evaluations should be made for
devices identified in (d) above:

**Cord Loop Evaluation.** Loops created by mis-stowage of a corded
device should be evaluated to determine if they pose an egress hazard.
It should be shown that, with the handset stowed in its cradle, an
unstowed cord does not become a hazard which can entrap or snag limbs or
clothing during an emergency evacuation. Evaluations should be made with
a 5^th^ percentile female and a 95^th^ percentile male, as follows:

a\. Any cord loop that can be formed by mis-stowing the handset using
reasonable force should be evaluated to determine that the location of
the loop does not pose an egress hazard. Loops formed below the level of
the armrest and contained within the bounds of the seat bottom cushion
should be acceptable.

b\. Any loop that can be formed by mis-stowing the handset using
reasonable force, which extends into an aisle, must be unable to
encircle an appendage (limb or clothing) without significant
manipulation or contrivance.

c\. Any loop that can be formed by mis-stowing the handset using
reasonable force, in a location where a limb may be encircled, must be
easily escapable by normal passenger movement, or the handset must be
able to be pulled free with normal motion and strength.

**Cord Length.** Applicants must demonstrate that their handset
installation cord length will not permit the handset to lie flat on the
floor when the handset is not properly stowed. Also, on seat back
mounted handsets, the cord length must be restricted so that the device
cannot be used by anyone seated across the aisle or by anyone seated in
a row behind the row directly facing the unit. Note: This does not
preclude the passing of the handset forward to the row on which the
handset is mounted.

**Passenger Injuries and Head Strike Considerations.** Regardless of
handset usage for TT&L or the cord retraction mechanism type, all
installations within the passenger head strike arc must exhibit
acceptable head strike characteristic, i.e., § 25.562(a) and §
25.785(d)(2), Amendment 25‑72, or § 25.785(c)(2), Amendment 25-71. If
they fail to meet acceptable norms, they must be redesigned as
appropriate.

The telephone handset installation should not contain any pointed
corners or sharp edges that can be touched or struck within the
passenger head strike arc. Additionally, it is important to ensure that
a seat back with a telephone complies with § 25.785(b), i.e., a
passenger\'s head striking the telephone under the minor crash
conditions appropriate for the type certification basis of the airplane
in which the telephone is installed will not suffer a serious injury.

For handset installations in airplanes which do not have § 25.562,
Amendment 25-64, in their type certification basis, it would be
sufficient to show that the telephone installation does not make it more
hazardous to strike the seat back. This can be shown by using the
bowling ball test described in AC 25-17, Transport Airplane Cabin
Interiors Crashworthiness Handbook, for doing [comparison
tests]{.underline} of the seat back with and without the telephone
installed. As noted in a memorandum from ANM-100, dated July 13, 1994,
testing done at the Civil Aeromedical Institute (CAMI) indicates that
the bowling ball test should [not]{.underline} be used as an absolute
pass-or-fail test for passenger head strike. In the case of the plain
seat back, the ball should be dropped on a typical hard surface within
the head strike area, such as the top of the food tray. If the telephone
installation rebound energy and deceleration are essentially equal to or
lower than the plain seat back, the installation would be acceptable.
The weight of the ball used in these comparison tests should be
approximately 13 pounds, as noted in the previously referenced (July
1994) memorandum.

An alternative approach to the bowling ball test is to show that the
telephone handset is located outside the head strike arc of the
passenger. When this approach is used between seat rows, it is usually
based on the forward seat back breaking over, so that the passenger\'s
head misses the telephone. In this case, consideration must be given to
the breakover features. Many new seat designs intended to pass the new
dynamic seat test requirements (but not necessarily found to be in
compliance with §25.562(c)(5)) have restricted or locked-out seat back
breakover. Additionally, seat backs on seats bordering the passageway to
an exit may also have limited or no breakover. This limitation may
impact the ability of the seat back to move out of the way of the
passenger. If the telephone handset is mounted on a partition, the
telephone should be shown to be entirely outside the 35-inch passenger
head strike arc discussed in paragraph 81b(3) of AC 25-17.

For installations in airplanes which have § 25.562, Amendment 25-64, in
their type certification basis, the required level of performance is the
measurement of the head injury criterion (HIC) described in
§ 25.562(c)(5). The HIC would also be an acceptable alternative to the
comparative bowling ball test for the installations discussed in the
previous paragraph. To show that the telephone handset installation is
outside the head strike arc of the passenger, the arc generated by the
dummy used in the HIC test, extrapolated to a 95th percentile male, is
satisfactory.

Irrespective of the type certification basis of the airplane, the tests
noted above must take into account whether or not the telephone handsets
are allowed to be used during takeoff and landing. If the telephone
system is intended to be used during those phases of flight, the tests
must be conducted with the handset removed from the holder, [in addition
to]{.underline} tests with the handset installed. If satisfactory
results cannot be achieved with the handset removed, the system should
not be allowed to be operated during takeoff and landing.

**Associated Placards:** If placards are installed which state when a
handset may (or may not) be used, at least one placard should be in
plain sight of the occupant of any position from which the handset is
likely to be used, whether or not the handset is stowed. These, and any
other safety related placards, should be of sufficient size and color
contrast (lettering to background) so as to be easily visible to all
expected users under normal cabin lighting conditions. Visibility during
low light level conditions, which are often encountered during night
flights, is desirable, but not mandatory.

Finally, this guidance material covers compliance for cabin safety
issues only. All other applicable certification regulations still apply.

**CORDED DEVICES**

##   {#section .unnumbered}

## 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 02-115-20, CORDED    |                            |
|       | ELECTRICAL DEVICES**           |                            |
+=======+================================+============================+
| **C   | **Comment**                    | **Disposition**            |
| ommen |                                |                            |
| ter** |                                |                            |
+-------+--------------------------------+----------------------------+
| Ge    | [Passenger Injuries and Head   | This Policy Memo           |
| neral | Strike                         | establishes an acceptable  |
| Avi   | Consideration]{.underline}     | means of compliance, but   |
| ation |                                | not the only means.        |
| Man   | Per the ARAC agreements        |                            |
| ufact | regarding installations in     |                            |
| urers | airplanes which do not have    |                            |
| A     | Amendment 25-64 in their type  |                            |
| ssoci | certification basis, it was    |                            |
| ation | decided that seatback mounted  |                            |
| (     | items weighing less than 3     |                            |
| GAMA) | pounds would not require       |                            |
|       | additional assessment for      |                            |
|       | blunt trauma. As mentioned in  |                            |
|       | the memo, they would have to   |                            |
|       | be properly designed to ensure |                            |
|       | that no sharp edges or corners |                            |
|       | are exposed to the occupant    |                            |
|       | seated behind the seat back.   |                            |
|       | This option should be added to |                            |
|       | the Policy Statement.          |                            |
+-------+--------------------------------+----------------------------+
| C     | It is Cessna\'s belief that    | The statement has been     |
| essna | the Policy Statement No.       | added \"... is applicable  |
| Air   | ANM-02-115-02, Corded          | to typical commercial air  |
| craft | Electrical Devices, should     | carrier passenger          |
| Co    | only be applicable to Part 25  | configurations, i.e., 14   |
| mpany | certificated aircraft with a   | CFR part 121 and part 135  |
|       | passenger capacity more than   | operations.\"              |
|       | 19.                            |                            |
+-------+--------------------------------+----------------------------+
| Matsu | In the section titled \"New    | The sentence has been      |
| shita | Policy,\" the 2^nd^ sentence   | revised as follows: \" The |
| Avi   | of the 2^nd^ paragraph should  | reliability of the cord    |
| onics | read. \"The reliability of the | reels should be            |
| S     | cord reels should be           | established by the         |
| ystem | established by the             | manufacture, e.g.,         |
| Corp. | manufacturer, and the data     | lifecycle testing, or      |
|       | made available on request.\"   | analysis supported by      |
| (MAS) |                                | testing. The data or       |
|       |                                | analysis with supporting   |
|       |                                | data should be made        |
|       |                                | available upon request.\"  |
+-------+--------------------------------+----------------------------+
| MAS   | In the section titled \"New    | The paragraph has been     |
|       | Policy,\" in both paragraphs   | revised.                   |
|       | (a) and (b) should read in     |                            |
|       | part. \"...then no cord length |                            |
|       | and no cord loop evaluations   |                            |
|       | are required.\"                |                            |
+-------+--------------------------------+----------------------------+
| MAS   | In the section titled \"New    | Do not concur, the AFM is  |
|       | Policy,\" in paragraph (a)     | not intend to be used for  |
|       | should read in part. \"If the  | this type of cabin         |
|       | devise is not intended for use | amenity, per AC 25.1581-1. |
|       | during \[TT&L\], and is        | A placard is the           |
|       | placarded against such use or  | appropriate method of      |
|       | is appropriately restricted in | restricting the use of the |
|       | the AFM(S),...\"               | device.                    |
+-------+--------------------------------+----------------------------+
| MAS   | In the section titled \"New    | The paragraph has been     |
|       | Policy,\" in paragraph (c)     | revised.                   |
|       | should read in part. \"...and  |                            |
|       | it is not installed on an      |                            |
|       | aisle, cross aisle, or exit    |                            |
|       | row...\"                       |                            |
+-------+--------------------------------+----------------------------+
| MAS   | In the section titled \"New    | The paragraph has been     |
|       | Policy,\" in paragraph (d)     | revised.                   |
|       | should read in part. \"...and  |                            |
|       | is installed on an aisle       |                            |
|       | armrest, cross aisle armrest,  |                            |
|       | aisle side seatback or in an   |                            |
|       | exit row,...\"                 |                            |
+-------+--------------------------------+----------------------------+
| MAS   | In the section titled \"Cord   | The sentence has been      |
|       | Length,\" the last sentence    | revised.                   |
|       | should read. \"Also, on seat   |                            |
|       | back mounted handsets, the     |                            |
|       | cord length must be restricted |                            |
|       | so that the device cannot be   |                            |
|       | used by anyone seated across   |                            |
|       | the aisle or by anyone seated  |                            |
|       | in a row behind that           |                            |
|       | immediately facing the unit.   |                            |
|       | Note: This does not preclude   |                            |
|       | the passing of the handset     |                            |
|       | forward to the row on which    |                            |
|       | the handset is mounted.\"      |                            |
+-------+--------------------------------+----------------------------+
| MAS   | In the section titled          | The sentence has been      |
|       | \"Passenger Injuries and Head  | revised as follows: \"...  |
|       | Strike Considerations\" the    | i.e., § 25.562(a) and §    |
|       | first sentence should read in  | 25.785(d)(2), Amendment    |
|       | part. \"... head strike        | 25‑72, or § 25.785(c)(2),  |
|       | characteristic, i.e., §        | Amendment 25-71.           |
|       | 25.562(a) and § 25.785(d)(2)   |                            |
|       | Amendment 25‑72 or §           |                            |
|       | 25.785(c)(2) for aircraft      |                            |
|       | prior to Amendment 25-72.      |                            |
+-------+--------------------------------+----------------------------+
| MAS   | In the section titled          | Both paragraphs have been  |
|       | \"Passenger Injuries and Head  | revised as such; \" have   |
|       | Strike Considerations\" the    | § 25.562, Amendment 25-64, |
|       | first sentence of both         | in their type              |
|       | paragraphs 3 and 5 should read | certification basis        |
|       | in part. \"... have FAR 25.562 |                            |
|       | Amendment 25-64 in their type  |                            |
|       | certification basis...\"       |                            |
+-------+--------------------------------+----------------------------+
| MAS   | In the section titled          | The sentence has been      |
|       | \"Associated Placards\" delete | deleted.                   |
|       | the first sentence.            |                            |
+-------+--------------------------------+----------------------------+
| MAS   | In the section titled          | Do not concur, the AFM is  |
|       | \"Associated Placards\" the    | not intend to be used for  |
|       | third sentence should read.    | this type of cabin         |
|       | \"If in lieu of the            | amenity, per AC 25.1581-1. |
|       | appropriate restrictions in    | A placard is the           |
|       | the AFM(S) to non-use during,  | appropriate method of      |
|       | TT&L, placards are installed   | restricting the use of the |
|       | which state when handset may   | device. The sentence has   |
|       | (or may not) be used, at least | been revised as follows.   |
|       | one placard should be in plain | \"If placards are          |
|       | sight of the occupant of any   | installed which state when |
|       | position from which the        | handset may (or may not)   |
|       | handset is likely to be used,  | be used, at least one      |
|       | whether or not the handset is  | placard should be in plain |
|       | stowed .                       | sight of the occupant of   |
|       |                                | any position from which    |
|       |                                | the handset is likely to   |
|       |                                | be used, whether or not    |
|       |                                | the handset is stowed.\"   |
+-------+--------------------------------+----------------------------+
| B     | Page 1, first paragraph: Add   | The letter was issued by   |
| oeing | the following. \"This guidance | the Seattle Aircraft       |
|       | also supersedes the previously | Certification Office to    |
|       | published letter dated May 21, | Boeing and is not TAD      |
|       | 1999.\"                        | policy and will not be     |
|       |                                | addressed .                |
+-------+--------------------------------+----------------------------+
| B     | Page 3 paragraph 2: Delete the | The FAA does not agree     |
| oeing | second sentence, which states  | with deleting the          |
|       | \" The reliability of the cord | sentence, however, it has  |
|       | reels should be shown by       | been rewritten as follows: |
|       | lifecycle testing.             | The reliability of the     |
|       |                                | cord reels should be       |
|       |                                | established by the         |
|       |                                | manufacturer, e.g.,        |
|       |                                | lifestyle testing, or      |
|       |                                | analysis supported by      |
|       |                                | testing. The data or       |
|       |                                | analysis with supporting   |
|       |                                | data should be made        |
|       |                                | available upon request.    |
+-------+--------------------------------+----------------------------+
| B     | Page 3 paragraph 3 in both     | The paragraph has been     |
| oeing | Items a. and b. should read in | revised. . \"...then no    |
|       | part. \"...then no cord loop   | cord length and no cord    |
|       | and length evaluation is       | loop evaluations are       |
|       | required.\"                    | required.\"                |
+-------+--------------------------------+----------------------------+
| B     | Page 3 paragraph 3 in Items a  | The sentence has been      |
| oeing | should read in part \"...and   | revised as follows:        |
|       | is restricted                  | \"...is restricted         |
|       | appropriately...\"             | according, e.g., by        |
|       |                                | appropriate                |
|       |                                | placarding...\"            |
+-------+--------------------------------+----------------------------+
| B     | Page 4, paragraph 3, Item c.   | The sentence has been      |
| oeing | should read in part \"...      | revised.                   |
|       | tension cord and it is not     |                            |
|       | installed on an aisle, cross   |                            |
|       | aisle or exit row...\"         |                            |
+-------+--------------------------------+----------------------------+
| B     | Page 3, paragraph 3 Item d.    | The sentence has been      |
| oeing | should read in part \"If,      | revised.                   |
|       | however, the device is         |                            |
|       | intended for use during TT&L,  |                            |
|       | and does not have a constant   |                            |
|       | tension cord, and is installed |                            |
|       | on an aisle armrest, a cross   |                            |
|       | aisle armrest or aisle side    |                            |
|       | seatback...\"                  |                            |
+-------+--------------------------------+----------------------------+
| B     | Page 4, paragraph 2 and the    | The sentence has been      |
| oeing | last paragraph, in section     | revised as follows: \"     |
|       | \"Passenger Injuries and Head  | ...have § 25.562,          |
|       | Strike Considerations\" the    | Amendment 25-64, in their  |
|       | first sentence should read in  | type certification         |
|       | part. \"...have 14 CFR §       | basis...\"                 |
|       | 25.562 Amendment 25-64 in      |                            |
|       | their type certification       |                            |
|       | basis...\"                     |                            |
+-------+--------------------------------+----------------------------+
| B     | Page 5, paragraph 2,           | Do not concur, the AFM is  |
| oeing | \"Associated Placards\" Delete | not intend to be used for  |
|       | the entire paragraph           | this type of cabin         |
|       |                                | amenity, per AC 25.1581-1. |
|       |                                | Placards are the           |
|       |                                | appropriate method of      |
|       |                                | restricting the use of the |
|       |                                | device.                    |
+-------+--------------------------------+----------------------------+
| B     | Page 6, \"Corded Devices\"     | It is the intend of this   |
| oeing | flow chart: Add the following  | Policy to evaluate all new |
|       | information to the flow chart: | configurations being       |
|       | If a modification (in          | installed either by STC or |
|       | production or post-production) | under a production         |
|       | to an existing certified       | certificate.               |
|       | interior configuration that    |                            |
|       | includes corded devices is     |                            |
|       | being done, and all of the     |                            |
|       | following condition exist,     |                            |
|       | then the cord devices do not   |                            |
|       | need to be evaluated to the    |                            |
|       | criteria in the policy memo,   |                            |
|       | unless the design is as        |                            |
|       | defined in Item d on page 3:   |                            |
|       |                                |                            |
|       | There is no change to the seat |                            |
|       | part number; and               |                            |
|       |                                |                            |
|       | There is no change to the IFE  |                            |
|       | or telephone handset; and      |                            |
|       |                                |                            |
|       | There is no change to the      |                            |
|       | cord, cord reel equipment, or  |                            |
|       | cradle: and                    |                            |
|       |                                |                            |
|       | There is no change to the      |                            |
|       | installation of the handset /  |                            |
|       | cord reel / or cradle in the   |                            |
|       | seat.                          |                            |
+-------+--------------------------------+----------------------------+
| B     | Page 6, \"Corded Devices\"     | The statement has been     |
| oeing | flow chart: Change the phrase  | revised.                   |
|       | in the diamond block that      |                            |
|       | states \" Located in an Exit   |                            |
|       | Row or Aisle\*\" to state the  |                            |
|       | following \" Located in an     |                            |
|       | Exit Row or Aisle\* or Cross   |                            |
|       | Aisle\"                        |                            |
+-------+--------------------------------+----------------------------+