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RECORD OF EX PARTE CONTACT 

AD DOCKET NUMBER: 2010-NM-156-AD 

FAA EMPLOYEE CONTACTED: 

Mr. Jeff Gardlin, Aerospace Engineer (Cabin Safety), FAA Transport Airplane Directorate, ANM-100 

Mr. Larry Armia, Supervisory Civil Aviation Specialist, FAA Representative, Tokyo, Japan, APC-TYO 

Ms. Dianna Lee, Civil Aviation Specialist, FAA Asia-Pacific Area Office, Singapore, APC-001 

DATE AND TIME OF CONTACT: 21 October 2010, 0830 - 1700 

TYPE OF CONTACT: Briefing, Regent Hotel, Singapore. 

NAMES OF ALL PERSONS INVOLVED IN CONTACT, INCLUDING TITLES AND AFFILIATION: 

See Attached list at end of this record 

TOPIC(S) DISCUSSED (Be specific): 

Presenters: 

Mr. Jeff Gardlin, Aerospace Engineer (Cabin Safety), FAA Transport Airplane Directorate, ANM-100 

Mr. Peter Chittenden, Cabin Safety Engineer, European Aviation Safety Authority (EASA) 

Mr. Steven Higgins, EASA 

Summary: Mr. Jeff Gardlin chaired the information-sharing session relating to the non-compliance issues 

associated with aircraft seats manufactured by Koito Industries Co. Ltd. of Japan. A similar meeting was held at 

the European Aviation Safety Authority (EASA) Headquarters in Cologne the prior week, and this meeting 

provided an opportunity for authorities and air carriers in the Asia-Pacific region to come together to discuss the 

next steps in coping with the safety and non-compliance issues. Both FAA and EASA have published a 

proposed Airworthiness Directive (AD) to address Koito seats and the unsafe condition affecting the operators. 

Over 100 representatives from various Asia-Pacific air carriers, airworthiness authorities, modifiers, and others 

(see attached list) participated in the meeting. In addition, Koito President and CEO Takashi Kakegawa 

expressed his apologies and regrets to the audience during the meeting. 

FAA/EASA Presentation: Same presentation that was presented in Koln, Germany was presented at this 

briefing. Towards the end of 2009, FAA and EASA became increasingly aware of allegations that the Koito seat 

company had been falsifying certification test results, and had not controlled production conformity for an 

appreciable period. TC holders (Airbus, Boeing) and JCAB progressively added confirmation to these 

allegations in the first Quarter of 2010. It became clear that unsafe conditions existed, and thus mandatory 

action was needed. FAA and EASA coordinated thoughts and close agreement resulted on an Airworthiness 

Directive framework. The level of safety performance concerned is in three basic areas: structural integrity, 

flammability, and injury. These proposed criteria include: 

Structure – Seats must meet most basic structural requirements at their certification basis, either 6G, 9G, or 16G. 

16G for current models. 

Flammability – Most seat parts have to meet the Bunsen burner test. Seat cushions have to meet a much more 

stringent oil burner test. A three year retrofit for cushion requirements is proposed as the only remedial 

flammability criteria. 

Injury – Evolved from qualitative to add quantitative requirements. Not all injury criteria addressed in the FAA 

proposal and have not been retrofit. Therefore, minimum level of safety is determined based on historical 
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criteria prohibiting sharp edges. 

Non-compliance could affect seat performance in turbulence. 

Proposed AD: FAA and EASA addressed a proposed AD with four phases spanning a 2 to 6 year time period: 

1. Determine basic static strength and injury. 

2. Show seat cushion flammability. 

3. Show “dynamic seats” meet 16G requirements. 

4. EASA Proposed AD (PAD) only requirements (longer final phase-out timescale for seats that meet 

above AD minimum conditions but don’t meet full certification requirements). 

The proposed AD would require determining if affected seats and seating systems and their components are 

compliant with certain FAA and EASA regulations to establish a minimum level of safety, and removing those 

seats and seating systems in the affected fleet that are shown to be unsafe. If they are modified, rather than 

removed, modifications must meet Part 21 requirements. Modifications that leave non-compliance cannot be 

approved. The only exception is the replacement of seat cushions. Removal and replacement of wear-out parts 

such as foodtrays and armrest covers are not considered modifications. Proposed ADs anticipate compliance 

data equivalent to certification data. 

EASA and FAA have direct responsibility for only a limited portion of the affected fleet (European and U.S. air 

carriers). Data to show compliance for other countries are the responsibility of the foreign authorities. 

This meeting does not substitute for the formal comment process against FAA Notice of Proposed Rule-Making 

(NPRM) and EASA Proposed AD (PAD). Participants are encouraged to provide comments online. 

JCAB Presentation: The JCAB representatives reported that the noncompliance issues affect 1,000 aircraft 

that are in operation worldwide and equipped with approximately 150,000 Koito seats. Most seats have an FAA 

TSO Design Approval based on JCAB Specification Approval. JCAB listed several wrongdoings by Koito as 

addressed by the whistleblower. JCAB reported on its ongoing investigations of Koito including review of 

drawings for the production, conformity, and design analyses. Based on the results of the investigation, JCAB 

instructed Koito to conduct tests that confirm compliance status of in-service seat models. Dynamic, static, and 

conformity tests of the seats and seat cushions have been conducted by Koito and witnessed by the JCAB. 

JCAB believes that all data obtained from Phase 1 and 2 tests could be used for in-service seat models to show 

compliance with ADs proposed by FAA and EASA. Use of those test data will alleviate burden on operators in 

compliance finding and taking necessary corrective actions, if any. JCAB urged FAA and EASA to accept their 

test results and apply them to in-service seats. JCAB also asked cooperation from Boeing and Airbus in 

utilizing Koito data to show compliance with the proposed ADs. 

JCAB has no plans to issue its own version of AD now. In the future, the JCAB AD (called TCD) will be issued 

and be based on the FAA and European AD. (Note: JCAB mentioned that they have issued an AD to Japan 

Airlines (JAL) on flammability. This came as a surprise to the audience. However, this AD is not related to the 

Koito issue.) 

Comments from Mr. Takashi Kakegawa, President and CEO, Koito Industries: Mr. Kakegawa expressed 

his deepest apologies and regrets to the meeting participants for the confusion caused by his staff of his 

company on this particular issue. As far as the aerospace sector is concerned, Koito has been in contact with the 

JCAB, Boeing, and Airbus, and conducting validation tests to ensure safety of seats in service. Koito has been 

working diligently to resolve this issue. Koito will continue to work with all parties concerned and ensure the 

safety of its products. He asked the audience for continued support, cooperation, and understanding in this 
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regard. 

Some Questions and/or Comments:

1. Various Operators: Two year plan and proposed timeline for airlines to meet AD requirements are 

unrealistic. 

2. Taiwan CAA: FAA and EASA should accept JCAB’s latest conformity test results. 

3. Continental (COL): Can FAA and EASA review JCAB’s Phase 1 and 2 test data now? 

Ans. Yes, JCAB is translating the data into English now. It will be available in one month. 

4. EVA Airways (Taiwan): Limited information coming from JCAB, FAA, and EASA. Should 

communicate more among themselves, before rushing to issue an AD. 

5. Operators: We are not questioning the AD. We would like to ask for an extension regarding the twoyear compliance. 

6. AAPA Rep. – Issuing an AD does not help this certification issue. The ball should be in the court of the 

regulators, without burdening the operators. 

7. Japan Airlines (JAL) Rep. – Concerned that operators may rush to Boeing and Airbus, seek validation 

through tests, and attempt to resolve the issue. 

Ans. By Boeing: Boeing is looking to narrow down the “family” of seats (i.e. Generation 1, 2, or 3 

seats). By serial numbers, Boeing can determine what dynamic tests were run at that particular time. 

Economy seats can be validated; however, for first class seats, it will be the operators’ responsibility. 

JAL Rep. – Can Boeing assign a POC on this issue? 

Ans. By Boeing: Boeing has not assigned anyone yet. Boeing will select the highest number of seats 

of a “family” that are affected in economy class (e.g. outer, inner, center, forward, or rear seats) and 

conduct 16G tests for compliance. 

8. Operator: How can Boeing conduct seat tests when airlines don’t have any spare seats? Will the 

aircraft have an empty “hole” in the cabin? 

Ans. : Possibilities are to install a non-Koito seat, or to re-pitch the seats. 

9. Boeing Rep. Can airlines go from one seasonal configuration to another (summer/winter) after the AD 

is released? 

Ans. FAA/EASA: Existing approved configurations are still approved. Once and AD is promulgated, 

that may affect reconfigurations. 

10. Operator: Can’t you just accept the JCAB drawings and validate? This removal of seats is going to 

kill us. 

Ans. FAA/EASA: There is a statement in the NPRM for alternative methods of compliance. Please 

review this language. 

11. Thai Air: Will Koito replacement or spare parts be considered a modification? 

Ans. FAA/EASA: Replacement parts must meet requirements specific to them, but for the FAA, the 

proposed AD does not consider a one for one replacement a modification. 
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12. Singapore Airlines: Let’s look at JCAB’s presentation. There seems to be no problem for the metallic 

parts produced by Koito. Second, there seems to be no problem by latest data provided and verified by 

the JCAB. We can apply them to the in-service seats. So, what is the issue? Can’t FAA and EASA 

work with JCAB and come up with something that will work for the airlines? We should not be 

retesting and revalidating, as well as removing seats from the aircraft. I urge the authorities to work 

together as we think the JCAB report is very significant. 

13. AAPA Rep: This region is very conscientious and follows the AD. There should be more work done by 

the regulators before issuance of an AD, especially after listening to the JCAB’s presentation. 

14. Taiwan CAA: Boeing and JCAB have witnessed each validation test. They should share the data and 

present them to us so that we can come up with our own determination. 

15. JAL Rep.: Why do we need to remove the seat cushion for testing and compliance? Used seat cushion 

adheres to its original design. 

Ans. FAA/EASA: Seat cushion is part of the seat and must meet original type design. Select a sample 

that is representative of the seats in the cabin. 

16. EVA Rep: Ask JCAB and Koito to supply spare parts readily. Urge FAA and JCAB to talk some more 

before the issuance of an AD. We do not believe there are direct safety or risk concerns with the current 

seats. It is unusual for an airline to receive an AD without first receiving a Service Bulletin from Boeing 

or Airbus. 

Ans. FAA/EASA: This is an unusual situation. Please ask your question as a formal comment. 

17. AAPA Rep: The Koito seats that are in-service are viable products. We have not had a safety incident 

during turbulence involving a Koito seat. We must look forward to how we can efficiently install spare 

parts to existing seats to overcome the problem. 

Statistics – Approximate Number of Seats Affected:

Continental Airlines: 40,000 seats. 

All Nippon Airways: 24,000 seats. 

Japan Airlines: 9,000 seats. 

EVA Airways: 5,000 seats. 

China Airlines: 3,000 seats. 

Singapore Airlines: 1,600 seats. 

Breakup Session: In the afternoon, the operators and airframe manufacturers met separately for an hour to 

gather their thoughts and reported out. They emphasized that the 2-year time period is impractical, that three to 

five years may be more appropriate. They believed the issuance of the AD should be re-examined, pending 

JCAB’s latest data. They asked JCAB for more flexibility in obtaining design data from Koito on the spare 

parts and sharing them with other manufacturers so that they can meet compliance requirements. They believe 

Koito is unable to conduct conformity testing for all operators within a short span of time. The lack of a “level 

playing field” makes it difficult for operators to meet the requirements of EASA, FAA, and their own foreign 

authority. 

Conclusion: A healthy exchange of opinions and comments took place between the authorities and the 

operators. The proposed timeline offered by FAA and EASA to replace the seats with new seats or spare parts 

seems unrealistic to the operators, given the economic impact and workload involved. However, FAA and 

EASA have determined that unsafe conditions currently exist. It is not known whether FAA and EASA will 

agree to accept JCAB’s proposal to apply new test data to in-service seat models. All participants believe that 
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this situation is unique, and they are anxious to learn the next steps in the proposed AD process, especially if 

and when the AD is issued. 

COMMITMENTS MADE BY FAA/DOT PERSONNEL: 

FAA will consider comments made through the NPRM process as identified on the Federal Register web site for 

the NPRM and via the NPRM guidance for submittal of comments. 

Were any documents discussed? ( X ) YES (attach copies or reference) ( ) No 

Included Attachments: 

101021 JCAB Presentation.pdf 

PREPARED BY: Patrick T. Farina DATE: 06 November 2010
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Oct. 21, 2010 Koito Meeting (Singapore) Attendees List: 

Name Company/Agency 

Tadaki Sasaki Koito - Director 

Noriyuki Ono Koito - Executive Managing Director 

Tsuneo Yamaguchi Koito - Senior Executive Managing Director 

Takashi Kakegawa Koito- President 

Michael Dunican Boeing- Fleet Support Engineering 

Terry Wagstaff Boeing- Seats Engineering 

Ben Oani The Boeing Company - Field Service 

Hong Wee Jett8 Airlines 

Lynn Yao Jett8 Airlines 

Kok Wee Yong Jett8 Airlines 

John Tubbesing The Boeing Company- Engineering 

Hsien-Lun Chou EVA AIR 

Basak Oz Turkish Airlines Technic Inc. 

Koichi Yabuki ANA 

Saskia Freriksen KLM 

Maurice Laarakker KLM 

Jan van de Maat KLM 

Satoshi Okuyama Japan Airlines International Co., Ltd. 

Yuthasit Suwamloy Thai Airways International 

Hiroshi Ogawa All Nippon Airways 

Susumu Sato All Nippon Airways (ANA) 

Andrew Thie V australia 

Patrick Schirmer The Boeing Company -Fleet Support 

Brian Porter V australia 

Kenji Ohashi ALL NIPPON AIRWAYS 

Chiratthitikorn Maleekaew Thai Airways International PCL 

Yew Kwang Tan Singapore Airlines 

Abel Li Singapore Airlines 

Frank Bindels The Boeing Company 

Brian Wood Continental Airlines 

Jeff Gardlin FAA 

Larry Arima FAA - Tokyo 

Diana Lee FAA – Singapore 

Steven Higgins EASA 

Jean-Philippe Tarres Airbus 

Suwedh Sundarakul Thai Airways International PCL 

Hans-Jürgen Lohmann Airbus Operations GmbH 

Martin Eran-Tasker Association of Asia Pacific Airlines 

Surakit Rattanachan Thai Airways International PCL 

Hiroshi Ueda Nippon Cargo Airlines 

Nonito Cedro Qatar Civil Aviation Authority 

Samsudin Ab. Majid Dept Of Civil Aviation Malaysia 

Yiu Wah Kam Singapore Airlines 

Du-Sheng Yao CHINA AIRLINES 

Jiann-Shin Tseng CHINA AIRLINES 

Noboru Yanagisawa Nippon Cargo Airlines 

Huey-Ling Mau CHINA AIRLINES 

Peter Chittenden EASA 

Yoshihiro Fujimaki Japan Civil Aviation Bureau 
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Takayuki Sakai Japan Civil Aviation Bureau 

Ching-Far Yeh EVA AIRWAYS 

Tzuu-Jiann Chyi EVA AIRWAYS 

Kess Chiang Singapore Airlines 

Mervyn Sirisena Singapore Airlines 

Shun Liang Kwok Singapore Airlines 

Kazunori Kato Japan Transocean Air Co., Ltd. 

Wee Hong Tang Jamco Aero Design & Engineering 

Masamichi Kato Tamco Aero Design & Engineering Pte Ltd 

Rahimah Othman Singapore Airlines 

Wai Seng Sito Singapore Airlines 

Teck Chyang Chin Singapore Airlines 

Weng Khoon Lim SIA Engineering Company 

Riaz Akram Qureshi Jamco Aero Design and Engineering 

David Wei-Min Lin CAA/Taiwan 

Eric Yu-Cheng Chen CAA/Taiwan 

Leonard Tan Jamco Aero Design and Engineering 

Andrey Froltsov Transaero 

Lesley Yip Singapore Airlines 

Wee Cheong Lian Civil Aviation Authority of Singapore 

Weng Khin Fong Civil Aviation Authority of Singapore 

George Foo Civil Aviation Authority of Singapore 

Kian Ann Soh Civil Aviation Authority of Singapore 

Jonathan Tan Civil Aviation Authority of Singapore 

Kok Choo Tan Civil Aviation Authority of Singapore 

Mun Cheok Ng Civil Aviation Authority of Singapore 

Vincent Ng Civil Aviation Authority of Singapore 

Chun Kwok Lau Civil Aviation Authority of Singapore 

Choong Cheng Chew Civil Aviation Authority of Singapore 

Kah Han Tan Civil Aviation Authority of Singapore 

Frederic Louis WilmerHale 

Eiji Kobayashi Nishimura & Asahi 

Jennifer Trock Pillsbury Winthrop Shaw Pittman LLP 

Kenneth Quinn Pillsbury Winthrop Shaw Pittman LLP 

David Lefrancq Airbus 

Marc Makil Singapore Airlines 

Lim Yen Yang AWAS 

J.T. Sarungallo DGCA- Indonesia 

Mulyanto DGCA- Indonesia 

Christopher Hartman Continental Airlines 

Arnold Juan Cathay Pacific 

Abdullah Al-Sharhan Kuwait Airways 

Sze Kang Tan Singapore Airlines 

Peng Yoeng Koh Singapore Airlines 

Sim Chen Liang Singapore Airlines 

Stanley Yeo Singapore Airlines 

Tran Chi Dung Vietnam Airlines 

Tran Minh Hai Vietnam Airlines 

THIS FORM IS TO BE PLACED IN THE PUBLIC DOCKET 

FOR THE SUBJECT RULEMAKING ACTION.