Civi{jl:viatWn !Bureau

!Ministry oj Latta; Infrastructure, 'Transport ana'Tourism

2-1-3, KasunllgH>eld, ClIlycliH·ku,

TOKYO 100-8918, JAPAN

TEL -81-3-5253-8135 Jo"AX-81-3-5253-1661

March 5, 2010

KOKU-KU-KI-1025

Dear Mr. Bahrami,

Thank you very much for your letter dated February 17, 2010. dealing with problems associated

with aircraft seats manufactured by Koilo Industries, and requesting the provision ofinfummtion on the

plan to address problems relating to in·servicc seats.

In response Lo your letter, this is to provide you with the plan of aclions to address problems

relating to in-service seats by Koilo under the strict oversight by the JeAB and timelines for those

activities.

(Enforcement action by the JCAB)

First of all, r would like to infonll you that the JCAB issued the letter of reconunendation to

Koita on Febmruy 8, 2010, which instrUcts it to take fOllO~viJlgactions, and disclosed the issue to the

public in accordance with the basic policy for the disclosuJ of infolmalion within MLlT.

I. Conduct thorough review of its systems ldating t1 design and production of aircraft seats,

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including its cOlporate culture and institutions, and submit ~horough improvement plan by Febmm)' 26.

(On Febmal)' 26, 20 I0, Koilo submitted the request to eXtend the deadline for the submission of the

improvement plan until March 12,2010.) I

2, Conduct review of the compliance status of all aircraft seats a~'eady delivered by Koito urgently.

TIle review of the aircraft seats with higher priority shall Je completed by the end of MAY (phase 1)

and the rest shaU be done by the end of this year (phase 2).

3. For the time being, prohibit delivel}' ofllewly manufactured aircraft seats, except for those that the

JCAB confirms the full compliance with the applicable tedmical standards,

I have attached a copy of the press release (provisional translation only) issued by the JCAB on
this issue (attachment 1), which you may have seen ah-eady bocause my staff sent the same copy to

your staffs in Seattle and Los Angeles.

(Scope of plan to address in·service seats)

Pm'agraph 2 above relates to the plan to address in~servjce ~at.", basic ideas of which were

plesented to the FAA in theJCAB - FAA meeting in Seattle in December 2009.

As already infunned to the FAA, 17 items offi-audulent activities by Koito have been confinned,

including falsification of test results, design bhanges without proper authorization and falsification of

inspection records.

Because the records for those fraudulent activ.ities are missing; incomplete or lost, and it is not

possible to exactly identify problems for eabh scat model, the plan to addiess in~service seats shall

cover all models of aircraft seats delivered b~ Koito and being used n~~\'. Thele are 133 models (the

number is continuously under investigation) .of inwselvice seats on Boeing and AirbllS airplanes in the

world, and the JCAB is cOimnitted to confirm the compliance status of all 133 models with the

applicable technical standards, as quickly as possible. Please refer to the attachment 2 to this letter

.which lists a1l133 models of in·service seats! As you om see fi..om the attaclunent 2, there ate about

150,000.in selvice seats on about 1,000 airplJnes operated by airlines of23 eOlmtries and 1 region.

(RMcsting of in-service scats)

As described in pal"agraph 2 above, necessary lewtesting of in-service seats will be conducted by

Koito in two phases. In the phase I, re ..testitl~ of higher priOlit)' wilt be conducted by the end of May,

and in the phase 2, confilmation of the Jest ofjthe seat models wi1Jbe conducted by the end ofth.is year.

The re~testing of higher priority is defmed as follows:

For thetest to Column stmctural strength (static load test, dynarnic icad test ulcludingthose for HIe)

.AJ1133 seat models have been sOl1e1 out .int.oj 1 "-Seat model grOl;ps" b~ on the stmctnral

similarity. TIle most critical seat model among those belong to the same "seat model group" is subject

to Ie·testing in the first place.

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For the flammability test of the materials

·There are about 1,500 non-metal materials used in 133 models of in-service seats. Among them,

about all 700 materials made of leather and textile are subject to applicable flammability test In

addition, the materials that have not been tested yet are also subject to the flammability test.

FBL for seat cushions

All seat cushions that the JCAB confirmed falsification in the previous testing arc subject to

re-testing. (33 models)

(Design changes without proper authorization)

Regarding the design changes without proper authorization, all related documen~ including

drawings used for actttal production, have been checked and all changes have been reviewed. _The

result will be reflected to re-testing exercises mentioned above. For example, the result of the review

of design changes which may affect the structural strength will be reflected in the process of

determination of the most critical seat models in telms of structural strength. Also, materials that are

chang~d without authorization and applicable flammability test will be subject to re-testing for

flammability.

(ConfOJmity related problems)

Regarding the eonfonnity related problems, including falsification of inspection records in the

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production process, following actions are taken to identifY influences on the compliance status of.

in·sclviec seats. I .

(1) Koito had the largest number of seat delivcdes fi:om 2003 to 2008. TIlis is most likely periodKoito might have confonnity related plUblems including fdlsified inspection records, due to schedule

pressure.

(2) Compare scats delivered during this time frame, using spare seats stored by customer airlines,

with_current-on~ by conducting tear down inspection to validate coherence of each manufacturing

process. This is being done by the cooperation from customer airlines including JAL. ANA and .

foreign customer airlines.

(3) Ship-the seats identified above baek to Koito for confonnity inspection of primary structure.

(4) Analyze dala 10 dctcITIlme severity of non-conformitics.

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These processes have been implemented on 5 sets of seats, which-cover, all the manufacturing

process of primary structure in Koito and I its suppliers. Critic'a:l,non-confonnitics have not been

identified so far. It is plmmed that more sets of seats go through the process in parallel with re-testing in

phase 1 and phase 2 mentioned above. I -

(New shipment by Kojto)

Regarding the new shipment by Koito, as mentioned 'hi paragraph 3 above, delivery of newly

manufactured aircraft seats is proWbited, except for those tbat the JCAD directly confmns the full

compliance with the applicable technical standards. It is the intention of the JCAB to eosme that

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uewly delivered seats arc fiilly compliance with the applicable technical standards.

'Therefore, even if the seats are of already approved design, JCAB requires re-testing, which will '

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be directly witnessed by the JCAB inspectors, unless"it is proved,that there were no fhmdulent

activities in the previous approval process. Iniaddition, the JCAB ensures that all activities by Koito arc

"watched" and aU document:.1tions are properlY processed.

If the re..testing for new shipment shO\~s norr-compliance with the applicable technical standards,

necessaty C01TCctiveactions will be taken fol' the new shipment and relevant in-service seats. Iu

addition, the result will be reflected to the plan to address in"scrvice seats problems.

(Conective actions)

I would like to stress that any condition discoverr:d by the l'e..testing and other confumation

process which may impacts safety OJ' airwobliness of in·service aircraft w1ll lead to immediate and

appropriate conective actions to ensure the Jfety~d integrity ofthe fleet.

The JCAD intends to continuously wdrrk closely with the FAA in this:aspect, including sharing

any ilJfonnation which may affect operational safely and consultations on possible fleet wide actions

on Boeing aircraft and necessary actions ourelevant TSOs. "

Specifically, once non-eompliante is found, the JCAB requites Koito, possibly with the

teclmical assistance D:om ai.rcraft mallutacttll~lS, to review the situation and come up with appropriate

corrective actions immediately. After its mV1l review- of the" situation and the proposed actions, the

JCAB will contact the FAA to seek views on)feet wide actions and actions onrelevatit TSOs.

In this context, yoUI' cooperation and abistancc" is ofthe greatest value to us.

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(Already continued non-rompliance)

While Kono has been already in the process of identifYing any non<Olnpliance with the

applicable technical standards, so far, one instance of non-rompliance was continned tluuugh the

re-testing of seats for the new shipment, where the materia! used for the arm caps of particular seat

models cannot pass the flammability test (vertical) required by FAR Part 25.

The JCAB instructed Koito to urgently come up with the corrective actions for the airplanes

equipped with the seats aIrected by this problem. Koito, while considering the appropriate corrective

actions with assistance by aircraft manufacturers, has already started to manufacture the replacement

parts with the improved material. The JCAB will contact FAA and EASA to seek their views 00 the

proposed corrective actions and how the fleet-wide action can be taken, since tills problem aftects seats

models installed on both Boeing and Airbus airplwlcs.

Taking this opportunity, I would like to express our sincere gratitude to Boeing, which has been

cOllunitted to support to Koito in establishing and implementing the plan to address in-service seats,

including planning of corrective actions in case where non-compliance is found, as well as

improvement ofthe quality systems ofKoito.1 am sure that the SUppolt by Boeing is of great value to

us alt in the smooth and appropriate implementation ofthe plan to address ill-service seats as well.

I would also like to infmm you that the JCAB will share all infotmation with EASA, which is

the certificating authority of Airbus airplanes, so that we call take hannonized approach to tackle this

difficult issuc,

r hope that infotmation in this letter is of any help to you to understand the cunent situation and

provides necessary clarification. I would like to add thJ J have instl1lcted my staff to send more

detailed information on the plan to add less in-service scatJ and to contact the FAA mOle frequently to

provide updated ilUOImation on the progress, including non-compliance found in the process and

relevant conective actions.

Finally, I would like to repeat that the JCAB is committed to address in·service seats issue, while"

dealing with new shipments. In this context. understanding, cooperation and support by the ·FAA is

really indispensable.

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Please do not hesitate to contact me if you have any questions or _comments, or need any fm1her

clarifications.

Your undersrdnding and cooperation on this matter is highly appreciated.

I

ShigelU Takano

Director of Airworthiness Division

Engineering Department

Civil Aviation Bureau

Enclosure:

(Attachment 1) Press Release (provisional Translation)

(Attachment 2) Seat ModeJ List

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