## Civi{jl:viatWn !Bureau !Ministry oj Latta; Infrastructure, 

### 'Transportana'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 seatsmanufactured byKoilo Industries, and requesting theprovision ofinfummtion onthe plantoaddress problems relatingtoin·servicc seats.
In response Loyour 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 bythe JCAB) First of all, 

## rwould 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 inaccordance 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, I including its

### cOlporateculture and institutions, and submit ~horough 

### improvement plan by Febmm)' 26. (On Febmal)' 26, 20I0, Koilo submitted the request to eXtend the deadline for the submission of the improvement plan until March 12,2010.) 

# I 2, Conduct review ofthe compliance status of all aircraft seats a~'eady delivered by Koito urgently. TIle review ofthe aircraft seats with higher priority shall Je completed by the end ofMAY (phase 1) and the rest shaUbe done bythe end ofthis year (phase 2). 3. For the time being, prohibit delivel}' ofllewly manufactured aircraft seats, except forthose that the JCAB confirms the fullcompliance with the applicable tedmical standards,
Ihave attached acopy ofthe press release (provisional translation only) issued by the JCAB onthis issue (attachment 1), which you may have seen ah-eady bocause my staff sent the same copy to your staffs inSeattle and Los Angeles.

(Scope ofplan 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 theFAA intheJCAB

- FAA meeting inSeattle inDecember 2009. As already infunned to theFAA, 17items offi-audulent activities by Koito have been confinned, including falsification oftest 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 itis 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 133models (the number is continuously under investigation) .ofinwselviceseats on Boeing and AirbllS airplanes inthe 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 1,000airplJnes operated by airlines of23 eOlmtries and 1region.

(RMcsting ofin-service scats) As described inpal"agraph 2 above, necessary lewtestingofin-service seats will be conducted by Koito intwo phases. In the phase I, re.. testitl~ ofhigher priOlit)' wilt be conducted by the end ofMay, and inthephase 2, confilmation oftheJestofjthe seatmodels wi1Jbeconducted by the end ofth.is year.
The re~testing ofhigher priority is defmed asfollows:
For thetest toColumn stmctural strength (static load test, dynarnic icad test ulcludingthose forHIe) .AJ1133 seat models have been sOl1e1out . int.o

### j 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 toIe·testing inthe first place.

2Fortheflammability test ofthematerials ·There are about 1,500 non-metal materials used in 133 models ofin-service seats. Among them, about all 700 materials made of leather and textile are subject to applicable flammability test In addition, thematerials thathave notbeen tested yetare also subject tothe flammability test.
FBL forseatcushions 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 ofthe review of design changes which may affect the structural strength will be reflected in the process of determination of the most critical seat models intelms of structural strength. Also, materials that are chang~d without authorization and applicable flammability test will be subject to re-testing for flammability.

(ConfOJmityrelated problems) Regarding the eonfonnity related problems, including falsification of inspection records in the I 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:om2003 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 baektoKoito forconfonnity inspection ofprimary structure. (4) Analyze dala 10dctcITIlmeseverity ofnon-conformitics. 3These processes have been implemented on 5 sets of seats, which-cover, all the manufacturing process of primary structure in Koito and Iits suppliers. Critic'a:l,non-confonnitics have not been identified so far. Itisplmmed that more sets 

### ofseats go through theprocess inparallel with re-testing in phase 1andphase 2mentioned above. 

# I -

(New shipment byKojto) 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 ofthe JCAB to eosme that 

### I uewly delivered seats arc fiillycompliance with the applicable technical standards. 'Therefore, even ifthe seats are ofalready approved design, JCAB requires re-testing, which will ' 

### I be directly witnessed by the JCAB inspectors, unless"it is proved,that there were no fhmdulent activities inthe previous approval process. Iniaddition, theJCAB ensures that all activities by Koito arc "watched" and aUdocument:.1tions areproperlYprocessed.
Ifthere..testing for new shipment shO\~snorr-compliance with the applicable technical standards, necessaty C01TCctiveactions will be taken fol' the new shipment and relevant in-service seats. Iu addition, theresult will be reflected to theplan 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 inthis:aspect, including sharing any ilJfonnation which may affect operational safely and consultations on possible fleet wide actions onBoeing aircraft and necessary actions ourelevant TSOs. " Specifically, once non-eompliante is found, the JCAB requites Koito, possibly with the teclmical assistance D:omai.rcraftmallutacttll~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" isofthe greatest value to us.



# I 4(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 00the proposed corrective actions and how the fleet-wide action can be taken, since tillsproblem aftects seats models installed onboth Boeing and Airbus airplwlcs.

Taking this opportunity, Iwould 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 SUppoltby Boeing isof great value to us altinthe smooth and appropriate implementation ofthe plan to address ill-service seats aswell.
I would also like to infmm you that the JCAB will share 

### all infotmation with EASA, which is the certificating authority ofAirbus airplanes, so that we call take hannonized approach to tackle this difficult issuc,


## rhope that infotmation inthis letter is ofany 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 addless in-service scatJ and to contact theFAA mOle frequently to provide updated ilUOImation on the progress, including non-compliance found in the process and relevant conective actions. Finally, Iwould like torepeat thatthe JCAB iscommitted toaddress in·service seats issue, while" dealing with new shipments. In this context. understanding, cooperation and support by the ·FAA is really indispensable.



## sPlease do not hesitate to contact me ifyou have any questions or_comments, orneed any fm1her clarifications.
Your undersrdnding and cooperation on this matter ishighly appreciated. 

### I

ShigelUTakano Director ofAirworthiness Division Engineering Department Civil Aviation Bureau

Enclosure: (Attachment 1)Press Release (provisional Translation) (Attachment 2) Seat ModeJ List

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