Dear Linda,

While CAR 3 and 4a do not specify any burn or flammability standards (for
example, see CAR 3 below), it doesn't make sense to use upholstery materials
that do not meet modern burn standards.  The FAA specific standard is FAR
25.853 (a) & Appendix F Part I (a) (1) (ii) however, it makes further sense
to upgrade that to the even more stringent Federal Standard 191 A-5903.1
(CID-A-A-2950A - which supersedes CCC-A-680a).  This Federal Standard must
be met by any fabric/foam/thread/rug manufacturer that desires to sell
product to the Federal Government, hence, there are very few vendors that
don't strive to meet these product standards.  A popular website for
purchasing fabrics is http://www.designerhomefabrics.com/ - they carry 5,641
different materials.  Each fabric lists the burn standards that it meets.
 Whichever fabric you end up with, make sure to demand copies of the
applicable burn certifications.

There is still some confusion on the part of your FSDO office, A&P and A&P
IA on this subject.  I recently attended the annual all day FSDO A&P IA
refresher course and this was the first topic covered.  The basic scenario
presented to the A&P IAs in attendance by the FAA was "You are performing an
Annual and you check out the interior on a CAR 3 or 4a airplane only to
discover a newly upholstered interior (any or all seats, side panels, rugs,
ceiling).  You request the burn certs for each material as they are
obviously not the original materials installed when the plane was built.
 The plane owner is unable to produce them.  Do you sign off the airplane
Annual placing the airworthiness liability squarely on your shoulders?"  The
final answer was left up to each A&P IA.

Refurbishing these interior materials is an allowable log book activity for
the airplane's owner just like changing the engine oil and filter.  Due to
the ambiguities of interpretation, I make certain that I have all the burn
certificates for each material in the aircraft records, just as if the
airplane was type certificated under FAR 23 rather than CAR 3 or 4a.

As far as requiring a "No Smoking" sign to meet CAR 3 requirements, please
also consider that directly over your knees is a gasoline tank - ON YOUR
SIDE of the firewall !!!

Yours,
Chris Koch
Buffalo, NY

*CAR 3 Personnel and Cargo Accommodations*

§ 3.389    *Doors.*  Closed cabins on all airplanes carrying passengers
shall be provided with at least one adequate and easily accessible external
door.  No passenger door shall be so located with respect to the propeller
discs as to endanger persons using the door.

§ 3.390    *Seats and berths**—(a)  Passenger seats and berths.*  All seats
and berths and supporting structure shall be designed for a passenger weight
of 170 pounds (190 pounds with parachute for the acrobatic and utility
categories) and the maximum load factors corresponding to all specified
flight and ground load conditions including the emergency conditions of §
3.386.

(b)     *Pilot seats.*  Pilot seats shall be designed for the reactions
resulting from the application of the pilot forces to the primary flight
controls as specified in § 3.231.

(c)     *Categories U and A.*  All seats designed to be occupied in the U
and A categories under § 3.74 (c) (4) shall be designed to accommodate
passengers wearing parachutes.

§ 3.391    *Safety belt or harness provisions.*  Provisions shall be made at
all seats and berths for the installation of belts or harness of sufficient
strength to comply with the emergency conditions of § 3.386.

§ 3.392    *Cargo compartments.*  Each cargo compartment shall be designed
for the placarded maximum weight of contents and critical load distributions
at the appropriate maximum load factors corresponding to all specified
flight and ground load conditions.  Suitable provisions shall be made to
prevent the contents of cargo compartments form becoming a hazard by
shifting.  Such provisions shall be adequate to protect the passengers from
injury by the contents of any cargo compartment when the ultimate forward
acting accelerating force is 4.5g.

§ 3.393    *Ventilation.*  All passenger and crew compartments shall be
suitably ventilated.  Carbon monoxide concentration shall not exceed 1 part
in 20,000 parts of air.
You can download the Federal Standard 191A from here:
http://www.everyspec.com/FED-STD/ - it even specifies how the testing is
performed.

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