Do FAA/PMA approved parts still need burn testing?

hish747

hish747

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Hish747
I'm replacing some plastic interior trim pieces in our 1974 Archer using FAA/PMA approved parts from vantage plane plastics. Do I still need to do the burn testing?
Thanks,
Hish
 
If they're PMA'd they've already been tested sufficiently.
 
You would only be burn testing if you were seeking PMA. That's why parts cost so much, the certification process.
 
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GlennAB1 said:
You would only be burn testing if you were seeking PMA. That's why parts cost so much, the certification process.
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That's not true. If you have a Part 23 aircraft (and I believe his later Piper is one) then any material must be certified flame resistant. If you buy stuff that was legally manufactured for aircraft (PMA, TSOA, manufacturer's production certificate) then that should already be done for you. If you want to go down to Bill's Leather Emporium and buy some stuff to redo you seats, then you'll have to have it tested and there are people who will do that to the FAAs standards.

If you have an older CAR 3 certified plane like mine, the rules just say the material needs to be flame resistant. There's no requirement to certify it as such. I can use that cowhide because leather is inherently flame resistant.
 
GlennAB1 said:
You would only be burn testing if you were seeking PMA. That's why parts cost so much, the certification process.
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You can buy carpet anywhere and send it out for burn, assuming it passes, that is likely all data needed to install into most aircraft.
 
There is no flame standard for CAR3 aircraft. You can check the Type Certificate Data Sheet for the certification basis, but I expect that the Warrior is largely a CAR3 aircraft with perhaps one or two part 23 regs thrown in. The certification basis goes back to the original type certificate which for the PA-28 was certainly CAR3 originally.
 
Kristin said:
There is no flame standard for CAR3 aircraft
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Correct.
.You can check the Type Certificate Data Sheet for the certification basis, but I expect that the Warrior is largely a CAR3 aircraft with perhaps one or two part 23 regs thrown in. The certification basis goes back to the original type certificate which for the PA-28 was certainly CAR3 originally.
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I did check. The certification basis changed with model year. His 1974 Archer is part 23 I'm fairly sure.
 
flyingron said:
Correct.


I did check. The certification basis changed with model year. His 1974 Archer is part 23 I'm fairly sure.
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From the TCDS 2A13

PA-28-181: CAR 3 effective May 15, 1956, including Amendments 3-2 and 3-4;
paragraphs 3.304 and 3.705 of Amendment 3-7 effective May 3, 1962; FAR 23.207,
23.221, 23.955 and 23.959 as amended by Amendment 23-7 effective September 14, 1969;
FAR 23.1557(c)(1) as amended by Amendment 23-18 effective May 2, 1977; and FAR
23.1327 and 23.1547 as amended by Amendment 23-20 effective September 1, 1977.
FAR 36, Appendix G, Amendment 36-16 for the PA-28-181 (Archer III), S/N 2890206
through 2890231, and 2843001 and up.
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flyingron said:
Correct.


I did check. The certification basis changed with model year. His 1974 Archer is part 23 I'm fairly sure.
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For a 1974 Archer, which is a PA-28-180, this from the TCDS:

PA-28-150, PA-28-160, PA-28-180, PA-28-235, PA-28S-160, PA-28S-180, PA-28R-180, and PA-28R-200: CAR 3 effective May 15, 1956, including Amendments 3-1 and 3-2; paragraphs 3.304 and 3.705 of Amendment 3-7 effective May 3, 1962; FAR 23.955 and 23.959 as amended by Amendment 23-7 effective September 14, 1969; and FAR 23.1327 and 23.1547 as amended by Amendment 23-20 effective September 1, 1977.

I haven't looked up the individual parts of 23 to see if any related to flammability, but the basic certification is still CAR3, as it is for the later Archer II, PA-28-181.
 
Funny, we just discussed this over at Beechtalk.

Materials for aircraft that fall under part 91 (part 23 built) just need a burn cert to meet FAR 23.853(a), but do not have to meet the FAR 23.853(d) spec (the real FAR burn test). Basically FMVSS 302 is sufficient for FAR 23.853(a) (which most materials will already pass). The rub comes in if you ever try to take your plane (or sell your plane into) part 135 operation, in which case the interior components would need to meet FAR 25.853(a) or 23.853(d). So if you don't use "FAR-certified" materials, you may have a resale value or marketability issue.

You can get a burn cert for $40 from Skandia.
 
All aircraft fall under part 91, I don't know what point you're making.
Not all aircraft are subject to part 23. Those built under CAR 3 don't require any burn testing.
 
flyingron said:
All aircraft fall under part 91, I don't know what point you're making.
Not all aircraft are subject to part 23. Those built under CAR 3 don't require any burn testing.
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Poor wording on my part. All aircraft operated under part 91 only.

Planes that would be operated under Part 135 are required to meet a more stringent spec (23.853(d) or 25.853(a)). My point was that if you do your interior with materials that are minimally flame treated (as required by part 23.853(a)), and then sell it to someone who would add it to a 135 ticket, it would then be unable to operate legally on that 135 ticket.

Just something to think about for the resale and marketability of your plane. Now, if you've got a 152 or a Navion, or something like that, it doesn't really matter... but a Bonanza or Lance could someday end up on a line or in an operation.

You're right about CAR 3... but it certainly does not apply to everyone.
 
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