Using Auto Headrests in a Plane

[SoCal 182 Driver]

Friends -

I've been having an interesting debate with a guy on another forum about whether it's legal to use Toyota Camry headrests in a Cessna 182P. My position has been that if the plane originally came with headrests from Cessna, then the only way to legally replace them is with OEM, STC, or PMA headrests (which would include burn certs for the materials). His view is that because the headrests are removable, he doesn't need to worry about an OEM, STC, or PMA part, or a part that has burn certs for the fabric and foam.

I'm interested to hear others' views on whether the Toyota headrests can legally be used (as-is) in this guy's Cessna.

Thanks!

 

[Gary Ward]

Been there done it.
Technically I bet it is a no go right out of a Camry into your Cessna. Not legal I am thinking?
Just the fact that you put a Toyota part on your Cessna should be illegal.lol
Ironically…
The camry headrest is a better quality headrest than.a original Cessna.
I bet the fabric used In a 2005 Camry headrest is pretty flame retardant?
Maybe more so than the material used back in the day in some old Cessna?

 

[Bell206]

whether the Toyota headrests can legally be used (as-is) in this guy's Cessna.

Short answer, yes. But the guy's premise is wrong as simply being "removeable" is not the qualifier whether it needs an approval or not. How it gets installed determines the end result and any approvals. You can install anything you want in an aircraft, legally. The trick is to know which method to use.

 

[SoCal 182 Driver]

Been there done it.
Technically I bet it is a no go right out of a Camry into your Cessna. Not legal I am thinking?
Just the fact that you put a Toyota part on your Cessna should be illegal.lol
Ironically…
The camry headrest is a better quality headrest than.a original Cessna.
But I bet the fabric used In a 2005 Camry headset is pretty flame retardant?
Maybe more so than the material used back in the day?

You're probably correct on all points, but would the FAA view it the same way?

 

[SoCal 182 Driver]

Short answer, yes. But the guy's premise is wrong as simply being "removeable" is not the qualifier whether it needs an approval or not. How it gets installed determines the end result and any approvals. You can install anything you want in an aircraft, legally. The trick is to know which method to use.

I think his view is, as the owner, he can go to the local auto salvage yard, find something that fits, slide them into place in his plane, and he's good to go.

 

[Bell206]

I think his view is, as the owner, he can go to the local auto salvage yard, find something that fits, slide them into place in his plane, and he's good to go.

And that is where he is wrong. A replacement part is required to have an approval like PMA etc. However, if his mechanic went and got the same part he could legally install it as an alteration which does not require the part have an approval. Pilots cant perform alterations under prevent mx, only part replacements which require approved parts except for standard parts.

This is no difference than installing those non-existant "experimental" radios and such. Now the mechanic would have to do his due diligence on the headrest as any other part and determine it meets any other requirements like flame-resistant, etc. Which in my experience most modern vehicle name brands have ASTM materials installed and could be confirmed by a letter from Toyota.

 

[unsafervguy]

I think his view is, as the owner, he can go to the local auto salvage yard, find something that fits, slide them into place in his plane, and he's good to go.

bell206 don't forget fan the flames (see what i did there) about the fact that a burn certificate in not needed for a car3 aircraft.

 

[Stewartb]

Not required equipment. Nobody cares. I’ve never had headrests in my two Cessnas.

 

[guest user]

Those really do look almost factory

 

[pfarber]

And that is where he is wrong. A replacement part is required to have an approval like PMA etc. However, if his mechanic went and got the same part he could legally install it as an alteration which does not require the part have an approval. Pilots cant perform alterations under prevent mx, only part replacements which require approved parts except for standard parts.

This is no difference than installing those non-existant "experimental" radios and such. Now the mechanic would have to do his due diligence on the headrest as any other part and determine it meets any other requirements like flame-resistant, etc. Which in my experience most modern vehicle name brands have ASTM materials installed and could be confirmed by a letter from Toyota.

Interior parts are a little different. An owner/operator can completly redo the interior with non-pma parts as long as they meet the TSO/Certification standards.

They can even do thier own burn testing if they want to, as long as its documented. There are many references on how to do it.

As for the radio, you can install any radio that meets TSO. All you gotta do it prove it. I'm not sure if any ac has a required radio via TCDS.

 

[Bell206]

As for the radio, you can install any radio that meets TSO.

FYI: you'll find there is no "meet TSO" requirement on radios in most cases. Transponders, ELTs, IFR GPS, etc. sure.

 

[kmacht]

Does a burn certificate really matter on a headrest? If there are flames at head level in the cockpit the last thing you are worrying about is if the headrest is fireproof.

 

[Checkout_my_Six]

I'm not signing the annual inspection with all that in there. I'll even snap a few pics when I'm done to prove that it wasn't there.

Now if you want it in there....it won't hurt a thing. Just not on my signature.

Is the rule stupid?....yes.

 

[SoCal 182 Driver]

Does a burn certificate really matter on a headrest? If there are flames at head level in the cockpit the last thing you are worrying about is if the headrest is fireproof.

Make that argument to the FAA and see what kind of response you get.

 

[Bell206]

Does a burn certificate really matter on a headrest?

Its not so much location based as it is merely a certification standard for interior materials. Even in the old days under CAR 3 it was only a standard. Back then it did have two versions in if the aircraft permitted smoking or not. No smoking you just needed flash-resistance materials but if smoking was allowed then the interior material needed to be flame-resistant with no separate certificate needed. Boils down to there were enough people burned alive in aviation incidents/accidents that a new standard had to be introduced when it came to interior material. Now in more modern times with synthetics and smoke issues these materials need a burn certificate in certain aircraft. Kinda of like the only time you have too much fuel on board an aircraft is when your on fire.

 

[455 Bravo Uniform]

So is that why my plane and others have a “no smoking” sticker?

 

[Bell206]

So is that why my plane and others have a “no smoking” sticker?

As I recall yes. I would have to research it but I believe both CAR 3 and Part 23 state somewhere if smoking is not permitted there must be a no smoke placard and if smoking is permitted there be enough ashtrays, etc.

 

[Checkout_my_Six]

As I recall yes. I would have to research it but I believe both CAR 3 and Part 23 state somewhere if smoking is not permitted there must be a no smoke placard and if smoking is permitted there be enough ashtrays, etc.

I think CAR 3 addresses that....but, there is this thingy called "The change product rule" which makes this mute and causes new changes to follow current rules....unless granted an exemption.

§ 3.388 Fire precautions—
(a) Cabin interiors. Only materials which are flash resistant shall be used. In compartments where smoking is to be permitted, the materials of the cabin lining, floors, upholstery, and furnishings shall be flame-resistant. Such compartments shall be equipped with an adequate number of self contained ash trays. All other compartments shall be placarded against smoking.

§ 3.48 Susceptibility of materials to fire. Where necessary for the purpose of determining compliance with any of the definitions in this section, the Administrator shall prescribe the heat conditions and testing procedures which any specific material or individual part must meet.
(a) Fireproof. "Fireproof" material means a material which will withstand heat equally well or better than steel in dimensions appropriate for the purpose for which it is to be used. When applied to material and parts used to confine fires in designated fire zones "fireproof" means that the material or part will perform this function under the most severe conditions of fire and duration likely to occur in such zones.
(b) Fire-resistant. When applied to sheet or structural members, "fire-resistant" material shall mean a material which will withstand heat equally well or better than aluminum alloy in dimensions appropriate for the purpose for which it is to be used. When applied to fluid-carrying lines, this term refers to a line and fitting assembly which will perform its intended protective functions under the heat and other conditions likely to occur at the particular
location.
(c) Flames-resistant. "Flame-resistant" material means material which will not support combustion to the point of propagating, beyond safe limits, a flame after removal of the ignition source.
(d) Flash-resistant. "Flash-resistant" material means material which will not burn violently when ignited.
(e) Inflammable. "Inflammable" fluids or gases means those which will ignite readily or explode.

 

[Bell206]

Here is the old Part 23 version:
Sec. 23.853 — Passenger and crew compartment interiors.
For each compartment to be used by the crew or passengers:
(a) The materials must be at least flame-resistant;
(b) [Reserved]
(c) If smoking is to be prohibited, there must be a placard so stating, and if smoking is to be allowed—
(1) There must be an adequate number of self-contained, removable ashtrays; and
(2) Where the crew compartment is separated from the passenger compartment, there must be at least one illuminated sign (using either letters or symbols) notifying all passengers when smoking is prohibited. Signs which notify when smoking is prohibited must—

 

[455 Bravo Uniform]

Wow, cool. I thought it was silly, but actually has compliance roots.

 

[pfarber]

FYI: you'll find there is no "meet TSO" requirement on radios in most cases. Transponders, ELTs, IFR GPS, etc. sure.

Im gonna say 'radio' includes nav/comms and gps units.. anything with a transmitter must meet specs.

Also, what does TSO C-37e cover if not comm gear?

 

[pfarber]

I'm not signing the annual inspection with all that in there. I'll even snap a few pics when I'm done to prove that it wasn't there.

Now if you want it in there....it won't hurt a thing. Just not on my signature.

Is the rule stupid?....yes.

And this kids, it why you always talk to a shop before you give them your plane.

 

[Bell206]

Im gonna say 'radio' includes nav/comms and gps units.. anything with a transmitter must meet specs.

If you are Part 21 producing radios for install in TC'd aircraft you need to follow a specification. But to install radios or other equipment in a TC'd aircraft there is no requirement to use "spec'd" equipment unless called out specifically by regulation like transponders and ELTs. For example, you can legally install off the shelf marine, CB, and FM radios in aircraft which most do not follow a TSO spec. Regardless, a TSOA is not an installation approval only a design and production approval.

 

[unsafervguy]

If you are Part 21 producing radios for install in TC'd aircraft you need to follow a specification. But to install radios or other equipment in a TC'd aircraft there is no requirement to use "spec'd" equipment unless called out specifically by regulation like transponders and ELTs. For example, you can legally install off the shelf marine, CB, and FM radios in aircraft which most do not follow a TSO spec. Regardless, a TSOA is not an installation approval only a design and production approval.

bell206, i will give him half a point, it better meet FCC spec if you want to transmit on it.