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Posted

I have a very vague idea of what CAR3 means compared to part 23. What does it mean in practical terms? Does it mean I don't have to run a vacuum gyro? Can I install non burn certified interior? Is there no sense of required equipment other than VFR day requirements?

Help me out. Thanks!

Posted

Is there a particular reason you wouldn't want to conform to the newer standards particularly for flammability of materials?  How many times have we all heard about pilots who survive a crash only to be severely injured or killed by a post-crash fire?

 

Just because you might not have to comply with 43.13 doesn't mean it isn't a good idea to adhere to those methods.

  • Like 1
Posted

Actually, yes...

 

Turns out that flammability standards of ALL commercially available rugs and fabrics are tougher 41.13.  You simply cannot buy anything flammable anymore.  I understand from a discussion with a reputable (and very large) custom aircraft interior shop that they have NEVER had one single batch of commercial grade UL or fire certified approved carpet or material refused by their lab due to flammability issues in their 15 years of testing.  They still send out each and every batch of material for testing regardless, but they find it to be just another burdensome cost to production.

 

Just one of those regs that have outlived the technology.

 

Personally, I don't really see betting my life on that to save $40. There is also the liability issue. If a passenger or the next owner is injured you can bet that there will be lawyers asking you why you decided to ignore the more stringent standards.

Posted

Well let's revisit this again.

 

43.13 is NOT a certification standard. CAR-3 and Part 23 are. They are the standards that the aircraft maker was required to meet for certification of the airplane. The manufacturer then writes a a maintenance manual for the repair and care of the airplane. Mooneys have different manuals going back to the beginning. 

 

An owner (the person responsible for the maintenance on any airplane) is only required to reach the level of what the airplane was originally certified to. A 1965 Mooney only needs to be maintained to the maintenance manual that was issued with it and NOT anything "required by the MANUFACTURER" on a later date or by accessory makers (mandatory vacuum pump changes by maker). 43.13 is used for maintenance and repair of airplanes when NO MANUFACTURERS INSTRUCTIONS ARE AVAILABLE, as noted on the first page of 43.13 and can not be used if it goes against what the aircraft manufacturer required originally. 

 

There is a caveat in the remaking of interiors that is of note here. NO manufacture's maintenance manual specified what was required for redoing interiors back then SO 43.13 can be used as guidance for what is ACCEPTABLE in the eyes of the FAA.

43.13 specifically notes what can be used in both CAR-3 and Part 23 airplanes for remake of the interior as NO manufacturer's data is available. This is all contained in 43.13 paras 9-60 through 9-64. The acceptable level of "fire protection"  that the material meets must be stated in the log book entry for the interior installation. Your IA can not sign off an annual if he sees a new interior and it doesn't meet the required standards for fire protection. 

 

In the case of CAR-3 airplanes it needs to meet a "National Standard" such as UL flash proof, for Part 23 airplanes they need to meet Part 23 standards and will always show that on any log book entry. 

 

In summery, Part 43.13 is not a "certification standard" but an "acceptable standard" for repairs and maintenance of airplane when "manufacturer's data" is not available. If the manufacturer has issued a maintenance manual, structural repair manual or what ever (when the airplane was made) that trumps 43.13 for everything contained in it. A 1964 Mooney CAN be maintained to the level of a 2010 Mooney Maintenance manual but that is not required. Only the 1964 manual level is required. 

  • Like 1
Posted

Sorry Ryoder, to high jack your topic, but I did a bit more digging on the subject of flammability in older CAR-3 aircraft. 

 

I think we are ALL missing the point.  Apparently we may not need ANY flammability standards at all if placarded appropriately.  I looked up the actual CAR-3 text at: www.navioneer.org/riprelay/Yet%20More%20Navion%20Files/car_part3.pdf

and cut and pasted the following:  (my bold emphasis was added)

*************************************************************************************************

CAR -3 (1949 rev) relating to interiors

S 3.388 Fire Precautions – (a) Cabin interiors. Only materials which are flash-resistant (see definition below) 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 ashtrays. All other compartments shall be placarded against smoking.

*****************************************************************************************************

Definition according to CAR 3..

(d ) Flash-resistant. “Flash-resistant” material means material which will not burn violently when ignited.

********************************************************************************************************************************************

 

 Which still leaves me to wonder...Do I have to test for flash resistance at all if placarded as "no smoking" in my older CAR-3 aircraft?

Yes and no, I think. From AC 43-13.1B:

(1) If fabric is bought in bulk to refurbish the interior, seats, and ceiling liners for a CAR-3 aircraft used in part91 operations, a manufacturer’s statement, declaring that the material meets the American Society for Testing and Materials (ASTM) or similar national standard for either flash resistance or flame resistance, would be acceptable, but only for a CAR-3 aircraft installation. (Refer to 14 CFR part 43, section 43.13(a).) A manufacturer’s statement is acceptable due to neither the Civil Aeronautics Administration (CAA) nor the Federal Aviation Administration (FAA) having published an FAA fire standard for either flash or flame resistance for interior materials for CAR-3 aircraft.

So simply referencing the ASTM approval would suffice for CAR-3 airplane if there were no ashtrays and with a placard saying no smoking.

Interestingly, there are some spray on type fire proofing sprays that reference an ASTM number. As an IA, I would reference all of these documents in my logbook entry as the basis for approval, and if the spray on stuff was used, I would note that it was applied per the manufacturer's instructions to meet the ASTM standard.

Cliffy- if you happen to read this- what do you think of this rationale?

Posted

Just how fire proof are those ABS plastic interior panels and that seat foam?

What about leather? Is that considered flash-proof?

 

I hope I never find out!

Posted

I am not quite seeing the issue. Assuming that you want to redo your interior, why would anyone put something unsafe in the plane WRT fire? Of course, you can go overboard with this and I think some of the posts have tried to establish the limits of the envelope, but the fact remains that there is no reason to not have a gorgeous interior, easily exceed regulations AND be very safe from a flash fire. What you don't want is the interior "going up in a ball of flame" with you in it. That will happen if you run down to Home Depot, buy some plastic sheets and slap them on the inside of your fuse. Likewise, if you let your wife sew slipcovers for your seats out of material that Aunt Bessie left for her in her hope chest.

 

My seats were recovered with leather used by GMC for the interior of their trucks and SUVs. The specs on that leather exceed the FAA requirements for my Mooney and I have the paperwork to prove it--keep in mind that GMC has far deeper pockets than I do. I went with Bruce Jaeger's Spatial Interior, which is not only STC'd, but uses the same plastic slated for commercial jets. You can bet the specs on that plastic exceed what was originally in my plane.

 

That said, we pulled out yards of 50 YO fiberglass fabric, well known for it's fire resistance. I can't speak for the foam underlayment, but these guys weren't idiots.

Posted

In the case of Home Depot plastic sheets and the factory interior, it's acrylic vs abs. They both give off toxic fumes and burn easily. Ithat will kill you before the fire. I thought the Spatial interior was ABS as well?

I think the newer Mooneys are vacuum formed fiberglass and epoxy.

Posted

Short answer... we have the freedom to use just about any suitable materials we want to update our interiors.  Just about anything you purchase that is used commercially for interiors will not go up in flames, but you would be wise to verify/check/test that for yourself as it would be utterly stupid to install something flammable inside your plane.  CAR3 does not require the extensive testing that modern Part 23 & 25 requires, but I suspect anything you purchase will meet the requirements.  If you want to be doubly-sure, send some samples off for testing... it isn't expensive.

Posted

Scott,  I'm pretty sure that upgrading the entire interior is a major alteration.  So you and I both know that you will have to comply with the current regulations. 

Posted

It's not a major anything...43.13 appendix A par c (11) list interior work as preventive maintenance.

But that brings another question on Car 3 cat if 43.13 is even valid.

-Matt

  • Like 1
Posted

Scott, I'm pretty sure that upgrading the entire interior is a major alteration. So you and I both know that you will have to comply with the current regulations.

It may seem that way, but it definitely is not a major alteration by the definitions that the FAA uses.

It's not a major anything...43.13 appendix A par c (11) list interior work as preventive maintenance.

But that brings another question on Car 3 cat if 43.13 is even valid.

-Matt

You are actually referring to FAR 43 Appendix A (or more precisely, 14 CFR Part 43). The 43.13 you are referring to is actually AC 43.13, an advisory circular, and yes, it does apply where manufacturer's data either does not exist or is lacking detail.

FAR 43 also applies as you have used it here.

And specifically para C, Preventive Maintenance, says that the owner/operator of the aircraft if he/she holds at least a private pilot's license may REPAIR upholstery and decorative furnishings, not replace them.

Posted

Actually I was referring to 21.93 (a).  If you redo your interior, I'm think that you will change the empty weight and possibly the CG of the aircraft and thus change the operational characteristics, maybe not.  But in the end these are not requirements but regulatory guidance and depending on who you talk to will give you different answers; just like we are debating here.  Wouldn't it just be easier to comply with part 23 and not hang on to CAR 3?  Thus avoiding a lot of hassle.  Its really not that hard. 

Posted

N1395W  I agree with what you say.

 

BTW I've been gone a couple of  days and just getting caught up.

 

43.13 trumps the "old" CAR-3 quotation as CAR-3 was cancelled when we had the complete rewrite to FARs.

Any change in the interior needs to have "some" notation in the log book as to fire suppression acceptability for an IA to sign off the next annual (per the applicable 43.13 paragraphs).

One can use the 43.13 reference and show a "National Standard" compliance (ATSM. UL, etc) from the material manufacturer for CAR-3 airplanes, one can show FAA certified material certs per Pt 23 compliance or one can show "treatment " of any fabric according to the manufacturer's directions. You can also send out any material for testing and get the certs that way.

A local 135 group treats their interiors for compliance by spraying BUT what they use needs to be redone on a continuing basis AND signed off. Just one spray down is not sufficient forever..

As to W&B, one should weight each seat and interior piece before it is worked on and then after the new covering are installed to find the weight difference, If it is less than 1 pound in total no W&B change needs to be computed BUT it still must be noted in the log book when noting the interior refurb. How many interiors do you think change the interior weight by less than 1 pound? :-)

So, you still need an A&P to do the W&B sign off.  For the seat installations and W&B calcs, you need to figure the weight change for each seat AND figure the ARM for where that seat is installed to get the corrected W&B figure for the airplane.

As has been noted here, it is probably easier and money ahead to just get Pt 23 certified material. A local upholstery shop I know of

runs into this all the time and they say they have all kinds of FAA certified material available so it doesn't seem to be too hard to find or cost prohibitive for those who wish to have their interiors done by the local auto upholstery shop. 

It can be done that way but you need to involve your local A&P and follow the regs. 

  • Like 1
Posted

I forgot to add- "What's American Idol"?  I don't have a clue as I've never watched it. I know, Luddite.

I don't have a smart phone as they're smarter than I am!

Posted

Keep in mind most plastics themselves melt while burning. Similar to having gasoline on fire...

What makes them fire resistant is something that has been mixed into the polymer at the molecular level.

There are technical tests to define this. But for your own knowledge, trim a piece, light it, and observe...

If the fire is self-sustaining with flaming drips, this is bad....

If the fire keeps going out, this is better...

If you can't light it on fire, this is best...

Can you light a piece of leather on fire?

I have tested some materials that got delivered to work, with official flame testing paperwork...

I was very happy with the results in my fireplace. Untreated styrene foam can burn like gasoline, the fire will spread quickly.

Treated styrene was self extinguishing...

They both look and act the same, accept the flaming part.

No need to be cheep with this. Good products that are fire resistant are not much more expensive...if at all.

Now, if there was a way to mix flame retardants into the fuel tanks after a hard landing.....

Best regards,

-a-

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