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khill5
Joined: 10 Jan 2006
Posts: 1
Location: Indianapolis
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 Posted: Sat Oct 21, 2006 3:18 am Post subject: FAA seat belt requirement |
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The FAA inspected my RV-9A yesterday and all went well, thank you very much. I now have a legal airplane and am preparing for the phase 1 flyoff. However, the inspector said my seat belts, the 4 point style from Van's, were not TSO'd and therefore not legal for me to use. He said I would have to change them to a TSO'd brand before I could fly the plane. Has anyone else run into this? I talked to Van's and their opinion was "it is an experimental and therefore the non-FAA PMA seatbelts are acceptable." Do I make the government happy and maybe avoid problems down the road by changing them or continue with what I have installed?
Ken Hill
Plainfield, IN.
[quote][b]
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Kenneth Hill |
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n616tb(at)btsapps.com
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| Posted: Sat Oct 21, 2006 4:08 am Post subject: FAA seat belt requirement |
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Continue with what you have. I had a couple of these things on my inspection also, but being experimental means we can use what we want. There are a few thousand airplanes flying with those seatbelts including mine.
Tim
RV-6 N616TB
Repositioned to Texas
24 hours and counting
From: owner-rv-list-server(at)matronics.com [mailto:owner-rv-list-server(at)matronics.com] On Behalf Of kenneth hill
Sent: Saturday, October 21, 2006 5:22 AM
To: rv-list(at)matronics.com
Subject: FAA seat belt requirement
The FAA inspected my RV-9A yesterday and all went well, thank you very much. I now have a legal airplane and am preparing for the phase 1 flyoff. However, the inspector said my seat belts, the 4 point style from Van's, were not TSO'd and therefore not legal for me to use. He said I would have to change them to a TSO'd brand before I could fly the plane. Has anyone else run into this? I talked to Van's and their opinion was "it is an experimental and therefore the non-FAA PMA seatbelts are acceptable." Do I make the government happy and maybe avoid problems down the road by changing them or continue with what I have installed?
Ken Hill
Plainfield, IN.
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LarryRosen
Joined: 16 Jan 2006
Posts: 415
Location: Medford, NJ
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| Posted: Sat Oct 21, 2006 4:12 am Post subject: FAA seat belt requirement |
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Below is a post from the AeroElectric-List. It mostly addresses
requirements for VFR and IFR operations, but towards the bottom it
addresses seat belts. How hard you try to convince the FAA that in your
choice.
Larry Rosen
RV-10 #356
10/09/2006
Hello Rob, The FAA has a back hand way of applying FAR Sec 91.205 to
Amateur Built Experimental Aircraft (ABEA) and it takes a little
research and careful reading of different documents to sort out what
applies when.
First, if you are operating the ABEA day VFR then none, I repeat NONE,
of 91.205 applies to the instrumentation or equippage of that aircraft.
(See Note 1 below).
Hard to believe isn't it, but that is true because as you noted 91.205
applies to aircraft with standard category US airworthiness certificates
and not to our ABEA's that instead receive special airworthiness
certificates. (This is what permits very simple ABEA's like a Woody
Pusher or Breezy to fly legally day VFR with nothing in the way of
91.205 instruments or equipment if the builder / pilot chooses to do so).
Second, the instant that you start operating that ABEA at night or under
IFR then 91.205 comes into play, not to the entire extent (See Note 2
below) that it does for aircraft with standard airworthiness
certificates, but compliance with 91.205 for ABEA's does become
extensive. Why is that?
It is because each ABEA has been issued a special airworthiness
certificate that includes a set of Operating Limitations that contain
these words "After completion of Phase I flight testing, unless
appropriately equipped for night and/or instrument flight in accordance
with 91.205, this aircraft is to be operated under VFR, day only."
The intent and interpretation by the FAA of that sentence is that if the
ABEA is operating VFR at night then paragraphs 91.205 (b) and (c) must
be complied with. If the ABEA is operating under IFR then paragraphs
91.205 (b), (c), and (d) must be complied with. (I suppose that some sea
lawyer could argue that for day IFR one would not have to comply with
91.205 (c) (1) and thereby not comply with 91.205 (b), but that is not
the way that the FAA interprets the word "appropriately" in that
sentence in the Operating Limitations.)
Because this subject is a bit convoluted I have put together a table
that lays the information out in fairly compact reference form. I will
send you a copy of this table attached to a separate email. If anyone
else would like a copy just email me. This table was also published on
page 50 of the June 2006 issue of Kitplanes magazine.
Please let me know if you have any questions.
OC -- The best investment we will ever make is in gathering knowledge
Note 1: While 91.205 (b) (15) may not apply that does not excuse an ABEA
from complying with 91.207 regarding ELT's.
Note 2: Certain sub paragraphs of 91.205 refer to needing "approved"
items. This issue becomes a bit fuzzy because since there are no
certification criteria published for ABEA how can one determine whether
an item is "approved" or not for installation in an ABEA?
A commonly taken position both by many builders and by FAA and DAR
initial airworthiness inspectors of ABEA's is that if the item can
affect operations by other aircraft as well as the ABEA, such as
exterior lighting for example, then an item which has been approved for
installation on standard airworthiness certified aircraft will be
required on the ABEA.
On the other hand arguments have been successfully made that if the item
affects only the internal functioning of the ABEA, such as seat belts
and shoulder harnesses for example, then these items do not have to be
"approved" (by a TSO marking for example). I have been involved in a few
of these discussions and, with the aid of communication from FAA
headquarters, have forced the inspector to back off the TSO marking
requirement for both seat belts and shoulder harness which were already
purchased and installed by the builder. I do not recommend letting it
get to that point though. Instead I recommend coordinating with the
inspector before the belts are purchased to determine his individual
requirements.
---
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Larry Rosen
#40356
N205EN (reserved)
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december29(at)bellsouth.n
Guest
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| Posted: Sat Oct 21, 2006 4:14 am Post subject: FAA seat belt requirement |
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Yep,
I have the same concerns as mine hasn't been inspected yet. I purchased two sets of 5 pt harnesses from Simpson that are super strong and certified for NASCAR. I'm hoping to not have a problem, I guess it depends on the inspector.
John
80002
[quote] ---
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n616tb(at)btsapps.com
Guest
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| Posted: Sat Oct 21, 2006 4:27 am Post subject: FAA seat belt requirement |
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It does depend on the inspector. Mine never said a word about my seat belts. Other things he did say, some of which I changed and some I didn’t. Bottom line is once completed and inspected, if he didn’t *require* you to change something before signing you off, then you make the choice. It sounds like Ken has a completed inspection. If this is so and you are happy with your installation then I say just go start flying and have fun. It sounds like Larry provided good info also for backing to your plan.
Tim
From: owner-rv-list-server(at)matronics.com [mailto:owner-rv-list-server(at)matronics.com] On Behalf Of John Porter
Sent: Saturday, October 21, 2006 5:13 AM
To: rv-list(at)matronics.com
Subject: Re: FAA seat belt requirement
Yep,
I have the same concerns as mine hasn't been inspected yet. I purchased two sets of 5 pt harnesses from Simpson that are super strong and certified for NASCAR. I'm hoping to not have a problem, I guess it depends on the inspector.
John
80002
[quote]
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Gary.A.Sobek
Joined: 09 Jan 2006
Posts: 217
Location: SoCAL USA
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| Posted: Sun Oct 22, 2006 10:49 pm Post subject: FAA seat belt requirement |
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Ken:
Read AC 20-27E section 7 d (2). (its on page 4)
http://members.eaa.org/home/govt/rules/ac20-27e.pdf
or
http://www.airweb.faa.gov/Regulatory_and_Guidance_Library/rgAdvisoryCircular.nsf/0/0ca2845e2aafffbb86256dbf00640cb2/$FILE/AC20-27F.pdf
it says:
"d. Designing the Cockpit/Cabin. When you design the cockpit or cabin, you
should do the
following:"
-------- snip ---------
"(2) Install FAA TSO-approved seatbelts and shoulder harnesses. ..."
Note that it says "...you should..." not that you must.
I am trying to find in the regulations and FAA orders where it says that you
MUST have seatbelts in an amateur built experimental aircraft . I do not
know any DARs or FAA inspectors that will put their name on the Special
Airworthiness Certificate pink slip (FAA Form 8130-7) on any amateur bult
aircraft that does not have seat belts.
If you find the FAA REQUIREMENT that says you MUST have seatbelts in an
amateur built experimental, please post it to the list.
Gary A. Sobek
"My Sanity" RV-6 N157GS O-320 Hartzell,
1,962 + Flying Hours So. CA, USA
http://www.rvdar.com
----Original Message Follows----
From: "kenneth hill" <khill5(at)indy.rr.com>
Reply-To: rv-list(at)matronics.com
To: <rv-list(at)matronics.com>
Subject: FAA seat belt requirement
Date: Sat, 21 Oct 2006 07:21:34 -0500
The FAA inspected my RV-9A yesterday and all went well, thank you very much.
I now have a legal airplane and am preparing for the phase 1 flyoff.
However, the inspector said my seat belts, the 4 point style from Van's,
were not TSO'd and therefore not legal for me to use. He said I would have
to change them to a TSO'd brand before I could fly the plane. Has anyone
else run into this? I talked to Van's and their opinion was "it is an
experimental and therefore the non-FAA PMA seatbelts are acceptable." Do I
make the government happy and maybe avoid problems down the road by changing
them or continue with what I have installed?
Ken Hill
Plainfield, IN.
_________________________________________________________________
Find a local pizza place, music store, museum and more…then map the best
route! http://local.live.com?FORM=MGA001
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pbesing(at)yahoo.com
Guest
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| Posted: Mon Oct 23, 2006 4:20 pm Post subject: FAA seat belt requirement |
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No, No, No...it does not depend on the inspector. The inspector is WRONG if he says it has to be TSO'd. This has been hashed out many times with respect to IFR equipment requirements, that it has to be TSO'd in an experimental. There is not one thing on the aircraft that has to be TSO'd. Go find another inspector. Van's has sold thousands of seatbelts I'm sure, and it has never been a problem as far as I know.
Das Fed, you out there? You can clarify this, I'm sure.
Paul Besing
John Porter <december29(at)bellsouth.net> wrote:
[quote] Yep,
I have the same concerns as mine hasn't been inspected yet. I purchased two sets of 5 pt harnesses from Simpson that are super strong and certified for NASCAR. I'm hoping to not have a problem, I guess it depends on the inspector.
John
80002
[quote] ---
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rocketbob(at)gmail.com
Guest
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| Posted: Tue Oct 24, 2006 7:01 am Post subject: FAA seat belt requirement |
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I was told by an FAA FSDO inspector that he could not deny an airworthiness certificate based on the construction of the aircraft. To paraphrase, he said that as an experimental aircraft builder I have the perogative to test materials, components, construction techniques, etc. If I want to test a bolt to see how quickly it could fail in flight, that is my perogative as an experimental aircraft builder. These were his words, not mine. I can't imagine why seat belts would be any different than using non-certified grade 10 bolts to secure them to the airframe, as an example. One could easily argue that grade 10 bolts have much higher tensile strength compared to an AN bolt... and unless you have the paperwork for each bolt in your airplane how could you positively identify AN bolts..they could be counterfeited. This is one of those things that it all depends on who you talk to at the FAA. What I would tell the inspector, in a friendly way, is to have him show you where it says that the seatbelts *must* be TSO'ed... The question should end right there because he won't be able to.
Regards,
Bob Japundza
RV-6 flying F1 under const.
On 10/23/06, Paul Besing <pbesing(at)yahoo.com (pbesing(at)yahoo.com)> wrote: [quote]No, No, No...it does not depend on the inspector. The inspector is WRONG if he says it has to be TSO'd. This has been hashed out many times with respect to IFR equipment requirements, that it has to be TSO'd in an experimental. There is not one thing on the aircraft that has to be TSO'd. Go find another inspector. Van's has sold thousands of seatbelts I'm sure, and it has never been a problem as far as I know.
Das Fed, you out there? You can clarify this, I'm sure.
Paul Besing
John Porter < december29(at)bellsouth.net (december29(at)bellsouth.net)> wrote:
[quote] Yep,
I have the same concerns as mine hasn't been inspected yet. I purchased two sets of 5 pt harnesses from Simpson that are super strong and certified for NASCAR. I'm hoping to not have a problem, I guess it depends on the inspector.
John
80002
[quote] ---
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