FLAMMABILIT Y
FLAMMABILIT Y TESTING
aircraftinteriorsinternational.com
NOVEMBER 2019 051
The smoke
release regulations
remain a key
factor in
cabin safety
upon aircraft manufacturers to keep smoke
requirements in their products once the FAR 25
regulations are changed.”
UNPREDICTABILITY
At the heart of this issue is the unpredictability of
materials’ reactions to flame, not just alone but as part of
combined assemblies. Even when materials pass tests as
separate elements, they may fail tests when combined.
As Morgan explains, this dynamic also applies
particularly to his smoke emissions concerns: “In
combined assemblies, it has been my experience that
smoke release is very much a matter of the materials
selected and the environment that they are in. To
completely eliminate smoke requirements would not
be good,” he says.
Morgan expressed this concern in his comment to
the NPRM, stating, “I would strongly encourage the FAA
to keep the smoke regulations in place for now due to the
proven need to keep smoke release low to see escapes,
and instead have the FAA set up another research group
to see what the real amount of smoke release should be
across materials. I’m in favour of regulatory reform to
simplify testing while maintaining safety, but as proposed,
I believe some unacceptable materials will slip through
onto aircraft once the smoke requirement is removed.”
Predicting these types of unexpected interactions
requires a different specialisation than most OEMs have
in-house.
“It has been my experience across many fire-safe
materials that companies rely upon regulations to set
minimum levels of fire safety,” Morgan says. “Commercial
material producers do not keep fire safety scientists on
staff to guide them about product liabilities in fire events
– they rely upon government scientists and regulators
to guide them.”
And that is the main challenge of moving away from
prescriptive regulations on fire testing. “There are two
ways that people might handle performance-based
standards for fire testing. Some people would be proactive
and test thoroughly because they don’t want to do
ABOVE AND BELOW: AIRBUS HAS
GRANTED TESTING APPROVALS
TO SKANDIA’S LABORATORIES
FOR FLAMMABILITY
ENGINEERING AND LAB TESTING,
AS WELL AS FOR ENGINEERING
AND BURNING AIRCRAFT CABIN
MATERIALS TO TEST TO HEAT
RELEASE, SMOKE DENSITY AND
TOXICITY STANDARDS
“ I believe some unacceptable
materials will slip through
onto aircraft”
something that could cause a problem,” Morgan says.
“Others would go by what works for them, even if they
are not expert in the area. It is important to do due
diligence, even you feel your product is safe. In my
opinion, it’s asking too much of OEMs and vendors to
take on that burden. With prescriptive regulations, the
government sets those requirements since they have
the data or past crash event experience to back it up.”
Morgan allows that any new
technologies that change the
risk landscape would warrant
the ‘threat based’ approach
to regulation.
/aircraftinteriorsinternational.com