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G-ZBKF.

AAIB Bulletin: 5/2021 G-ZBKF AAIB-26975

Safety Recommendation: 2021-017

2021-017: It is recommended that the Civil Aviation Authority require that passenger seats in commercial air transport aircraft are designed to minimise the chance of portable electronic devices becoming crushed in mechanisms.

The UK CAA design and certification specialists continue their attendance with the Society of Automotive Engineers (SAE) International Seat Committee meetings to discuss the entrapment of PED’s against the minimum performance standards for seats.

The UK CAA have issued CS-UKTSO (Certification Specification – United Kingdom Technical Standard Order) to amendment 18. The release at amendment 17, as discussed in the last CAA Update, was the most recent update applicable to seats (C127) and references Aerospace Recommended Practice (ARP) 5526 Rev D, remaining harmonised with EASA and FAA.

The current published recommended practice from SAE Aircraft Seat Design Guidance and Clarifications – ARP5526 Rev F, section 3.30 provides guidance relating to object entrapment but is not yet referenced in UKTSO-C127. The development of the future revision of this Technical Standard Order remains in work with EASA, FAA, and the UK CAA.

The UK CAA Cabin Safety Panel (Panel 11) of design and certification specialists have continued routine monthly engagement with EASA Panel 11, allowing coordination across a variety of cabin safety related topics, including PED entrapment. There has been active support from EASA with the discussions, and the UK CAA is now attending a further regular engagement meeting with EASA and FAA to, as far as possible, harmonise the position of the Regulators on seat safety.

Through these engagements, there has been meaningful progress on the actions regarding implementation of updated Certification Specifications (CS). EASA propose an update of CS 25 Acceptable Means of Compliance (AMC) to CS 25.601 General, and 25.1309 Equipment, systems and installations, to be included at the next release of CS 25 to amendment 29. The AMC will be updated to include reference to SAE AS6960, ‘Performance Standard for Seat Furnishings in Transport Aircraft’, Section 3.2.3 which addresses Object Entrapment in seat furnishings.

It is anticipated by EASA that the Notice of Proposed Amendment (NPA) introducing this enhancement to CS25 will be released in Early June 2026, which will be actively reviewed by UK CAA. The full release of CS25 amendment 29 by EASA is expected to be no later than January 2027. After release of EASA CS25 amendment 29, UK rulemaking will follow their publication to adopt UK Certification Specifications pursuant to Article 76(3) UK Reg (EU) 2018/1139.

The UK CAA will continue to monitor PED entrapment events through the requirements of assimilated Regulation (EU) No. 376/2014, through its engagement in the SAE seat committee and discussion with other regulators.

Considering the aforementioned, we propose the next update to AAIB is provided before the end of May 2027.

Adequate - Open

May 2027

AAIB Recommendation transmittal

Date

08/04/2021

Status

Open

CAA Initial Update

Date

14/07/2021

The CAA partially accepts this recommendation and supports the Safety Action taken by EASA in regard to requesting the SAE International Seat Committee develop design standards and/or recommended practices in relation to the design of seats for commercial air transport aircraft to minimise the chance of portable electronic devices becoming crushed in mechanisms.

Evolution of seat design standards will benefit from a global position and the CAA will work with the international regulatory community to review supporting evidence and global data that may support future amendments to global and UK Certification Specification and/or recommended practices.

Status

Open

AAIB Classification

Date

28/07/2021

Status

Partially Adequate - Open

CAA Update

Date

31/01/2021

The CAA has continued to strengthen the UK State of Design capability recruiting Design Specialists who will be able to engage with other authorities and seek participation in the SAE International Seat Committee to the design of seats for commercial air transport aircraft and where appropriate to make recommendations to minimise the chance of portable electronic devices becoming crushed in mechanisms.

The evolution of seat design standards will only be effective when agreed on a global basis. The UK CAA will continue to work with other lead international regulatory authorities to review and support future amendments and updates to the Certification Specifications and /or recommended practices.

The CAA continue to monitor similar PED entrapment events through the requirements of CAA Regulation (EU) 376/2014 (as retained and amended in UK domestic Law under the European Union withdrawal Act 2018) and through its engagement in the SAE committee. Currently the CAA do not envisage an immediate change to the Certification Specifications or Recommended Practices to aircraft seat design. We will continue to monitor progress and changes through the SAE working group and, on that basis, we would recommend that recommendation 2021-017 is now closed.

AAIB Classification

Date

01/03/2022

Status

Not Adequate - Open

CAA Update

Date

30/08/2022

As previously stated, the CAA has strengthened the UK State of Design capability by recruiting design specialists who are collaborating with other authorities and participating in the SAE1 International Seat Committee which is engaged in the design of seats for commercial air transport aircraft, and where appropriate, are making recommendations to minimise the chance of portable electronic devices becoming crushed in mechanisms.

The SAE seat committee and other international regulators recognise the risks that Portable Electronic Devices (PED) entrapment present and these risks have been discussed. The SAE seat committee have developed the following guidance material after presentations were provided by EASA on serious incident G-ZBKF: 
“Small objects brought by the passenger (i.e., cell phones, PC tablets, computers, wallets, chargers, cords, keys, etc.) shall not be able to migrate to a location in the seat or furnishing where the object may prevent the return of critical features to a TTL (Take off, Taxi, Landing) position or create a potential fire hazard due to being crushed.

Seat furnishings shall be designed so that small objects are easily retrievable if they migrate into the seat or furniture structure. This may be done by prevention (seals, brushes, or shrouds), or the object can fall into an accessible area for retrieval. For any area that allows items to fall to the floor under or around a Seat Furnishing, there must be adequate access (removal of panels by crew member, by extending features such as a legrest, etc.) to allow the crew member to retrieve them.”

Currently this guidance material is located within SAE AS6960 - Performance Standard for Seat Furnishings in Transport Aircraft. The intention from the international regulatory community is for this material to be included within the minimum performance standards for seats, within either SAE ARP5526 or SAE AS8049, which may be referenced in a future revision of CS-ETSO2 (ETSO-C127).

The CAA continue to monitor PED entrapment events through the requirements of CAA Regulation UK Reg (EU) 376/2014 (as retained and amended in UK domestic Law under the European Union withdrawal Act 2018) and through its engagement in the SAE seat committee. The next steps for the SAE committee is to revise SAE ARP5526 or AS8049 after which the CAA would consider how to adopt the revised standards.

We will continue to monitor progress and changes through the SAE working group, with the next committee meeting taking place in March 2023. In addition, our design and certification specialists are raising the risks of PED entrapment with UK state of design organisations for their awareness and consideration during their certification projects.

In light of the aforementioned, we propose the next update to AAIB is provided before the end of April 2023.

AAIB Classification

Date

18/10/2022

Status

Partially Adequate - Open

CAA Update

Date

27/04/2023

The UK CAA design specialist has now started to attend SAE1 International Seat Committee meetings to raise and discuss the entrapment of Portable Electronic Devices (PED) and how this can be mitigated.

The committee have agreed to review and discuss the minimum performance standards for seats, with the view to amending either SAE ARP5526 or SAE AS8049, which may be referenced in a future revision of CS-ETSO2 (ETSO-C127).

The CAA will continue to monitor PED entrapment events through the requirements of CAA Regulation UK Reg (EU) 376/2014 (as retained and amended in UK domestic Law under the European Union withdrawal Act 2018) and through its engagement in the SAE seat committee.

Considering the aforementioned, we propose the next update to AAIB is provided before the end of November 2023.

AAIB Classification

Date

23/06/2023

Status

Partially Adequate - Open

CAA Update

Date

23/11/2023

The UK CAA design and certification specialists are actively attending the SAE1 International Seat Committee meetings to discuss the entrapment of Portable Electronic Devices (PED)and how this can be mitigated. In addition, guidance is being drafted to prevent entrapment of occupant limbs within seat mechanisms, and many of the mitigating factors would have a positive impact on PED entrapment.

The committee are reviewing the minimum performance standards for seats, with the view to taking recently published recommended practise from SAE ARP5526 Rev F, section 3.30(object entrapment) and including as a requirement within SAE AS8049, which would be referenced in a future revision of CS-ETSO2 (ETSO-C127). AS 8049 is currently being reworked to convert the document into a set of requirements shown in a compliance matrix format.

For reference, the current revision of seat TSO within the UK system is currently C127b, which references ARP5526 Rev C. We are currently consulting on the introduction of C127c, which references ARP5526 Rev D, which aligns us with both EASA and the FAA. Note that object entrapment is not introduced until ARP5526 Rev F, so this update would not levy any requirements relating to object entrapment.

It should also be noted that referencing object entrapment within the TSO minimum performance standards would only be applicable to the equipment so would not fully mitigate scenarios involving other installations (e.g. seat furniture, monuments etc). To fully mitigate this, we are investigating including requirements at the installation level (e.g. CS-23/25/27/29 etc).

The UK CAA specialists have also started to engage with other regulators with a view to harmonise the approach to introducing requirements to prevent PED entrapment. The FAA have recently released an AMOC (https://www.govinfo.gov/content/pkg/FR-2023-08-04/pdf/2023-16094.pdf) which allows the use of SAE AS6960, section 3.2.3 (object entrapment) as an acceptable means of compliance to 25.601 and 25.1301(a)(4). EASA are considering other options such referencing PED entrapment (not just for seats) in the next issue of CS25 as an AMC to 25.601 and/or 25.1301(a)(4) and/or referencing ARP5526 Rev F 3.30 in their up-issue of CS-ETSO 127c to CS-ETSO 127d as an amendment to the standards. It is the UK CAA intention to work closely with EASA as UK CAA share concurrence in the approach which will ensure harmonisation.

The UK CAA will continue to monitor PED entrapment events through the requirements of CAA Regulation UK Reg (EU) 376/2014 (as retained and amended in UK domestic Law under the European Union withdrawal Act 2018), through its engagement in the SAE seat committee and discussion with other regulators.

In light of the aforementioned, we propose the next update to AAIB is provided before the end of May 2024.

CAA Update

Date

17/05/2024

The UK CAA design and certification specialists are actively attending the SAE1 International Seat Committee meetings to discuss the entrapment of Portable Electronic Devices (PED)and how this can be mitigated. In addition, guidance is being drafted to prevent entrapment of occupant limbs within seat mechanisms, and many of the mitigating factors would have a positive impact on PED entrapment.

The committee are reviewing the minimum performance standards for seats, with the view to taking recently published recommended practise from SAE ARP5526 Rev F, section 3.30(object entrapment) and including as a requirement within SAE AS8049, which would be referenced in a future revision of CS-ETSO2 (ETSO-C127). AS 8049 is currently being reworked to convert the document into a set of requirements shown in a compliance matrix format.

Since the last update, the CAA have revised the Certification Specification (CS-ETSO) to amendment 17, which introduces a new revision of seat TSO within the UK system (C127c), which references ARP5526 Rev D. This now fully aligns us with both EASA and the FAA. Note that object entrapment is not introduced until ARP5526 Rev F, so this update has not levied any requirements relating to object entrapment.

It should also be noted that referencing object entrapment within the TSO minimum performance standards would only be applicable to the equipment so would not fully mitigate scenarios involving other installations (e.g. seat furniture, monuments etc). To fully mitigate this, we continue to investigate introducing requirements at the installation level (e.g. CS23/25/27/29 etc).

The UK CAA specialists are now engaged with other regulators with a view to harmonise the approach to introducing requirements to prevent PED entrapment. The FAA have released an AMOC (https://www.govinfo.gov/content/pkg/FR-2023-08-04/pdf/2023-16094.pdf) which allows the use of SAE AS6960, section 3.2.3 (object entrapment) as an acceptable means of compliance to 25.601 and 25.1301(a)(4). EASA are considering other options such referencing PED entrapment (not just for seats) in the next issue of CS25 as an AMC to 25.601 and/or 25.1301(a)(4) and/or referencing ARP5526 Rev F 3.30 in their up-issue of CS-ETSO 127c to CS-ETSO 127d as an amendment to the standards. The UK CAA continue to work closely with EASA as UK CAA share concurrence in the approach which will ensure harmonisation.

The UK CAA will continue to monitor PED entrapment events through the requirements of assimilated Regulation (EU) No. 376/2014, through its engagement in the SAE seat committee and discussion with other regulators.

In light of the aforementioned, we propose the next update to AAIB is provided before the end of May 2025.

AAIB Classification

Date

30/05/2024

Status

Partially Adequate - Open

CAA Update

Date

29/05/2025

The UK CAA design and certification specialists remain active with their attendance with the Society of Automotive Engineers (SAE) International Seat Committee meetings to discuss the entrapment of PED’s against the minimum performance standards for seats.

With the view to taking recently the published recommended practise from SAE Aircraft Seat Design Guidance and Clarifications – ARP5526 Rev F, section 3.30 (object entrapment) and including as a requirement within the SAE Performance Standard for Seats in Civil Rotorcraft, Transport Aircraft, and General Aviation Aircraft - AS8049E, which would be referenced in a future revision of Certification Specification – European Technical Standard Order (CS-ETSO) (ETSO-C127).

The CAA have issued CS-ETSO to amendment 17, which introduced a new revision of seat TSO within the UK system (C127c), which references ARP5526 Rev D. This aligns the CAA with both EASA and the FAA. Note that object entrapment is not introduced until ARP5526 Rev F, so this update has not included any requirements relating to object entrapment.

There has been limited progress on the actions regarding implementation of updated Certification Specification (CS) requirements over the last 12 months. This is partly due to the limited attendance of other regulatory Authorities at the monthly cabin safety technical coordination meetings. Full engagement with these meetings has now restarted which has enabled us to progress this topic and EASA are also now willing to discuss their plans for introducing rulemaking (potentially as an AMC to CS 25.601 General).

If this is successful, the UK rulemaking would follow their publication to adopt UK Certification Specifications pursuant to Article 76(3) UK Reg (EU) 2018/1139.

The UK CAA will continue to monitor PED entrapment events through the requirements of assimilated Regulation (EU) No. 376/2014, through its engagement in the SAE seat committee and discussion with other regulators.

In light of the aforementioned, we propose the next update to AAIB is provided before the end of May 2026.

AAIB Classification

Date

14/07/2025

Status

Adequate - Open

CAA Update

Date

01/06/2026

The UK CAA design and certification specialists continue their attendance with the Society of Automotive Engineers (SAE) International Seat Committee meetings to discuss the entrapment of PED’s against the minimum performance standards for seats.

The UK CAA have issued CS-UKTSO (Certification Specification – United Kingdom Technical Standard Order) to amendment 18. The release at amendment 17, as discussed in the last CAA Update, was the most recent update applicable to seats (C127) and references Aerospace Recommended Practice (ARP) 5526 Rev D, remaining harmonised with EASA and FAA.

The current published recommended practice from SAE Aircraft Seat Design Guidance and Clarifications – ARP5526 Rev F, section 3.30 provides guidance relating to object entrapment but is not yet referenced in UKTSO-C127. The development of the future revision of this Technical Standard Order remains in work with EASA, FAA, and the UK CAA.

The UK CAA Cabin Safety Panel (Panel 11) of design and certification specialists have continued routine monthly engagement with EASA Panel 11, allowing coordination across a variety of cabin safety related topics, including PED entrapment. There has been active support from EASA with the discussions, and the UK CAA is now attending a further regular engagement meeting with EASA and FAA to, as far as possible, harmonise the position of the Regulators on seat safety.

Through these engagements, there has been meaningful progress on the actions regarding implementation of updated Certification Specifications (CS). EASA propose an update of CS 25 Acceptable Means of Compliance (AMC) to CS 25.601 General, and 25.1309 Equipment, systems and installations, to be included at the next release of CS 25 to amendment 29. The AMC will be updated to include reference to SAE AS6960, ‘Performance Standard for Seat Furnishings in Transport Aircraft’, Section 3.2.3 which addresses Object Entrapment in seat furnishings.

It is anticipated by EASA that the Notice of Proposed Amendment (NPA) introducing this enhancement to CS25 will be released in Early June 2026, which will be actively reviewed by UK CAA. The full release of CS25 amendment 29 by EASA is expected to be no later than January 2027. After release of EASA CS25 amendment 29, UK rulemaking will follow their publication to adopt UK Certification Specifications pursuant to Article 76(3) UK Reg (EU) 2018/1139.

The UK CAA will continue to monitor PED entrapment events through the requirements of assimilated Regulation (EU) No. 376/2014, through its engagement in the SAE seat committee and discussion with other regulators.

Considering the aforementioned, we propose the next update to AAIB is provided before the end of May 2027.