The reporter expressed a safety concern related to the passenger safety in the refurbished [aircraft type] operated by [operator].
The reporter advised that in the economy section of the aircraft, there is a removable iPad entertainment pack in the back of each seat. These have to be removed and stowed for take-off and landing. This left an exposed metal slide-able holder, which is at approximately adult forehead height and would do considerable damage in the event of a sudden braking incident or an accident.
Operator's response (Operator 1)
The (mini iPad) personal electronic device (PED) holder was a design modification introduced on the [aircraft type] domestic economy class seats under a European Aviation Safety Agency (EASA) supplemental type certificate as part of the [aircraft type] reconfiguration program. The function of the device is shown in the pictures below. Additionally, with this design change the seat has been qualified to a new EASA European Technical Standing Order.
The Device Retainer (clip) is machined from 6061-T6 aluminium, which is glass beaded with a polane [polonium hydride] painted finish.
The Device Retainer (clip) is inside the head arc radius as defined in Joint Aviation Requirement (JAR) 25 Change 13, Section 2, ACJ 25.785(c), see screen shot below from the [chair type] diagram shown below:
De-lethalisation compliance was substantiated through head injury criterion (HIC) testing per Federal Aviation Administration (FAA) Policy ANM-03-115-31.
During the first dynamic test case (V14-1029), the device retainer broke during impact, and detached from the seat, leaving a sharp protrusion, resulting in a failed test. As a result, the device retainer was redesigned via [number] to include a constant material thickness throughout the radius portion of the device as shown in the extract below. This redesign allowed the device to bend flat against the seat back without breaking.
This design change was then qualified through another dynamic test case, where the HIC test resulted in a pass.
Regulator's response (Regulator 1)
CASA has reviewed the matters raised in the REPCON and is satisfied with the operator’s response.
CASA was not involved in the certification of this seat or feature as the product was approved by a recognised country under Civil Aviation Safety Regulation 1998 (CASR) 21.010B, and thus automatically accepted under CASR 21.502(1). CASA has been alerted to this design feature previously. The operator is technically correct and in compliance with current regulations and policy.