If it’s “off the shelf” it’s off the list. That’s the policy some completion and refurbishment centers have adopted recently as the cost and time required for FAA approval of commercial off-the-shelf (cots) cabin items has spiraled beyond reason.
The problem began about 18 months ago. As the demand for business aircraft picked up, so did customer demand for commercial off-the-self items in the cabin, from Sony DVD players to Krups espresso makers.
One design engineer recalls a widebody executive/VIP interior that is “full of cots [items]–can openers, blenders, microwave ovens, dishwashers–and he bought six of everything to be sure that if something broke, it could be replaced without going through the entire certification process that a new item would require.”
Even as the demand for cots items grew, the FAA was looking at a $30 million budget shortfall for 2005 and limitations on backfilling of vacated job positions. Some “prioritizing of the workload” was required, and the cots certification process came out at the lower end of the list.
Since last January, the FAA has required a 90-day review period for any cots item being considered, during which the agency may approve the request and offer guidance with regard to the certification process. “All applications are taken on a case-by-case basis,” said an FAA spokeswoman, “and applicants with a proven track record for meeting deadlines are given priority.” The spokeswoman said the idea is not to deny these applications. She noted, however, that it is a possibility.
“The FAA isn’t the bad guy,” said Fred Nolfe, manager of aircraft interior specifications and design for Dassault Falcon Jet in Little Ferry, N.J. “At the same time,” he added, “it has definitely created a problem for the interior completion and refurbishment industry.”
It’s problem enough that Dassault is “currently taking a ‘no cots’ stance,” said Nolfe. “We would certainly accommodate a customer who absolutely wanted a cots item,” he added, “but we are definitely not encouraging them.” Dassault annually builds and installs interiors in some 50 new Falcons at its completion and refurbishment facilities in Little Rock, Ark.
Interior designers and engineers emphasize that it isn’t just the time required
for the testing necessary to certify a cots item, but the delay has a ripple effect on everything else in the cabin. The cabinetry, wiring and ventilation designs all have to wait for approval of the cots items.
While the time required to certify a cots item is lengthy, the cost too is likely to make a customer wince. A commercial off-the-shelf microwave may sell for $99 at the local Sears. But by the time the item has been put through the entire program required for FAA certification–burn, environmental, vibration, crash, altitude, even fungus testing–the cost might be in the $40,000 range.
Also to be considered is the fact that if the item breaks, replacement with even the same cots item will require a new series of tests before certification. Steven Davison, director of strategic sourcing for Raytheon Aircraft, estimates that testing requirements have doubled in the last 10 years. For some cots items, Raytheon relies on independent completion and refurbishment centers. “Our after-market relationships are such that we can send an operator to an authorized service center such as Duncan Aviation for cots items.”
“The regulatory environment is getting tighter,” said Patrick Altuna, executive v-p of Landmark’s Associated Air Center in Dallas. “We try to minimize the number of cots, but sometimes it’s unavoidable,” he explained. “There are no fax machines that have already been certified, so we have to purchase a cots machine.”
At other times, it’s the customer’s choice, and then the work begins. In one instance, said Altuna with a wry chuckle, it was a karaoke machine.
Meanwhile, completion and refurbishment centers–independents and OEMs alike– are moving away from cots items in favor of those already FAA-certified and built for use aboard aircraft.
Companies such as Audio International of Little Rock, Ark., provide an extensive line of audio/video entertainment components and complete entertainment systems. TIA Products of Sterling, Va., specializes in appliances, from ovens and coffee makers to refrigerators and water heaters.
Even so, there will always be customers whose desires are particularly specific, and the only solution is a commercial off-the-shelf system. “The customer is always right,” said one interior designer. “Provided they have the time and the money.”