Bose QC2 w/ Ufly Mic - earbuds now required by FAA

[Weasil]

Friday, February 1, 2008
http://www.aviationtoday.com/av/categories/military/18859.html
Opinion Allows Flexibility In Pilot Headsets

Airline pilots have embraced a wide variety of active noise reduction (ANR) products to improve communications and protect their hearing in relatively high-noise cockpits such as the ubiquitous Boeing 737. A popular ANR application combines the Bose QuietComfort 2 (QC2) headphones with the UFlyMike boom microphone adapter (UFM) designed by retired Southwest captain Mike Lackey.
The UFlyMike adapter plugs into the existing headphones jack without modifications, says UFlyMike, based in Colorado Springs, Colo. The adapter had passed testing requirements of Technical Standard Order (TSO)-C139 and was awaiting FAA certification.
Several thousand airline pilots have found this combination offers optimum noise reduction while providing exceptional clarity in the 83 to 88 dBA ambient noise environment found in the 737 and several other aircraft.
In early 2007, FAA inspectors within the certificate management offices of two major airlines objected to pilot use of the QC2/UFMs, ostensibly claiming that airline pilots could use only headsets authorized by FAA TSO. Eight months after receiving a request for clarification, the FAA’s Office of the Chief Counsel responded that federal regulations do not prohibit airline pilots from using non-TSO’d products to supplement already-installed communication equipment that meets minimum requirements.
According to a letter dated Oct. 12, 2007, and signed by Rebecca B. MacPherson, FAA assistant counsel for regulations: "There is no specific requirement that aircraft operating under 14 CFR, part 121 be equipped with headsets or that flight crewmembers use headsets produced under a TSOA (TSO authorization).... Use of a non-approved headset to supplement the operation of an aircraft equipped in accordance (with) those regulations would not... be considered a regulatory violation."
Airline pilots do not have to use headsets at all, but they do have to use boom microphones below 18,000 feet. One major airline’s minimum equipment list (MEL) allows pilots to substitute their own personal equipment for installed equipment, and Boeing’s 737 operating manual allows the use of "any standard microphone." In this context, "standard" is permissive; it means "commonly used or supplied."
Some FAA inspectors object to use of the QC2s because the headphones require some minimum voltage from one AAA battery to keep the earcup circuit closed. They argue that if the battery dies, the earcups also die and the pilot cannot maintain communication. FAA "is particularly concerned," MacPherson said, "that Active Noise Reduction headsets and headset adapters used by flight crewmembers that rely on battery power are subject to failure when internal or externally connected batteries discharge under normal use. These headsets therefore may not be capable of providing the continuous, uninterrupted communications capability necessary for safe operation of the aircraft."
Pilots who use the QC2/UFM setup counter that QC2s provide plenty of warning beforehand, while substantially reducing communication-related risks.
First, a steady red LED in the right earcup starts flashing when a minimum battery life of five hours remains. Second, if the pilot ignores the flashing LED, he cannot miss obvious aural changes when the ANR circuitry starts cutting out as battery voltage approaches zero. Third, battery condition has no effect on the boom microphone. Finally, should the earcup circuit open, the pilot maintains communication by turning up the cockpit speaker and pulling back one earcup just as he would with any other headset-earpiece failure.
Using the risk assessment guidelines contained in FAA Advisory Circular 120-92 to assess the QC2/UFM setup reveals that the likelihood of failure is very low and the severity of consequences borders between negligible and minor, which places their use well within an acceptable risk range. Compared with the missed or misunderstood communications that occur on every flight, pilots find the QC2/UFM benefits far outweigh the risks. — Mitch Whatley
Mitchell R. Whatley is an attorney in Southlake, Texas, and a 737-800 captain with a major U.S. airline.
(Contacted by Avionics, Bose Corp. said it does not endorse the use of the QC2s by pilots, or their compatibility with another manufacturer’s product. The company issued this statement:
"The Bose QuietComfort 2 headphones are designed for noise reduction while listening to entertainment channels in air transport aircraft, such as audio or movie sound channels, and should not be used as a headset for communicating with air traffic control. They are not engineered to meet the needs of pilots and do not meet civil aviation authority standards for communication headsets. Given this, we can not endorse the inclusion of the Bose QuietComfort 2 headphones in your story on aviation headsets in this context or in regards to its compatibility with another manufacturer’s product, like UFlyMike.
The UFlyMike product enables an external source to provide music playback into the QC2 headphones without priority muting or control of received aircraft radio, air-traffic control directions or cockpit intercom communications. This design may allow music to mask critical cockpit communications.
Bose also does not recommend this type of usage with the QC2 headphones because no incoming audio will be heard with a discharged or improperly installed battery. This shortcoming could result in the potential of missed air-traffic control communications while piloting an aircraft. For pilot use, we recommend the Bose Aviation Headset X. The product is TSO-approved and features a microphone with the appropriate power and intelligibility for transmission and reception of flight information. It is engineered to withstand the altitude and temperature conditions common in non-commercial aircraft.")

 

[Salukipilot4590]

I don't know about you guys but when I was originally in the market for a new headset I narrowed the options down to the Zulu, QC2-UFM, X, and DC X11. Having tested out the X11 and found that it was ultimate sht I decided to go with the X since I'd flown with it for a while back at SIU.

Can't beat a B-X! (Unless you get word that you're getting furloughed and don't have the money for one anymore. Then, yeah you can beat an X...with nothing.)

 

[CA1900]

Why don't you cheap fracks just buy some real honest to God aviation headsets in the first place?

Because it's the most comfortable headset I've ever worn. More comfortable than the Bose X by far, for me.

You'd only have spent $200 or so more on the bose x...

If by $200, you mean $500, then you're absolutely right.

Not to mention the qc2 eats batteries...

For my use, it "eats" a single AAA battery a month. I think I can fit it into the budget.

 

[Weasil]

k...so can you just plug your regular earbuds (ipod ones) into the qc2 for the backup...or do you have to buy the ones sold by uflymike?

Here's what the FAA says

In order for this combination to meet TSO requirements, the Bose QC2 Headset/UFlyMike combination must be used in conjunction with the TSO’d earbuds

This was verified by a phone call to Mike (at UFM).

I am thinking about just switching to the bose x, but that thing looks big a heavy like the david clarks...

 

[asapilot]

Here's what the FAA says

In order for this combination to meet TSO requirements, the Bose QC2 Headset/UFlyMike combination must be used in conjunction with the TSO’d earbuds

Yes, that is what the FAA says about them meeting TSO requirements, but not about them meeting FAR requirements. Remember, TSO is a manufacturing standard.

This doesn't mean you can't use them, you just need to know what your company and the aircraft it operates require.

 

[Sioux115]

It seems like another witch hunt by the FAA. We just got notice yesterday at QX from our friendly FAA Certification Management reminding us "that the use of a non-TSO’d headset, whether it be the headset or microphone all or in part, is not acceptable."

It goes on to state,"The FAA will begin emphasizing the inspection of headsets during routine en-route inspections to insure compliance with this policy. Each pilot must be able to show an inspector that the headset / microphone being used is TSO’d, either via suitable markings on the headset or other official documentation. Failure to show a properly approved headset may subject the user to additional action."

 

[Weasil]

Yes, that is what the FAA says about them meeting TSO requirements, but not about them meeting FAR requirements. Remember, TSO is a manufacturing standard.

This doesn't mean you can't use them, you just need to know what your company and the aircraft it operates require.

This email came from the company - It was from the Chief Pilot. They are instructing us to use only TSO'd equipment. As you say, the FAR's may not require that but the company now does. The FAA has reinterpreted their own regulations - they can do that. In fact following a recent ruling by an ALJ, the FAA can reinterpret the meaning or intent of their regulations post incident. IE: You may have thought you were complying with the letter of the law, but after you get violated they can say, yes I know we issued an interpretation stating you can use non-TSO'd headsets but we have changed our minds.

Judging by the email from QX, I'd say they are going to go after other brands that are non-TSO'd also.

 

[BigLebowski]

Here's what the FAA says [/FONT]

This was verified by a phone call to Mike (at UFM).

I am thinking about just switching to the bose x, but that thing looks big a heavy like the david clarks...

yeah used to wear the BoseX myself; overkill in the crj and very very heavy on those 3+ hour legs. I switched to the clarity aloft...works as well as the BoseX and weighs 1.2 ounces.

The only problem is the ear plugs provide such a good seal in the ear that when you have a little bit of sinus/inner ear issues it makes "equalizing" a real pain in the a**

 

[belchfire]

For me it has nothing to do with being cheap, I like them. Don't want to use anything else. They work great in the CJ-1 and I don't like Bose 10's. I also have Telex 750's and David Clark's.

That's a good enough reason...I used to use Lightspeeds-I preferred the audio on them to the big Bose. Being out of the Jball I'm using Sennheiser now. Not as expensive as the TSO'd Bose, just as good with outstanding transmit and receive audio. They even have a model you can plug your ipod or cell phone into if you want to spend an extra $150...

I wish I had never wasted the my (not trust fund as someone accused) money on those crappy Telex sets-see, I went cheap on headsets once too. Dismal audio quality. Light and cheap are the only positive qualities Telex can offer. I did get my first set of D-C's as a Christmas gift-still have them too, on the off chance I ever get to fly a little bug smasher again...

Bottom line is that you get what you pay for. You wanna save a few bucks you are going to get some kind of compromise. You'll end up better off in the long run just spending the money up front on a quality product that meets the requirements of the FAA and your GOM.

 

[ackattacker]

There is, quite simply, no regulatory requirement to use headsets at all. Only a boom microphone below 18,000 feet. And the boom microphone portion of the UFlyMike is TSO'd, not that it even matters.

The more you read about this the more ridiculous you realize it is. Individual FSDO cannot make up requirements which don't exist. There is no way to "interpret" into existence a new regulation.

 

[asapilot]

This email came from the company - It was from the Chief Pilot. They are instructing us to use only TSO'd equipment. As you say, the FAR's may not require that but the company now does. The FAA has reinterpreted their own regulations - they can do that.

I'm not sure the FAA has reinterpreted their own regulations. Without knowing, it's hard to say which came first.

1) If the company is now requiring you to use TSO'd equipment per the approved manuals, then yes, it's regulatory but it was the company's doing, not the FAA's. The FAA can't dictate what is put in your manual outside of the regulatory requirements.

2) If the FAA has told your company that they must use TSO'd headsets, then I would go to your Chief Pilot or DO and request some documentation. The FAA can't make up a rule, they have to have some basis for requiring it of the company and I'd be very surprised if the company just accepted it without requesting documentation themselves.

I do happen to know it was an inspector from the QX office that built up this issue again recently.

 

[mblackey]

It's amazing how much better educated we have become over the past two years since the headset debacle began. A few points I'd like to emphasize:

There is no FAA requirement to use a TSO'd headset or microphone.

Neither Bombardiers nor Boeings were type certified with headsets. If it were, they would be "installed" equipment, maintenance would own them, and only maintenance could install/remove them from the aircraft. Second, rampers and maintenance couldn't use non-TSO'd headsets (which they do).

FAA POIs are not authorized to interpret TSO Authorizations.

FAA CMOs are not authorized to evaluate operational policies of air carriers.

The ONLY valid verification that an article is TSO'd is the FAA Authorization Letter and/or FAA database (which is miserably inaccurate). The sticker on a TSO'd article is NOT a valid verification.

Components/parts of a TSO'd article do not require separate TSO Authorizations or TSO stickers.

Requiring pilots to provide proof of TSO Authorization is unprecedented. If it's that important, headsets should belong to maintenance, and there should be proper documentation and inspections conducted.

TSO Authorizations are not standardized; which criteria are met by a manufacturer and which are required by the FAA to grant a TSO Authorization is totally random.

TSO test criteria are not public domain, i.e., they are not available to 99.9% of us, including the FAA.

If TSO'd only headsets are required, then 3rd party non-TSO'd modifications to TSO'd headsets are also longer authorized. Examples: custom earmolds, ANR inserts for DCs, any repair done on any headset that was not done by a certified facility and accompanied by an FAA Form 8130-3.

As far as the UFlyMike:

The TSO'd configuration is the UFM with earbud and a headband.

The earbud we sell is the only authorized earbud, since it was TSO tested. Any earbud with a 2.5mm plug will work. If you already own a UFM or purchase a new one, we sell the earbud at our cost ($79 separate, $75 with a UFM).

If you use a QC2 as a headband, it doesn't matter if it's on or off. The QC2 passed TSO test requirements powered on, even though we only list it as a mechanical headband in our TSO.

THE ONLY WAY TO CORRECT THIS FIASCO OVER HEADSETS IS TO CONFRONT THE IGNORANT. IF YOU KNOW OF SOMEONE IN AN OFFICIAL CAPACITY WHO NEEDS TO BE CONFRONTED, LET US KNOW, PLEASE.

Mike
UFlyMike LLC

 

[DoinTime]

It's amazing how much better educated we have become over the past two years since the headset debacle began. A few points I'd like to emphasize:

There is no FAA requirement to use a TSO'd headset or microphone.

Neither Bombardiers nor Boeings were type certified with headsets. If it were, they would be "installed" equipment, maintenance would own them, and only maintenance could install/remove them from the aircraft. Second, rampers and maintenance couldn't use non-TSO'd headsets (which they do).

FAA POIs are not authorized to interpret TSO Authorizations.

FAA CMOs are not authorized to evaluate operational policies of air carriers.

The ONLY valid verification that an article is TSO'd is the FAA Authorization Letter and/or FAA database (which is miserably inaccurate). The sticker on a TSO'd article is NOT a valid verification.

Components/parts of a TSO'd article do not require separate TSO Authorizations or TSO stickers.

Requiring pilots to provide proof of TSO Authorization is unprecedented. If it's that important, headsets should belong to maintenance, and there should be proper documentation and inspections conducted.

TSO Authorizations are not standardized; which criteria are met by a manufacturer and which are required by the FAA to grant a TSO Authorization is totally random.

TSO test criteria are not public domain, i.e., they are not available to 99.9% of us, including the FAA.

If TSO'd only headsets are required, then 3rd party non-TSO'd modifications to TSO'd headsets are also longer authorized. Examples: custom earmolds, ANR inserts for DCs, any repair done on any headset that was not done by a certified facility and accompanied by an FAA Form 8130-3.

As far as the UFlyMike:

The TSO'd configuration is the UFM with earbud and a headband.

The earbud we sell is the only authorized earbud, since it was TSO tested. Any earbud with a 2.5mm plug will work. If you already own a UFM or purchase a new one, we sell the earbud at our cost ($79 separate, $75 with a UFM).

If you use a QC2 as a headband, it doesn't matter if it's on or off. The QC2 passed TSO test requirements powered on, even though we only list it as a mechanical headband in our TSO.

THE ONLY WAY TO CORRECT THIS FIASCO OVER HEADSETS IS TO CONFRONT THE IGNORANT. IF YOU KNOW OF SOMEONE IN AN OFFICIAL CAPACITY WHO NEEDS TO BE CONFRONTED, LET US KNOW, PLEASE.

Mike
UFlyMike LLC

I think most people would prefer it if you spent your time making a fail safe product rather than trying to justify the deficiencies of your current product.

 

[mblackey]

I forgot to mention: TSO's have nothing to do with reliability, safety or performance.

 

[goodgig]

So do you have to have the buds available, or do you have to use them constantly?