Never before in the history of commercial aviation has this been an issue. There has never been a "liability" concern by air carriers or a litigation against an air carrier involving a pilot's personal equipment. Mysteriously, TSO'd headsets have become a big issue at a number of air carriers. This sudden interest appears to be coming in through the air carrier legal. The rumor is that a major headset manufacturer is trying to put a small one out of business.
This could turn into a HUGE issue for pilots and their employers if we let the attorneys start flying the airplanes. It is in ALL our best interests to not get blindsided, so I offer the following to address with your leadership in reference to TSO headset requirements:
There are a number of air carriers that require pilots to use TSO'd headsets, even though there is no FAR requirement. That's okay and certainly their call, but unfortunately, many ops manuals are poorly written and inaccurate. TSO requirements have also only being enforced piecemeal at many carriers. No one cared before, but with this new interest there's some holes that many air carriers will have to fill if they now require, or intend to require, TSO'd only headsets with any "chicken little" company attorneys involved:
1. Many ops manuals are written very poorly and partially or improperly reference TSO references and/or TSO requirements, e.g., ASA requires headsets that have been certified under TSO-C57a and C58a. They forgot C57, C58, and C139. FedEx requires TSO'd headsets that have 500 ohms impedance when TSO standards are 150-600 ohms.
2. There is a gross assumption by many that a "TSO" is a "TSO." There are 23 environmental testing categories for TSO certification. There is no set standard by the FAA as to which categories a manufacturer must test their product to, so there is a lot of latitude, e.g., the infamous Bose Aviation X headset was only tested in 9 of the 23 categories. It is also only certified to 15,000 MSL. Does your company have specific guidelines or will any TSO do? I only bring this up because the attorneys can have a field day with this.
3. There is no provision for third party modifications to TSO'd articles. Any modification by a third party voids a TSO, e.g., custom earmolds and substitution of the earpiece clip on Plantronics MS50 style headsets voids the TSO, per FAR Part 21, Subpart O. Those gel earmolds on the DCs? They gotta go. A local FAA POI saying "it's okay" won't hack it when the FARs are clear. Again, a field day for litigation.
4. What about ramper headsets? Normally, they are not TSO'd but plugged into the same system. For air carriers that let the passengers listen in to ATC communications, those supplied and personal headsets aren't TSO'd. Modifications to aircraft, e.g., SWA has installed Medlink headsets in all their aircraft, and they are not TSO'd.
5. If TSO'd headsets must be used, they require scheduled inspection, maintenance and authorized repair programs to retain TSO certification. There should also be appropriate entries in the MEL/CDL. Are those programs inplace at your carrier? Is it properly addressed in the MEL/CDL?
My 2 cents.
Mike
SWA (retired)
This could turn into a HUGE issue for pilots and their employers if we let the attorneys start flying the airplanes. It is in ALL our best interests to not get blindsided, so I offer the following to address with your leadership in reference to TSO headset requirements:
There are a number of air carriers that require pilots to use TSO'd headsets, even though there is no FAR requirement. That's okay and certainly their call, but unfortunately, many ops manuals are poorly written and inaccurate. TSO requirements have also only being enforced piecemeal at many carriers. No one cared before, but with this new interest there's some holes that many air carriers will have to fill if they now require, or intend to require, TSO'd only headsets with any "chicken little" company attorneys involved:
1. Many ops manuals are written very poorly and partially or improperly reference TSO references and/or TSO requirements, e.g., ASA requires headsets that have been certified under TSO-C57a and C58a. They forgot C57, C58, and C139. FedEx requires TSO'd headsets that have 500 ohms impedance when TSO standards are 150-600 ohms.
2. There is a gross assumption by many that a "TSO" is a "TSO." There are 23 environmental testing categories for TSO certification. There is no set standard by the FAA as to which categories a manufacturer must test their product to, so there is a lot of latitude, e.g., the infamous Bose Aviation X headset was only tested in 9 of the 23 categories. It is also only certified to 15,000 MSL. Does your company have specific guidelines or will any TSO do? I only bring this up because the attorneys can have a field day with this.
3. There is no provision for third party modifications to TSO'd articles. Any modification by a third party voids a TSO, e.g., custom earmolds and substitution of the earpiece clip on Plantronics MS50 style headsets voids the TSO, per FAR Part 21, Subpart O. Those gel earmolds on the DCs? They gotta go. A local FAA POI saying "it's okay" won't hack it when the FARs are clear. Again, a field day for litigation.
4. What about ramper headsets? Normally, they are not TSO'd but plugged into the same system. For air carriers that let the passengers listen in to ATC communications, those supplied and personal headsets aren't TSO'd. Modifications to aircraft, e.g., SWA has installed Medlink headsets in all their aircraft, and they are not TSO'd.
5. If TSO'd headsets must be used, they require scheduled inspection, maintenance and authorized repair programs to retain TSO certification. There should also be appropriate entries in the MEL/CDL. Are those programs inplace at your carrier? Is it properly addressed in the MEL/CDL?
My 2 cents.
Mike
SWA (retired)
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