FAA Significant Standards Differences (SSD)

General Comments and Assumptions:

This following list of SSD regulations that require direct title 14, Code of Federal
Regulations (14 CFR) part 25 compliance is based on the 14 CFR Part 25/Certification
Specifications (CS) 25 Amendment pair noted here:

Amendment Pair:
14 CFR Part 25 Amdt. 25-146, effective 11/19/2018
CS 25 Amdt. 25, effective 06/24/2020.

1. This SSD list includes only regulations where compliance with the CS minimum
standard would not be accepted by the FAA. (NOTE: The SSD list is identified as
the “FAA-SSD” list to clarify that it is only intended for FAA validations of EASA
products).

2. Only regulations that have a regulatory difference will be included in the SSD list.
Identical regulations that have differences in guidance/interpretive material will be
addressed, if required, as separate Safety Emphasis Items (SEI).

3. The SSD definition is taken from the Technical Implementation Procedures (TIP)
Revision 6, Section 3.5.13.2:

An SSD must be identified when in order to meet the minimum standard of the
VA relative to that of the CA, the difference requires type design changes,
approved manual changes, additional of different demonstrations of compliance,
or the imposition of operational limitations.

(a) This impact determination is accomplished by the VA for each VA

standard, by comparison to the corresponding CA standards.

(b) Multiple CA standards, taken together may satisfy the objective of a

single VA standard; in such cases, an SSD need not be identified.

4. CS 25 does not provide standards for reciprocating-powered airplanes, skiplanes,

amphibians, flying boats, or airplanes with standby rocket engines. Differences
concerning standards for those airplanes are not reflected in this list.

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 FAA Significant Standards Differences (SSD)

Subpart A
25.2 CS does not specify any retroactive requirements
25.3 14 CFR 25.3 requires compliance with Appendix K for ETOPS type
design approval. Neither 14 CFR 25.3 nor Appendix K have a
corresponding CS.
Subpart B
25.21(g)(3) EASA permits use of comparative analysis; CFR does not.
25.21(g)(4) EASA permits use of comparative analysis; CFR does not.
Subpart C
25.365 14 CFR25.365 includes structural design considerations for operation
above 45,000 feet.
25.562(b) 14 CFR 25.562(b) applies to all seats; CS excludes flight deck crew
seats mounted in the forward conical area of the fuselage from floor
warpage test requirements, while 14 CFR 25.562 has no such
exclusion.
25.571(e) AC 25.571-1D, 14 CFR 25.571(e) requires consideration of uncontained rotor and
AC 20-128, and fan damage to structure not limited to pressurized compartments
Policy PS-
ANM100-1993-
00041
Subpart D
25.619 Additional CS reservation to seek “other appropriate measures” may
result in 14 CFR 25.619 non-compliance.
25.629(d)(8) The FAA includes requirements to show airplanes to be free of
aeroelastic instabilities within the envelope specified in 14 CFR
25.629(b)(2) for failures, malfunctions, and adverse conditions of 14
CFR 25.629(d). This includes the uncontained rotor and fan damage
conditions of 14 CFR 25.571(e).
25.631 FAA rule is specific to empennage structure and requires
consideration of 8 pound bird impact, while the CS requires
consideration of 4 pound bird for all structure, including empennage.
25.773(e) 14 CFR Amdt 25-144 introduced a new requirement not in CS-25. A
vision system with a transparent display surface located in the pilot’s
outside field of view, such as a head up-display, head mounted
display, or other equivalent display, must meet the requirements of
25.773(e) (1) through (e)(4) in non-precipitation and precipitation
conditions.
25.785(b) 14 CFR part 25 does not include this CS provision regarding berths
intended only for the carriage of medical patients, in which they need
not comply with the requirements of 25.562. Applicants must
petition for exemption from 14 CFR 25.562 to apply the EASA
version of the rule.

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 FAA Significant Standards Differences (SSD)

25.785(g) 14 CFR 25.785(g) includes requirement for single point release, and
accessibility of controls when seated and strapped in. 14 CFR
25.785(g) also requires means to secure restraint system when not in
use.
25.809(h) Specific to 14 CFR 25.809(h) (tail cone exit).
25.811(g) 14 CFR 25.811(g) is more stringent; it does not allow universal
symbolic exit signs.
25.812(b)(1) 14 CFR 25.812(b)(1)(i), 25.812(b)(1)(ii) and 25.812(b)(2) is more
(i), stringent; it does not allow universal symbolic exit signs and has
25.812(b)(1) requirements for exit marking letter size and background area.
(ii), and
25.812(b)(2)
25.831(g) Policy 00-113- Unique 14 CFR 25.831(g) requirement for temperature exposure
1034, dated time requirements.
1/4/01
25.841 AC 25-20, 14 CFR 25.841 establishes cabin pressure altitude requirements for
Policy ANM- failure scenarios not shown to be extremely improbable.
03-112-16,
dated 3/24/06
Subpart E
25.901(b) CS references only CS E20 (d) and (e) for engine installation
instructions vs. 14 CFR 25.901(b) reference to 14 CFR part 33 for
engines and part 35 for propellers. Compliance with CS 25 does not
ensure that the powerplant installation complies
25.901(c) The FAA requires the fail-safe concept - no failure(s) will jeopardize
the safe operation of the airplane. CS requires compliance with CS
25.1309. 14 CFR 25.901(c) includes the “fail-safe” requirements as
part of the rule in 25.901. Fail-safe is applied by guidance in
25.1309 and is therefore not mandatory by 25.1309.
25.901(d) The FAA requires that the APU installation meet the applicable
provisions of subpart E (application of engine installation
requirements). EASA has clearly defined requirements in CS-25
subpart J.
25.903(a)(3) New requirement with no equivalent in CS 25.
25.904 14 CFR part 25, Appendix I restricts ATTCS thrust to maximum
takeoff thrust or power approved for the airplane. CS25 Appendix I
permits the ATTCS to increase thrust up to a maximum thrust or
power approved for use following engine failure.
25.905(c) 14 CFR 25.905(c) refers to additional requirements for the propeller
blade pitch control system compared to CS 25.905(c). The CS
references only CS-P 420 vs. 14 CFR reference to 14 CFR sections
35.21, 35.23, 35.42 and 35.43.
25.907 The CS-P contains the airplane requirements vs. 14 CFR 25.907
containing the airplane requirements.

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 FAA Significant Standards Differences (SSD)

25.929(a) New requirement added for appendix O to part 25 icing conditions

without equivalent in CS 25 at Amendment 15. FAA requires
evaluation for appendix O to part 25.
25.933(a)(1) The 14 CFR 25.933(a)(1) does not allow demonstration that in-flight
thrust reversal is extremely improbable as a compliance method,
however the FAA routinely accepts it as an equivalent safety finding.
25.954 AC 25.954-1 § 25.954 (a) provides definitions for a critical lightning strike and
what is considered a fuel system. CS 25.954 provides no definitions.

§ 25.954(b) requires prevention of catastrophic fuel vapor explosion

due to lightning and its effects, including direct lightning strikes,
swept lightning strokes, and lightning-induced or conducted
electrical transients. CS 25.954 requires prevention of ignition of
fuel vapor by direct lightning strikes, swept lightning strokes, and
corona and streamering without assigning a failure condition (e.g.,
catastrophic). It does not use the word “include.” It does not require
the consideration of lightning-induced electrical transients as does §
25.954.

§ 25.954(c) requires that catastrophic fuel vapor ignition is extremely

improbable, whereas CS 25.954 does not contain this requirement.

§ 25.954(d) requires the type design to include CDCCLs and

inspection, test procedures, and mandatory replacement times to
ensure the continued effectiveness of those CDCCLs (reference
Appendix H, H25.4(a)(5). CS 25.954 does not contain these
requirements.
25.963(e)(2) AC 25.963-1 The CS includes an exception that fuel tank access panels need not
be more fire resistant than the surrounding fuel tank structural
material. The 14 CFR 25.963(e) does not.
25.981 AC 25.981-1C 14 CFR 25.981(a)(3) requires that an ignition source cannot result
from each single failure, from each single failure in combination with
each latent failure condition not shown to be extremely remote, and
from all combinations of failures not shown to be extremely
improbable. These ignition source requirements must be met with
consideration of the effects of manufacturing variability, aging, wear,
corrosion, and likely damage. CS 25.981(a)(3) only requires
demonstrating that an ignition source does not result from each single
failure and from all combinations of failures not shown to be
extremely improbable using CS 25.1309. 14 CFR 25.981(b) requires
the flammability exposure of tanks other than a main tank meet the
requirements of Appendix M if any portion is located within the
fuselage contour, which may require the installation of a Flammability
Reduction Means (FRM). CS 25.981(b) only requires an active FRM
meet the requirements of App. M to CS 25 if an FRM is needed to
meet the 3% fleet average flammability requirement.

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 FAA Significant Standards Differences (SSD)

25.1093 AC 20-73 FAA requires demonstration of capability to operate the engine and
Policy dated essential APU under the conditions of falling and blowing snow.
8/3/92 FAA has issued policy memorandum dated August 3, 1992 regarding
conditions that must be considered.
25.1093 Significantly reworded regulation in revised rule and added new
(b)(1) requirements for appendix O to part 25 and appendix D to part 33 in
(b)(1).

FAA requires demonstration of capability in appendix O to part 25

airplanes and appendix D to part 33 for all airplanes. FAA also
requires demonstration of capability to operate the engine and
essential APU in the conditions of falling and blowing snow. Refer
to FAA policy memorandum dated August 3, 1992 and advisory
circular 20-147A.
25.1103(a) CS does not contain the induction system drainage requirements of 14
CFR 25.1103(a). While this section applies primarily to reciprocating
engine installations, it does apply to turbine APU installations.
25.1193 14 CFR 25.1193(e)(3) is applicable to an APU and is more restrictive
(e)(3) than CS 25J1193(e)(3). 14 CFR 25.1193 requires a fireproof nacelle
skin / cowling for both ground and flight conditions.
Subpart F
25.1301 14 CFR 25.1301(a)(4) requires each item of installed equipment to
(a)(4) function properly when installed, not just those whose improper
functioning would reduce safety per CS 25.1309(a)(1)
25.1303 The CFR specifically requires a “non-stabilized magnetic compass,”
(a)(3) while the CS has a general requirement for a magnetic direction
indicator. The FAA has approved alternative standby magnetic
direction indicators, through an equivalent level of safety
determination.
25.1303(b) In (b)(4), by reference to section 14 CFR 121.305(k), requires third
attitude indicating system, when installed, to be independent of other
attitude indicators, and operative without selection after total failure
of electrical generating system.
25.1319 14 CFR part 25-146 does not adequately address cybersecurity. Until
such a rule is published, the FAA applies previously harmonized
special conditions for internal and external network access
protections.
25.1333(b) AC 25-11A 14 CFR 25.1333(b) requires that equipment, systems and
installations must be designed so that one display of the information
essential to safety of flight which is provided by instruments must
remain available to the pilots. The CS does not include specific
display requirements, but rather requires that sufficient information is
available to one pilot.
25.1415(c) 14 CFR 25.1415(c) requires survival equipment to be attached to the
life raft.

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 FAA Significant Standards Differences (SSD)

25.1420 CS-25 includes 25.1420(d) provisions for use of comparative

analysis for demonstration of compliance to provisions of
25.1420(a)(b)(c). The CFR does not include this provision.
25.1447 The 14 CFR 25.1447(c)(3) is more stringent requiring installation of
(c)(3) flight crew member oxygen dispensing equipment equipped with
certain design features depending on the flight level operation or
exposure to cabin pressure altitudes exceeding 34,000 feet during a
decompression which is not extremely improbable.
25.1457 The 14 CFR 25.1457 differs significantly in some respects. It is more
stringent in disabling automatic erasure functions, regardless of
recording duration, within 10 minutes of impact (d)(2). It requires
(d)(6) that the DFDR and CVR be in separate containers when both
are required, except for provisions for combination recorders. It
requires (d)(5)(i) 10 ± 1 minutes of backup electrical power, while
CS-25 requires at least 10 minutes (no ceiling). The 14 CFR also
requires (a)(6) recording of datalink communications when datalink
equipment is installed while CS-25 does not. The CVR must
generally be located as far aft as is practicable (e)(1), except for
combination recorders.
25.1459 The 14 CFR 25.1459 is more stringent in some respects. In (a)(5) it
requires that the automatic means of stopping the recorder disable
each erasure feature and do so simultaneously with stopping the
recording, regardless of recording duration. It requires in (a)(8) that
the DFDR and CVR be in separate containers when both are
required, except for provisions for combination recorders. Each
DFDR must generally be located as far aft as practicable (b), except
for ejectable recorders.
Subpart G
25.1529 CS does not include ICA availability requirements contained in the
14 CFR 25.1529. EASA IR 21A.61 allows deferred availability of
certain ICA "dealing with overhaul or other forms of heavy
maintenance" until after delivery, as long as they are made available
prior to the scheduled task threshold. The 14 CFR 25.1529 requires
complete ICA prior to delivery of the first airplane or issuance of a
standard certificate of airworthiness, whichever occurs later. CS
does not include Fuel System Limitation requirements in Appendix
H25.4. Also, 14 CFR H25.4 refers back to 25.571 which is an SSD.
25.1535 14 CFR 25.1535 refers to ETOPs airworthiness requirements of
Appendix K. 14 CFR K25.1.1 and K25.1.2 are covered in CS
25.1535. Other requirements of Appendix K are not addressed in
CS25.
25.1581 CS 25.1591 is a specific EASA requirement that if complied with
will result in a 14 CFR 25.1581 non-compliance. Such information,
if provided in the FAA AFM, must be in an unapproved section.
Appendix H

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 FAA Significant Standards Differences (SSD)

H25.4(a)(5) These are new airworthiness limitation requirements for the

identification of CDCCLs for each lightning protection feature
approved under 14 CFR 25.954. Appendix H of CS 25, Amendment
22, does not contain these requirements.
H25.6 14 CFR part 25-146 does not adequately address cybersecurity. Until
such a rule is published, the FAA applies previously harmonized
special conditions for internal and external network access
protections.