by Ms. Jenkins
(Phoenix, AZ, USA)
With reference to a cockpit display unit ("Product"), will the airworthiness regulatory authorities (FAA and EASA) approve one company ("Seller") applying for TSO on the hardware, with a different company ("Buyer") applying for a TSO approval on the embedded software of the same "Product?
ANSWER: That is a good question. I will offer you my thoughts on the subject, but would also suggest you contact an FAA Aircraft Certification or Manufacturing District Office for a definite answer. You can follow the links below for contact information:
FAA Aircraft Certification Offices
FAA Manufacturing Inspection District Offices
FAR 21.601 states in part that “A TSO authorization is an FAA design and production approval issued to the manufacturer of an article which has been found to meet a specific TSO, and an article manufacturer is the person who controls the design and quality of the article produced (or to be produced, in the case of an application), including the parts of them and any processes or services related to them that are procured from an outside source.
Based on the above regulation, I would say that the hardware manufacturer would have to be the applicant for the TSO.