EFK APPLICATION CHAPTER: 16

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1. INTRODUCTION

1.1. General

One of the characteristics that current FAA guidance material uses to

differentiate Class 1 EFB devices from Class 2 devices is the method
used to secure the device during critical phases of flight. FAA securing
methodology requirements differ between Class 1 and 2 devices. FAA
guidance states that a device that uses a securing system that is not
permanently attached to the aircraft, but is continuously viewable during
critical phases of flight, is a Class 1 EFB. This chapter discusses
securing requirements and the securing systems that UPS will utilize
during flight operations.

2. MOUNTING REQUIREMENTS

2.1. Class 2 Mounting Requirements

FAA Order 8900.1 paragraph 4-1643(B) states Class 2 EFB devices, “are
typically attached to the aircraft by a mounting device, and may be
connected to a data source, a hard-wired power source, and an installed
antenna.” It goes on to state in 4-1644(H), “When attached to its
mounting device, the EFB must not interfere with flight crew duties and
must be easily and safely stowed when not in use. In addition, the
attached EFB must not obstruct flight crew primary and secondary fields
of view, nor impede safe egress.”

AC 120-76B paragraph 4(e) defines Class 2 EFBs as, “Typically portable

COTS-based computers used for aircraft operations that are considered
PEDs, having no FAA design, production, installation approval, or
approved data requirements for the device. Class 2 EFBs are attached
or secured to a permanently installed aircraft mount during use.
Class 2 EFBs must be capable of being easily removed from or secured
to their mounts by flight crew personnel” (emphasis added).

2.2. Class 1 Securing Requirements

FAA Order 8900.1 paragraph 4-1643(A) states that Class 1 EFBs, “are
portable, commercial off-the-shelf (COTS) devices which are a part of a
pilot’s flight kit and are not attached to the aircraft.” It goes on to state
that “Class 1 EFBs that have Type B applications for aeronautical charts,
approach charts or electronic checklist must be secured and viewable
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during critical phases of flight and must not interfere with flight control
movement” (emphasis added).

AC 120-76B paragraph 4(d) defines Class 1 EFBs as, “Portable

commercial off-the-shelf (COTS)-based computers, considered to be
PEDs with no FAA design, production, or installation approval for the
device and its internal components. Class 1 EFBs can be authorized for
use during aircraft operation and are usually readily handled or carried
on/off the aircraft. Class 1 EFBs are not attached or mounted to the
aircraft; they must be secured or stowed during critical phases of flight.
Class 1 EFBs that have Type B applications for aeronautical charts,
approach charts, or electronic checklist must be secured and viewable
during critical phases of flight and must not interfere with flight control
movement” (emphasis added).

2.3. Class 1 vs. 2 Mounting Comparison

2.3.1. Device Portability

The AC 120-76B definition of a Class 2 device clearly describes a

mounting device that is permanently attached to the aircraft
structure. With this in mind, the portability described in the
definition relates to the portability of the EFB device itself, not the
mounting device.

The FAA Order 8900.1 and AC 120-76B definitions of a Class 1

device makes it clear that Class 1 devices are portable devices that
are usually carried on/off the aircraft and are not permanently
attached or mounted to the aircraft. This is consistent with the way
UPS proposes to utilize the iPad as an Electronic Flight Kit.

2.3.2. Secured and Viewable

AC 120-76B requires Class 1 EFBs that have Type B applications

for aeronautical charts, approach charts, or electronic checklist
must be secured and viewable during critical phases of flight.
This is also consistent with the paper charts and manuals currently
carried in the pilot’s flight kit. These paper documents may be “free
floating” during non-critical phases of flight and are typically
secured to a chart holder or other location during critical phases of
flight.
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The suction cup and kneeboard securing systems UPS will utilize
meet all FAA requirements for ensuring each EFK is secured and
viewable during critical phases of flight.

2.3.3. Part of Pilot’s Flight Kit

FAA Order 8900.1 paragraph 4-1643(A) specifically states that a

Class 1 device is, “part of a pilot’s flight kit.” AC 120-76B
paragraph 4(d) states, “Class 1 EFBs can be authorized for used
during aircraft operation and are usually readily handled or carried
on/off the aircraft.” FAA guidance material does not provide Class
2 EFBs such flexibility.

2.3.4. Class Comparison Summary

Sections 2.3.1 thru 2.3.3 clearly describe the fundamental

difference between Class 1 and 2 devices; class 2 devices, “are
attached or secured to a permanently installed aircraft mount”,
while Class 1 devices, “are part of a pilot’s flight kit.” Class 1
devices using a Type B application are the electronic equivalent to
the paper charts and manuals currently contained in the flight kit of
almost every airline crewmember.

3. MOUNTING/SECURING GUIDANCE MATERIAL

3.1. General

Because the guidance material is written in a way to provide the flexibility

necessary to support technological innovation, thorough analysis is
necessary to ensure compliance with FAA policy and safe, reliable flight
operations.

UPS has exhaustively researched and examined all available EFB

guidance material as it relates to the mounting and securing of EFBs on
the flight deck. UPS’ analysis looked at the body of guidance material as
a whole and analyzed the material based on when the material was
written and how the policy language has evolved since AC 120-76A was
published in 2003. This methodology considers the maturing of the
guidance material over time and compares how similar requirements
have evolved, providing the most complete and conservative analysis of
FAA requirements.
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For example, a laptop manufactured in 2003 could not be utilized as an

EFB in the same way as an iPad in 2011. A 2003 era laptop could be
used as a Class 1 device and could be carried as part of the pilot’s flight
kit. However the physical size and weight of a laptop from this era would
require a robust mounting system in order to secure it for use during
critical phases of flight. This type of mounting would necessitate
permanent mounting to the aircraft structure, categorizing it as a Class II
device. However, the light weight and compact size of an iPad requires a
much simpler securing system that would not necessarily need to be
permanently mounted to the aircraft structure. Therefore an iPad could
be “secured and viewable” during critical phases of flight while
maintaining a Class 1 categorization, while it would be difficult, if not
impossible, to categorize a 2003 era laptop in the same way.

3.2. UPS Analysis of Mounting Requirements

The AC 120-76B paragraph 4(d) definition of a Class 1 device as a

device that is, “not attached or mounted to the aircraft” means that a
Class 1 device cannot be attached or mounted to the aircraft in a
permanent manner (i.e. using a mounting device that is permanently
attached to the aircraft structure). The following excerpts from FAA
guidance material supports this definition:

• AC 120-76B paragraph 4(d) – “Class 1 EFBs can be authorized for

use during aircraft operation and are usually readily handled or
carried on/off the aircraft” (emphasis added).
• FAA Order 8900.1 paragraph 4-1643(A) – “Class 1. These EFBs are
portable, commercial off-the-shelf (COTS), devices which are part
of a pilot’s flight kit” (emphasis added).
• AC 120-76B paragraph 4(e) – “Class 2 EFBs are attached or secured
to a permanently installed aircraft mount during use” (emphasis
added).

Therefore, according to FAA policy, it is acceptable to temporarily secure

a Class 1 device to the aircraft to meet the FAA requirement of being
“secured and viewable during critical phases of flight.” Temporarily
securing a device to the aircraft necessitates some type of securing
system. In order to maintain a Class 1 categorization, the securing
system must also be portable and must not permanently mount to the
aircraft structure.

FAA guidance material makes it clear that a mounting device

permanently attached to the aircraft structure requires AEG involvement
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for authorization and is typically approved through TC, amended TC, or

STC. Because a Class 1 securing system is not permanently attached to
the aircraft structure, no AEG involvement, TC, amended TC or STC
approval is required.

Taken in the total context of the guidance material, it stands to reason the
securing system used to secure a Class I device during critical phases of
flight must meet certain minimum criteria. While securing criteria for
Class 1 devices are not clearly specified by the guidance material, UPS
has developed minimum criteria from published Class 2 mounting
requirements. Compliance with this list of criteria ensures that the UPS
securing solutions for the iPad Class 1 secured device provide an
equivalent level of safety as that provided with a Class 2 mounted device,
but without the requirement for AEG approval.

Each of the following criteria will be demonstrated for each securing

system in each aircraft type during the Secured and Viewable
demonstrations that will be conducted as part of the EFK Operational
Suitability process.

1. Portable system not permanently attached to aircraft structure

a. FO 8900.1 paragraph 4-1643(A)
b. AC 120-76B paragraph 4(D) and (E)
c. AC 120-76B paragraph 9(A)
2. Provide adequate access to EFB controls
a. AC 120-76B paragraph 10(j)(1)
3. Provide adequate visibility and display in all anticipated light
conditions
a. FO 8900.1 paragraph 4-1644(A)(2)
b. AC 120-76B paragraph 10(j)(1)
c. AC 120-76B paragraph 10(j)(2)
d. AC 120-76B paragraph 11(c)
4. Provide adequate adjustability for user preference, glare reduction,
and interface orientation changes
a. FO 8900.1 paragraph 4-1644(A)(3)
b. AC 120-76B paragraph 10(j)(1)
5. Provide adequate EFB security during all normal flight operations
a. AC 120-76B paragraph 10(j)(1)(b)
b. AC 120-76B paragraph 10(j)(3)
6. Does not obstruct the pilots primary and secondary fields of view
a. FAR 25.773 Pilot Compartment View
b. FO 8900.1 paragraph 4-1644(H)
c. AC 120-76B paragraph 10(j)(1)
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7. Does not obstruct or impede emergency egress

a. FO 8900.1 paragraph 4-1644(H)
b. AC 120-76B paragraph 10(j)(1)
c. AC 120-76B paragraph 10(j)(3)
8. Does not obstruct or impede access to aircraft controls or displays
a. AC 120-76B paragraph 10(j)(1)
9. Does not interfere with flight crew accomplishment of any flight
crew duty or task associated with operating any aircraft system
a. FO 8900.1 paragraph 4-1644(H)
b. AC 120-76B paragraph 4(d)
c. AC 120-76B paragraph 10(j)(1)
d. AC 120-76B paragraph 9(a)
10. Does not interfere with the movement of any primary or secondary
flight controls
a. FO 8900.1 paragraph 4-1643(A)
b. AC 120-76B paragraph 10(j)(3)

4. SECURED AND VIEWABLE SOLUTION

Because UPS will utilize EFKs using Type B software applications (e.g.
terminal chart viewer) during critical phases of flight, each device must be
located and secured during critical phases of flight in a way that ensures its
constant availability for use. This requires a location that provides the
crewmember easy access and device interaction while also providing
maximum viewability. The location must also ensure that primary and
secondary fields of view are not obstructed and that emergency egress is not
impeded.

UPS has elected to provide two securing solutions. One securing solution will
be a suction cup securing system manufactured by National Products Inc. An
additional option will be the use of a kneeboard. Two kneeboard systems will
be available to crewmembers in lieu of using the suction cup system.
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4.1. Suction Cup Securing Solution

4.1.1. General

UPS will the National Products Inc. (NPI) RAM-B-189-TAB3U iPad

suction cup securing system as a securing methodology on all fleets.
Each model utilizes NPI’s double suction cup system. The approved
suction cup system model to be utilized by UPS will be maintained in the
EFB Administration Manual.

TAB3U

The TAB3U will accommodate an iPad while in a thin protective case.

The TAB3U consists of an attachment base with dual suction cups and a
cradle that the EFK clips into. A double socket connector arm connects
the cradle to the double suction cup base. The double socket connector
arm allows adjustment of viewing angle and change of orientation. The
EFK can be easily secured or removed by a flight crewmember in
seconds without the use of any tools.

The suction cup system will be carried by the crewmember as part of

their flight kit and requires no equipment to be installed or maintained on
the aircraft. This approach provides for the EFK to be temporarily
secured during critical phases of flight without the use of any mounting
device permanently attached to the aircraft. The system does not require
Instructions for Continued Airworthiness (ICA) or administrative control
processes because the system is not part of the aircraft, but instead is
part of the pilot’s flight kit. This is consistent with other items in use in the
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cockpit today such as a clipboard, handheld calculator or slide rule type

flight computer.

The suction cup system will be secured to the side window aft of the
forward windscreen at each pilot station. Placement on the side window
ensures the EFK will not interfere with primary sight lines. Pilot
placement in the designated securing location (for each fleet) will ensure
the EFK does not interfere with secondary sight lines or window operation
when secured. Securing procedures for each fleet are contained in the
Flight Operations Manual and EFK Training Guide.

4.1.2. Engineering Analysis

The following section details the results of the analysis that UPS
conducted to ensure the suction cup securing solution meets the
securing criteria outlined in section 3.2.

4.1.2.1. EFK Controls and Display

The designated securing location ensures excellent access

to all external EFK controls and touch screen. The EFK is
located within arms-length of an average sized person and
well within a 90° field of view when facing forward at either
pilot station. This, coupled with the backlit display of the
iPad provides Jeppesen chart viewability as good, or better,
than the approved chart holder (for paper charts) on all fleet
types. It provides a great improvement in chart visibility on
the MD-11 where the (paper) chart holder is located on the
outboard side of each pilot seat at approximately waist level.
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4.1.2.2. Adjustability

The articulation provided by the double socket connector

arm allows precise adjustment of horizontal and vertical
viewing angle. This allows adjustment for optimal viewing
angle, reference seat location and glare reduction. Rotation
between portrait and landscape orientations is also
supported.

4.1.2.3. Holding Power

Demonstrating crashworthiness is not required for Class 1

devices. Nevertheless, National Products Inc., manufacturer
of the suction cup securing system, has conducted a holding
power analysis for the system to ensure sufficient EFK
security during all normal flight operations. The test results
certify that the system complies with the requirements of
FAR 25.561, Emergency Landing Conditions.

FAR 25.789, Retention of items of mass in passenger and

crew compartments and galleys applies to “items of mass
(that is part of the airplane type design) in a passenger or
crew compartment or galley”, and therefore is not applicable
to a Class 1 EFB that is secured in accordance with 8900.1
and AC 120-76A/B (emphasis added).

FAR 121.576, Retention of items of mass in passenger and

crew compartments requires that “The certificate holder must
provide and use means to prevent each item of galley
equipment and each serving cart, when not in use, and
each item of crew baggage, which is carried in a
passenger or crew compartment from becoming a hazard by
shifting under the appropriate load factors corresponding to
the emergency landing conditions under which the airplane
was type certificated” (emphasis added). Therefore, this
requirement is also not applicable to a Class 1 EFB that is
secured in accordance with 8900.1 and AC 120-76A and AC
120-76B.

Nevertheless, the NPI suction cup system does protect

against the shifting hazard described in FAR 25.789(a) and
121.576, (reference FAR 25.561 compliance), providing
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additional evidence of the excellent holding power provided

by this system.

The following table summarizes the holding power

engineering test results. The full test reports are included as
attachments to this chapter.

RAM-B-189-TAB3U SHOCK TEST

Test Direction g Level Tested
Upward 4.0
Forward 12.0
Sideward 5.5
Downward 8.0
Rearward 2.0

Engineering analysis confirms that the NPI suction cup

system provides security well in excess of that required
during normal flight operations including operation in areas
of moderate to severe turbulence and normal in-flight,
takeoff and landing vertical and horizontal loads.

NPI has stated that the suction cup system has no life-
limited parts and that suction cup holding power will not
degrade over time. This documentation is included as an
attachment to this chapter. UPS crewmembers are required
to report all issues encountered with a suction cup system
including holding power using the online event report
system. UPS will utilize these reports to verify that holding
power does not degrade over time. If issues are identified,
UPS will work with the manufacturer to develop a plan for
repair or replacement.

4.1.2.4. Primary and Secondary Fields of View

The suction cup system will be utilized to secure an

electronic flight kit on the side window (located immediately
aft of the forward windscreen) on each UPS fleet type.
Securing an EFK to this location does not block the view of
any existing cockpit control or display and ensures an
extensive, clear, and undistorted view to enable each
crewmember the ability to safely perform any maneuvers
within the operating limitations of the airplane, including
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taxiing takeoff, approach, and landing in compliance with

FAR 25.772, Pilot Compartment View.

4.1.2.5. Emergency Egress

An EFK and its securing system must not impede

emergency egress. The following table lists primary and
secondary emergency exits for all UPS fleet types.

UPS FLEET EMERGENCY EXITS

Fleet Primary Exit Secondary Exit(s)
B747-400F Upper Deck Service Door Cockpit Overhead Hatch/L1 Door
B747-400SF Upper Deck Doors Cockpit Overhead Hatch/L1 Door
B757-200 Cockpit Windows Crew Entry Door
B767-300 Crew Entry Door Cockpit Windows
MD-11 Crew Entry Doors Cockpit Windows
A300-600 Crew Entry Door Cockpit Windows

UPS will provide crewmembers with drawings illustrating the

designated securing location for each fleet type as part of
EFK flight crew procedures. The designated securing
locations ensure that window operation is unimpeded with
the suction cup system secured to the window. In addition,
the securing instructions contained within UPS EFK flight
crew procedures states the following:

“The suction cup system must be attached in the designated

securing location and must comply with the following
requirements:
• Must not interfere with operation of the window including
the window handle
• Must not block the sight lines used during any phase of
flight”.

Refer to section 6 of this chapter for the designated securing

locations for each fleet.
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The following table illustrates compliance with applicable

Federal Aviation Regulations pertaining to emergency
egress on transport category aircraft. Compliance with each
of these regulations will be validated during the Secured and
Viewable demonstrations conducted in accordance with
Chapter 4 of this application.

EMERGENCY EGRESS FAR COMPLIANCE – SUCTION CUP SYSTEM

FAR SUBJECT COMPLIANCE
NUMBER
25.801(a)(2) Emergency egress assist The suction cup system does not interfere with the
means and escape routes use of emergency escape ropes installed on any
UPS fleet type or the inertia reels installed on UPS
B757/767 and B747 aircraft.
25.803 Emergency evacuation The suction cup system does not impede
operation of the window when used as an
emergency exit as required by paragraph (a) or
the evacuation demonstration required by
paragraph (c).
25.807 Emergency exits The suction cup system does not modify the
window design or dimensions specified by this
regulation.
25.809 Emergency exit arrangement The suction cup system does not:
1. Prevent viewing of the conditions outside the
exit when the window is closed as specified by
paragraph (a).
2. Prevent opening of the window from inside or
outside within the time specified by paragraph (b).
In addition, the means to open the window is
unchanged with the suction cup system in place.
3. Impede the means to retain the exit in the open
position once the exit is opened in an emergency.
25.810 Emergency egress assist The suction cup system does not interfere with the
means and escape routes use of emergency escape ropes installed on any
UPS fleet type or the inertia reels installed on UPS
B757/767 and B747 aircraft as specified in
subparagraph (a)(2).
25.811 Emergency exit marking. The suction cup system does not obstruct or
obscure any emergency exit marking.
25.812 Emergency lighting The suction cup system does not obstruct or
obscure any part of the aircraft emergency lighting
system.
25.813 Emergency exit access The suction cup system does not change, obstruct
or impede emergency exit distribution or access.
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4.1.2.6. Access to Aircraft Controls and Displays

The designated securing location ensures that the EFK does

not obstruct visual or physical access to aircraft controls
and/or displays on any fleet in accordance with FAR
25.1321, Instruments: Arrangement and Visibility and FAR
25.777, Cockpit Controls.

4.1.2.7. Accomplishment of Flight Crew Tasks

The designated securing location ensures that the EFK does

not interfere with flight crew accomplishment of any task
(normal, abnormal or emergency) associated with operating
any aircraft system in accordance with FAR 25.1321,
Instruments: Arrangement and Visibility and FAR 25.777,
Cockpit Controls.

4.1.2.8. Flight Control Movement

The designated securing location ensures that the EFK does

not interfere with the movement of any primary or secondary
flight controls on any fleet.

4.1.3. Maintenance Requirements

Securing the suction cup system to the forward side window (on
either side) does not alter compliance with the design,
fragmentation, and redundancy requirements of FAR
25.775, Windshields and windows.

NPI has provided documentation to UPS that there are no life-

limited parts or parts that degrade over time and that the holding
power of the suction cups does not degrade over time.

The suction cup Original Equipment Manufacturer (OEM) has

provided documentation that states cleaning the PVC suction cups
with the Celeste Sani-Com towelettes provided on UPS aircraft will
not degrade the suction cup material or suction cup operation over
time.
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4.1.4. Documentation of Proper Attachment of Suction Cups

UPS will provide documentation to flight crews on the proper use of

the suction cup system. This documentation will include the
designated securing locations, and procedures to attach and
remove the suction cup system, including inspection and cleaning
of the suction cups to prevent scratching of the window surface.
This documentation will be included in UPS flight crew manuals and
the FAA approved EFK training program.

4.2. Kneeboard Securing Solution

4.2.1. General

A kneeboard solution will also be available for each aircraft type. Each
approved kneeboard will be evaluated as part of the validation process to
ensure it adequately performs its function and does not interfere with
flight control movement. Approved kneeboards will be maintained in the
EFB Administration Manual.

APPROVED KNEEBOARDS
Manufacturer Model Aircraft Type Approval
Tiet MyClip All Fleets

The kneeboard will be carried by the crewmember as part of their flight kit
and requires no equipment to be installed or maintained on the aircraft.
This approach provides for the EFK to be temporarily secured during
critical phases of flight without the use of any mounting device
permanently attached to the aircraft. This alleviates the need for
Instructions For Continued Airworthiness (ICA) and administrative control
processes, because the system is not part of the aircraft, but instead is
part of the pilot’s flight kit.

The following section details the results of the analysis that has been
conducted to ensure the suction cup securing solution meets the
requirements outlined in section 3.2.

4.2.1.1. EFK Controls and Display

A kneeboard locates the EFK on the top of the pilot’s thigh

ensuring excellent access to all external EFK controls and
touch screen. The EFK is located within arms-length of and
within a 90° field of view when facing forward at either pilot
station. This provides Jeppesen chart viewability as least as
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good as the approved chart holder on all fleet types. It

provides a great improvement in chart visibility on the MD-11
where the chart holder is located on the outboard side of
each pilot seat at approximately waist level.

4.2.1.2. Adjustability

Each of the approved kneeboards allows EFK orientation to

be easily changed between portrait and landscape.

4.2.1.3. Holding Power

The thigh strap used to secure the kneeboard to the pilot’s

leg is also adjustable to ensure EFK security during all
normal, abnormal and emergency flight operations. Security
will be demonstrated in the Secured and Viewable
demonstration as described in Chapter 4 of this application.

4.2.1.4. Primary and Secondary Fields of View

Each kneeboard will be used to secure the EFK to the top of

the pilot’s thigh. Securing an EFK to this location does not
block the view of any existing cockpit control or display and
ensures an extensive, clear, and undistorted view to enable
each crewmember the ability to safely perform any
maneuvers within the operating limitations of the airplane,
including taxiing takeoff, approach, and landing in
compliance with FAR 25.772, Pilot Compartment View.
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4.2.1.5. Emergency Egress

An EFK and its securing system must not impede

emergency egress. Primary and secondary emergency exits
for all UPS fleet types are listed in paragraph 4.1.2.5.

UPS EFK flight crew procedures state; “The kneeboard must

be attached to the crewmember’s leg so that it does not
interfere with flight control movement”. Because the
kneeboard is attached to the crewmember’s thigh, it must be
removed before emergency egress. This can be quickly
accomplished and will be demonstrated as part of the
Secured and Viewable demonstration described in Chapter 4
of this application.

The following table illustrates compliance with applicable

Federal Aviation Regulations pertaining to emergency
egress on transport category aircraft. Compliance with each
of these regulations will be validated during the Secured and
Viewable demonstrations conducted in accordance with
Chapter 4 of this application.

EMERGENCY EGRESS FAR COMPLIANCE – KNEEBOARD

FAR SUBJECT COMPLIANCE
NUMBER
25.801(a)(2) Emergency egress assist The kneeboard system does not interfere with the
means and escape routes use of emergency escape ropes installed on any
UPS fleet type or the inertia reels installed on UPS
B757/767 and B747 aircraft.
25.803 Emergency evacuation The kneeboard system does not impede operation
of the window when used as an emergency exit as
required by paragraph (a) or the evacuation
demonstration required by paragraph (c).
25.807 Emergency exits The kneeboard system does not modify the
window design or dimensions specified by this
regulation.
25.809 Emergency exit arrangement The kneeboard system does not:
1. Prevent viewing of the conditions outside the
exit when the window is closed as specified by
paragraph (a).
2. Prevent opening of the window from inside or
outside within the time specified by paragraph (b).
In addition, the means to open the window is
unchanged with the kneeboard system in place on
the crewmember’s thigh.
3. Impede the means to retain the exit in the open
position once the exit is opened in an emergency.
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25.810 Emergency egress assist The kneeboard system does not interfere with the
means and escape routes use of emergency escape ropes installed on any
UPS fleet type or the inertia reels installed on UPS
B757/767 and B747 aircraft as specified in
subparagraph (a)(2).
25.811 Emergency exit marking. The kneeboard system does not obstruct or
obscure any emergency exit marking.
25.812 Emergency lighting The kneeboard system does not obstruct or
obscure any part of the aircraft emergency lighting
system.
25.813 Emergency exit access The kneeboard system does not change, obstruct
or impede emergency exit distribution or access.

4.2.1.6. Access to Aircraft Controls and Displays

The EFK attached to a kneeboard does not obstruct visual or

physical access to aircraft controls and/or displays on any
fleet in accordance with FAR 25.1321, Instruments:
Arrangement and Visibility and FAR 25.777, Cockpit
Controls.

4.2.1.7. Accomplishment of Flight Crew Tasks

The EFK attached to a kneeboard ensures that the EFK

does not interfere with flight crew accomplishment of any
task (normal, abnormal or emergency) associated with
operating any aircraft system in accordance with FAR
25.1321, Instruments: Arrangement and Visibility and FAR
25.777, Cockpit Controls.

4.2.1.8. Flight Control Movement

The EFK attached to a kneeboard does not interfere with the

movement of any primary or secondary flight controls. This
will be demonstrated as part of the Secured and Viewable
demonstration described in Chapter 4 of this application.
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5. EQUIVALENT LEVEL OF SAFETY STATEMENT

Current and proposed FAA regulatory guidance makes it clear that it is

acceptable to temporarily secure a Class 1 device to the aircraft to meet the
requirement of being “secured and viewable during critical phases of flight.” It
is also clear that in order to maintain a Class 1 classification, the securing
system must be portable and must not utilize a mounting device that is
permanently attached to the aircraft structure.

FAA guidance material also makes it clear that a mounting device

permanently attached to the aircraft structure requires AEG involvement for
authorization and is typically approved through TC, amended TC, or STC.
Because the suction cup securing systems and kneeboard systems (as listed
in paragraphs 4.1.1 and 4.2.1, respectively) are not permanently attached to
the aircraft structure, each maintains its Class 1 classification as a securing
system, and therefore does not require AEG involvement or TC, amended TC
or STC approval.

After a careful review of all current and proposed guidance material, it is the
UPS position that the National Products Inc. suction cup securing system
described in this white paper meets all of the requirements as a method to
safely and reliably secure the iPad as a Class 1 EFB during all phases of
flight. It meets or exceeds all applicable requirements specified in the
regulatory guidance material, including the following:

1. Portable system not permanently attached to aircraft structure

2. Provides adequate access to EFB controls
3. Provides adequate visibility and display in all anticipated light conditions
4. Provides adequate adjustability for user preference, glare reduction, and
interface orientation changes
5. Provides adequate EFB security during all normal flight operations
including meeting FAR 25.561 crashworthiness requirements.
6. Does not obstruct the pilots primary and secondary fields of view
7. Does not obstruct or impede emergency egress
8. Does not obstruct or impede access to aircraft controls or displays
9. Does not interfere with flight crew accomplishment of any flight crew duty
or task associated with operating any aircraft system
10. Does not interfere with the movement of any primary or secondary flight
controls

As part of the UPS Operational Suitability validation process, a Secured and

Viewable Demonstration will be conducted for each aircraft type that UPS
operates. These demonstrations will be conducted in an actual aircraft that
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accurately reflects the aircraft configuration being validated. The

demonstration will be conducted by members of the UPS Electronic Flight Kit
development team for the benefit of UPS FAA CMO inspectors. The
objectives of the demonstration will be to validate the suitability of the suction
cup and kneeboard securing systems to secure the iPad as a Class 1 EFB
during all phases of flight. The demonstration will specifically validate the
securing criteria listed in paragraph 3.2 of this chapter.
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6. DESIGNATED SECURING LOCATION

This section depicts the designated securing locations for each fleet type.
These illustrations are included in the Flight Operations Manual to provide
guidance to crewmembers in the correct placement of the suction cup
securing system on each fleet type.

6.1. B747-400
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7. UPS FLEET PHOTOS

The following photographs illustrate the iPad secured in the NPI suction cup
system on each UPS fleet type. The securing locations depicted in these
photographs do not necessarily indicate the designated securing location for
each fleet. The designated securing locations for each fleet type are
contained in the UPS Flight Operations Manual.

7.1. B747-400
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7.2. B757-200
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7.3. B767-300
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7.4. MD-11
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7.5. A300-600