No cleaning product is FAA approved. Here is what the labels actually mean

There is no such thing as an FAA-approved cleaning product. FAA approval attaches to type design, to parts and to repairs. It does not attach to consumable chemicals, and it never has. If a vendor tells you their product is FAA approved, that is not a small exaggeration. It is a claim about a thing that does not exist.

What does exist is a chain of responsibility, and the FAA sits outside it. Understanding who is actually in that chain is genuinely useful, because it tells you what questions to ask.

Who is actually in the chain

EPA regulates the label. For antimicrobial products, EPA registration under FIFRA licenses the specific claims on that specific label, based on submitted efficacy and safety data. It is not a quality mark and it says nothing about aircraft.

Boeing and Airbus qualify material compatibility. This is the real gate. Boeing’s D6-17487 covers evaluation, certification and qualification testing of airplane maintenance materials, and BSS7432 covers evaluation of airplane maintenance materials. A product tested against these has passed a battery of ASTM tests. Airbus has its own AIMS documents doing the same job.

SAE writes the test specifications. The AMS series covers cleaner categories: AMS1526C for a water-miscible pressure-spray exterior cleaner, AMS1533C for a solvent-base gel exterior cleaner, AMS1550B for a water-base interior hard surface cleaner, AMS1452 and AMS1453A for aircraft disinfectants. Worth noting that AMS1550B says explicitly that the cleaner shall not be used on interior fabrics of aircraft, which is the kind of detail that gets lost when a product is described simply as aviation approved.

The OEM maintenance manual carries the method. This is the part with regulatory force behind it. 14 CFR 43.13(a) requires each person performing maintenance to use the methods, techniques and practices prescribed in the current manufacturer’s maintenance manual or Instructions for Continued Airworthiness, or other methods acceptable to the Administrator. Note the word: acceptable, not approved.

The operator approves the product. EASA says the operator’s engineering department should provide a technical review and approval of use for each cleaning and disinfecting product. IATA says any products used need to be approved by the airline. That is where the decision actually sits.

The FAA is not in that list. Its own bulletin on cabin disinfection, SAIB NM-20-17, routes the question straight to the airframer: any disinfectants used should be compatible with the aircraft and approved by the aircraft manufacturer for use on board the aircraft. And the FAA notes in the same document that its contents do not have the force and effect of law and are not meant to bind the public.

The FAA actually withdrew from this subject

This is the detail that settles the argument. The FAA once did publish guidance on selecting cleaning chemicals: Advisory Circular 43-205, Guidance for Selecting Chemical Agents and Processes for Depainting and General Cleaning of Aircraft and Aviation Products, issued in 1998.

It was cancelled in February 2017. The cancellation memo gives the reason as outdated information, with current information available in industry documents, and directs users to documents produced by the manufacturers of the aircraft and the products used.

So the FAA looked at the question of which cleaning products belong on an aircraft, and handed it to industry. There is currently no active FAA advisory circular on selecting aircraft cleaning agents at all.

What a qualification actually earns a product

This is the part worth understanding, because it is genuinely valuable and it is not what most people think it is.

When a product is qualified to Boeing D6-17487 or an equivalent, it has passed material compatibility testing. The tests are specific:

• ASTM F1110, sandwich corrosion. Evaluates whether the chemical corrodes aluminum alloys when it is trapped between faying surfaces, which is to say in a lap joint. This is the test that exists because residue does not always rinse out.
• ASTM F502, effects on painted surfaces. Looks for streaking, discoloration and blistering, and measures softening with a pencil hardness set.
• ASTM F484, stress crazing of acrylic. Tests the compound against acrylic that is under bending stress, because a chemical that is harmless on a relaxed coupon can craze a window that is under load. Stretched acrylic is tested unannealed, which is the realistic case.
• ASTM F519, hydrogen embrittlement. Notched high-strength steel specimens under sustained load for 200 hours. This is the landing gear and high-strength fastener question.

Read that list again and notice what it measures. Every one of those tests asks whether the product causes harm. Not one of them asks whether it cleans well.

Boeing says so itself. In its own test letter for D6-17487, Boeing states that it makes no claims or guarantees as to the actual performance of the wax and polish. That is the sentence to keep. A qualification is a compatibility clearance for named substrates, at a named dilution, against a named revision of a document. It is not a performance claim and it is not an endorsement.

What to actually ask a vendor

Four questions.

1. Which document, which revision, and can I see the report? Qualifications are revision-scoped and formulation-scoped. A report from 2014 against an old revision, for a formulation that has since changed, is not what it appears to be.
2. At what dilution was it tested? The clearance is for the dilution tested. Using it neat because the aircraft is dirty is outside the clearance.
3. Which materials was it cleared against? A cleaner cleared for painted exterior surfaces is not thereby cleared for stretched acrylic, wool, aniline leather or de-ice boots.
4. What does the airframe manual say? Because under 14 CFR 43.13(a), that is the document that actually matters.

Why we bother writing this down

Because the phrase FAA approved gets used as a substitute for the four questions above, and it does the opposite of what it appears to do. It ends an inquiry that should have started one.

Everything we use is chosen against the manufacturer’s guidance for the specific materials it will touch, and which product goes where is written into the procedure rather than left to whoever is holding the bottle. That is the method, it is why cabin work is scoped by material rather than by room, and the reason the procedures live in a system rather than in a binder is so the answer is the same at every field on the same day.