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The 21st Century Model of Certification

I just got off the phone with senior leadership at the FAA and all I can say is “WOW.”

The FAA is talking very seriously about a new model of certification for the aerospace industry focusing on approval of design processes and risk-based oversight in order to better leverage the FAA’s resources to ensure safety of the growing aerospace marketplace.

I shouldn’t be surprised.  The models are there, and they’ve worked.  We’ve sat on Federal Advisory Committees that have made these recommendations to the FAA.  The industry has been talking about this for years.  But sometimes when you talk about projects for too long, you start to lose hope that they will ever come to fruition.

But this idea has the support of the FAA’s senior management and that is what will make the difference.

The new model of certification will likely rely on paradigms like:

  • Safety Management Systems (SMS)
  • A company’s library of FAA-approved or FAA-accepted methods to demonstrate compliance to the regulations
  • FAA Centers of Excellence that can assist with issues that go beyond the approved compliance libraries
  • Self-certification of compliance (following the successful model currently used for issuing TSOA)

Under this new paradigm, a company that specializes in PMAs for landing gear (for example) would have a library of compliance methods – test and procedures that are designed to show compliance to the regulations (including ways to demonstrate true identicality with an existing compliant design).  By following the compliance methods from the library, the company would be able to demonstrate compliance for future landing gear parts.  This would allow the company to more readily develop compliant designs that can be readily PMAed based on the methods that are already known to be sound.

This would involve a major restructuring of how the FAA oversees design approval.  Moving to a TSOA-like self certification should permit small businesses to react very nimbly to market forces and it allows the FAA to more readily focus its resources on real safety issues based on risk assessment.  This paradigm could be supported by FAA Centers of Excellence that would be able top provide support to the design approval community on technical issues.

This paradigm could also impose more responsibility on the design approval applicant.  It would likely be reflected in design systems that would be subject to FAA surveillance.  This would replace the current model in which designs are reviewed.  It would be analogous to the modern approval to production quality systems, in which the FAA approves  system rather than approving each individual part and product that comes out of the system.

For PMA companies, this could help companies bring part to market faster, when those parts fall within the compliance library, because it would limit the FAA’s involvement in projects where compliance can clearly be shown based on known and accepted methods.

We are currently working with the FAA on a presentation (“challenge session“) about this new paradigm; we hope to add this to the program for the 2015 MARPA Conference.

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About Jason Dickstein

Mr. Dickstein is the President of the Washington Aviation Group, a Washington, DC-based aviation law firm. He represents several aviation trade associations, including the Aviation Suppliers Association, the Aircraft Electronics Association, the Aircraft Fleet Recycling Association and the Modification and Replacement Parts Association.

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