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Aircraft Parts, aviation, FAA, FAA Design Approval, FAA Production Approval, Manufacturing, PMA, Regulatory, Safety Management Systems, Uncategorized

Challenges Apparent in Reconciling Performance Based Regulations and Emerging Technologies

MARPA had the opportunity this week to attend the 2016 FAA-EASA International Aviation Safety Conference that was held in Washington, DC. The conference provides an opportunity for the regulatory agencies and industry to get together to discuss emerging issues in aviation safety and strengthen the cooperation between both the regulators themselves as well as the regulators and industry.

One notable panel discussed performance-based regulations (PBR) and their development, implementation and oversight as a part of the ongoing safety management adoption. The goal of PBR is essentially to retain the high level requirements and clearly establish what those high-level regulations are trying to achieve, while clearing out more detailed prescriptive regulations. Those detailed regulations would then be replaced by industry consensus standards.

In theory, this should clear the way for innovation by focusing more on ensuring a satisfactory outcome (that complies with the regulations) is the result, rather than focusing on prescriptive compliance-based rules. (How this exactly squares with a safety management system focused on systems and processes rather than the outcome per se is a conversation for another day.)  Performance-based regulations can free the hands of regulated parties and avoid the trap of innovation stagnation in which companies are forced to design or produce in only limited ways in order to comply with the regulations.

Although moving to a PBR approach may be a laudable goal, the next panel demonstrated how challenging it may be for regulators to break free of deeply ingrained compliance-based approaches to oversight.  Relevant to PMA manufacturers, the “fast-moving technologies” panel spent a significant amount of time discussing certification of projects using additive manufacturing techniques.

In theory, a PBR approach would be ideal for approving parts manufactured using emerging technology like additive manufacturing (AM).  If a part can be produced using AM techniques (like 3D printing) that meets all the design requirements (dimensions, material composition, durability, etc) of a part that is traditionally machined, an outcome-focused approach like PBR claims to be should have no problem approving that part. Conversely, if a 3D printed part cannot be made to conform to the approved design, our quality assurance systems reject the part and we go back to the drawing board.

However, it became clear during that panel that we can expect to see more of the same compliance based review of processes in seeking to obtain approval of parts manufactured using emerging technologies like AM.  Of course to borrow from Captain Renault I was shocked, SHOCKED to find that the OEM panelist expressed skepticism that “sub-tier” suppliers or those in the aftermarket were capable of producing approved parts using these methods. But of greater concern was his statement that the regulators might also question that ability.

Part of this concern on the part of the regulators arises from the fact that the regulators themselves do not fully understand technologies like AM yet. The FAA is currently working with industry to determine what controls will need to be in place and what the oversight requirements will be with respect to AM. It will therefore be very important for any PMA manufacturer seeking to use new techniques to manufacture parts to engage the FAA early in the process and demonstrate to the FAA its competence with the technique. This may involve educating the FAA in some cases (and refuting the implications of some larger OEMs that only they know the “special sauce” of new technology).

This much was supported by FAA AIR-1 Dorenda Baker, when she explained that the key to getting approval when relying on new technology is ensuring an understanding on both sides. The FAA needs to be brought into the process very early on. When the FAA is brought in at the last minute, problems and confusion can arise, because what might seem clear to the applicant, who has been working with the technology for months or even years, can seem confusing to the regulator seeing it in action for the first time.  Ms. Baker explained that we don’t want questions being asked for the first time, or engineers trying to understand new processes, at the time of certification. We, as applicants relying on new manufacturing techniques, need to engage the FAA early and often.

Of course this is somewhat inconsistent with a performance-based approach. As we mentioned above, if the goal of PBR is to ensure an outcome that satisfies high-level regulations, it should be less important how we get to the result than that we obtain a satisfactory result. A need on behalf of the regulator to understand fully the processes by which we obtain the result is more consistent with systems oversight (their stated goal) but doesn’t square perfectly with a PBR approach.

Nonetheless, it thus becomes clear that the PMA industry will have to fight this battle of fast moving technology on two fronts: First, we will have to (again) battle against an OEM-driven (mis)perception that only OEMs are capable of understanding and safely applying emerging technologies like additive manufacturing. Second, we will have to work very closely with the regulators to continuously demonstrate our competence and expertise in applying these technologies, and in effectively implementing systems that consistently produce the desired outcome.

There is a lot happening right now; from fundamental shifts in the role regulators play to the way we design and manufacture parts. By frequently engaging with the regulators we are able demonstrate our competence and abilities (simultaneously refuting any implications by competitors to the contrary) and keep the regulators closely engaged so that the certification process moves smoothly and we are able to nimbly adapt to changes as they happen.

MARPA will continue to keep you updated as old regulations change and new regulations emerge.

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