The FAA has issued a draft policy statement that would enable FAA-authorized witnesses to remotely witness certain engineering tests via video. Although limited in scope–it would not apply to production-related activities, conformity inspections, or engineering compliance by inspection, among other things–the policy could prove beneficial by allowing necessary test witnesses to do so remotely rather than in person.
Draft Policy PS-AIR600-XX-XX – Remote Test Witnessing arose out of a Part 23 ARC recommendation that the FAA develop policy to enable remotely witnessed tests. Such a policy in theory would be “more cost effective . . . improve certification timeliness . . . [and] reduce FAA resource burdens.” We agree that these considerations could be beneficial, but as always we want to make sure the policy is useful to industry and doesn’t contain any language that could lead to unanticipated problems.
As demands on the FAA’s resources become greater, and its budget becomes tighter, it will be important for the FAA and industry to find ways to partner to optimize FAA resources to ensure projects move as efficiently as possible. Permitting remote witnessing of certain test could help to speed this by allowing witnesses to handle multiple applicants in various locations in a more efficient manner. This would speed the certification process for applicants who would be better able to fit testing into their approval process (especially if the test witnessing can be done by viewing a recording, rather than in real time), and reduce the burden on the FAA both in terms of cost and travel time by allowing witnessing to be performed from a central location. This policy would be of significant value in those cases where witnessing must be performed at non-US suppliers and facilities.
The crux of the policy is summarized in the first paragraph:
FAA witnessing of engineering certification tests provides the FAA with confidence that the applicant’s test setup, test execution, and test results are valid. For some tests, remote witnessing using video can enable the FAA-authorized test witness to gain an acceptable level of confidence that the observed testing was performed correctly without the need for the witness to be physically on-site. Remote witnessing using video may be conducted either real time or by viewing the recorded video after the tests are completed. Applicants may request remote test witnessing when they satisfy the eligibility criteria of this policy statement.
The policy states that any applicant seeking a design approval would be permitted to request remote witnessing of its tests. It appears that an applicant could make such a request at any time, for instance when the FAA-authorized witness is suddenly unavailable for some reason, but the policy makes clear the preference would be to make such requests as early in the process as possible, and “preferable in the certification plan and the specific test plan.”
The policy goes on to lay out the expected equipment requirements and capabilities that should be considered, and suggests the information that should be included the first time an applicant requests remote witnessing form its FAA managing office. These factors include:
- Describing the articles/systems to be tested and associated test information
- Describing the testing associated risks
- Identifying the applicant’s representatives who will perform or support the on-site tests and describe their skills
- Explain how the equipment and setup ensure proper test witnessing
- Identifying any additional issues to performing remote test witnessing and how those issues will be managed for the specific tests
- Include certifying statements
The policy includes additional information for ODA holders to implement remote test witnessing as well.
The FAA concludes that “remote test witnessing of eligible test projects can provide a viable option for the FAA authorized witness to achieve an acceptable level of confidence that the tests are following the procedures and achieving the intended result.” MARPA too thinks that the FAA can achieve great confidence in our members’ test procedures via remote witnessing. We will be offering out comments on this draft policy, but before we do we’d like to hear from our members to determine if there are any unforeseen issues about which we should be aware and identify to the FAA. Comments are due March 1, 2018, so email any comments on this policy to VP of Government and Industry Affairs Ryan Aggergaard at email@example.com no later than February 21 so that we can be sure to include your thoughts and concerns.