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:
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.
The MARPA 2012 Conference will be held in a month, on October 3-5, 2012 at the Renaissance Las Vegas Hotel. But the deadline for making hotel reservations at the discounted rate is Monday, September 3!
We have negotiated a room rate of $129.00 per night (not including taxes) for single/double occupancy. This rate applies on a limited basis for rooms up to three days before and after the event, for those who wish to extend their stay. This is the lowest rate available to any group at the Conference Hotel during this time period! In order to qualify for this special rate, you must book your room by Monday, September 3, 2012. Click here for a link to the hotel for the MARPA room block. Clicking this link should automatically reference the 2012 MARPA discount code (which is mrpmrpa).
You can also call the hotel directly at (800) 750-0980. Make sure to ask for the “MARPA” rate in order to get our discounted rate!
The MARPA 2012 Conference will be held October 3-5, 2012 at the Renaissance Las Vegas Hotel. Please make your reservations early for the Conference: the hotel has sold out early for the past several years and we expect the hotel to sell out again this year.
We have negotiated a room rate of $129.00 per night (not including taxes) for single/double occupancy. This rate applies on a limited basis for rooms up to three days before and after the event, for those who wish to extend their stay. This is the lowest rate available to any group at the Conference Hotel during this time period!
In order to qualify for this special rate, you must book your room by Monday, September 3, 2012. Click here for a link to the hotel for the MARPA room block. Clicking this link should automatically reference the 2012 MARPA discount code (which is mrpmrpa).
You can also call the hotel directly at (800) 750-0980. Make sure to ask for the “MARPA” rate in order to get our discounted rate!
Welcome to the Closing Day of the 2011 MARPA Conference. We’ve put together this Agenda in order to make sure that attendees can find what they’re looking for! If you have any questions, please ask anyone wearing a Staff ribbon or a Board ribbon.
Please remember to submit your Conference Survey and your Association Survey before you leave. We use this feedback to help improve MARPA programs for the members. Also, each timely-submitted survey enters the completing-party in the Conference-end drawing for a MARPA-radio-controlled helicopter (you must be present to win!).
|7:30 am – noon||Registration Desk||Hotel Lobby|
|7:30 am – 8:30 am||Breakfast||Renaissance I|
|7:30 am – noon||Exhibits Open||Renaissance I|
|8:30 am – 10:00 am||Opening Session||Renaissance II-III|
|>→Day Two Keynote: How will the FAA Support the Industry’s Increasing Certification / Approval Needs?, David Hempe, Manager, Engineering Division, Federal Aviation Administration|
|→European Plans for Parts, Frederic Copigneaux, Deputy Certification Director, European Aviation Safety Agency|
|→ New Developments in PMA Regulation and Policy, John Milewski, PMA Program Manager|
|10:00 am – 10:30am||Break||Renaissance II-III|
|10:30 am – 12:00 noon||Renaissance I|
|PMAs and the Government Market Panel
Moderated by Stu Nibley, Dickstein Shapiro LLP and joined by Ryan Perry, US Air Force
|→Air Carrier Panel: Ask Questions and Get Answers!, Moderated by David Linebaugh, Delta Tech Ops and joined by additional MARPA Air Carrier Members:
|→Meeting Closes … THANK YOU!||At the close of the meeting, we will hold a drawing for a MARPA-radio-controlled helicopter|
MARPA has filed comments with the FAA on the DRAFT Sequencing Standard Operating Procedure (SOP) [“Aircraft Certification Service Sequencing Procedure”].
The SOP details the FAA’s mechanism for prioritizing certification, approval and validation projects.
This SOP would have a tremendous affect on the rights of private parties. The sequencing decisions about which projects will get FAA resources and which ones will be delayed, will have a tremendous impact on business and profitability, because the FAA approval process is often a bottleneck on innovation. A safety improvement project that is delayed for weeks or months could inhibit safety not only because of the delay, but also because for many companies – particularly smaller ones – delay can mean the difference between whether the company is successful or whether the company may run out of financing before it can bring its safety improvement to the marketplace.
MARPA’s comments address a variety of issues raised by the FAA’s draft in an effort to assist the FAA in improving the draft SOP. Many of MARPA’s comments center around the safety index values established in the SOP, which appear to provide an unfair advantage to companies meeting certain profiles. In particular, it appears that small businesses could be placed at a competitive disadvantage by the draft SOP.
While this permits the FAA to operate for a few more months, the continuing resolution still fails to permit the FAA to confidently develop a strategic plan for the nation’s aviation infrastructure.
After more than a week the FAA remains unfunded. Congress still has not passed a law that authorizes payment of the FAA’s bills.
As we discussed in this blog a week ago, The FAA Authorization was allowed to lapse at midnight on July 23. As a consequence, 4000 FAA employees who were deemed “non-essential” were furloughed. While the newspapers may call these personnel “non-essential,” in many cases they are the safety professionals who are absolutely essential to continued advances in aviation safety. These people remain out of work, today. In addition, the Associated General Contractors (AGC) estimates that 70,000 construction workers and workers in related fields have been affected.
This issue seems to have become the victim of bigger stories – the impending debt deal has riveted CNN viewers but it has also distracted the public from the fact that we’ve already stopped funding the FAA.
The FAA posted their own press release on the status update this morning. In their press release, they implored Members of Congress “not to fly home for the August recess without passing an FAA bill.”
The bill cuts FAA funding by $4 billion over the next four years.
The bill adds production privileges to Certified Design Organizations (CDO), turning them in to Certified Design and Production Organizations (CDPOs). The bill also affirms the deadline for CDPO is January 1, 2013.
The bill requires a study of certification and approval mechanisms. It must estimate the expected number of applications for production certifications and approvals and recommend process reforms necessary to allow the Administrator to review and approve the applications in a fair and timely fashion. Congress also expects the study to address methods for enhancing the effective use of delegation systems, including organizational designation authorization (ODA).
The bill would establish an advisory committee to address inconsistent regulatory interpretation.
The bill reverses a recent decision of the National Mediation Board (NMB), which we had discussed in this blog on June 2, 2010. The NMB decision made it easier for unions to organize employers in the airline and rail industries, and conformed these industries with the labor practices of other industries; however, the decision had changed 75 years of precedent in the airline and rail industries. The Bill wold reverse the decision and return collective bargaining to the status quo.
The bill would also strengthen the FAA’s requirements to perform certain cost-benefit analysis. The recent drug-testing-reg-flex debacle had undermined public confidence in the FAA’s ability to perform statutorily-required cost-benefit analysis.
The bill would require the FAA to verify that each certified foreign repair station has been subject to a safety assessment.
The bill must be conferenced with the Senate version in order to come up with a final version.
The global aviation safety community met in New Orleans on June 8, 2010 at the FAA EASA International Safety Meeting. The FAA EASA International Safety Meeting is an opportunity for the government of the world to coordinate their aviation safety regulatory and implementation efforts. FAA Associate Administrator Peggy Gilligan provided an update on US aviation safety activities.
Gilligan explained that the FAA Reauthorization Bill is still under development. The House and Senate have passed their different versions and those pieces of legislation are awaiting reconciliation. Reconciliation will lead to a harmonized vision of the strategic plan for the FAA. The delay in achieving this final legislation, though, has an effect on the entire international aviation community.
Our international aviation community is a network of networks, and we are all inter-reliant. The Icelandic volcano was a good example of how the entire community is affected by a domestic event. When our community recognized a need to work together on the issue, ICAO pulled all of the world’s governments together to work on this issue together. This shows that what happens in one nation can affect all of us together.
Thus, it is particularly important that the world’s governments work together to achieve the goals that will support NextGen. This means developing a proactive approach to safety management and just culture. And this is why the FAA feels that SMS is an important element to develop the ideals that will support effective use of the NextGen system.
Peggy Gilligan also provided a quick update on some of the recent changes in her organization. She explained that Jay Pardee is leading the FAA’s Accident Prevention and Investigation Service, and Tony Fazio is his deputy. This is an expanded role for the traditional accident investigation group, and it is intended to permit them to implement a State Safety Program that examines data to proactively prevents aviation safety hazards in the future. The group is able to eapand its role to include proactive accident prevention because the FAA has been so successful in limiting accidents, and this group’s expertise is well suited to analyzing data to prevent hazards from arising in the future. John Allen (Director of the FAA Flight Standards Service) and John McGraw have been joined by Ray Towles in the leadership of Flight Standards. Ray Towles will take over as Deputy Director for the Field. McGraw continues to be Deputy Director for Policy.
The FAA announced a new focus on professionalism as an element supporting the NextGen system.
The FAA EASA International Safety Meeting opened in New Orleans today (June 8, 2010). The FAA EASA International Safety Meeting is an opportunity for the government of the world to coordinate their aviation safety regulatory and implementation efforts. Industry is invited to support those efforts.
David Grizzle keynoted the meeting. Grizzle is currently acting as the Deputy Administrator, but his normal role is FAA Chief Counsel.
He noted that the FAA does not want to be perceived as presumptuous. As an example, he noted that the US FAA was asked to get involved in responding to the Icelandic volcano. In responding to those requests, he explained that the FAA wanted to provide support where it was needed, but the FAA did not want to be seen as claiming special knowledge.
This became an issue because the United States would have approached the volcano issue differently, but did not want to interfere with European decisions. Grizzle explained that air carriers have excellent systems, and they have the resources that can help them make flight decisions. Thus, the FAA would have trusted existing air carrier systems to prevent unsafe flight operations. So in Europe when the governments closed down broad swaths of airspace, this was a different approach than what the US would have done.
The US is working with its counterparts in other nations to coordinate international development of NextGen. Nextgen represents a significant culture change. So the FAA is trying to ake the underlying principles of NextGen and trying to let them become pervasive principles that pervade the operations of the agency and the industry. Grizzle explained that Nextgen is not just about technology – it is about standards and operating principles. One of these is the principle of partnership. There is an element of collaboration in air traffic management that is elemental to Nextgen and that simply does not yet exist in today’s air traffic management paradigms. Another element is performance based safety standards. Instead of telling operators how to achieve safety, they will give them standards that must be met and permit the operators to choose their own strategies for meeting those safety standards. This gives rise to a new emphasis on professionalism. Some of the recent problems in aviation have been attributable to a deficiency of professionalism – violations of norms and standards that no one finds acceptable.
Discussions of professionalism can be uncomfortable because, like ethics, professionalism can be somewhat difficult to quantify, and it can be somewhat difficult to define in a way that is uniformly accepted.
Professionalism means that the individuals are principle-based actors, and not just followers of rules. This involves a mindset and attitude about the conduct of one’s life that is more pervasive than the norm. This poses a challenge for the FAA and other aviation authorities about how do we teach professionalism.
The FAA is trying to focus on a “just culture” paradigm. Part of the “just culture” paradigm is the idea is that we do not punish people for good faith mistakes (assuming the accidental actor reports and proactively works with the FAA to seek preventative paradigms), but rather we try to learn from those mistakes and we use the information learned from those incidents to prevent future problems. This “just culture” paradigm is about focusing on behavior rather than outcome. But there will be a challenge in trying to convince people that identifying remedies and preventative paradigms is more important to long-term safety than allocating blame.
An important element of this “just culture” paradigm is rewarding energetic good faith reporting. If we encourage reporting, then we encourage data collection that supports a risk-based reporting environment.
Grizzle made a call for leadership from the entire international aviation community in order to make our professionals, the leaders that we all need them to be.