FAA REPORT ON AIRCRAFT CERTIFICATION HOLDS GREAT POTENTIAL, BUT WILL IT RESULT IN IMPROVEMENTS TO THE CERTIFICATION PROCESS?

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ARTICLE: GAMA Statement on FAA Report to Congress on Aircraft Certification Process Review and Reform

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The U.S. Congress, in §312 of the FAA Modernization and Reform Act of 2012, directed the FAA to assess the aircraft certification and approval process and report the results by August 10, 2012. The FAA, in turn, chartered the Aircraft Certification Process Review and Reform Aviation Rulemaking Committee (ARC) on April 12, 2012 to perform the assessment. The ARC – composed of industry and FAA representatives – provided its recommendations on May 20 to improve the efficiency and reduce costs through streamlining and reengineering the certification process. Acting Administrator Huerta addressed cover letters to the Chairs of the House and Senate Committees and forwarded the ARC report verbatim.

The report indicates that a comprehensive implementation plan will be developed by October 2012 and that the FAA will begin to implement the recommendations starting February 13, 2013. The report, which is 83 pages, documented 19 other studies and assessments in the past decade to improve the certification process. That history sadly repeats past collaborative efforts aimed at the same problems and each of those exercises ended with similar promises to facilitate change and improvements, which appear to lead to eventual inaction. It appears that the program reviews the FAA performs are not tracked and managed as to what has been implemented and whether the change was effective. More importantly the certification process has a poor track record of consistently monitoring project management metrics or accountability to ensure both the applicant and FAA are meeting milestones and compliance activities that is documented in the agreed-upon certification plan.

One of the highlights of the report includes expanded use of delegations, especially Organization Designation authorization or ODA, an option which could greatly enhance the product certification process and address future concerns about certification backlog and FAA resources. The benefits of ODA that improve the efficiency and lower the cost of certification processes are not yet fully realized because of the slow transition to a systems approach to certification by the FAA. Type certification and design approval workload for the FAA is expected to grow because of increased introduction of new aviation products. To meet this demand the FAA must either increase its resources, which is very unlikely to happen, or expand the delegation program to enable certification functions currently reserved for the FAA to be completed by certified design organizations (CDO). The FAA needs to publish a CDO proposed rule soon!

Another high order recommendation is for manufacturers and Part 21 certificate holders to implement Safety Management System (SMS). There is no argument that SMS will positively benefit manufacturers and improve the certification process. ICAO has already added design and manufacturers to the list of service providers for which each Member State should require SMS, beginning in November 14, 2013. The FAA is actually at the global forefront of adding a design and manufacturer SMS as it recognizes that organizational issues (new plants, outsourcing, supplier changes, etc.) can cause hazards that affect the product. FAA SMS guidance materials for manufacturers can be found here.

The ARC report outlines 6 specific recommendations which need to be addressed. With an organization, which is already challenged and is facing greater external requests for authority, one would hope that this report will drive change and ensure the recommendations are really managed, tracked and implemented this time, otherwise we will be reading and writing about another report covering the same issues in a few years.

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