Improving Aircraft Safety (1980) / Chapter Skim
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Type Certification and Rule Making
Type Certification and Rule Making
Pages 19-48
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From page 19... ...
Rule making, conducted at the agency's headquarters in Washington, D.C., involves establishing the regulations and technical standards that must be met by the manufacturers and airlines in the course of designing, producing, operating, and maintaining the aircraft. Within each regional office, the group that reviews and approves each new aircraft design is the Type Certification Board.
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From page 20... ...
The process is characterized by a progression of design and testing activities conducted by the applicant and reviews for compliance by the FAA project team, punctuated by a small number of meetings -- perhaps four to six -- of the Type Board at critical decision-making points. Once the FAA project team has familiarized itself with the application, the board holds a preliminary meeting, attended by the FAA team and its applicant counterparts, to make an initial evaluation and to identify the pertinent design certification criteria, including the regulations, standards, and criteria that the applicant must meet, and the means by which the applicant must demonstrate compliance.
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From page 21... ...
While much smaller in numbers than the manufacturer's staff, the FAA staff must be capable of holding the company to appropriate standards of design and proof, of going beyond the letter of the standard to provide interpretation and to ask the right questions, and, with the aid of companyemployed Designated Engineering Representatives, of painstakingly checking the company's work to assure compliance. The attributes of technical expertise, assertive judgment and independent initiative within the FAA are critical to its success.
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From page 22... ...
Yet in making judgments about the safety of aircraft, some interpretation is necessary. The current FAA organizational structure, which allocates type certification activities for the various categories of aircraft among several regional offices, results in a superficial level of technical oversight.
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From page 23... ...
In the Western and Northwest Regional Offices, where certification of new domestic transport aircraft is concentrated, the work assignments of the engineering staffs are not limited to the certification of new aircraft types. The amount of time devoted to other functions varies according to specialties and the phase of design and test work in which the transport manufacturer is engaged.
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From page 24... ...
The Western Regional Office, whose airworthiness jurisdiction extends to Douglas, Lockheed, and a number of airlines, which is in the process of certificating the DC-9-80 and has just finished the certification of the L-1011-500, provides the most dramatic example. The office has operated for nearly a year with many vacant positions, including those of regional director, deputy director, and chief engineer would serve Certification Board.
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From page 25... ...
In October 1979 he announced the intention to recruit a number of "national resource specialists" in such technical disciplines as aeroelasticity, advanced materials, special manufacturing processes, and airline maintenance techniques.8 In April 1980, he advised our committee that he was exploring the merits of selecting either the Western or Northwest Regional Office as a "lead region" to coordinate type certification activities for transport aircraft. The "lead region" concept is already being employed for such other aspects of FAA certification responsibility as engines and helicopters.
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From page 26... ...
A comparatively small number of engineers would remain in the regional offices for day-to-day operations, to provide sign-offs and spotchecks of the work of the type certificate applicants, and to continue to oversee the remaining important regional activities involving the certification and surveillance of production, maintenance, continuing airworthiness, and responses to service difficulties. These functions are best served from regional offices close to the production and maintenance facilities.
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From page 27... ...
Certainly, the FAA would have to pursue a vigorous recruiting campaign to attract the engineers and scientists best suited to the central engineering organization; and the challenges and rewards of such an organization would have to be made sufficiently attractive to induce experienced professionals to make career changes to become airworthiness professionals for the FAA. The possibility of building and nurturing a technical organization of high competence and esprit de corps by centralizing technical functions has ample precedent in The early National Advisory Committee for government.
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From page 28... ...
To skimp _~ to building and maintaining a requisite level of FAA staff competence places the system's efficient operation in jeopardy over the long run and threatens the agency's mandate to provide "the highest degree of safety" in flight.
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From page 29... ...
It is the committee's view that this revised organizational structure for airworthiness engineering, coupled with a recommendation to improve the type certification process (described later in the report) will result in a significant improvement in the quality of airworthiness certification and the overall effectiveness of the FAA.
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From page 30... ...
but are appointed by the FAA regional director only after he is satisfied with their personal and professional qualifications and experience. Once appointed, they are delegated by the FAA administrator, through the regional office, to represent the FAA in helping to determine that the aircraft design complies with the relevant requirements of the regulations.
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From page 31... ...
The advantages of the designee system are apparent. It enables the FAA to have a substantially increased number of highly qualified technical people reviewing and checking thousands of pages of data to determine whether or not all the pertinent regulations and procedures have been satisfied.
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From page 32... ...
Further, the process invites a review that focuses, however superficially, on the details, often at the expense of closely examining overall design concepts. This is the case, in large part, because the FAA lacks the qualified experts to provide the proper leadership for the type certification process -- a finding that led the committee to recommend establishment of a central engineering organization.
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From page 33... ...
The Need for Timely Rule Making The airworthiness system depends not only on the safety consciousness of aircraft manufacturers and air carriers but on the premise that the standards embodied in the Federal Aviation Regulations for design, production, maintenance, and operation will be set and kept as up-to-date as they reasonably can be through the rulemaking process. Primarily through its headquarters staff, the FAA manages its rule-making steps in the following ways: 0 Proposals for possible rules are reviewed initially by the staffs of the offices of airworthiness, aviation safety, and flight operations, under the associate administrator for Aviation
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From page 34... ...
This board, an independent federal agency whose charge includes investigating and determining the probable cause of civil aircraft accidents, also may make recommendations for changes in the regulations as a result of its findings. When a matter is considered serious enough to justify a new or revised rule, headquarters project teams, typically comprising engineers from the rule-making and airworthiness offices and a regulatory attorney, are asked to develop the safety, technical, and economic justifications and to draft the proposed rule.
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From page 35... ...
an Advance Notice of Proposed Rule Making, calling for materials with lower toxicity properties. Soon afterward, research and development revealed the inadequate understanding of fire dynamics and the
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From page 36... ...
A case in point involves two proposals discussed and agreed to by the FAA and the industry at a 1974 Airworthiness Conference,13 concerning the use of continuous-gust criteria for strength and structural deformation design, and the need for a safety analysis of the probability of fuselage openings. Although the hole-size criteria have been applied by the FAA through Airworthiness Directives and Type Certification negotiation, and continuous-gust criteria have been used by industry, largely on a voluntary basis, the FAA has not yet incorporated into the Federal Aviation Regulations the detailed rules requiring these practices -- some six years after they were first proposed.
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From page 37... ...
a systematic approach to identifying the need for new rules or the modification of existing ones, coupled with set priorities and schedules; (iii) a capability to react to unforeseen emergencies (arising from an accident, for example)
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From page 38... ...
Examples include: or life limits on, Type Certificates;14 changes in accelerate and stop distances;15 concern over regulations dealing with failure analysis and numerical probabilities;16 and such "key design elements" as "compartment fire protection, emergency exits, seats and shoulder harnesses".17 Discussions with former FAA officials, and with industry personnel who participated in past reviews, have convinced the committee that this process is a good one, provided that the review is well organized, the agenda is planned in advance, and the FAA follows through in a , _ , the desirability of requiring revalidation of, ~, businesslike way. The same procedures should be used for identifying the need for new standards, for discussing their significance, and for determining the state of the art necessary to write the rule.
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From page 39... ...
A formal interagency agreement between NASA and FAA could be established through which FAA submits requirements to NASA in accordance with FAA developed priorities and plans. NASA could perform the necessary research and development on a predetermined time scale.
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From page 40... ...
As an additional task, the FAA should develop a systematic approach to updating the entire body of Federal Aviation Regulations. While scheduled rule making and annual conferences can be expected to address new standards reflecting advancements in knowledge and new design practices, the systematic updating of the regulations should result in revising or deleting rules and criteria that have become obsolete.
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From page 41... ...
The designer seeks to anticipate and defend against likely malfunctions and hazards that could defeat the component being designed. However, many of the fatal accidents that have occurred with airplanes manufactured by companies visited by the committee have involved rare and improbable combinations of mishaps, aspects of which were outside the "design environment" of the components in question, such as maintenance-induced damage, undefined weather hazards, and damage sustained outside the operating regimes.
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From page 42... ...
These procedures, however, fail to take into account an important consideration: structures designed not to fail when subjected to conditions within the design environment sometimes do fail, usually as a result of hazardous conditions outside the design environment. Examples of such hazardous conditions might include maintenance-induced damage, hard impact by ground servicing equipment, cargo-induced damage, or perhaps even faulty quality control during manufacturing.
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From page 43... ...
One is the decompression venting of wide-body aircraft. The designer takes into account unanticipated structural damage resulting, for instance, from the inadvertent opening of a cargo door or from a mid-air collision, which could cause floor failure, and a secondary problem, such as the possible interference with control cables.
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From page 44... ...
Other rulemaking issues also arise during the certification process in the regional office. Several of these, including cockpit design, the interpretation of cabin safety, and the methods for determining crew complement, affect in a direct way other parties as well as the manufacturers and airlines with which the regional offices customarily deal.
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From page 45... ...
consistent with the statute, any manufacturer may apply to the FAA and hold confidential any information provided to the FAA that would adversely affect the company's interest, as long as the information "is not required in the interest of the public.''l9 In practice, we are recommending that the regional offices, through their respective Type Certification Boards, increase the observance of rule-making formalities with respect to their special rule-making decisions -- just as they now do in issuing Airworthiness Directives when time permits in nonemergency cases. The committee envisions the situation where, subsequent to providing notice concerning the regulatory and certification bases, the Type Certification Board would invite all interested parties to make formal submissions for review at one of its early meetings.
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From page 46... ...
IMPROVING AI RCRAFT SAFETY/4 6 The procedure contemplated should in no way restrict the type board or design certification project engineers from also seeking additional technical advice and counsel from such appropriate sources as other government agencies and individual specialists and consultants, paid or volunteer, from industrial and academic settings.
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