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Certification, Maintenance, and Operations: Strengthening the Process Links

Certification, Maintenance, and Operations: Strengthening the Process Links. CPS Response Activities Ruth Harder, FAA. Topics. Background of CPS Response Activity CPS Response Aviation Rulemaking Committee (ARC) Status & Progress International Collaboration Opportunities. Background.

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Certification, Maintenance, and Operations: Strengthening the Process Links

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  1. Certification, Maintenance, and Operations: Strengthening the Process Links CPS Response Activities Ruth Harder, FAA

  2. Topics • Background of CPS Response Activity • CPS Response Aviation Rulemaking Committee (ARC) Status & Progress • International Collaboration Opportunities

  3. Background • During investigation of the Jan 2000 Alaska Airlines Flight 261 MD-83 accident, particular attention was given to the processes associated with how critical airplane systems are certified and eventually maintained and operated • As a result, the FAA initiated a review of major processes being used in the U.S. to certify commercial transport airplanes • The Commercial Airplane Certification Process Study (CPS) Team was chartered in Jan 2001

  4. Certification AREAS INTERFACE Operations and Maintenance Background • The Study focused on the adequacy of the processes related to the “arrows” in this figure:

  5. Background • The CPS Report was completed March 2002 • The Report contained 15 Findings & 2 Observations • Addressed multiple Certification, Maintenance and Operations interfaces • Report Internet Access: • http://www.aia-aerospace.org/issues/subject/faa/faa_cert_study.pdf

  6. CPS Response • Prior to final release of the CPS Report, FAA and industry began activity to address the Report’s Findings/Observations. • An FAA/Industry team was chartered in Jan 2002 to develop a strategic plan for response. • The response team worked closely with study team as the Report was finalized.

  7. CPS Response ARC CPSR OVERSIGHT BOARD Ray Ron Mac John Nick Sabatini Jim John Wolfgang Fred Valeika Hinderberger Armstrong Hickey Chairman Ballough Goglia Didszuhn Herzner ARC Working Groups Ruth HarderCo-Chair Carol GilesCo-Chair Operators ALPA FAA ATA Manufacturers

  8. CPS Response ARC • Phase I [Strategic Planning] - COMPLETE • FAA/Industry Team began 2/25/02 • Strategic Action Plan was completed 4/15/02 • Phase II [Detailed Planning] - IN WORK • Phase III [Implementation] - FUTURE

  9. Phase II Status • Phase II [Detailed Planning] - IN WORK • Oversight Board gave Phase II Go-Ahead 6/14/02 • Most Team Leads Identified by 8/31/02 • Kickoff Meeting held 9/24-25/02 • Order 1110.133 signed 1/17/03, chartered the CPS Response Aviation Rulemaking Committee • All-Lead Meetings and Oversight Board Briefings to be held regularly through 2003 • Detailed plans expected to take 12-16 months to complete (last team ECD 06/01/04)

  10. Findings/Observations Mapping to Change Areas

  11. CPS CHANGE AREAS Design/Cert Production Operations, Maintenance, Alterations 1. Safety Information Management A.Critical Design Information B.COS Information D.OEM-Operator Information Transfer C.Precursor Awareness/Lessons Learned 2. Human Factors Integration 3. In-Service Changes 4. AVR Integration

  12. Change Area 1A Critical Safety Systems & Assumptions Task:Define methods to identify critical design safety features and necessary assumptions that are essential for understanding critical safety features for each aircraft in the existing fleet as well as new designs. Co-Leads:FAA-Chuck Huber, Industry-Jim McWha Members:Roger Knepper (Airbus); Larry Schultz, Stewart Hann, Gil Palofox (Boeing); Mark Millam (NW); Sara Knife (GE); Brett Portwood, Linh Le, Lynn Pierce, Patrick Safarian (FAA).

  13. Change Area 1A Work Plan and Schedule • Define process for identification of Safety critical features/equipment. [May 2003] • Define process to protect Safety Critical features during Maintenance, Alterations and Repair activities. [Jun 2003] • Define process to build more robustness into Design and Analysis of Safety Critical Functions. [Aug 2003] • Define process to improve validity of assumptions that may have safety implications. Where appropriate, specific recommendations for documentation additions/changes will be made. [Sep 2003] • Draft report on implementation of above processes [Oct 2003]

  14. Change Area 1A Proposed Solutions • Incorporate “Safety Critical Processes” into certification, maintenance, operation, repair and alteration activities through: • Development of Policy Memo for Defining Flight Critical System Components • Issuance and future revisions of draft FAR 25.1309 and AC 25.1309-1B as submitted by ARAC • Revision of industry standards regarding safety assessments and continued operational safety (ARPs 4754, 4761 and 5151) • Revision to MSG-3 Process to provide better linkage between maintenance programs and safety assessments prepared for type certification

  15. Change Area 1A Proposed Solutions (cont.) • Improve communication process between ACO and AEG regarding safety critical information as used in MRB and MEL development • Incorporate the identification of safety critical components and significant safety events into requirements for reporting of service difficulties • Enhance the Instructions for Continued Airworthiness to provide for improved oversight of safety critical features during maintenance, repair and alteration activities

  16. Change Area 1B COS Information Task: Ensure that FAA and industry data management programs effectively provide data to identify accident precursors by: • Developing efficient and relevant data collection requirements based on user needs • Providing incentives for voluntarily reported data that is legally protected • Recommending elimination or consolidation of ineffective data programs Co-Leads:FAA-Holly Thorson, Dave Soucie Industry-Dave Harrington (Airbus) Members:Terry McVenes (ALPA); Michel Tremaud (Airbus); Matt Humlie(DL); Gary Martin (HP); Scott Moreen (Boeing); Brian Will (AA); Jay Hiles (IAM); Joe Tintera, Roy Patzke, John Craycraft, Kevin Kuniyoshi, Chris Spinney, Diana Takata, Ron Rhoades, FAA.

  17. Change Area 1B Work Plan and Schedule • Determine safety information needs for AVR/industry (March 2003) • Develop “Information Requirements Model” (May 2003) • Validate “Information Requirements Model” (July 2003) • Recommend changes to existing data programs and FAR’s (October 2003)* * Potential 3-6 month delay due to industry support & validation of the model

  18. Change Area 1B Proposed Solutions Safety Information Requirements Model includes: • Fundamental principle - data should be maintained/analyzed by the airplane manufacturers and safety information should be provided to the FAA (an alternative to SDR reporting may be recommended) • Specifications for standard reporting requirements/data definitions • Formal links between AIR & AFS to improve safety • Incentives for reporting data that is legally protected • Reporting criteria that continually evolves - based on known accident precursors (COSP), flight critical equipment (I-A), lessons learned (I-C), and human factors (II)

  19. Change Area 1CLessons Learned/Precursor Awareness Task: Develop AVR airplane-level awareness for improved identification and risk assessment of accident precursors. Define methods to capture, share and use lessons learned information throughout industry and the life cycle Co-Leads:FAA-Dan Cheney, Industry-Jim Daily (Boeing) Members:Tony Broderick, Michel Tremaud (Airbus); Michael Borfitz, Bill Rankin, Dave Carbaugh (Boeing); Jack Cole, Robert Peel (ATA); Joe Bracken, Steve Corrie (ALPA); Al Spain (Jet Blue), Randy Wallace (DL Ret.); Sarah Knife (GE); Mike Bartron (PW); Steve O’Neal, John Golinski (FAA)

  20. Change Area 1C Work Plan and Schedule • Identify alternatives for communicating lessons learned to all appropriate parties. Perform the analysis necessary to select the most appropriate method(s). [May 2003] • Develop plan for creating and implementing the selected communication method(s). [Jun 2003] • Develop the lesson learned event criteria. Release an initial draft of the lessons learned event list. [May-Jun 2003] • Define methodology for reviewing events in order to capture appropriate lessons learned material. Mine information gained by CAST in their development of the JSAT and JSIT processes. Dry run the process. [Jul 2003]

  21. Change Area 1C Work Plan and Schedule (cont.) • Develop the plan for how industry can review and analyze the lessons learned accident set. [Aug 2003] • Industry meeting to select and dry run the analysis process. [Sep 2003] • Using Industry Team method, identify lessons learned event set and implement lessons learned process [Sep – Dec 2003] • Define alternatives and select the appropriate method for maintaining the lessons learned “database”. [Oct 2003] • Complete Implementation Plan development for 1C [Feb 2004]

  22. Change Area 1D OEM-Operator Info Transfer Task: Define “safety related” communications & define process for ensuring that appropriate communications take place between OEMs and operators on safety recommendations related to maintenance or operational procedures Co-Leads:Industry-Jim Daily (Boeing), Don Collier (ATA) FAA-Barry Basse Members:Michel Tremaud, Dave Harrington (Airbus); Michael Borfitz (Boeing); Jack Cole, Robert Peel (ATA); Bob Meade (GE).

  23. Change Area 1D Work Plan and Schedule • Develop definition of “Safety related”. Participate in Team 1.A to develop the definition and ensure the scope of 1A’s efforts address the needs of 1D. [per Team 1A schedule] • Coordinate with CAST to identify potential duplicative efforts. Identify which activity should take the lead on specific areas of overlap. [Defer till initial team meeting] • Research current communication methods utilized by OEM’s to address safety related communication. [Apr-Jun 2003] • Review how U.S. airlines receive, review and communicate safety related information with their OEM’s. [Apr-Jun 2003]

  24. Change Area 1D Work Plan and Schedule (cont.) • Review safety communication needs and methods used by non-U.S. operators. Enlist the aid of IATA and ICAO to help with this area. Ensure that the global needs, communication methods, and constraints are considered. [Sep 2003] • Identify and document communications “best practices”. [Nov 2003] • Assemble industry team to develop methods to ensure two-way safety related communication [Dec 2003] • Develop CPS Phase III implementation plan that will address how to formalize, encourage, or implement the usage of “best practices”. [Mar 2004]

  25. Change Area 2Human Factors Integration Task: Develop industry/FAA comprehensive plan to address all human factors issues that have resulted in accidents in the past and/or that could result in accidents in the future. The plan should address the pre-and post-certification HF aspects throughout the life cycle. Co-Leads:FAA-Kathy Abbott, Industry-Al Prest (ATA), Curt Graeber (Boeing) Members:TBD

  26. Change Area 2 Work Plan and Schedule • Identify team comprised of HF expertise from industry and government, with three HF Subteams: 1. Maintenance 2. Safety Information Management Liaison 3. Design/Operations (1996 FAA HF Team Report Update) • Review the CPS report and its associated reference material; identify the key human factors issues [Jun 2003] • Review current regulatory and industry human factors activities that address the related areas, including the interface between flight operations, maintenance, and the airplane. (CAST, HWGs, etc.) [Jul 2003]

  27. Change Area 2 Work Plan and Schedule (cont.) • Subteams provide action plans [Apr-Jul 2003] • Coordinate with other change areas [Ongoing] • Integrate output from HF Subteams [Jan 2004] • Develop a consolidated plan that addresses the human factors issues and provides an implementation strategy [Mar 2004] a.   Identify gaps in application of HF to each area b.   Develop recommendations to fill the gaps

  28. Change Area 3 Repairs & Alterations Task: Define methods to provide: • An industry standard logic process for use in determining repair and alteration classification. • A coordinated alteration process that ensures the original OEM safety intent is not compromised. • A process that ensures consultant DER approved designs are compliant with regulatory requirements. • Enhanced air carrier/repair station quality assurance programs. Co-Leads:FAA-Barry Basse, Jess Lewis Industry-Mark Yerger (Federal Express) Members:Dave Harrington (Airbus); Page McGirr (GE); Owen Schrader (Boeing); Don Collier (ATA); Randy Wallace (DL ret.); Mike O'Neil, Chris Gavriel, Mike Reinert, Kevin Kendall, Leo Weston (FAA)

  29. Change Area 3 Work Plan and Schedule • Team develop expanded guidance for Major/Minor Decision Logic (AC 120-77) [May 2003] • Evaluate options, develop new approach for repair approvals [Sep 2003] • Develop process and procedures for use of manufacturer-identified critical safety features (from 1A). [Dec 2003] • Assess use of certification basis and certification checklist process for DERs, assess need for evaluations of DER submittals [Feb 2003] • Define industry standard for outsourced quality control, review draft AC 120-CASS [Apr 2004] • Develop Implementation Plans for above solutions [Jun 2004]

  30. Change Area 4AVR Integration Task: (internal FAA) Define AVR-level policy for improved internal and external communication and coordination between AIR and AFS. Develop processes to ensure improved communications on technical issues with industry Co-Leads:FAA-Phil Canal, Brenda Courtney, Russ Jones, Van Kerns; Industry-N/A Current Status: • Two Subteams - Business Systems and Operational Systems • Kickoff Meeting held May 2003

  31. CPSR ARC Prioritization • The CPSR Oversight Board recently directed its working groups to assess and prioritize the CPSR tasks across the four Change Areas • The need for prioritization was recognized due to difficulties in gaining active airline participation for all of the working groups • Higher priority will be given to CPSR tasks that have the strongest correlation with AIR-AFS integration issues

  32. CPSR ARC FAA & Industry Goals • Insure that key CPS messages are understood and carried forward in implementation • Teams address action plans from an integrated systems perspective. • Review CPS initiatives periodically to insure links with other major safety initiatives continue to be integrated • Define measurement/success criteria for future management of progress to completion. • Communicate with industry and FAA ‘owner’ organizations to insure full commitment to the recommended actions.

  33. CPSR ARC Success Factors • To improve safety, Airplane System Awareness must continue to improve throughout FAA and industry worldwide. • Change will be necessary in many or all involved organizations, not just within the FAA or any single organization. • All parties (manufacturers, operators, and authorities) must be fully involved in and committed to the CPSR safety solutions.

  34. International Collaboration - CA1B Opportunities for sharing of safety data • CPS 1B working group has strong relation to: • ECCAIRS reporting system, voluntary shared database for COS data • JSSI Working Group on Occurrence Data Analysis Specifications

  35. International Collaboration - CA1B Opportunities for sharing of safety data (cont.) • Future potential for increased sharing of safety information through bilateral agreements • Future industry sharing methods should yield improved information to authorities

  36. International Collaboration - CA1C Opportunities for increased sharing of Lessons Learned • 1C Team is building industry/authority consensus on criteria and process for capture of LL • Solutions could be used to provide infrastructure and methods for enhanced global sharing.

  37. International Collaboration - CA2 Increased integration and coordination of world-wide HF activities • Design/Operations subteam to consist of team that issued 1996 HF Report • Consolidated HF Plan will give integrated implementation strategies that better support HF activities across international community

  38. International Collaboration - CA3 Increased consistency in repair data approval methods • CA3 team member is also part of JAA team tasked to examine JAR 21 M process for accepting approved repairs • CA3 team recommendations are expected to enhance European acceptance of U.S. repair approvals • Related to Repair Data Acceptance Topic

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