Baines Simmons’ report on the 2015 EASA – FAA International Aviation Safety Conference
Principal Consultant and Part 21 Subject Matter Expert, Duane Kritzinger, represented Baines Simmons at the recent EASA-FAA International Aviation Safety Conference in Brussels.
The conference brought together over 350 senior aviation professionals from regulators, manufacturers, airlines and associations from all world regions to discuss global aviation safety issues.
The following extracts from the conference’s keynote speeches highlights points of particular interest:
- Keynote speech by Margus Rahuoja, Director Aviation & International Transport Affairs, European Commission, who emphasised the need for Authorities to remove duplication and cost. A key enabler towards achieving this is risk-based oversight driven by the proper exploitation of data available from robust Safety Management Systems.
- FAA Highlights by Peggy Gilligan, Associate Administrator for Aviation Safety, who emphasised that aviation is a global industry, so safety cannot be restricted by national borders. The purpose of the conference is about removing these borders and barriers and SMS is currently the biggest initiative driving aviation forward, but it needs to remain nimble.
- EASA Highlights by Patrick Ky, Executive Director, who spoke about the Vision 2020 initiative which strives to fully integrate the local NAA’s with EASA. He equated the EASA-NAA interface with that which the FAA has with its regional offices. The idea is to be less fragmented and to optimise the use of resources and skills available. However, this would require a more stable and harmonised approach to NAA funding. Another initiative (currently in the feasibility phase only) is the “Big Data Project”, where all data (not just accidents/incidents) will be more pro-actively exploited. Cyber security is another topic which EASA is considering – a recent conference, where hackers were invited, exploited just how real this threat is to the industry.
- Keynote speech: Global aviation safety for a global industry Tony Fernandes, Entrepreneur, CEO AirAsia provided an inspirational talk on his journey in founding Air Asia (in 2001) and its phenomenal growth and success. The Asian region is a huge growth market for aviation, containing two thirds of the world’s population, a very large (and growing) middle and upper class, and a growing aviation supply chain. From a regulatory perspective the aviation industry in Asia is currently burdened by disjointed and fragmented local NAA’s and Tony issued a plea for EASA to exert its influence and legacy to assist and encourage Asia in adopting a similar model.
We also attended the following workshops, output from which will directly influence our courseware and consulting services in the future.
PANEL 2: Remote Pilot Air Systems (RPAS)
The discussion focused on the challenges and opportunities set by the use of RPAS in existing or new types of aerial activity i.e. a Tool, Toy or Transport. New practical applications for RPAS are detected on a daily basis, supported by technologies mostly developed by companies and individuals outside the scope of traditional authority stakeholders. The Amazon Prime Air will particularly stretch the boundaries for integrating RPAS into the aerospace system. EASA, FAA and Transport Canada provided presentations on their rulemaking activities. Although all three of these regulators are using a risk-based approach (generally considering different approaches for low, medium and high risk RPAS), there are still significant differences. Harmonisation is still needed (possibly under ICAO), but in the meantime, the industry is moving rapidly ahead (e.g., Transport Canada issued less than 50 Special Flight Operator Certificates in 2012 and over 1500 in 2014). Research indicates a 19% compound growth rate per annum in this industry for the foreseeable future.
What became obvious from this session is that industry is enthusiastic and often very experienced. In contrast, regulators are lagging/reactive and are currently perceived to be an obstacle to development of the industry. It is worth mentioning that JARUS is a current initiative with the purpose to recommend a single set of technical, safety and operational requirements for the certification and safe integration of Unmanned Aircraft Systems (UAS) into airspace and at aerodromes. The objective of JARUS is to provide guidance material aiming to facilitate each authority to write their own requirements and to avoid duplicate efforts. However, it was emphasised that industry has a role to play too by forming associations to achieve standardisation in its supply chain (as the rest of the aviation industry has achieved).
PANEL 3: Manufacturers
This discussion focussed on multinational industry cooperation (as illustrated below) in design and production of aeronautical products, which places challenges on both authorities and industry.
Before a foreign aircraft is registered in a state (or a foreign engine or propeller is installed on any aircraft registered in a state), that state will need to confirm that the product(s) meet(s) its own airworthiness requirements. The process is known as “Type Validation”, where the importing state’s Authority examines the exporting state’s TC/STC to establish compliance with the importing state’s applicable requirements.
Bilateral Agreements (or other Working Arrangements) between NAAs help make the process easier and less burdensome on industry. It is also meant to reduce the burden on the Regulators, and, during this session, both the FAA and EASA confirmed that this approach should always be focussed on risk, novelty and unique technology – and that the certification staff will need to justify internally why a “Validation Item” or “Additional Technical Condition” needs to be raised.
It was acknowledged that the recurring problem with the certification process is that “we have a system in place, but you are never really in control of that system”. The interaction with the authorities is often unpredictable and the regulators often find themselves in the critical path of the programme. Pro-active management by the applicant of the Certification Programme Plan is essential and close co-ordination with the Regulator is essential.
PANEL 5: Manufacturers – Adapting the Level of Involvement to the Risk
Today’s technological developments are taking place much faster and at a much higher level of complexity than ever before. This is particularly true in the areas of aeronautical product design and related manufacturing methods (e.g. the extent of and dependence on IT utilisation) as illustrated below.
Within this changing environment, the regulators need to operate, at best, with their current scope of resources or, at worse, with a diminished set of resources. This has become the driver for risk-based oversight where the regulator will focus its attention on those areas with the highest risk, and rely on the expertise in industry to self-regulate the rest, but always under NAA oversight.
An example of how this will influence EASA DOA and POA organisations can be seen in the recently closed NPA 2015/03, “Embodiment of Level of Involvement (LOI) requirements into Part-21”. The FAA and Transport Canada are following a similar approach gradually implementing a risk based approach to determining their level of involvement in product certification, both domestically and in validation projects. This will inevitably mean that not all applicants will be treated the same, and the scope of authority involvement will be driven by the applicant submitting more robust Certification Programme Plans.
PANEL 7: Manufacturers – Supply Chain Control
There are multiple audits and multiple standards to follow for organisations who are subcontractors to a Type Certificated project. For them it requires duplication of work or the use of multiple standards for the same task. Suppliers provide parts/appliance/services to multiple integrators, each of which demands own interface procedures, different competence evaluations, different delegation surveillance schemes and different design standards. Combine this with multiple audits and the whole process becomes expensive and inefficient.
The workshop explored the need for harmonisation and simplification to bring more uniform standards of conformity amongst:
- Regulators at international level
- Aircraft manufacturers (to encourage mutual recognition of surveillance activities)
- Industry to implement standards resulting from the previous 2 points and recognise a supplier’s capability (in a similar way as DOAs are recognised)
With reference to the last point above, Airbus did a short presentation showing how they intend to use the LOI approach based on their perception of performance and competence of their suppliers. This approach would still be under the clear understanding that single and ultimate responsibility stays with the TC/STC holder under his DOA, but that the scope of surveillance can be tailored to the level of confidence the DOA has in its supplier.
The conference also explored how mutual surveillance activities could be enabled, and it is useful to consider two distinct types of data required form suppliers:
- Characteristics independent of contract/project: This is typically data to be found in a DOA’s Handbook, and includes Organisation Description, Quality System, Monitoring System, Qualification of Personnel, Key Procedures, etc. This area is prime territory for mutual recognition.
- Project Specific Requirements: This is where each contract specifies its interfaces, specifications, constrains and Verification & Validation (V&V) activities.
The question was asked: “Can we outsource initial investigation and/or surveillance of suppliers?” EASA confirmed that it is possible but that the following 4 conditions would need to be demonstrated by that party:
- Must have defined procedures
- Must have sufficient resources
- Independent and free of conflict of interest
- Subject to DOA (and therefore EASA) oversight
Two significant outcomes of this workshop were:
- Building upon the success of the use of 3rd party surveillance, the European industry is to consider developing a similar system to mutualise the surveillance of the system aspects of their subcontractors in the design domain. The industry has run a “DOA think tank” which is about to publish a first draft of an EN standard, which could be used as a basis for the mutualisation of design subcontractor surveillance.
- EASA confirmed that the topic of using accreditation bodies (e.g. UKAS) is something that has been neglected when EASA was formed (mainly due to other regulatory priorities) resulting in DOAs and EASA spending too much time having to witness low level testing (e.g. Flammability). In contrast to the EASA position at the DOA conference in 2011, EASA is now open to suggestions from industry to use independent accreditation bodies and encourages industry to form a consolidated proposal to EASA to alleviate the effort associated with this type of supplier oversight.