Too Many Assumptions, Without Validation...

[Michael Grove]

 ... Call Certification Process of 737 MAX Into Question

 The Joint Authorities Technical Review (JATR) observations published  

 today call into question whether Boeing’s approach of certifying the

 737 MAX as an evolution of previous 737 aircraft, rather than as new

 type certification, led to too many false assumptions to ensure safety.

Boeing’s decision to certify the aircraft as the next generation of an existing aircraft type allowed the manufacturer to rely on previous approvals for various systems, and assume their compliance without looking at the impact of changes on the whole of the aircraft as a complete system.

The implication of the JATR’s findings is that this decision led to everything else that followed. Had the aircraft been developed as a new aircraft type, then a closer scrutiny of the various aircraft systems may have revealed vulnerabilities and forced closer analysis of human factors in operation of the aircraft.

 

   [IT] WAS during the very first week of my Air Traffic Control Training,

   that all of us students, straight from Grammar School, having achieved

   the appropriate Maths and Physics GCE 'A' Level qualifications, had  

   ingrained into our mindset the words of the Civil Aviation Act, which

   state that:

     

    "NOTHING within these rules and regulations, will

    preclude an Air Traffic Controller from taking any

    action necessary to ensure SAFETY FIRST and 

    EXPEDITION SECOND" in the context of the very fact

    that an Air Traffic Controller ASSUMES NOTHING!!!

 

    Never forgetting that [IT] WAS the UK who first established a system

   of Air Traffic Control, and [IT] WAS our Course Leader/Chief Instructor 

   who had been seconded to Germany to establish a version of same in

   Europe under the auspices of the Marshall Plan. Commercial Air Traffic

   in the USA however, was flying under the absolute misconception of

   [BE]ing CONTROLLED for almost a decade, before the realisation dawned

   following a mid-air collision over the Grand Canyon, that their system   

   was in fact only a Flight Information System. 

 

“JATR team members recommend that the FAA review and update the regulatory guidance pertaining to the type certification process with particular emphasis on early FAA involvement to ensure the FAA is aware of all design assumptions, the aircraft design, and all changes to the design in cases where a changed product process is used. The FAA should consider adding feedback paths in the process to ensure that compliance, system safety, and flight deck/human factors aspects are considered for the aircraft design throughout its development and certification,” the JATR finds.

If these findings are accepted by the FAA and other regulators, it will lead to closer scrutiny of what substantiates a major change requiring new type certification. That would affect the design process and approval timeline of future next generation aircraft as well as other aviation products submitted for certification.

The FAA’s initial finding in March of this year, following the Ethiopian Airlines crash, was that the Boeing 737 MAX was still airworthy given the lack of a formal accident report and technical information supplied by Boeing. Other regulators disagreed and made an independent determination to ground the aircraft regardless of the FAA’s opinion.

The JATR members found that the FAA’s information sharing following the two aircraft accidents was inadequate and the FAA should review its own policies for evaluating risk after an accident. “ATR team members recommend that the FAA review its policies for analyzing safety risk and implementing interim airworthiness directive action following a fatal transport aircraft accident. The FAA should ensure that it shares post-accident safety information with the international community to the maximum extent possible.”

The JATR’s findings and recommendations are just that. They will not lead to regulatory change by default. The critical next steps of filtering through which of these findings are valid and actionable are still up to the FAA. In a brief statement, the FAA’s Administrator, Steve Dickson, has committed to reviewing these recommendations and taking appropriate action.

“Today’s unprecedented U.S. safety record was built on the willingness of aviation professionals to embrace hard lessons and to seek continuous improvement. We welcome this scrutiny and are confident that our openness to these efforts will further bolster aviation safety worldwide. The accidents in Indonesia and Ethiopia are a somber reminder that the FAA and our international regulatory partners must strive to constantly strengthen aviation safety.” But at this point, the scrutiny placed on the approvals process for the Boeing 737 MAX is not limited to regulators.

The world is in[DEED] watching.