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SOC-ARC Moving Beyond “Transactional” Certification

Following the FAA-EASA Annual Safety Conference, the Safety Oversight and Certification Aviation Rulemaking Committee (SOC-ARC) held its second meeting in Washington, D.C. on June 21-22. The first half day was attended by industry only followed by another half day meeting with industry and FAA representatives.

The SOC-ARC is the next step in the FAA’s AIR Transformation Initiative designed to update certification policies and procedures to reflect the agency’s greater emphasis on risk-based oversight. Among the key initiatives is recognition that “mature” (a term yet to be defined) applicants for design approvals do not require the same level of oversight as those with less experience in the certification process. The same philosophy can be seen in today’ Organizational Designation Authorizations (ODAs). 

Rather than continuing to focus on transactional approaches to certification and overseeing each required compliance finding to the applicable airworthiness standards, the agency will recognize robust compliance assurance systems where they exist (and audit to those systems). For such applicants, the FAA will focus its resources on new and novel design features, new technology and higher-risk certification issues. Less mature applicants requiring a more traditional approach to certification will also be accommodated.

The SOC-ARC previously appointed three sub-task groups to address Flight Standards Integration, Performance Measures and an applicant’s Compliance Assurance System. Each of the groups reported out at the June meeting and identified the scope of their review. Each group requested the appointment of subject matter experts to support the next phase of their work, which will be ongoing. The next meeting will be held in the Dallas-Ft. Worth area in September. The SOC-ARC must report its recommendations to the FAA by the end of 2018.

Trade association members of the ARC include (in addition to ARSA):

Aerospace Industries Association
General Aviation Manufacturers Association
Modification and Replacement Parts Association
Aircraft Electronics Association
Aerospace and Defence Industries Association of Europe

Industry members of the ARC include:

Boeing
Gulfstream
GE
Bell
Garmin
Textron Aviation
UTC-Pratt & Whitney
Rockwell Collins
Duncan Aviation
Astronautics
Wipaire

Government employee unions are also involved:

Professional Aviation Safety Specialists
National Air Traffic Controllers Association
American Federation of State, County and Municipal Employees

Previously on AIR Transformation...

4/9/18 - AIR Transformation by Another Name: ARSA Helps Kick Off SOC-ARC

April 9, 2018

On April 3, the Safety Oversight & Certification Aviation Rulemaking Committee (SOC-ARC) held its initial meeting at the MITRE Corporation in Vienna, Virginia to discuss the committee’s charter and plan for the next steps in the Aircraft Certification Service’s (AIR) Transformation initiative. MITRE is facilitating the effort under contract to the FAA.

The purpose of the SOC-ARC is to provide a venue for industry stakeholders to identify and recommend initiatives to improve the efficiency and effectiveness of the certification and safety oversight system. The ARC, which was chartered in January 2018, will do much of its work in task groups that will focus on important elements of the certification system including industry compliance assurance systems, product performance, AIR interfaces with AFS relating to certification, international compliance and others.

The meeting was well-attended by industry and FAA representatives in both AIR and the Flight Standards Service (AFS). Like ARSA, most of the industry attendees have been active participants in the AIR Transformation process (see below) which has been working to align the agency’s oversight model with established risk-based principles. In addition to ARSA (which is represented by its Managing Director & General Counsel, Marshall S. Filler), other trade associations represented on the SOC-ARC include the General Aviation Manufacturer’s Association (GAMA), Aerospace Industries Association (AIA), the Aircraft Electronics Association (AEA) and the Modification and Replacement Parts Association (MARPA). Company representatives involved in the AIR Transformation effort also attended, including Boeing, GE, Gulfstream and HEICO.

The committee will evaluate the FAA’s existing regulatory structure and supporting guidance, industry practices for meeting airworthiness standards and ensuring compliance, self-monitoring, self-reporting and self-correcting processes and the changes needed in those processes to implement safety management systems.

The committee has been tasked with submitting a report to the FAA by the end of 2018 containing the results of its assessment along with its recommendations to improve the efficiency and effectiveness of the certification system while maintaining the high level of safety achieved under the current certification structure and processes.

Stay tuned for updates as ARSA continues to support the SOC-ARC.

3/6/18 - The Future is Here for AFS & AIR

March 6, 2018

On March 5, the Federal Register published the FAA’s final rule on the functional reorganizations of both the Aircraft Certification Service (AIR) and Flight Standards Service (AFS). The rule is the result of ongoing efforts by each organization involving both government personnel as well as ARSA and other industry stakeholders.

Attendees at the 2018 Annual Repair Symposium will get updates from the agency on each initiative:

AIR Transformation

As part of a longer-term strategy, AIR underwent a “holistic” process to review, update and improve its certification strategy, management systems and organization to realign into a functional structure.

Future of Flight Standards Initiative

As part of a larger effort to overhaul culture and improve efficiency/responsiveness, AFS reorganized into function-based structure (rather than geography):

  • Four directors.
  • Eight deputy directors.
  • Twenty-eight division managers.
    • Regional structure replaced by four functional organizations: Air Carrier, General Aviation, Standards, and Foundational Business.

To review the final rule, follow the link below to the Federal Register:

Final Rule: Aviation Safety Organization Changes
Published: 03/05/2018
Docket #: FAA-2018-0119
Effective date: 03/05/2018

The FAA Aircraft Certification Service (AIR) and Flight Standards Service (AFS) have reorganized to align with functional organization design concepts. The AIR reorganization included eliminating product directorates and restructuring and re-designating field offices. The AFS reorganization included eliminating geographic regions, realigning headquarters organizations, and restructuring field offices. Currently, various rules in the Code of Federal Regulations refer to specific AIR and AFS offices that are obsolete after the reorganizations. This rule replaces specific references with generic references not dependent on any particular office structure. This rule does not impose any new obligations and is only intended to eliminate any confusion about with whom regulated entities and other persons should interact when complying with these various rules in the future.

4/11/17 - Working Groups Explore Complexity of AIR Transformation

April 11, 2017

On April 6, ARSA’s Managing Director and General Counsel Marshall S. Filler and Regulatory Affairs Director Ryan Poteet attended the second joint government-industry meeting, hosted by MITRE, to discuss the progress of the Aircraft Certification Service (AIR) Transformation.

The meeting brought together the initiative’s working groups – each tasked with evaluating and plotting steps to achieve certain transformation process objectives – to report back on their efforts so far. The key takeaway from these briefings was the complexity and interdependence of each aspect of the aviation regulatory system; overhauling AIR cannot be accomplished in a vacuum and the groups’ goal is to make the transition seamless.

Training needs were key to the deficiencies noted during the meeting. The process will fail if an independently-conceived, utopian framework for AIR is fumbled in execution through lack of information. The agency’s goal, through its industry partners, is to prevent poor follow through and currently aims to have a draft comprehensive strategic plan by September. Implementation will follow shortly thereafter.

Stay tuned to ARSA as the association and its industry allies help the FAA through the details.

2/14/17 - Filler, Poteet Helping 'Transform' AIR

February 14, 2017

On Feb. 7, Marshall S. Filler, ARSA’s managing director and general counsel, and Ryan Poteet, ARSA’s regulatory affairs director, joined officials from the FAA, MITRE and representatives from every facet of the aviation industry to discuss the transformation of the FAA’s Aircraft Certification Service.

The meeting’s focus was on industry and its assessment of how certification activities should proceed in the future. This monumental undertaking could not be accomplished in a vacuume and industry perspective is essential to avoiding pitfalls and ensuring each segment of the aviation safety system works in unison.

The industry-FAA collaboration will continue with the addition of working groups to analyze discrete regulatory and policy issues. Filler is slated to lead the International Working Group, which is tasked with analyzing ICAO obligations, the FAA’s role in shaping global standards and agency partnerships with other NAAs, among other things. Poteet has been chosen to participate on the Accountability Framework Working Group, which is tasked with analyzing compliance models, how the FAA will oversee certification projects and the development of agency guidance.

Stay tuned as ARSA continues to provide its perspective and shape agency policy objectives.



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