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FAA is granting Boeing “limited delegation” to certify airworthiness

theregister.com

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Re: FAA is granting Boeing “limited delegation” to certify airworthiness

#61

Post by salawat »

user_7832 wrote: post #46
salawat wrote: post #38

Earlier quoted context omitted.

Which defeats the purpose of adversarial review by a regulator. When your paycheck is signed by who you are regulating, you absolutely cannot force handling of what your employer doesn't want to handle. And seeing as FAA has had reciprocity in terms of certification with other countries (which if other countries were smart, they'd cease recognizing until the U.S. gets their shit straight), it's really an egregious ab…

(Caution, my thoughts are a bit rambly and scattered. It's been a while since I studied this in detail for a class where I had deep divided into the max 8 crash and FAA's lapse, so my memory is a bit foggy.) The short answer is that unfortunately it's practically almost impossible to do this any other way, short of massively increasing funding for the FAA (which is presumably politically not going to be done.) The lo…

>You end up with the engineers at Boeing et al, and the regulatory folk at FAA etc.

Incorrect. The engineers acting as FAA delegates are paid by Boeing, not the FAA. Toxic incentive. Stop shining that apple Leroy, plane needs to get shipped, and bossman is getting testy.

As far as your arguments on the information propagation front go, MCAS was deliberately designed against industry best practices and perception managed from regulators to do everything possible to avoid simulator training. Stop assuming good faith. This was malice. Malice that could only be executed upon because Boeing deliberately appointed junior engineers who didn't know the right questions to ask to FAA delegate positions.

I will not buy that delegating to the company is fine. The only people who benefit from that are the companies. I don't give a damn about the convenience to someone incentivized to go and industrially produce the least safe air transport product they can get away with. I care about the public's safety given I already know the market selects for incentive setters that flirt with risk in dangerous ways. And yes, that means we, the public, should damn well pay for that regulatory edifice. Especially if the rest of the world will treat FAA certification with reciprocity.

Re: FAA is granting Boeing “limited delegation” to certify airworthiness

#62

Post by dehrmann »

user_7832 wrote: post #47

If you're wondering - hey, that sounds terrible, why doesn't the FAA do anything about it? Answer, because it practically can't without maybe a 10x or more budget boost that's practically impossible. Why? Copying from another comment I made on this thread: (Caution, my thoughts are a bit rambly and scattered. It's been a while since I studied this in detail for a class where I had deep divided into the max 8 crash an…

> This isn't unique to just aviation btw but most industries

Most of us work in tech. Imagine an auditor coming in and trying to sort out if one of the most complex systems at your company is "safe." What's safe? Every previously known failure mode and every new one you're going to be blamed for when it happens.

Re: FAA is granting Boeing “limited delegation” to certify airworthiness

#63

Post by xdfgh1112 »

dehrmann wrote: post #62
user_7832 wrote: post #47

If you're wondering - hey, that sounds terrible, why doesn't the FAA do anything about it? Answer, because it practically can't without maybe a 10x or more budget boost that's practically impossible. Why? Copying from another comment I made on this thread: (Caution, my thoughts are a bit rambly and scattered. It's been a while since I studied this in detail for a class where I had deep divided into the max 8 crash an…

> This isn't unique to just aviation btw but most industries Most of us work in tech. Imagine an auditor coming in and trying to sort out if one of the most complex systems at your company is "safe." What's safe? Every previously known failure mode and every new one you're going to be blamed for when it happens.

That's literally the security industry and third party security assessments are routine in tech.

Re: FAA is granting Boeing “limited delegation” to certify airworthiness

#64

Post by jjav »

user_7832 wrote: post #47

If you're wondering - hey, that sounds terrible, why doesn't the FAA do anything about it? Answer, because it practically can't without maybe a 10x or more budget boost that's practically impossible. Why? Copying from another comment I made on this thread: (Caution, my thoughts are a bit rambly and scattered. It's been a while since I studied this in detail for a class where I had deep divided into the max 8 crash an…

> If you're wondering - hey, that sounds terrible, why doesn't the FAA do anything about it? Answer, because it practically can't without maybe a 10x or more budget boost that's practically impossible.

You're correct in that the FAA can't (or at least, it would be wildly impractical) have a staff of in-house experts that equal or exceed the experience of the manufacturer engineers on every possible topic.

But, that's not necessary to enforce a process of quality. It can be done by enforcing that the company must establish and document the processes to ensure quality, including which experts need to sign off on what. Then the FAA needs to hold the engineers who sign off professionally responsible and their managment legally liable if any circumvention is discovered down the line.

Re: FAA is granting Boeing “limited delegation” to certify airworthiness

#67

Post by t_mann »

user_7832 wrote: post #47

If you're wondering - hey, that sounds terrible, why doesn't the FAA do anything about it? Answer, because it practically can't without maybe a 10x or more budget boost that's practically impossible. Why? Copying from another comment I made on this thread: (Caution, my thoughts are a bit rambly and scattered. It's been a while since I studied this in detail for a class where I had deep divided into the max 8 crash an…

Do you know how it works in other places where planes get built, eg Europe, Brazil? The incumbents on both sides will always tell you that there's no other way things could be done. Looking at how they get done elsewhere seems like a good sanity check.

Re: FAA is granting Boeing “limited delegation” to certify airworthiness

#68

Post by _DeadFred_ »

quartesixte wrote: post #48
tjr wrote: post #34

This article seems a bit light on details, but a little more at the FAA website: https://www.faa.gov/newsroom/faa-statement-boeing-airworthin... https://www.faa.gov/other_visit/aviation_industry/designees_... It is typical for aerospace companies to have in-house "FAA delegates" who function in the stead of direct FAA reviewers, and it looks like all that is going on here is the FAA is allowing Boeing to go back to u…

I know a couple of people through my professional network who hold this title and what I've gathered is that delegates have a lot of autonomy and authority. And Boeing does organize the company and even its information systems to practically treat them as FAA regulators. And, FWIW, the type of person who ends up self-selecting into this kind of work are serious people who deeply care about airline safety. It is a rat…

Was at a different aerospace company. Our internal people were really good. And by paperwork FYI they generated 1-2 filing cabinets worth of documentation per tail number of notes/quality checks/etc.

They could have IT set legal hold on email accounts, filesystems, PLM/MLM, etc and only us in IT and them knew, not even higher management. They could scrap $20,000 parts. It's also a small world, so chances are your internal people worked with the FAA person (who could be a consultant or full time FAA employee) at a past job so people know if trust levels are warranted.

There's also a whole other layer of oversite people might not realize. The company's insurance company (think Lloyd’s). They will have their own people who will come do on sites as well and do pretty intensive audits of everything from engineering through production.

Re: FAA is granting Boeing “limited delegation” to certify airworthiness

#69

Post by hgomersall »

dehrmann wrote: post #62
user_7832 wrote: post #47

If you're wondering - hey, that sounds terrible, why doesn't the FAA do anything about it? Answer, because it practically can't without maybe a 10x or more budget boost that's practically impossible. Why? Copying from another comment I made on this thread: (Caution, my thoughts are a bit rambly and scattered. It's been a while since I studied this in detail for a class where I had deep divided into the max 8 crash an…

> This isn't unique to just aviation btw but most industries Most of us work in tech. Imagine an auditor coming in and trying to sort out if one of the most complex systems at your company is "safe." What's safe? Every previously known failure mode and every new one you're going to be blamed for when it happens.

It's not about declaring things to be safe. It's about having documented and adhered to processes that show safety is taken seriously at every point in the design, manufacture and maintenance of safety critical systems.

Re: FAA is granting Boeing “limited delegation” to certify airworthiness

#70

Post by _DeadFred_ »

salawat wrote: post #61
user_7832 wrote: post #46

Earlier quoted context omitted.

(Caution, my thoughts are a bit rambly and scattered. It's been a while since I studied this in detail for a class where I had deep divided into the max 8 crash and FAA's lapse, so my memory is a bit foggy.) The short answer is that unfortunately it's practically almost impossible to do this any other way, short of massively increasing funding for the FAA (which is presumably politically not going to be done.) The lo…

>You end up with the engineers at Boeing et al, and the regulatory folk at FAA etc. Incorrect. The engineers acting as FAA delegates are paid by Boeing , not the FAA. Toxic incentive. Stop shining that apple Leroy, plane needs to get shipped, and bossman is getting testy. As far as your arguments on the information propagation front go, MCAS was deliberately designed against industry best practices and perception man…

You are talking about type certification which is a different certification/process way prior to this. This is talking about 'certificate of airworthiness' for a specific tail number. This is confirmation that the aircraft/tail number was built to type design. It has nothing to do with defining/certifying type design.

The FAA cert of airworthiness just confirms that this tail number was build exactly to type design, or, if required, anything that didn't went through non-conformance (say someone accidentally drilled a hole in the wrong spot and engineers had to decide if that compromised type design, mitigate it if needed, document it, and include documentation on all that with the tail number). There is no malice here this position/certification doesn't do what you seem to think it does.

You salary concern is wrong too. Aviation is a small world. The QA person has to be approved by the FAA to have a job. Boeing can threaten a paycheck, the FAA a career. Boeing is also Union in Seattle.

But again you should not be asking questions at this level just confirming the tail number was manufactured exactly to type design. You should be doing type design checks, that were approved as part of the type design process, and signed off and approved by the FAA. If the system requires someone to be an aerospace engineer level asking smart question during this phase, the entire FAA system failed and it wouldn't matter if FAA was on site or not. This is 1-2 filing cabinets worth of documentation that checks were performed and everything conformed to type. Documenting/verifying every part's serialized number in case of grounding/recall. That assemblies were assembled in the type design specified order, not the faster way Bob on the floor came up with (I think this was the problem with the doors, contractors not doing to type design and type design not requiring auditing in a way that caught that). Stuff like that.

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