Monday, December 27, 2010

Reverse Engineering: Building New Pieces for the Airworthiness Puzzle

Welcome to Wired!

incomplete-puzzleIn many ways, maintaining the airworthiness of a transport category aircraft is akin to constantly reworking a jigsaw puzzle. Whether it is a pneumatic or hydraulic valve, tooling used for sheet metal repairs, or a bushing or bearing, each piece is important. For whatever reason, if it no longer measures up to its  type certification data, the puzzle is incomplete, says ASIG Managing Director Luke Ribich, which means the airplane is not airworthy, unable to earn its keep.

If a piece cannot be economically replaced or repaired, or it does not deliver the desired reliability, creating a new piece by reverse engineering the original may well be the most efficient and cost-effective solution, especially when its costs can be shared by a fleet over time because “high-volume programs can buy down the unit cost,” says Ribich.

For example: An airline with a DC-8 fleet needed engine thermocouple harnesses, an expensive item from the OEM with a long lead time. ASIG reverse engineered the harness, and manufactured certified PMA parts for a fraction of the cost of buying them from the OEM.

Better reliability is another benefit of reverse engineering, especially with pieces of older puzzles. “In their day, the 707 and DC-8 were good to have 70 percent dispatch reliability. Today, operators want 92 percent or better dispatch performance,” Ribich says, “and you might not get that out of some of those older materials and process designs.” In addition, “A lot of those old parts suffer from self-inflicted wounds, otherwise known as maintenance malpractice, caused by improper handling by technicians.”

To create a piece of the puzzle ASIG’s engineers dissect an existing product or component. Drawing on an arsenal of tools, from micrometers and laser scanning devices to testing equipment that analyzes metallurgy, hardness, surface texture, and electrical properties, there isn’t anything they don’t know about it. At the same time, they assess the original’s design for reliability, performance and material durability.

In crafting the new piece, which fits the airworthiness puzzle just as the original did, ASIG’s engineers employ all the advances made in design, materials, and manufacturing since the OEM created the original part. ASIG not only produces reverse-engineering technical data packages equal to those of its STC efforts, says Ribich, it can manufacture parts “that stand up to government verification, validation, and qualification” examinations.

Reverse engineering can also be a great learning tool. The lesson, he says, is to create compatible parts that deliver lower cost and better documentation and require less time to manufacture. MROs, (maintenance, repair, and overhaul companies) are turning to ASIG, seeking replacements for expensive parts with long lead times, like the bushings, bearings, and other fittings used in flight control system components.

“The OEM charges $60,000 for this hand-sized chunk of metal because of its captive market, which drives up the costs of these things,” Ribich says. Given the cost and lead time, when one reaches two-thirds of its service value, many airlines “will buy another one, just to have it in stock.” Replacing these items with reversed-engineered PMA parts enable MROs to give their customers more responsive, economical, and flexible service.

In the past, there was some question about using PMA parts on transport category aircraft. This issue came to a head with replacement blades for turbine engines, which are not inexpensive. But the FAA settled that issue several years ago, Ribich says, paving the way for greater use of PMA pieces in the airworthiness puzzle .

Until next time, stay 5x5, mission ready, and Wired!

Thursday, December 16, 2010

Building Blocks Simplify RFQ Process

Welcome to Wired!

building blockPreparing a request for a quote to integrate new equipment, and the capabilities it provides, can often grow into a process more complicated than it needs to be. An RFQ is like any other business document; its efficacy depends on clear, concise, comprehensive communication. To avoid the stress and delay that comes with making it more difficult than it needs to be, work backwards one block of information at a time.

Everything builds on the cornerstone, on a concise statement of work, says ASIG Managing Director Luke Ribich. “The number one issue with RFQs is the absence of clearly defined operational goals: We want to do this. We want these system qualifications. We want this improved dispatch reliability. We want to satisfy these regulatory requirements by this date and time.”

Rather than being afraid to admit that they don’t know what they don’t know, operators should “be open to the education that comes from it,” Ribich says. “More often than not we’ll get a call from an operator saying ‘I have this problem. I have this need.’ So we start with consultations, research the available solutions, help them create their statement of work, and then, based on the operational requirements, show them what the project  is going to entail.” 

Not fully understanding  the complexity and allowable regulatory  parameters that shape the certification process can lead to confusion. To some, “the certification package consists of installation drawings, wiring diagrams, instructions for continued airworthiness, approved flight manual supplements, and the document data list.” But that’s only the half of it. These things follow the engineering and test data, annotated with the appropriate FAA guidance, that proves to the aircraft certification office’s satisfaction that the new system integrates with the existing systems without suffering or causing problems.

To overcome this confusion, using the cornerstone statement of work, ASIG explains its SEMPER process and leads an operator  through the realities of the certification process. (For an idea of what’s involved, see the three-part STC Symphony.) With the statement of work, “we typically ask for the baseline tech data,” Ribich says, the maintenance manuals, wiring diagrams, repair manuals, and related aircraft documentation pertinent to system being integrated.

If they have already done internal research, in their RFQ operators can identify the equipment, by manufacturer and part number, they would like to use. “That way we can start to gather the necessary intel, if you will, on the device, the spec sheets, the installation data, the OEM manual, what the sensor inputs and outputs are, and all the physical and environmental requirements for mounting and placement.”

But this research is not mandatory. “If they haven’t identified equipment up front, we’ll do a cost configuration assessment,” says Ribich, and present options, as the statement of work allows, that offer the best efficiency, economy, and scalability.

TimeIsMoneyHow much time a project takes depends on its complexity, and the number of separate steps. Design and certification is one step, or line of business, and the manufacture of PMA parts and/or installation kits is another line of business because “the kitting costs won’t be finalized until the design data is finished.”

Customers can influence the timetable greatly. Instead of getting to work after it received the contract, ASIG spent four months educating a recalcitrant Part-121 customer that did not fully grasp the FAA certification requirements that prevented it from installing a system approved for the business-jet version of the airplane it used to transport paying passengers.

This project was nowhere near the complexity of another project, demilitarizing and converting a French Air Force DC-8-72 and its five-man cockpit  into an US-registered aircraft with with a three-man cockpit filled with 21st century systems. But it took less time, 4.5 months from contract award, “and we did the installation in a line flight environment, nosed into an FBO’s hangar.” Like the project, the RFQ that launched it was just as straightforward.

Until next time, stay 5x5, mission ready, and Wired!

Wednesday, December 15, 2010

ASIG Certifies iPad EFB on N-Jet Charter Fleet

EFB-PR2Little Rock, AR: December 13, 2010—Avionics & Systems Integration Group (ASIG) accepted—and quickly met—the challenge issued by N-Jet/Northern Illinois Flight Center: Make the Apple iPad a COTS electronic flight bag approved for FAA Operations Specification A061 “paperless” operations in its diverse Part-135 fleet of seven different aircraft models.

“The iPad EFB is about 1/10th the cost of a traditional Class 2 EFB. In addition, the iPad’s ability to use electronic aeronautical data in lieu of paper enroute charts and approach plates can cut the annual cost of paper data in half.  These two factors give the iPad EFB a compelling financial justification.” says ASIG’s Managing Director Luke Ribich, “By integrating the iPad EFB into its diverse fleet,” wrote N-Jet CEO Howard Seedorf, ASIG “has allowed us to reduce our aircraft weight, lessen the burden and expenses associated with managing revision transmittals while improving crew resource management.”

Equally important, the FAA’s acceptance of the iPad EFB system and its documentation provides “future fit options by giving us great flexibility as commercial technologies bring forth new and advanced devices or, as we add additional aircraft types to our existing fleet” of the Citation Excel and Encore+, Astra/G100, and Falcon 10, 50, 900B, and 900EX EASy.

ASIG’s iPad EFB integration expertise includes iPad environmental testing for rapid decompression (RD) and electromagnetic interference (EMI), a “smart” power supply to mitigate FAA concerns about charging lithium batteries on aircraft and the ability to design and certify a variety of aircraft system interfaces for the iPad EFB.

Addressing its “technical and regulatory expertise,” N-Jet wrote that ASIG “went the extra mile to supply expert consultations and often supported short-notice teleconference meetings with our Primary Operations and Avionics Inspectors from our CHDO, [giving] our ASI’s a high degree of confidence in ASIG and the entire project, making the application process trouble-free.”

For additional information regarding ASIG's operating activities, product and services offerings join the company’s technical journal, Wired – an Avionics & Integration Weblog, ASIG’s bi-weekly newsletter or contact Mr. Mike Neder, Director of Business Development, toll-free at (866) 890-ASIG [2744] or ASIG sales group via email at sales@asigllc.com.

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Wednesday, December 1, 2010

FAA Requires Smart Power Sources for Portable Electronic Devices

Welcome to Wired!

From smart phones to laptop computers to the iPad, portable, personal, and productive electronic devices (PEDs) have not only changed our daily lives, they have redefined the AC outlets found on Part 25 transport category aircraft. Even though PED plugs fit in old-school “dumb” outlets, FAA Policy Memo ANM-01-111-165, Policy Statement of Power Supply Systems for Portable Electronic Devices on Part 25 Airplanes, makes it clear that these outlets are are NOT approved for this use.  

Most aircraft 110-volt AC outlets  today deliver 500 volt-ampere power to whatever is plugged into them, like the cleaning crew’s vacuum cleaner. An iPad is not a vacuum cleaner. Like most PEDs, it has a lithium-polymer battery. Feeding too much juice to lithium batteries can lead to bad things. In   thermal runaway a battery can  deliver shocks, burns, and smoke. And overloading the PSS circuit can shut down the electrical bus it is connected to, and maybe even the generator that powers it.

To avoid these problems—and their consequences—the FAA  requires “smart” PSSs that deliver “Goldilocks” power, not too much, not too little, just right for the PED’s operating needs. In a 1997 policy memo, the FAA said 100-watts adequately powered the laptops of that era, so it was the PSS’s max output. With the maturation and proliferation of the extended PED family, in 2005 the current memo doubled the power limit to 200 watts, still less than half that in dumb outlets.  

In an AC circuit, the 200-watt PSS maximum is better specified in volt-ampere (VA), which is like a watt but not identical. Electrical engineers prefer the volt-ampere because it is the unit of measurement used in the selection of conductors and devices that protect a circuit. Regardless the measurement, the consequences of too much power are the same.

PEDs today have no “novel or unusual design features” that require specific mention of them in federal aviation regulations or requirements, says the policy memo. The current regs and requirements provide an adequate level of safety and the memo lists all that apply to the certification of a PED PSS. Dated March 18, 2005, the memo supersedes 1997 policy for the installation of in-seat power supply systems. The current policy covers all PED power supply systems regardless of the outlet’s location: the cockpit, seats, cabin baseboards, or a cabinet on the aft bulkhead.

Related regulatory guidance can be found in two other policy memos: ANM-100-2000-00105 (September 18,2000), Certification of In-Flight Entertainment Systems, addresses wire installation and cabin components, including “smart” outlets. ANM-111-2002-01-04 (January 28, 2003), provides guidance on wiring design and instructions for continued airworthiness.

Limiting the PED PSS to 200 VA prevents its use for unintended functions, like driving a curling iron or hair dryer. It is for PEDs only, and further guidance can be found in Volume 4 of FAA Order 89001, which covers electronic flight bags (EFBs). A tablet computer like an iPad, worn as a kneeboard, is a Class I EFB. Mount it in a bracket and it is a Class II EFB. Regardless, it is still a portable electronic device that needs power.

Of particular interest is section 4-1644E, Power Sources: When the iPad’s battery is the primary power source, aircraft power can be secondary, recharging the battery in flight.  Continuing this thought, Section 4-1648A, EFB Power Source, points back to the PED PSS installation requirements. A note reiterates the safety hazards posed by over-charging or discharging lithium-ion batteries. “Operators should have lithium ion battery charging procedures which are in total accordance with the battery manufacturer’s charging instructions and prevent aggravation of lithium ion battery thermal hazards.”

With a “dumb” outlet that delivers a fixed flow of energy, this is easier said than done because every manufacturer has slightly different charging instructions. Some prevent overcharging by automatically reducing the AC input when the battery is topped off. Others tell the user to pull the plug when the LED stops flashing.

Therein lies the beauty of a smart power supply system like ASIG’s Astronics AES EmPower® system: it reacts to the load of the connected device and ensures against over-current, over/under-voltage, and frequency differential conditions. Once satisfied that the connected device does not demand more than these thresholds, it provides only the amount of volt-amperes deemed suitable for PEDs as established by the Federal Aviation Administration.

Naturally, there is much more involved in installing a power supply system specifically for PEDs whether they are video games, smart phones, or iPads. For more specifics, contact ASIG.

Until next time, stay 5x5, mission ready, and Wired!

Sunday, November 14, 2010

Compliance & Implementation: STC Symphony Part III

Welcome to Wired!

Part I: Certification Management is ASIG’s STC Symphony

Part II: Plan the Certification, Certify the Plansymphony_orchestra_02

With the certification plan accepted, the project manager and ASIG-FAA team assigned, Phase III of the STC symphony, Compliance Planning, begins, says Luke Ribich, ASIG’s managing director. It completes the certification plan by itemizing how tests and inspections will verify its realization.

How involved the FAA is in this effort depends on the project’s complexity, the available resources, and the experience of the applicant and its designated engineering and airworthiness representatives. Triggers for increased FAA involvement include rulemaking for special conditions, determining ELOS—equivalent levels of safety—developing issue papers, and tasks it never delegates.

Typically, the FAA delegates all but its direct responsibilities, so DERs and DARs, conduct the conformity inspections that demonstrate engineering and manufacturing quality and show compliance. Using common compliance means, such as those outlined in advisory circulars, streamlines the process. Parts built to a TSO have already earned FAA approval, and a Parts Manufacturer Approval, also handled by ASIG, does the same for equipment built specifically for the STC.

Ultimately, the ACO identifies critical test items that generate data for 100 percent compliance, providing special test instructions as necessary. Compliance planning completes the Certification Plan, and if everything it contains is successfully executed, the results will show compliance.

In Phase IV, Implementation, ASIG starts submitting the actual data to the project manager, according to the timetable. Type design data includes drawings, specs, dimensions, materials, processes, airworthiness limitations, and more. Other data comes from design evaluations and conformity inspections of parts, assemblies, installations, test articles and setups, and functions. The FAA evaluates it all to ensure that it matches everything specified in the certification plan.

The FAA can conduct any conformity inspection it wants, and the project must pass them before ground and/or flight testing can begin. When ASIG manufactures an installation kit, it must pass a conformity inspection, usually conducted by a staff DAR, before it can be installed, Ribich says. A second conformity inspection verifies, down to the smallest fastener, that the kit was appropriately installed.

During conformity inspections the test team is finalizing its comprehensive plan, which covers everything from the test items, process, and setup to when and where and witnesses. As with every other aspect of the certification plan, “everyone is on the same page about the level of testing,” and conformity inspections verify that the tests followed the approved plan. Meanwhile, the FAA’s aircraft evaluation group (AEG) is reviewing other aspects, like the electrical wiring interconnection system plan, ICA, and flight manual supplement.

Approved Stamp When it is clear the aircraft will meet the certification basis, the FAA issues a Type Inspection Authorization, an internal document clearing the aircraft is ready for its final certification inspections and tests. If these tests deliver as all previous data has predicted, and the AEG has signed off on its reviews, the FAA issues the STC.

Issuance of the STC begins Phase IV, Post-Certification Activities. With the airline in charge of operational safety and airworthiness accountability with ASIG, as appropriate they evaluate, report, and remedy any applicable problems and disseminate this information to all involved, because the rewards of an STC symphony also come with continuing responsibility.

Until next time, stay 5x5, mission ready, and Wired!

Tuesday, October 12, 2010

Plan the Certification, Certify the Plan: STC Symphony Part II

Welcome to Wired!

Part I: Certification Management is ASIG’s STC Symphony

In an STC symphony the certification plan is the score, the major-domo document that tells who is to play what note when. It is a living manuscript, says Luke Ribich, ASIG’s managing director. It changes as it matures because “stuff always pops up along the way.”

faa_logo Its genesis begins in Phase I, Conceptual Design, with the kickoff meeting where ASIG familiarizes the FAA Aircraft Certification Office (ACO) with the project and what FAA resources will be needed to complete it, “if we don’t already have access to them, which we usually do,” says Ribich.

Occasionally this briefing can take place virtually, says Ribich, but ASIG prefers meeting face to face, just as it does with its customers, because it simplifies mutually beneficial show-and-tell, the gathering’s essential purpose. Given the depth of detail derived from the definition of work with the operator, ASIG briefing includes who will supply major equipment and any related vendor relationships.

For example, in addition to “certification management and technology insertion,” ASIG may distribute the equipment it’s installing, such as EmPower and the OnBoard IFE system. Such arrangements rarely cause problems because everyone knows about them up front, just like any technical issues related to the STC, or unique or novel features it introduces.

In the simplest terms, in Phase I ASIG and the ACO discuss every aspect of the certification plan before ASIG writes it. The FAA reviews the submitted plan in Phase II, Requirements Definition, which leads to the project’s first milestone, FAA acceptance of the plan.

FARs Briefly, the certification plan includes General Information, a complete, concise description of the modification. It specifies compliance methods and verification data, including ground, air, and component testing. This must be congruent with the certification basis, says Ribich. In certain cases, a project may use a historic level of certification rather than current regulations.

The Schedule of Project Completion predicts all major milestones, submission of data and test plans, and when and where design, manufacturing, parts, installation, and conformity inspections will take place. Meeting deadlines is the key to avoiding delays, so ASIG coordinates all schedule changes with the ACO.

To expedite certification and reduce the demand on ACO resources, at the kickoff meeting ASIG requests that its staff DERs and DARs perform all appropriate engineering and airworthiness work on the FAA’s behalf. The certification plan lists this mutually agreed upon cadre of experts and their contribution to the project.

The Continued Airworthiness Plan tells how the design change will affect the instructions for continued airworthiness and the forthcoming updates. Likewise, there is a conformity plan. If the project involves hardware and/or software not already approved by TSO or conforming to RTCA standards, this, too, must be addressed in the plan.

When the plan passes muster, the FAA accepts it and the ACO assigns a project manager, and it is ready for Phase III, Compliance Planning.

Until next time, stay 5x5, mission ready, and Wired!

Friday, October 1, 2010

Certification Management: ASIG’s STC Symphony

Welcome to Wired!

At first utterance, certification management sounds like a mundane process. Far from it, says Luke Ribich, managing director of ASIG. It is a synonym for earning an supplemental type certificate (STC), a complex, overlapping five-phase effort illustrated by a flowchart that fills two pages in AC 21-40A, Guide to Obtaining a Supplemental Type Certificate. At almost every step, he says, there can be “a lot of gotchas for the unaware.”

STC-Flowchart-1 STC-Flowchart-2 Managing an STC effort is not unlike writing and arranging a symphony. Composing the score is just the first step. Then comes hiring the musicians, renting the hall, rehearsing, promoting the performance, and then conducting it for an audience of critics. To get a good review—the desired STC—everyone must play their parts without error, with each section reaching its crescendo on cue.

Anyone who covets such a composition can attempt the process on their own, but as his noble patrons immediately realized, commissioning Beethoven provided less costly gratification more quickly, saving them the time and gotchas of learning to do it themselves. Once commissioned, ASIG employs its SEMPER process to learn about and define an operator’s specific requirements.

Upon completing this conceptual research, the operator’s “job is to sit back and make decisions as presented, and provide any baseline data that we request,” Ribich says. ASIG handles almost everything with the FAA, delivering regular reports so everyone knows where the project is on its detailed timeline.

As in music, understanding the process enriches appreciation of the product. In this, the first of three parts, Wired will reveal the structure of ASIG’s STC symphony. Who participates in the conceptual sessions with ASIG depends on what equipment and/or capabilities the operator wishes to add to its fleet, says Ribich. ASIG recommends that the ensemble include all interested stakeholders from within engineering, tech service, and maintenance to operations. ASIG also recommends that the airline’s principal operations, avionics, or maintenance inspectors attend.

Involving the appropriate FAA inspectors early can be important on STC projects that involve operational approvals. ASIG handles every aspect of the certification, says Ribich, but the airline’s certificate management team must deal directly with the FAA on all operational approvals. Installing an iPad based electronic flight bag is a good example, Ribich says. ASIG develops the installation right down to the mounting bracket’s effect on human factors. But to use the approved installation the airline must get the approval of its POI. Involving the inspector early reduces the chances of a last-minute surprise.

During this process, ASIG writes and refines a detailed definition of the operator’s requirements. It ranges from regulations and policy on which the STC is based to cost configurations, ground and flight testing, and sourcing parts. When certain that no note is sour, ASIG schedules a kickoff meeting with the FAA Aircraft Certification Office, which starts Phase I of the STC symphony, Conceptual Design.

Until Next time, stay 5x5, mission ready, and Wired!

Wednesday, September 8, 2010

Aging Aircraft Safety Rule Deadline, Fatigue-Critical Structures & ASIG

Welcome to Wired!

In medicine, the guiding principle is “First, Do No Harm.” In other words, treating the malady is not supposed to adversely  affect the patient’s immediate health or long-term quality of life.

737 Convertable A similar rule will soon affect Part 121 and 129 operators. At the heart of the Aging Aircraft Safety Rule (AASR) is the requirement that the repair, alteration, or modification of fatigue-critical structures does not affect airframe integrity and safety. To ensure this outcome, by December 20, 2010, operators must have in place a maintenance program based on the airframe’s damage tolerance.

“Aging,” however, is a misnomer. AASR affects every US-registered airplane in 121/129 service that was delivered before the December 20, 2010 deadline. Whether you’re flying a venerable DC-8 or a 777 that was delivered yesterday, AASR applies to you. At best guess, it affects roughly 4,000 airplanes and 240 operators. (That number could more than double if Transport Canada and EASA decide to adopt its requirements.)

In the FAA dictionary, a fatigue-critical structure “is susceptible to fatigue cracking that could contribute to a catastrophic failure.” This includes structures that become susceptible to catastrophic fatigue cracking due to alteration or repair.

ASIG has built considerable knowledge of and experience with  AASR requirements and processes through years of STC work.  Since  January 11, 2008, the rule has required that STCs include damage tolerance inspections of fatigue-critical structures. It has made the same requirements for new or revised repair and master-change service bulletins. The point is that regardless of how the information is delivered, STC or service bulletin, the essential process for acquiring the necessary data is the same.

 Advisory Circular 120-93, Damage Tolerance Inspections for  Repairs and Alterations, provides the necessary guidance. To comply, by December 20 operators must reassess their structural maintenance programs and how they handle repair approvals. They must survey all active airplanes and document what existing  repairs, alterations, and modifications require damage tolerance inspections. Compliance might sound easy, but it requires complex process and procedural changes and revisions to existing maintenance programs.

In the FAA dictionary, an “existing” repair, alteration, or modification will have been performed before December 20, 2010 on a fatigue-critical structure not already covered by a damage tolerance evaluation and resulting inspections.

B727 The survey and evaluation process starts with an “as-delivered” aircraft, with  OEM supplied documents setting the baseline.  These documents define and list fatigue-critical structures and include updated damage-tolerance maintenance data in repair manuals and in  fleet and master-change service bulletins. STC holders, such as ASIG, provide baseline data for applicable modifications.

The Operator Implementation Plan (OIP) is built on the foundation of baseline data. It includes a timeline for such milestones as completing the fleet survey, determination of damage tolerance inspections, and accomplishment of those first inspections. The OIP is due by December 20, 2010, and the operator’s FAA principal maintenance inspector must review and approve it.  ASIG’s leadership team has its foundation in air carrier engineering management.  Their efforts have led to the derivation of a variety of FAA accepted procedural compliance programs supporting airframe “thumb-printing,” specifically those tracking, detailing and analyzing damage tolerance.   Damage tolerance programming and DTA show-compliance determinations are at the very core of ASIG’s Structural DER cadre.

Once the OIP and the individual airframe applications are approved, the work continues after the deadline as operators follow their OIP to compile their damage tolerance data and revise their maintenance programs that sustain fatigue-critical structures and airframe integrity.

ASIG extends its sincere thanks to thanks to Mr. Mike Gray of Sun Country Airlines for suggesting we address this industry critical topic.

Until next time, stay 5x5, mission ready, and Wired!

Monday, August 16, 2010

ITAR & Exporting Aviation Technology

Welcome to Wired!

Aviation is an industry with global reach and international relationships, but national borders still matter, especially when it comes to US aviation technology. For use beyond America’s shores it must be properly licensed under the International Trafficking in Arms Regulations (ITAR), established in 1976 to improve national security.

If you’re wondering what this has to do with aviation, peruse the United States Munitions List. On page 39, under Item 9—Category II, you’ll find “instrumentation, navigation, and direction finding equipment,” which includes “integrated flight instrument systems.”

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Item 10—Category II covers “Flight Control Systems” and its technology, including the “integration of the flight control, guidance, and propulsion data into a flight management system.”

And Item 11—Category II covers “Avionics,” with special interest in radar and laser radar systems (including altimeters), GPS, and systems capable of terrain mapping.

All of these systems can be easily modified to fly an unmanned aerial weapon to its target, says Luke Ribich, ASIG’s managing director, so the government likes to keep track of them.

It starts with the State Departments’ Directorate of Defense Trade Controls, keeper of the Munitions List. Another important player is the US Commerce Department’s Bureau of Industry and Security, which publishes the Commerce Control List. Intimately connected to multinational agreements and international relations, the CCL changes frequently.

labyrinth touch The point, Ribich says, is that export requirements for aviation technology is a complex regulatory labyrinth, and the penalties for taking a wrong turn can be expensive, often measured in seven figures, with jail time. Things have gotten even more serious since 9/11.

Earning and maintaining an export license is a substantial investment, Ribich says. Given its complexity and consequences,  it demands the full attention of dedicated resources. That’s fine for companies like ITT, Lockheed Martin, and Northrop Grumman, and ASIG, but an operator who periodically needs this expertise, not so much. 

Serving operators worldwide, ASIG maintains its export license as part of its comprehensive menu of engineering and certification services. By drawing on this international expertise for out of the ordinary projects, operators can focus on the demands of their daily operations, Ribich says. “Export can be easily done,” he continues, “if you’re set up with a State Department-approved ITAR-licensed export program.”

With many transport category aircraft owned by international leasing companies, export regs are important considerations. Giving an example, Ribich says several years ago a US operator sold its N-registered aircraft to an overseas company who, in turn, leased them to an European operator who registered them in its homeland.

“The leasing company is now leasing them back to the original owner,” and ASIG is reconfiguring them to the new (original) operator’s standards, taking care of all the government approvals so they will be FAA-approved when they return to America.

“We didn’t have any ITAR items in that project,” Ribich says, but ASIG knows that because it checked every system against the applicable regs. When it comes to national security, the government isn’t known for a lenient sense of humor, and ignorance is no excuse for not complying with the requirements.

Until next time, stay 5x5, mission ready, and Wired!

Wednesday, August 4, 2010

The Best of AirVenture Oshkosh 2010

Welcome to Wired!

EAA AirVenture Oshkosh is America’s annual cornucopia of aviation. Drawing all segments of the industry, it is the premier stage on which to debut new products and report the progress of innovations under development. Many things captured our attention, and the following made our Best of AirVenture list.

GE Aviation & Electric Aircraft

AV5-052 GE Aviation sponsored the inaugural Electric Aircraft Symposium, on July 30, and the Aviation Learning Center, home to related exhibits.  When it comes to transport category aircraft, electric propulsion is not yet practical, but it’s perfect for  aircraft systems because it  replaces “big and hot with small and cool,” GE Aviation President Chet Fuller told the roughly 300 participants.

With its generators producing 1.4 megawatts, the Boeing 787 is aviation’s first electric airplane, right down to anti-icing, he said. It replaces  pneumatic and hydraulic systems, which leak, and eliminates bleed air systems, explaining that heat and composites do not go well together.  Looking to the future Fuller said smart grids would deliver electricity without waste, variable frequency power would eliminate AC and DC systems, and that fuel cells would eventually replace wasteful APUs.

Sikorsky Innovations Preparing Electric Firefly

AV5-042 The technology development arm of its parent company, Sikorsky Innovations debuted Project Firefly, an electric powered helicopter. A a high-efficiency U.S. Hybrid electric motor and digital controller drives the S-300c’s stock rotor and transmission. Side-mounted Gaia lithium ion energy pods  provide the power. Approaching its first flight, the Firefly’s initial endurance goal is 15 minutes, said Sikorsky Innovations Director Chris Van Buiten. Upcoming flight tests will prove the system’s reduced complexity, noise, maintenance, and vibration. With no carbon footprint, it will deliver full power at altitude. This research will likely spawn new systems, he said, like an electric anti-torque tail rotor, which  promises numerous power, noise, and vibration benefits. 

Aspen Avionics Geo-referenced Charts

Evolution_georef_ChartDataAspen Avionics, working with Seattle Avionics Software, a software developer and data provider, has introduced geo-referencing  on its Evolution EFD1000 and EFD500 multifunction displays (recently approved for Class III aircraft, which weigh 6,000-12,500 pounds). Besides displaying the aircraft’s relative position on AeroNav (formerly NACO) instrument approach charts and airport diagrams, this new capability comes at no cost, other than a  database subscription. When users load the the July 28 Seattle Avionics chart update it automatically upgrades their systems with the new capability.

Avionics & Autopilots Act When Pilots Distracted

When multitasking in complex instrument airspace, single pilots can easily get distracted from their primary job of flying the airplane. Two avionics OEMs are addressing this problem from different angles.

Avidyne's DFC90 autopilot now offers speed-based Flight Envelope Protection. Currently, it’s STC’d for Cirrus SR20 and SR22 piston singles with Avidyne’s Entegra avionics system and S-Tec55X autopilot. With the autopilot engaged, it provides aural and visual warning when nearing high and low-speed parameters. If the pilot does not act, the DFC90 adjusts the pitch to maintain a safe speed while continuing to issue its warnings.

Garmin's Electronic Stability and Protection (ESP) System  maintains safe and stable flight when the autopilot IS NOT engaged. Driven by G1000 and G3000 avionics, ESP monitors attitude and airspeed—and tells the autopilot servos to make corrective pitch and roll inputs when the aircraft approaches unsafe attitudes and airspeeds. Recoveries are programmed to not exceed airframe g-limits.

AeroLEDs Frugally Bright Landing & Nav Lights

AV6-076 Amateur aircraft builders have been using LED aircraft lighting for some time. In 2007, AeroLEDs produced the first all LED nav/strobe system that meets the requirements of TSO C30C and C96a-C2, giving operators of certificated aircraft access to the reliable lights that use up to 80 percent less power than their incandescent counterparts. Just joining the landing light line is the SunSpot 64, a 35-ounce unit that produces 17,000 lumen on 224 watts and 8 amps at 28 volts.

New iPad EFB Applications

Jeppesen has introduced its Mobile TC application that searches and views terminal charts. Subscribers to JeppView get iPad access at no extra charge. Seattle Avionics Software is providing its ChartData to four new iPad apps: Flight Guide’s iEFB; Hilton Software’s WingX; Radenna’s SkyRadar; and Zivosity ‘s Beacon North America.

Until next time, stay 5x5, mission ready, and Wired!

Thursday, July 29, 2010

ASIG Tells the Rest of IFE Story

Welcome to Wired!

A recurring news story is the investment major airlines are making to upgrade the cabin amenities in their fleets. This CBS News report shows the benefits of power supplies for passenger electronic devices and seat-back in-flight entertainment screens. But like most such news stories, it ignores regional carriers and operators of smaller aircraft who are providing similar amenities to their  passengers with ASIG’s EmPower supplies and OnBoard IFE system.

The reporter notes that the seatback IFE system allows parents to control what their children see during the flight. With the OnBoard system, passengers need not invest the time to learn and input the parental settings in the seatback system because they  enjoy the IFE options on their personal electronic device, which is already configured to their particular needs.

For the rest of the story, see OnBoard Server is IFE Buffet, Major Amenities for Regional Cabins, and contact ASIG.

Until next time, stay 5x5, mission ready, and Wired!

Thursday, July 22, 2010

Log-In to VESSA™ for Cost-Efficient Engineering

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Optimizing productivity and controlling cost is important in any economy. Machines—and the people who operate, maintain, and keep them current—must be engaged in  productive effort most of the time. Make work need not apply.

VESSA-FULLIn aviation, some efforts are periodic or unpredictable, and staffing for them is contrary to efficiency’s goals. To satisfy an operator’s needs when they arise,  enterprising companies have developed cost- efficient solutions that go by many names, power-by-the-hour,  NetJets—and VESSA™, aka ASIG’s Virtual Engineering Services Subscription Agreement.

With almost every aspect of certification and airworthiness hinging on approved data, engineers are essential members of the aviation team, says Luke Ribich, ASIG’s Managing Director. When an unexpected workload or large project stretches the limits of the subscriber’s staff, VESSA™ provides immediate relief by allowing the subscriber to tap into ASIG’s full service engineering and certification expertise for as long as is necessary to eliminate the engineering overload and return to business as normal.

Launched in 2007, VESSA™ has served nearly 30 subscribers to date, each with a dedicated portal available from any computer with Internet access. ASIG maintains the servers—and security—which meets the requirements of an especially picky subscriber, the Department of Defense.

RolloverMom A typical subscription runs three years, and companies can adjust their  engineering requirements up or down annually. ASIG also offers “an AT&T provision,” Ribich says, referring to the  TV commercial where the mother admonishes her son for discarding his rollover minutes. “In other words, the engineering effort unused in any given month carries forward…so if you have a month that runs over, you’re not losing anything.”

Cash flow forecasting is another VESSA™ strong suit. If subscribers have an upcoming “program, like the CNS/ATM requirements coming down from NextGen, they can amortize the cost over the  year,” Ribich says. “Likewise, if their fleet changes or they need to reduce costs for some reason, they can make those adjustments at the end of each 12 months.”

Engineering is document intensive, so VESSA™ is an online library that enables subscribers to quickly find and use them, printing hardcopies as needed. Subscriber-provided  documents, from tech orders and diagrams to illustrated catalogs and ICA, are determined when setting up the subscription or project, and ASIG can digitize anything not already in electronic form.

VESSA PORTALSubscribers initiate projects by uploading the scope of work, and the system captures all online collaboration with ASIG’s engineers. Other pages present the project’s Gantt charts, milestones, any required photos and video, contact information for everyone on the project, links to viewers needed to examine data files and drawings, invoicing, a weekly status report, the engineering help desk, and many more features.

VESSA™ also works well with first-article and proof-of-concept manufacturing, Ribich says. And it’s all on-call, 24/7/365. Being online, its on-demand operation enhances efficiency. If a last-minute schedule change prevents a subscriber from reviewing a document for approval or changes, the task—not a roomful of people—waits for him without complaint—or loss of productivity.

Until next time, stay 5x5, mission ready, and Wired!

Tuesday, July 6, 2010

EWIS, EZAP & ICA: What’s It All Mean?

Welcome to Wired!

Two new acronyms have recently joined the aviation lexicon, EWIS (electrical wiring interconnection system) and EZAP (enhanced zonal analysis program). Both are intimately related to ICA (instructions for continued airworthiness).

EWIS was conceived on July 17, 1996, when TWA Flight 800 fell into the Atlantic 12 minutes after its New York departure. During its four-year investigation the NTSB never found what ignited the 747’s center wing tank,  but it did find a number of potentially unsafe conditions nearby, including cracked insulation, open-ended  splices vulnerable to moisture, and other repairs that didn’t comply with Boeing’s Standard Wiring Practices Manual.

AC Insp This discovery led to the FAA’s Aging Transport Systems Rulemaking Advisory Committee (ATSRAC). Composed of airlines, OEMs, and regulators, it inspected 81 aircraft, finding 3,372 discrepancies. They ranged from deteriorated wiring, corrosion, improper installation and repairs to contamination by metal shavings, dust, and flammable fluids.

The arcing IFE cables that likely brought down Swissair Flight 111 on September 9, 1998 reinforced the ATSRAC mission. After the Lear 35 carrying golfer Payne Stewart crashed in 1999, the NTSB urged the ATSRAC to look at all transport category aircraft. While the NTSB found no specific cause for the loss of pressurization, the system is controlled electrically.

Until this time, wiring rarely received any special maintenance or inspections, even though its failure causes delays, unscheduled landings, IFE system problems, and both nonfatal and deadly accidents. The ATSRAC recommended internationally harmonized certification requirements, standard wiring practices, and maintenance procedures to correct and prevent these consequences.

These recommendations led to NPRM 05-08, Enhanced Airworthiness Program for Airplane Systems/Fuel Tank Safety. Published on October 6, 2005, it christened EWIS and, for the first time, officially defined the electrical system and gave it a home, Subpart H of Part 25. The point is that safety depends on the reliable transfer of electrical energy, and that EWIS is equal to the critical systems it connects and controls.

Officially, EWIS is “any wire, wiring device, or combination of these, including termination devices, installed in any area of the airplane for the purpose of transmitting electrical energy, including data and signals, between two or more intended termination points…. This includes electrical cables, coaxial cables, ribbon cables, power feeders, and databuses.” Don’t think wires, think wiring diagram. EWIS covers everything a mechanic can maintain, repair, or modify.

The final rule (dated December 2007, with compliance starting 39 months later) bred dozens of advisory circulars. AC 25,17001-1, Certification of Electrical Wiring Interconnection Systems on Transport Category Airplanes, guides the creation of the original system and its modification by companies like ASIG. A third of its guidance pages is dedicated to the qualitative and quantitative safety assessment and analysis required for original and  supplemental type certification.

wireties-3  AC 25.27-A, Development of Transport Category Airplane Electrical Wiring Interconnection Systems Instructions for Continued Airworthiness Using an Enhanced Zonal Analysis Procedure, is the everyday bible. OEMs add EWIS (including electrical load data) to the ICA for an as-delivered configuration. Subsequent modifications, like ASIG’s OnBoard IFE server, must seamlessly integrate their ICA with the OEM’s.

Operators incorporate the new instructions with an EZAP, which determines the appropriate inspection and cleaning procedures. Simply put, mechanics evaluate EWIS’s condition and the affect of nearby items, such as plumbing or control cables, to its safety. An EZAP is a logical addition to aircraft covered by a zonal inspection program. On non-ZIP aircraft the EZAP will identify EWIS-related tasks that must be consolidated in the inspection and maintenance programs. (Those who hold the design approval for these aircraft may find it worthwhile to create a ZIP in conjunction with an EZAP).

Ultimately, OEMs, STC holders, aircraft operators, repair stations, and anyone who provides maintenance need to evaluate their overall philosophy and specific maintenance tasks so that EWIS receives the same care and attention as any other system critical to aircraft operation.

Until next time, stay 5x5, mission ready, and Wired!

Thursday, July 1, 2010

Airlines Upgrading Cabin Amenities

Welcome to Wired!

A recent Wall Street Journal article and video reported that a number of major US carriers are upgrading their coach cabin amenities with “better entertainment systems, Wi-Fi access, [and] more electrical outlets.”

American Airlines, as the article and video show, is upgrading its Boeing 737 fleet, replacing the old IFE system with flat-panel LCDs, power plugs, and Wi-Fi. Continental is adding power plugs to some of its aircraft, Delta is putting video on its international fleet, and United is adding video and power plugs to many of its Boeing 777s.

ASIG can help you keep pace with its OnBoard IFE server (See OnBoard Server is IFE Buffet for Passenger PEDs) and EmPower passenger PED power supplies (See Major Amenities for Regional Cabins).

Until next time, stay 5x5, mission ready, and Wired!

Wednesday, June 23, 2010

OnBoard Server is IFE Buffet for Passenger Personal Electronic Devices

Welcome to Wired!

image Actually talking to someone is rarely at the top of the list of things people do with their smartphones, at least that’s the impression given by Pew Research Center studies. Adding tablets like the iPad, netbooks, and old school laptop computers to the mix of personal electronic devices (PEDs) people use to connect with the wired world, ASIG realized that most airline passengers today fly with the display half of an in-flight entertainment (IFE) system. It only seemed right to meet passengers halfway and install its OnBoard IFE server and access terminal in the launch customer’s Boeing 737 NG.

Traditional IFE systems, with screens wired into the back of every seat, are heavy, expensive, and impractical on many smaller single-aisle jets. And keeping pace with technology is an expensive decision because the server that feeds the seatback displays is permanently installed.

Powered by Avionica equipment, the OnBoard server/access terminal is based on tablet computer technology and size (10.5-by-7.2-by-1.65-inches). Easily removable, it is securely mounted in a lockable dock. Combined, the server and mount weigh just 9 pounds, and keeping pace with new technology is simply a matter of remotely and wirelessly pushing content updates or plugging a freshly updated server into the dock.

Part of ASIG’s Wired Aircraft architecture, OnBoard distributes its IFE content through a secure Wi-Fi router. To connect with the outside world, ASIG can configure it with the appropriate Iridium gateway and/or satellite communication system. OnBoard’s solid-state drive holds up to 800 hours of content, from streaming video to web hosting of online catalogs. With the Iridium gateway it will handle point of sale applications with real-time credit card clearing and text messaging. With satcom, OnBoard gives passengers text e-mail and SMS service.

image OnBoard can also reduce the time and money it takes to keep an aircraft mission ready by storing all the necessary manuals, databases, LRU operating software, and code images, making them immediately available to technicians. In conjunction with the backend server based avSYNC software, OnBoard uses its wireless routers to keep its IFE and maintenance content current.

Maintenance technicians can remove the server from its locked mount and take it to where they are working. In addition to a variety of digital documents and databases, OnBoard can deliver a number of support applications, including ARINC 615, ARINC 615A dataloading, ARINC 429 databus analysis, TCAS diagnostics, DFDR download, flight data analysis, and many more.

OnBoard’s new menu software enables operators to build custom prompts and workflows, from one-touch operation to detailed data entry. Combined with the system’s scalability, you can design the system best suited to your passenger’s needs and your bottom line.

OnBoard is the third and final phase of ASIG’s Regional Aircraft Cabin Improvement Program. An April 2010 STC marked the completion of Phase II, which provides external power for passenger personal electronic devices (See Major Amenities for Regional Cabins). Phase I, STC’d in January 2010, brought eight-meal TIA convection ovens to the EMB-145.

Combining an OnBoard IFE server and access terminal with ASIG’s external power supply system to the passengers’ personal electronic devices operating at full capacity will go more than halfway in making their flight productive and entertaining.

Until next time, stay 5x5, mission ready, and Wired!

Monday, June 21, 2010

Building Unique, Flexible STC Solutions

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When bidding upgrades, most operators of transport-category aircraft look at deliverables and want to know the cost of four things: nonrecurring engineering, equipment, the kits that unite equipment and  airframe, and time and money it takes to consummate that union.

b727_09The answers to these questions define a  start-to-finish journey in four giant leaps, the categorical summation of the step-by-step route ASIG takes from the operator’s statement of work to installing the inaugural upgrade kit and shepherding it through certification. Optimized for efficiency and flexibility, each route is unique to the upgrade destination.

Each STC project has a unique list of documents that gives the FAA the data it needs for certification, says Managing Director Luke Ribich. ASIG builds a proprietary datalist with an application that compiles the necessary certification, manufacturing, and installation documents. Related applications compute the time and labor involved for each step, enabling ASIG to quickly answer the four main questions.

A full communication and navigation upgrade is a good example, says Ribich, because it has an involved document list, including the analysis of electrical load and system safety to weight and balance supplements. If the STC covers different aircraft, as an  all-model list (AML) would, an aircraft similarity report itemizes the applicable equipment. “More modern aircraft have a common nav pack or data bus,” but  classics like the Boeing 727-300 often have different electro-mechanical suites, depending on the initial operator. “That means more wire, different switches, and different boxes.”

A Service-Disabled Veteran-Owned Small Business (SDVOSB), ASIG assigns a highly experienced and proficient team of five to eight key employees to the prerequisite work that answers an operator’s four questions. They are the same people who make the plan happen once the deal is signed. An addendum to that agreement covers the kits, Ribich says, “because we can’t  price them until the engineering is done and the bill of materials is fully developed and bid out.”

ASIG always does the inaugural kit installation because it and any applicable ground and flight tests are part of FAA certification, which “goes extremely smooth when it’s a front to back, closed-loop program” handled by the same team. Once the STC is approved, ASIG drop ships kits to the operator.

ASIG will do phased installations, running cables and wiring on the first pass, and “ripping out the old hardware and dropping in the new on the second evolution,” Ribich says. ASIG will also work where the operator wants.

DC8_EFIS One of ASIG’s early projects proves this point and illustrates  its capabilities.  With  engineering liaisons and mechanics, a 22-person team turned a French Air Force DC-8-72 with a five-man cockpit  into an US-registered aircraft with with a three-man cockpit filled with 21st century systems. 

The to-do list was long: demilitarize the NATO equipment, install and certify a Universal EFIS with dual FMS, TAWS, and triple redundant RVSM digital air data system, as well as a cockpit voice and digital flight data recorders. “What made the project unique was the 10 pallet positions aft of the cockpit, followed by a 32-passenger combi section,” Ribich says. “A specialized flight director gave us some problems initially, but we designed and built a converter box that solved them.”

In a hangar the operator rented for the work, just big enough for the DC-8’s nose, the ASIG team brought everything it needed to install the new systems. Starting from scratch with a contract signed October 2005. all engineering was done the same day installations started, December 18. “We worked through Christmas Eve, were off through New Year’s Day, and completed all the work on March 28. The FAA issued the STC on March 12.”

Everyone at ASIG comes from the Part-121 world, Ribich says, “so we know it is a fast-paced environment that requires efficiency and flexible solutions.”

Until next time, stay 5x5, mission ready, and Wired!

Thursday, June 17, 2010

And the RAA Winners Are…

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ASIG exhibited at its inaugural Regional Airline Association (RAA) Annual Convention in Milwaukee. All registered attendees (roughly 1,500) were automatically entered in our drawing, as were those who stopped by the booth, and it was good talking with all of you. Without further adieu, the winners are…

Grand Prize - Tom Tom Go 730 GPS

Tom Haarmann

Customer Service Manager—GoJet Airlines

Dry-weave Moisture Wicking Sport Shirt

Gwendolyn Bentley 

Purchasing Manager—Republic Airlines

John Cross

Director of Materials –Colgan Air

Joe Grogan

Director of IEP—Pinnacle Airlines

Rich Rupslauskas 

Technical Services—Air Wisconsin

Ron Charles

Senior Director, DIA—Frontier Airlines

Terry Basham

Vice President, Customer Service—Trans States Holdings

Port Authority Moisture Wicking Golf Visor

Todd Hargrove

HazMat Senior Specialist--Southwest Airlines Company

Jimmy Owenby

Station Manager—SkyWest Airlines

Joe Williamson

Diversified Communications Group

Mike Lohmann

Training & Standards Director—Jazz Airlines

Randy E. Tweed

Chief Inspector—Commutair

June Donovan

Security Manager—JetBlue Airlines

Cindy Grzyb

General Manager—Continental Airlines

Thomas Reynolds

GM, Maintenance Operations—Atlantic Southeast Airlines

Lo Lyons

In-Flight Training Manager—ExpressJet Airlines

Until next time, stay 5x5, mission ready, and Wired!

Tuesday, June 1, 2010

PMA Parts Make Improvements Possible

Welcome to Wired!

Any aircraft is the sum of its parts, and if any one of them is not designed, tested, and approved for use on a specific make and model, the airplane cannot legally earn its keep. Airframe and powerplant OEMs are the primary source of approved parts, but usually they do not accommodate capabilities beyond those that existed when the aircraft earned its type certificate.

PMA FLowchartIncorporating new technology after an aircraft earned its TC requires a supplemental type certificate (STC). And the parts that bring everything from glass cockpits and NextGen avionics to cabin in-flight entertainment systems earn their right to fly through the Parts Manufacturing Approval (PMA) process.

As the PMA flowchart suggests, it’s an involved process. Often it starts with an approval from an Aircraft Certification Office (ACO). Most STCs involve major changes to an airplane’s capabilities, and the FAA requires proof that they do not adversely affect the airplane. As part of its STC efforts, ASIG  works with the necessary FAA offices.

Developing PMA parts not only makes STC’d  improvements possible, it creates the parts that maintain the new capabilities. ASIG engineers design needed parts as they develop an STC, but their work goes well beyond laying out an instrument panel or  wiring harness that connects it to the airplane. In transport-category aircraft each new part must meet the requirements of Part 25. In other words, the new part must be equal to—or better than—the part it replaces.

A new part proves itself through drawings, specifications, and documents that include all required computations and the results of an exhaustive testing plan. To be eligible for installation the part must be made of the appropriate materials. It must perform its intended function and be compatible with the parts or components to which it is connected. Tests must prove that the part performs reliably under all mission profiles, cyclic loads, the stress of pressure and temperature, and all other applicable operating conditions.

From this design and testing work ASIG creates the required plan for continued operational safety (COS). Central to this effort is determining how critical a part is by assessing the consequences of its failure. Starting with the part’s fatigue life, engineers apply the appropriate margin of safety by establishing its airworthiness lifespan. Further, they identify failure modes, provide corrective actions, and generate instructions for continued airworthiness. And they include a recordkeeping plan that starts when the part is manufactured and legibly numbered with permanent markings. 

An FAA Manufacturing Inspection District Office (MIDO) examines every scintilla of a PMA application. This can be time consuming, but ASIG’s designated engineering representatives approve much of the work before it goes to the FAA, significantly reducing the time to the MIDO’s final approval—and the time it takes to introduce new capabilities to your fleet.

Until next time, stay 5x5, mission ready, and Wired!