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!