The FAA, MAX and How Things Get Approved 

Kinja'd!!! "f86sabre" (f86sabre)
03/19/2019 at 09:23 • Filed to: Planelopnik

Kinja'd!!!9 Kinja'd!!! 30
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Many of you have read about the situation around the Boeing 737 MAX. Our own ttyymmnn !!!error: Indecipherable SUB-paragraph formatting!!! . You may have also have read some opinion pieces saying how the FAA is too cozy with the airlines and OEMs and that is how we ended up here. I’m not going to comment on any of that. I am going to tell you how big things can get certified on an airplane and why it isn’t always the FAA who does that.

There are basically two ways you can get things approved for use in commercial aviation. Your organization can develop the necessary engineering data (instructions, drawings, engineering substantiation, criticality or major/minor determinations, reports, allowances, specifications and potentially test articles) and submit them directly to the FAA for review and approval. The FAA typically has in its ranks folks who are qualified to review and approve this information. If they don’t like it they will send it back and you can do it again.

The challenge here is that the FAA only has so many of these people. That can mean long lines and considerable delay. Also, for many subjects that are on the more advanced end of technology the FAA may not have the expertise on staff to adequately judge the merits of a submitted item. The folks who work Aircraft Certification Offices are generally pretty sharp and willing to learn (the ones I typically deal with anyway), but they can’t be experts in everything.

The other method is !!!error: Indecipherable SUB-paragraph formatting!!! In this situation, an organization builds procedures to allow them meet very stringent FAA requirements that allow for select individuals within the organization to act on the FAA’s behalf for review and approval. The FAA reviews the org’s process and procedures and then vets out those who be allowed to wield approval authority. It is a huge responsibility for those who take on this authority. They work closely with the FAA on training, approval plans for complex issues and are regularly audited. They are held accountable for compliance to the FAA regulations and guidance.

It is a good program generally. The approvals are reviewed by subject matt er experts. There is clear process and procedure. People and organizations are held accountable. The FAA doesn’t need to have giant engineering teams and can focus on what is important to their mission. It works and it has helped get us to the safest mode of transportation in human history. That doesn’t mean it can’t be improved upon or that it is not without flaws. It is the best thing going though.

There is much, much more to it than what I have put down here. I could go on about how regulations come together, air worthiness directives, advisory circulars and all that, but it gets to be a lot. Some of the local subject matter experts can chime in if they feel like it. I do hope this helps educate you a bit about what is being said about the MAX. Boeing is a Delagated Authority. I don’t know if this came into play with the two crashes or not. What I do know is that the calls that the FAA is to cozy with anyone need to be justified by people who understand the process and not just armchair pundits.


DISCUSSION (30)


Kinja'd!!! TheRealBicycleBuck > f86sabre
03/19/2019 at 09:43

Kinja'd!!!1

Kinja'd!!!


Kinja'd!!! ttyymmnn > f86sabre
03/19/2019 at 10:04

Kinja'd!!!2

This is all well and good, but you sell a lot more newspapers with stories of backroom deals, unsupervised engineers, and cozy relationships between government and industry. Which, of course, is what you are alluding to. I suppose any system works well until it doesn’t, and while the relationship between Boeing and the FAA has gone well to this point, it is due for some scrutiny. It’s unfortunate that so many had to die to get to that point, though.

Thanks for the shout out.


Kinja'd!!! DipodomysDeserti > f86sabre
03/19/2019 at 10:12

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“ It works and it has helped get us to the safest mode of transportation in human history.”

[looks at feet]


Kinja'd!!! Future Heap Owner > f86sabre
03/19/2019 at 10:14

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So in this delegated authority process, the people who have final say over the certification are being paid by, and are in the command chain of, the organization that wants to make money by being certified? Sounds ripe for abuse by the certifiers’ superiors in the organization, who set the culture, cut the paychecks, decide bonuses and raises, and can reassign, transfer, demote, or fire them.

Thank you for explaining this.


Kinja'd!!! TheRealBicycleBuck > f86sabre
03/19/2019 at 10:20

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This happens in all government agencies which provide oversight. After Hurricane Andrew hit Florida, a disaster research team went in to survey the damage. They observed that e ntire neighborhoods were flattened with the exception of one or two houses. That pattern was repeated over many neighborhoods, so the team asked why those houses withstood the hurricane.

They were all built by the same guy.

His secret? He built them to code.

Most of these neighborhoods were built during the Florida housing boom. At the time, there weren’t enough inspectors on staff to adequately inspect all of the homes. Each inspector had to inspect 50 homes per day to keep up. As you can imagine, there was a lot of trust and “drive-by” inspections.

The most common substitution was on the roof. Roofers were using  staples instead of roofing nails. The surface area of a staple was insufficient to hold the shingles in place against hurricane-force winds. Lose the shingles, lose the roof, lose the house.

If they had been properly inspected, there’s a good chance much of the housing lost in Andrew would have been saved.


Kinja'd!!! MUSASHI66 > f86sabre
03/19/2019 at 10:29

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Wait...Boeing is a delegated authority for...Boeing planes? So they build them, and they are the ones that tell FAA that they are safe to fly, and FAA just says OK to that?


Kinja'd!!! BigBlock440 > DipodomysDeserti
03/19/2019 at 10:31

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I’ve never heard of anyone being attacked by a bear on an airplane...


Kinja'd!!! someassemblyrequired > f86sabre
03/19/2019 at 11:01

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I’m not sure delegated authority works if mistakes like this slip through. Boeing was trying to bamboozle the FAA and the airlines by short circuiting certification and training, when in reality this was an entirely new airplane.

The reaction after the initial crash was far too slow as well . The problems with MCAS are obvious (in terms of training and implementation), and should have triggered some self-reflection about other potential lurking issues. At a minimum it should have offered the upgrade with the AOA disagree light for free to all in-service operators immediately, while it worked on the software fix .


Kinja'd!!! DipodomysDeserti > BigBlock440
03/19/2019 at 11:24

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I have:

https://www.google.com/amp/s/gizmodo.com/bear-attacks-plane-pilot-fixes-plane-with-duct-tape-p-5447738/amp

but I’ve never heard of anyone being flown into a building while out on a hike.


Kinja'd!!! Lokiparts > f86sabre
03/19/2019 at 11:30

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It’s crazy how much this whole situation reminds me of the n ovel “Airframe” by Michael Crichton. It also involves an aircraft with a design flaw that causes the pilots to fight the aircraft for control.

Even though it is a work of fiction, he does a very good job fairly accurately explaining the inner workings of a large aircraft corporation, and what happens internally when they have to deal with incidents like this.


Kinja'd!!! BigBlock440 > DipodomysDeserti
03/19/2019 at 11:53

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Technically, he wasn’t attacked, just the plane was, but I’ll accept it.

As for being forcibly moved against a building, haven’t you ever seen a Sea gal or Schwarnegger movie?  Or Die Hard?


Kinja'd!!! Spamfeller Loves Nazi Clicks > f86sabre
03/19/2019 at 12:06

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What you’re leaving out is that Boeing is now known to have deliberately circumvented and subverted regulations and outright lied on the type certification for the MAX.

They claimed to have ‘certified’ the training materials and updated them. However, pilots have long been reporting the training materials are just copy and pasted from the old 737's.

Everything they submitted and ‘certified’ said the MCAS maximum adjustment was 0.6 degrees. What they delivered to customers could swing 2.5 degrees, or nearly full range of motion. To “improve flight feel.” It was a software change. And rather than comply with basic safety, they didn’t bother to update the AOA sensors to require any sort of validation.

Add to that that due to the budget cuts, multiple FAA staff have come right out and said ‘we were pressured to approve without even checking if Boeing was following the rules. We didn’t have enough people to see if Boeing followed the rules.’

There’s zero question Boeing actively circumvented safety regulations at this point. Unfortunately, there’s also zero chance they will be held liable in any way.


Kinja'd!!! f86sabre > Spamfeller Loves Nazi Clicks
03/19/2019 at 16:58

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I mentioned it...

“You may have also have read some opinion pieces saying how the FAA is too cozy with the airlines and OEMs and that is how we ended up here. I’m not going to comment on any of that. ”

Formal investigation will shine a light on what really happened and if it was intentional, being lazy or what. That investigation needs to happen quickly for sure.  I was just trying to explain the comments about FAA giving away authority and what was really behind that.


Kinja'd!!! f86sabre > BigBlock440
03/19/2019 at 17:01

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I’m not downplaying these two accidents. They are horrible and what led to them needs to be addressed. Even with those events aviation is still very safe. 


Kinja'd!!! f86sabre > someassemblyrequired
03/19/2019 at 17:02

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Potentially. We will see where the breakdowns were. 


Kinja'd!!! f86sabre > ttyymmnn
03/19/2019 at 17:03

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Yep, basically. I’m sure the MAX situation will drive change, hopefully for the good of aviation safety, but the notion of sdwlgated authority in and of itself isn’t bad. 


Kinja'd!!! Spamfeller Loves Nazi Clicks > f86sabre
03/19/2019 at 18:21

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Well, there’s “cozy” and then there’s “deliberate actions in direct contravention of established protocols, procedures, and policies.”

And the fact is, nothing Boeing says changes the established fact that they very intentionally misled every regulator in the world when they said the MCAS was limited to 0.6 degrees. That’s facts already in record and admitted to.

Because they know that admitting to a crime will have absolutely no consequences.


Kinja'd!!! someassemblyrequired > f86sabre
03/19/2019 at 18:46

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I have heard that the Seattle Times informed Boeing about the leaked MCAS failure effects analysis a week before the 2nd crash. So there were issues that raised concerns internally to the level that stuff was leaking to the press even before the Ethopian crash.


Kinja'd!!! bubblestheturtle > f86sabre
03/19/2019 at 20:37

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“777 MAX ”?


Kinja'd!!! f86sabre > Spamfeller Loves Nazi Clicks
03/19/2019 at 21:19

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Once again, I’m not arguing that fact. Just trying to explain how the process was intended to work so people who might not be familiar could  be more informed. It is a good process if used correctly. That said, like most anything , if peopl e get lax then it will go to crap. It doesn’t matter who’s organization is responsible.


Kinja'd!!! f86sabre > someassemblyrequired
03/19/2019 at 21:41

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Sadly, there now appears to be documented failures of the certification process in both the delegated and non delegated processses. What we are seeing here today has some similarity in what happened with the DC-10 in the 70s with its cargo doors. A new design feature was assumed to be safe for operation, details were missed or mis understood in certification and two aircraft were involved in cidents over a two year period.

https://www.airspacemag.com/flight-today/book-excerpt-flight-981-disaster-180967121/

As far as Boeing, the MAX and who knew w hat when goes, the DOT and others are going to bring all that to light hopefully. 


Kinja'd!!! f86sabre > Future Heap Owner
03/19/2019 at 21:44

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Like any process it is only as good as the intentions of those who implement it. If abused then  you have trouble. Most organizations who have delegated authority look at it as a privilege that needs to be carefully respected and protected.  There are big, painful issues that arise if you loose that privilege. Most treat it with the respect it deserves.  


Kinja'd!!! f86sabre > MUSASHI66
03/19/2019 at 21:47

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Yes, as does Airbus, Bombarider, Embrier, Cessna, Gulfstream and on and on.  Fundamentally it is a good process, probably better than the old days when the FAA did everything, but that doesn’t mean it is perfect.  Even in the delegated processes the FAA still has oversite and audit responsibility. 


Kinja'd!!! f86sabre > TheRealBicycleBuck
03/19/2019 at 21:57

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Dah, fixed. 


Kinja'd!!! f86sabre > bubblestheturtle
03/19/2019 at 21:58

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Fixed. 


Kinja'd!!! MUSASHI66 > f86sabre
03/19/2019 at 22:13

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I find that to be bizarre but I guess I don’t understand aviation that much. But this might change how things work, because it seems to me they flat out lied about stuff. 


Kinja'd!!! gmporschenut also a fan of hondas > f86sabre
03/19/2019 at 22:18

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everyone screams and gets butthurt as why regulations slow things down until shit actually starts falling out of the sky and then are “why didn’t they do some th ing?”

I work in another highly regulated industry and it drives me nuts. 


Kinja'd!!! TheRealBicycleBuck > f86sabre
03/19/2019 at 23:21

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I was beginning to wonder if you’d ever catch the joke....


Kinja'd!!! f86sabre > gmporschenut also a fan of hondas
03/20/2019 at 09:05

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Yeah, it can be frustrating. Rules are in place for a reason. Like any game you need to follow the rules. Sometimes if you don’t follow the rules  you can get away with it. Sometimes you don’t.


Kinja'd!!! f86sabre > MUSASHI66
03/20/2019 at 09:06

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It certainly will change things, but I don’t think it will eliminate delegated authority.