Avionics News January 2012 - 47

Advertisers Index
Aero Standard. . . . . . . . . . . . . . . . . . . . 74

THE VIEW FROM WASHINGTON
Continued from page 15

create is more appropriate. I think we created the advances in technology which forced the FAA leadership to continue to define “acceptable means of compliance” for new technologies in an effort to reach standardization. As a result, the agency has created volumes of documents to prescriptively define the performance standards of the modern repair station. I wish I could say the solution is simple, but I cannot. Thirty years ago, avionics were pretty much all the same. Radios did not differ much in technology, instruments were mostly steam gauges, and repair stations were managed with the same analog techniques. The FAA guidance simply told the inspectors what they “could not do” because industry was standard by design. The advances in technology that support the industry today and make repair stations more efficient have also created the opportunity for some creative “methods of compliance.” Add the industry’s political demand of “standardized” enforcement from the agency, and we end up with gigabytes of data in the flight standards information management system regarding the prescriptive standardized oversight of repair stations, and then another few gigabytes of data on the certification of new and novel products from the FAA. So, how do we get out of this? A good friend of mine once said, “Don’t complain unless you also offer a solution.” Well, here it is. I think the industry, as well as the FAA, have a role in the solution. First, the agency needs to standardize certification standards, and headquarters needs to manage all issues that are cross-platform standards. Goodness knows, the individual directorate all must have their own guidance on “demonstrating” compliance with the regulations, even though the regulatory language is (and was intended to be) the same across platforms. If the

safety standard exists in Parts 23, 25, 27 and/or 29, then the method of compliance should be the same. If the safety standard is intended to be higher for Part 25 or Part 29, then the standard, not the method of compliance, should reflect this. From a flight standards perspective, the agency needs a complete overhaul of its guidance. The basis of all modern quality systems is simple: define what you do in your manual, assure your processes conform to the regulations and perform the tasks to your documented processes. The FAA audit requirements of a business should be simplified. Audit the manual to the standards, and audit the business to its published processes (manual). The agency is ISO compliant, and yet does not use those same principles when auditing the public. Nowhere in the flight standards guidance does the agency actually define the intended goal of a regulatory requirement. Therefore, it is completely impossible for a field inspector to evaluate a modern process to determine “if” the modern process can achieve the intended goal of a requirement. The agency must publish the intended goal of each regulatory requirement – what is the goal, not how to achieve it. And, for the industry, know the rules, know your processes and be able to explain to the auditor how your process meets the intended outcome of a regulatory requirement. If you want to run an analog business, you can operate under the 40-year-old quality control regulatory system and let the FAA’s prescriptive guidance run your business. However, if you want to run a modern digital business, the responsibility to defend your processes is yours, not the salesperson who sold you the latest program. If you want to leverage technology and business advances and run an efficient performance-based system, you need to upgrade your quality system to a modern quality assurance approach, and then “say what you do, and do what you say.” q

Aircell . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 Aircraft Electronics Association. . . . 13, 76 CAL Labs . . . . . . . . . . . . . . . . . . . . . . . 74 Dallas Avionics . . . . . . . . . . . . . . . . . . IFC Device Technologies . . . . . . . . . . . . . . . 75 EDMO . . . . . . . . . . . . . . . . . . . . . . . . . BC Express Calibration Services . . . . . . . . 74 Flight Display Systems . . . . . . . . . . . . . 50 Flying Magazine . . . . . . . . . . . . . . . . . . 43 Garmin International . . . . . . . . . . . . . . . . 3 Georgetown Instrument Services . . . . . 51 Global Parts . . . . . . . . . . . . . . . . . . . . . 19 Greenwich / DAC International . . . . . . . 27 Mid-Continent Instruments . . . . . . . . . . . 5 Pacific Southwest Instruments . . . . . . IBC Preston Pressure . . . . . . . . . . . . . . . . . 75 ProCal Laboratories . . . . . . . . . . . . . . . 75 Saint Louis University . . . . . . . . . . . . . . 74 TangoWare . . . . . . . . . . . . . . . . . . . . . . 74 Tech-Aid Products. . . . . . . . . . . . . . . . . 75 TGH Aviation. . . . . . . . . . . . . . . . . . . 1, 75 Women in Aviation . . . . . . . . . . . . . . . . 55

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Avionics News January 2012

Table of Contents for the Digital Edition of Avionics News January 2012
