CERTIFICATION


COMMENT

While I have much certification experience, I do not do "certification" in isolation. I can help you estimate, develop and field a product or service with good values as part of integrated product development with a values-based business strategy - preferably from the conceptual stage and emphasizing future re-use of work- based on professional engineering principles. And I can help you set up engineering procedures and management guidance to enable good work for certification.

The best investment is in product that meets real world needs, of which regulatory requirements are only part (the majority of those are objectives based on user needs - including the safety expected by end users). That approach is more productive, profitable and satisfying for both of us in the long term.

The first focus must be on "what should be done for product values in the real world?".

That requires consideration of the operating environment, user needs, and economics (which contrary to popular marxist-like belief does not reward "cheap" or "shady" in the long run, but does require rational attention to costs and benefits including flexible strategy - I reject a split between safety and economics).

Quoting Flitestar President Tom Peghiny: "The things required under certification are the things you do anyway to meet the customer's expectations." - General Aviation News, September 14, 2001.

The poster child industry for missing the need to do the technical work was inflight entertainment.
Companies lost money because they did not do things they didn't "have to" do by regulation.
Being a non-essential not-required system the regulations required only that it not interfere with systems important to flight of the aircraft. Yet those things were necessary for functionning reliable product. Some people learned the hard way in that industry. (One subsidiary of an established avionics company, with local management having much avionics experience, exitted the industry because its reputation was shattered by unreliable product.)

A simple example of the variability of installation work is the case of a fuel flow sensor on a small airplane. It was installed close to exhaust tubing with two 90 degree fittings between the mechanical fuel pump and flow sensor. The aircraft was released into service.
Owner's troubleshooting of short term variations in engine output revealed the incompetent work. The sensor manufacturer's web site advises the 90 degree fittings will cause cavitation in the fluid flow (and heat does not help that). But installers should not need manufacturer's information to recognize the possibility or at least get help with installation design.

An example of the problem with software that "appears to work" is provided in my scanner information page. The default software mode of "detect regions" caused loss of data as small as a single character, which might not be obvious to the user.

And even the entertainment industry wants reliability: "Film makers are particular about the products they use.
"The thing about the film industry is they have the money, they do not have time," he said. "There's no allowance for mistakes, the product has to work."
------- Mark Obedzinski, manufacturer of a special effects consumable for the movie industry, quoted in the Vancouver Sun of May 13, 2002

And Transport Canada's experienced maintenance policy development chief Brian Whitehead:
"No one can have more influence on the conduct of a company than its owner."
(from his article The Role of the Certificate Holder, in Air Maintenance Update magazine of late 2002)


INFORMATION

Delegated authority
Transport Canada provides names of delegated persons on their web site.
FAA publishes lists as Advisory Circulars in the 183 number series.

FAA page providing information for Designees

Transport Canada Aircraft Certification Information
(Including links to regulations. TC also sell a CD-ROM with some regulations on it.)

CD-ROM of most FAA Regulations (Summit Aviation)
(including some FAA Handbooks and Aerodynamics for Naval Aviators)
(FAA publishes most regulations and advisories on their web site, not necessarily in one place easy to find.)

Canada's Regulatory Burden (a report)

A positive comment about FAA people.

I have been impressed by the work of the Flight Safety Foundation. I have seen little of the work of the Aviation Safety Institute recently (John Galipeau's columns were good) but IMO ASI's management of the AVSIG forum on Compuserve is not appropriate for a safety institute - specifically allowing smearing of those who support good work and advocate strong defense against terrorist attacks on aviation.

The Mediallion Foundation in Alaska seem to have worthwhile programs.


© Keith Sketchley
June 13, 2004 (1303PDT)

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