US Safety improvement Act released for unprecedented reshaping of Aircraft Certification and Pilot Training following 737 Max’s wake
03/12/2020 - Thomas Bessière
Following the recent, successive and tragic events of the Boeing 737MAX, the Federal Aviation Administration (FAA) responded to the recommendations of a formal report released by the special committee in charge of reviewing the FAA’s aircraft certification process. The consequences of these discussions are concretely materialized through a US Improvement Act that describes strict rules and a roadmap to deeply reshape the certification process and better include Human Factors aspects to limit risks of accidents. These improvement act from US Senate will considerably disrupt the way Human Factors are taken into account all along the Aircraft lifecycle (Design, Certification, Pilot Training and Flight operations).
Synthesis of Special Committee report (Jan.2020) and FAA response (Apr. 2020)
According to the report, FAA’s main objective must remain simple: Integrate the latest methods for evaluating human factors and onboard safety management systems by making better use of the data that can be measured inside the cockpit. The committee also concluded that certain industry assumptions used in the certification of aircraft are no longer appropriate today because they date back several decades. The committee considers that these assumptions should be updated. As a result of the committee’s statements, the FAA anticipates changes in regulations, guidelines, policies, and standards to be put in place in order to reach the stated goals. More in-depth training and awareness-raising actions with the new technologies that can now be used as a solution in aircraft, as well as communication actions with national and international organizations will be deployed.
Based on this, some findings and recommendations are highlighted on different aspects, included the following ones :
- System Safety:
- Findings: System Safety Assessments (SSAs) are an essential component of safety risk management that can be expanded to better consider human factors in order to provide additional safety value to the FAA’s aircraft certification process.
- Recommendations: Current guidelines recommend that human factors be considered when the system is new or novel, complex and/or integrated. In the future, the FAA should enhance standards to ensure that systematic human factor analyses are conducted for all safety-critical functions associated with a change under the changed product rule (14 CFR 21.101).
- FAA’s response plan: Re-evaluate our approach to the human-machine interface and interaction, and incorporate new rules, policy and associated training across the FAA and internationally to better integrate human factors-related evaluation and system safety assessment methodologies.
- Findings: Globalization drives the need to harmonize requirements, regulations, and standards in commercial aviation. Although U.S. products are operating worldwide, the FAA has no mechanism in place to ensure the maintenance and pilot training requirements for U.S. products operating under another civil aviation authority.
- Recommendations: The FAA should acknowledge the international profile of operators of U.S. State of Design aircraft and implement the necessary changes for its aircraft certification system to take into account differences in operations, training, and oversight across States.
- FAA’s response plan: Re-evaluate the approach to the human-machine interface in consideration of global flight crew profiles, incorporate new policy and training across the FAA and other CAAs, share lessons learned, and ensure that a strong infrastructure exists to support the introduction of new aircraft designs into the global fleet.
- Findings: Better data gathering, targeted analysis by experts, and the use of all available data to develop and implement corrective actions to mitigate risk would bolster aviation safety.
- Recommendations: The FAA should propose to ICAO the sharing of operational data internationally, to enhance safety initiatives.
- FAA’s response plan: Leverage state-of-the-art safety information sharing initiatives such as the ASIAS program to improve aviation safety worldwide, make FAA data and analysis tools available through an EIM system, improve data sharing internationally, and work with NASA to develop an in-time aviation SMS
- Safety Management Systems:
- Committee Finding: The FAA requires Safety Management Systems (SMS) for part 121 air carriers; however, there is no requirement for SMS for design and manufacturing organizations. Expanding SMS regulations to include design and manufacturing organizations would create better connections and management of functional and operational safety risk.
- Recommendations: The FAA must mandate implementation of SMS for design and manufacturing organizations and take the necessary steps to ensure a total system approach to safety, linking all safety requirements, from type certification to pilot training, and operational performance of the product.
- FAA’s response plan: Implement scalable SMS, involving all stakeholders.
The US bill drumbeating the evolution of Human Factors' consideration and a challenging safety roadmap
Consequently, a reform was proposed by the American Senate and would be voted in the coming days: “Aircraft Safety and Certification Reform Act of 2020”.
This reform lists the research requirements that must be processed in order to improve aviation safety. These objectives are quite clear:
- Enhance onboard aircraft technology,
- Improve aircraft design engineering and certification practices.
- Enhance the understanding of human factors concepts into the omnipresent context of evolution of automated cockpit systems,
- Use and/or implement tools to validate the assumptions of acknowledgement and reaction of pilots,
- Use and/or implement diagnostic tools to improve the clarity of malfunction indications transmitted to pilots in flight.
These objectives will be supported by strong and concrete actions:
- Develop of a Center of Excellence focused on automated systems and human factors in aircraft that are intended for use in air transportation.
- Mar. 2021: Initiate a review and may, after such review and as necessary, revise existing regulations, and supporting policies, guidelines, and advisory circulars, to integrate and emphasize human factors and human system integration, particularly those related to pilot and aircraft interfaces.
- Mid-2021: Develop research requirements to address the integration of human factors in the design and certification of aircraft that are intended for use in air transportation. (in consultation with aircraft manufacturers, operators, and pilots, and in coordination with the Administrator of the National Aeronautics and Space Administration)
- Jan. 2022: Revise existing policies for manufacturers of transport category airplanes that are expected to be operated for scheduled passenger air transportation to ensure that pilot operational evaluations for new airplanes that are in the process of being certified use pilots from air carriers that are expected to operate such airplanes.
The industry seems to engage important investments and energy to transform the way Human Factors are involved all along the Aircraft lifecycle (Design, Certification, Pilot Training, Flight Operations/Safety). To support this transformation, all stakeholders will need to innovate and build/consolidate a strong networks of researchers, legal experts, data scientists, flight data analyst and human factors experts in a very short time horizon.
The reports that helped us to write this article :