The Aerospace Community and Boeing

Boeing for decades was the most respected firm in aviation. Not American aviation, but in aviation.

“Without Boeing, you don’t get going.”

Pilots, airlines and engineers agreed.

Now we are watching one of the most capable large airframe manufacturers spiraling in.

My friends and business partners that hold airline transport licenses, all have Boeing ratings.

My favorite big airplane is the 757/767. Why? As an engineer it is just a good plane. For the non-pilot, non-engineer folks reading this, the 757/767 aircraft have a shared rating. This was done at a time when the FAA and companies like Boeing could trust each other and worked together effectively and competently.

The actual program for the airframe manufacturers to create a position called the Direct Engineering Representative (DER) was instituted 45 years ago to formalize that relationship in a regulatory environment. It has been a reasonable idea, but we have some evidence that there is probably time to reestablish more oversite.

This is not an outlier in the federal regulatory world.

We have seen similar issues with things like drug development and the use of Clinical Research Organizations (CRO). The FDA recognized some time ago that many of the relationships between the CRO’s and the pharmaceutical companies that hire them to run their drug trials were probably a little too friendly.

That said that model may be the way we will be going in terms of oversight and the aircraft certification process.

Currently, aircraft manufacturers retain their own DER's and certification engineers. In the process, systems engineers that are responsible for the engineering, design, and integration of the aircraft and the certification engineers ensure compliance with the specific regulatory requirements and in the case of the Boeing 737 Max, it is FAR 25. We engineering types know this as the certification requirement for transport aircraft and it is our shorthand for 14 CFR Part 25. Part 25 is specifically concerned with jet aircraft with 10 or more seats or a maximum takeoff weight (MTOW) greater than 12,500 pounds (5,670?kg); or propeller-driven airplanes with greater than 19 seats or a MTOW greater than 19,000 pounds (8,618?kg).

Aircraft and systems engineers are responsible for the aerodynamics, structures, propulsion, flight dynamics, controls and performance components that go into an aircraft. The certification engineers working with the DER’s effectively endeavor to provide documentation and technical demonstration of engineering, design, manufacturing, testing and performance of the aircraft so it meets the requirements of its certification.

Now going back to the model that has been part of the drug approval process for decades, we may now need to require an external organization that provides another level of regulatory review in the case of the derivation (or supposed derivation in the case of the Boeing 737 Max) and/or the design of new aircraft. (1)

The drugs community have an entire process to meet the criteria for demonstrating the efficacy of a new drug.

It begins with a formal study called an Investigative New Drug (IND) study Phase 1. This is the beginning of a three-stage process that has very detailed requirements for meeting the advancement to each phase. The study protocol, how the study is tested, its schedule and selection of subjects will be reviewed by an Institutional Review Board (IRB) which is composed of a group of people like medical doctors, physiologists, lawyers, regulatory affairs experts, patient advocates, and others.

Now we may be looking at a similar concept removing part of the process directly from the FAA and the aircraft manufacturer and beginning a new process to establish adequate quality of practice in the engineering, testing, certification and manufacturing of the aircraft.

What we call good engineering practice or GEP.

I know the engineers reading this are thinking, that’s crap!

Maybe, but there is a lot of crap to go around.

Let’s face it. The FAA is a great organization that has for most of its history done a fabulous job. The regional operations offices are always willing to help and most of them have built long standing, highly productive relationships with the aviation stakeholders from pilots to aircraft operators to airports. It has been at the foundation of collaborative aviation safety and quality in operations. And it has been these relationships that has built one of the finest aviation systems in the world.

But companies like Boeing are big. They are giant corporations with shareholder priorities that are not always compatible with Good Engineering Practice and that must change. When their workforce is responsible for the safety of the traveling public, it cannot be business as usual.

And it is time for the FAA and the Department of Transportation to become more proactive in innovating new ways of meeting regulatory compliance.

?References:

1). How ‘Boeing’s Fatal Flaw’ Grounded the 737 Max and Exposed Failed Oversight Sept. 13, 2021. https://www.nytimes.com/2021/09/13/NYT-Presents/boeing-737-max-crash-frontline.html