After getting married shortly after college graduation, my new spouse and I embarked on a honeymoon road trip. Nothing fancy. We thought touring the great state of Arizona would fill our time nicely. We threw some luggage into the car and off we went. We didn’t have much of a plan, except to explore places we haven’t seen. It seemed (at the time) that planning the trip would take out all of the spontaneity. Our spirits got dampened a bit when we pulled into our first destination and most of the hotel rooms were already booked. Turns out there was some kind of conference going on that week. We eventually found a hotel, but it was overpriced, marginally clean, had a spider or two, and not very comfortable. Sleeping in the car was actually an attractive option, but we elected the hotel, spiders and all. Just a little bit of planning could have made a dramatic difference in the outcome of that night. After that night, I started roughing out travel plans. What a difference did that make. Certification planning isn’t much different. A poor certification plan will give the same results as that murky hotel room. A well thought out certification plan will provide a much better experience. You and your regulatory agency will have some idea of where you are going before you get there.
A certification plan is the tool used for meeting 14 CFR part 21 requirements for certification and approval of a product, as well as a tool for managing the certification project. FAA Order 8110.4 describes the requirements and “The FAA and Industry Guide to Product Certification” (or “Certification Process Guide” (CPG) for short) contains a certification plan template. The CPG can be found on DRS along with FAA Order 8110.4. It isn’t the intent of this article to duplicate all of the information in FAA Order 8110.4 or the CPG. However, I’ve found it helpful while working certification projects to have a simplified bulleted list of certification plan requirements as a reference tool. This ensures the certification plan meets FAA requirements. Here are the basic elements that are required in a certification plan per FAA Order 8110.4:
- General information
- Applicant identification
- Application date
- Model designation
- Description of design or design change
- Intended regulatory operating environment (14 CFR part 91, etc)
- Proposed certification basis
- Applicable regulation paragraphs and subparagraphs
- Amendment levels
- ELOS findings
- Special conditions
- Description of how compliance will be shown
- Ground test, flight test, analysis, similarity, or other means
- Must be sufficient enough to determine that all necessary FAA data will be collected and all findings can be made
- List of documentation (compliance checklist)
- List of test articles
- Used to generate compliance data
- Identify features as necessary for the manufacturing inspector (conformity)
- Project schedule
- Preliminary hazard analysis submittal dates
- Substantiating data submittal dates
- Conformity and testing completion dates
- Expected date of final certification
- Identification of all Designated Engineering Representatives (DERs) intended for use in the project
- Identify area of authority
- Identify if the DER is approving or recommend approving
- Identification of all designated inspectors
- Manufacturing inspection representatives (DMIRs)
- Designated Airworthiness representatives (DARs)
- Organizational designated airworthiness representatives (ODAR)
- The designee’s authorized function codes
- The designee’s proposed inspection activities
The Part 21/Safety Management Systems (SMS) Aviation Rulemaking Committee was chartered by the FAA on October 15, 2012, and was responsible for making recommendations for updating Part 21 certification procedures. In the final report, the ARC describes the concept of the “Accountability Framework.” The accountability framework is the premise that applicants and approval holders have full responsibility (legal and regulatory) for compliance with all applicable requirements (e.g. 14 CFR). On the regulatory side, the FAA Administrator has the obligation to promote safe flight of civil aviation through regulatory oversight. The certification plan is the primary tool for defining how the applicant is going to show compliance. It also becomes the vehicle for which the FAA can determine their involvement in compliance findings based on the applicant’s compliance showings. In practice, the certification plan becomes a key piece in the accountability framework. It’s the applicant’s responsibility to submit a certification plan that meets the requirements of FAA Order 8110.4 so the FAA can accomplish their objective in promoting safety through discretionary involvement in the project.
Certifying Statements of Compliance
14 CFR §§ 21.20 and 21.97 at amendment 92 provide the regulatory basis for the applicant statement of compliance. As described in AC 21-51, Applicant’s Showing of Compliance and Certifying Statement of Compliance, it’s the applicant who is responsible for satisfying all applicable requirements. The FAA (or the FAA’s designees when delegated) will make the compliance findings, but that doesn’t change the applicant’s responsibility. Compliance findings made by the FAA or FAA designees do not relieve the applicant from the responsibility for showing compliance.
Plan the Work, Work the Plan
A well-executed certification project always starts with a well written certification plan and provides the practical execution of the accountability framework. A well written certification plan must meet the requirements of FAA Order 8110.4 and the CPG provides guidance as well as a certification plan template that applicants can utilize. As far as the basic elements required in a certification plan, the reference library page here contains the list for quick reference.
Joel Heck has been with Cessna, now Textron Aviation, for 24 years in engineering. His entire career has been focused on the design approval aspects of FAA certification, and his technical work experience in certification spans the Cessna, Beechcraft, and McCauley product lines.