Nine times out of ten, knowing how to put the power of the regulatory authorities to work for you instead of against you is the secret to success.
As mentioned in our recent article on developments of new Magnesium alloys for seats, even when the regulations expressly forbid the use of a product, a proactive and forward-thinking organization can participate in the process, initiate a review, and successfully obtain support for a valuable innovation. But it doesn’t happen in a vacuum. It requires an understanding of the processes for materials and component evaluation, and a commitment to support those processes.
Successful aviation and aerospace innovation is a direct result of the work of a community of specialists and not the isolated activity of a lone organization. For many who are new to aviation it may seem that we are a secret society who speak an odd form of pig-latin composed of random letters and numbers, and that we are resistant to change. Nothing could be further from the truth. The “pig-latin” is no more than a standardized method to communicate concepts in a short and efficient fashion. Becoming familiar with it is as essential (and simple) as becoming familiar with elementary mathematics. Like the language of mathematics, the language of aviation and aerospace is fixed and reliable, perhaps not written in stone, but certainly written on paper with the intent that all participants around the world work to the same quantified and measurable standards.
Further, to support those standards, the regulatory authorities have developed great competencies for testing and evaluation. For example, the FAA has a wealth of resources, labs, specialists, test centers, etc., who will put together the necessary testing with the goal of qualifying innovations to improve and modernize aviation. It is their mission to do so. In the FAA’s own words: “Innovation is our signature. We foster creativity and vision to provide solutions beyond today’s boundaries.” The FAA takes pride in its initiatives for research, and have the necessary funding and support from the US Government to ensure those initiatives are successful. They describe these as Research, Engineering and Development.
Take the example of the new Magnesium alloys again. Without the commitment and hard-work of Tim Marker of the FAA, putting the full resources of the William J. Hughes Technical Center on the project, by coordinating and conducting the many iterations of testing which were required to validate the new Magnesium alloys, there would have been no progress. FAA CAMI (Civil Aerospace Medical Institute) in Oklahoma is also well equipped to conduct comprehensive survivability and human factors studies. For example, they conducted in-depth dynamic tests on the performance of airbag restraints featured in a separate article here on the Runway Girl Network. The various FAA departments are staffed by experts in their field, with sufficient background and experience to properly evaluate the materials they review. And they want to evaluate new products. They enjoy the process. The same is true of EASA in Europe, CAA in the UK, CASA in Australia, all the regulatory bodies. Some may have more available resources to study innovations than others, but all cooperate.
So what are the steps to get it done?
1) Do your homework. All the information is out there and it is all free. Because regulatory bodies are civil service institutions, and government departments, their reports, minutes, regulations, etc. are publicly published documents. There are very few restrictions and the restrictions they have in place are ones manufacturers would want; mainly to protect intellectual property. Fortunately for all of us, today’s internet world means it’s all available immediately on your browser. Just do a quick search and you’ll have a wealth of information available.
2) Reach out. A simple phone call to the right MIDO (Manufacturing Inspection District Office) representative to ask for guidance and build relationships is essential. All the pertinent numbers are listed on the regulatory authorities’ websites. Doing your homework first is highly recommended, as general questions, without demonstrating any understanding of the topic are difficult for the authorities to address. There are so many relevant regulations for any single innovation that it really cannot all be answered as an open question. Get specific. Identify the regulations and tests you believe apply to your innovation and then double check with the authorities to see whether you are interpreting them properly. Representatives will go out of their way to help you understand your subject better. Again. They enjoy this.
3) Ask the harmonization question. There are some variations on policy from regulator to regulator. Groups dedicated to harmonization work every day to reconcile them, but it is best to ask whether other authorities will have the same policies. For example, if you ask the FAA they will know and help you understand the differences.
4) Get in there. There are FAA working groups on a whole series of aviation focus areas, most of which include participants from various international regulators. Join in. Participate in the decision making. The working groups actively evaluate regulations and set standards of testing. Being involved can help product innovators not only understand the requirements better, but are also the ideal stage to introduce new ideas. Here’s the best part: working groups are open to aviation suppliers. No secret handshake required. Just find out when the next one is meeting and attend. The best way to find out which one applies to you is to ask your MIDO Representative. They’ll know and will be glad to tell you. In fact, they may be part of the working group themselves. Everyone in aviation is affected by the Fire & Cabin Safety Working group to some degree or other. Attending those meetings is a great way to learn, network, and find answers to troublesome questions.
5) Where’s your DAR? Are you working with a Designated Airworthiness Representative? Get a DAR! DARs are private individuals who report directly to the FAA in order to extend the FAA’s reach. There are just too many things going on out there for the FAA to assign staff to all of them. They issue a special license (based on tough qualifications and standards) to qualified aeronautical experts to help them reach out to everyone. Consider trying to develop and submit a product to the FAA (or other regulatory body) without the aid of a DAR tantamount to trying to captain your own cruise ship on vacation. It’s not the best way to enjoy the journey. Expert consultants like George J. Ringger who directly contributed to the flammability testing article exclusive to the Runway Girl Network have multi-disciplinary training and various licenses with the FAA, as well as a comprehensive understanding of regulations world-wide. Consider their services one of the best investments your company will make in the product development process.
6) Go to school. Dedicated aeronautical universities, like Embry Riddle in the US and Cranfield University in the UK, carry out comprehensive studies on aviation matters. They are also a great place to recruit well-qualified graduates to join your team.
7) Consult the OEMs. The engineering teams responsible for your innovation at Airbus and Boeing can provide excellent additional guidance. However, they are not a substitute to working with the authorities, only a complement to the process.
8) Outsource. There are a number of exceptionally good outside laboratories available to contract for special testing not already covered by the regulatory authorities. Far too many to list in a single article. So look out for more exclusive articles from the Runway Girl Network which feature product innovations. We’ll be mentioning them. A great place to meet the right people at consultancy and labs is to join and participate in the Aviation Suppliers Association. Their annual meetings are not just a great place to network. They include unmissable presentations which explain the policies and regulations which govern aviation and provide practical solutions to suppliers in order to ensure compliance.
9) Follow Runway Girl Network. We’re doing the homework for you.
10) Really. Follow Runway Girl Network. We love doing our homework. It took me 16 years to learn all this the hard way. How long did it take you to read this article? Consider it time well spent.