The following is taken from FAA’s “Light-Sport Aircraft Manufacturers Assessment” Final Report issued May 17, 2010. It has not been edited or changed in any way other than to format for Web posting.
Light-Sport Aircraft Manufacturer Assessment
—– Final Report —–
Issued May 17, 2010
EXECUTIVE SUMMARY
This report presents the results of the Light-sport Aircraft Manufacturers Assessment (LSAMA), (herein referred to as assessment and team). This executive summary briefly discusses the assessment team’s analysis, conclusions, and recommendations based on data collected during the assessment.
GOAL
The assessment team’s goal was to review current LSA manufacturing industry systems and processes through on-site evaluation, analysis, and reporting. The team was also tasked to recommend enhancements to industry consensus standards for LSA design, manufacturing, continued airworthiness, and maintenance and FAA processes and procedures. The team’s methodology was to collect data from LSA manufacturers, including their extensions and distributors, located in the United States. The team collected data on LSA industry compliance with applicable regulations, standards, and existing processes.
METHODOLOGY
The team developed survey questions and data gathering tools, performed evaluations, analyzed collected data, and developed conclusions and recommendations. The team designed the questions to evaluate the LSA industry’s understanding and application of applicable regulations, standards, processes and procedures. The team developed conclusions and recommendations based on the analysis of the collected data, team observations, and comments and suggestions of individuals the team interviewed during the assessment.
The team evaluated 14 manufacturers, including their extensions and 16 distributors. This sample of 30 LSA facilities established a 93 percent confidence level that the results of this assessment represent the LSA industry as a whole. The assessment surveys began in September 2008 and were completed in March 2009. The assessment survey participants were cooperative and provided unrestricted access to their LSA facilities. They exhibited a willingness and desire to build and promote safe LSA.
CONCLUSIONS
This [Manufacturers Assessment report from May 17, 2010] identifies four areas that need minor to significant improvement. Deficiencies vary from facility to facility, by degree, quantity, and type.
1. Compliance with FAA-accepted consensus standards
The majority of LSA facilities surveyed could not fully demonstrate their ability to comply with certain consensus standards. The assessment indicates that manufacturers are making statements of compliance for aircraft that may not fully meet certain consensus standards. We have concluded that relying solely on the manufacturer’s statements of compliance, for the issuance of airworthiness certificates, should be reconsidered.
2. Implementation of manufacturing systems
Some manufacturers have failed to implement widely accepted internal quality control and production procedures that are necessary to assure minimal compliance to the ASTM consensus standards. Many manufacturers also lacked corrective action systems used to address systemic deficiencies. Further compounding this scenario is the fact that current consensus standards identify only minimum requirements without a systems-based approach which only exacerbates procedural and record keeping weaknesses. We conclude that these lack of controls may result in the production and distribution of such poorly documented aircraft that it may be very difficult to verify conformity.
Distributors have not developed and implemented manufacturing and quality system procedures for many of the tasks they perform. When distributors perform assembly, inspections, and other functions, they seldom use the manufacturers’ procedures, records, or controls. The consensus standards do not require distributors to use process control procedures and as a result, distributors have only partial manufacturing and quality system procedures and associated records. We conclude that the consensus standards need revision to require documented controls and processes for assembly and other production functions that distributors perform prior to airworthiness inspections and flight.
3. Understanding FAA regulatory requirements, policy and guidance, and industry consensus standards
We conclude that industry and FAA designees have inadequate knowledge of FAA regulatory requirements and policies and ASTM/industry consensus standards. The evidentiary factors for this conclusion include: (1) inadequate application of manufacturing process procedures necessary to establish eligibility, (2) misinterpretations of the intent of FAA regulatory requirements, policy and guidance, and industry consensus standards, (3) misinterpretations of overall roles and responsibilities of the various industry entities (manufacturers, their extensions and distributors), (4) non-standardized methods and sequencing of airworthiness certification, and (5) uncertainty of appropriate contacts for needed guidance.
4. Industry’s system for managing, assessing, and maintaining the effectiveness of the consensus standards
The industry does not have a means to communicate with manufacturers on how to comply with the requirements of the consensus standards. We conclude that the process for evaluating compliance with the standards and taking corrective action needs significant improvement. Additionally, the process for maintaining and updating consensus standards needs improvement.
RECOMMENDATIONS
The team developed its recommendations based on data analysis, conclusions, trending indicators, and industry responses to a questionnaire. Specific recommendations are located in section 2.1 through 2.8 of this report, and the following summarizes those recommendations:
Industry:
*** Take immediate steps to fully comply with FAA regulatory and consensus standard requirements.
*** Standardize the continuous airworthiness notification process for all LSA types.
*** Develop training to ensure industry fully understands FAA regulatory and policy requirements, and the methods and means to comply with those requirements.
*** Establish periodic meetings between FAA and industry to work toward full compliance to FAA regulatory and consensus standard requirements.
*** Conduct an initial conformity inspection of all first-time-manufactured LSA models.
*** Continue assessments of manufacturers, extensions, and distributors.
*** Review current accepted consensus standards for adequacy and revise existing standards or create new standards where necessary.
FAA:
*** Update existing policy (Advisory Circulars and Orders) pertaining to airworthiness certification requirements, registration marking, and designee management.
*** Update Designated Airworthiness Representative(s) (DAR) and advisor training.
*** Establish a process to receive safety alerts, directives, and other pertinent information.
*** Continue oversight of the LSA manufacturers to assure compliance with FAA requirements and ASTM consensus standards.
If you wish to download a PDF file version of the full-length “Final Report from FAA,” click here.
An even longer “Industry Participant Supplemental” report was offered only to companies that were assessed. The Supplemental Report reaches no new conclusions but supplies additional detail.
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