System Safety Assessments

---

At the core of 14 CFR is safety. The safety of those piloting aircraft, the safety of passengers riding in aircraft, the safety of everything flying in the national air space, and the safety of everyone on the ground. 

Per FAA regulations, safety is defined to be a sufficiently low probability of a hazardous event occurring. The methodologies used to define those hazards and probabilities are well defined, however, it takes many years of experience to effectively apply those methodologies. Conducting hazard analyses, fault tree analyses, and failure modes and effects analyses to substantiate compliance to safety requirements requires expertise in understanding the normal aircraft operating environment and how failures in complex avionics impact normal operation. It also helps to be fully cognizant of how component failures within the avionics effect the normal operation of the avionics unit. 

Being an electrical engineer who’s designed complex avionics circuitry for years, and then used that knowledge to conduct numerous component, system, and aircraft level safety assessments over the years, I can help navigate avionics manufacturers through these areas. Industry standards such as the SAE ARP 4754 and ARP 4761 provide good guidance on the mechanics of system safety assessments, but experience is necessary to apply those techniques to real-world avionics and aircraft operation. 

In addition, the FAA has issued an FAA Order that directs industry to a manual that defines in great detail how to assess such risks in determining whether actions such as issuing an Airworthiness Directive is required to address a noncomplaince that's been discovered. Called the Transport Airplane Risk Assessment Methodology (TARAM), I lead one of the first certification organizations in utilizing the TARAM to deal with an operation issue impacting thousands of aircraft. 

An additional safety related aspect of particular importance to an avionics manufacturer involves addressing noncompliances in the field with regards to notifications to the FAA. While 14 CFR regulations define when reporting such noncompliances to the FAA are absolutely required, it’s important for an avionics manufacturer to understand and effectively use what the FAA calls their Voluntary Disclosure Reporting Program.  Utilizing the VDRP provides a means for the FAA to avoid issuing civil penalties when avionics failures have a significant probability of impact on safe flight. 

For many years I’ve managed system safety organizations that addressed all noncompliances to determine if and when any reports to the FAA were made. It’s a fine line between reporting issues that create unnecessary activities by the regulatory agencies and not reporting issues that result in such actions as Airworthiness Directives that cost the avionics manufacturer millions of dollars in costs. If you're facing such an issue I can perhaps help provide perspective on the situation.