Report: Some Areas Need "Minor To Significant Improvement"

When it created created the LSA designation in 2004, the FAA took a less hands-on approach to the category, allowing the industry to take more direct responsibility for developing and maintaining standards for design, manufacturing, and continued airworthiness. The industry chose ASTM International to facilitate the development of standards for LSA.

In January 2008, the FAA established the LSA Manufacturers Assessment to evaluate the health, state of systems implementation, and compliance of the LSA industry as a whole. Specifically, the goal of the assessment was to gauge current LSA industry manufacturing systems and processes through on-site evaluation, analysis, and reporting under a continuous improvement process, and to provide recommendations to enhance aviation safety. The first assessment was published last month, and it gives the LSA industry mixed reviews.

For the purposes of the assessment, The FAA worked with 30 manufacturers, extensions, and distributors. All provided unrestricted access to their LSA facilities. During the interviews the participants were cooperative and willing to answer questions to the best of their ability. The LSA facilities involved significantly contributed to the successful completion of this assessment.

The report recommends correcting and improving several different areas of the LSA manufacturing industry and FAA policy and guidance. In its report, the FAA said that many of the companies surveyed during this assessment exhibited exuberance and confidence in their contribution to the LSA industry. The FAA says there is a willingness and desire, regardless of experience level, to build and promote safe LSA.

Four areas stood out: Compliance, Conformity, Oversight, and Advisory Material. The FAA says a review of the overall results indicates that a majority of LSA manufacturers could not fully demonstrate their ability to comply with FAA regulatory and policy requirements. The section summaries indicate that the manufacturer’s ability to demonstrate compliance varied a great deal. To address that situation, the FAA recommends that the LSA industry should take immediate steps to fully comply with FAA regulatory and policy requirements, and that the industry should establish periodic meetings to work towards full compliance with FAA regulatory and policy requirements.

The report indicates that most of the aircraft reviewed during the assessment exhibited deficiencies in the ability to fully meet basic requirements in certain ASTM consensus standards. The FAA recommends that LSA manufacturers should conduct an initial conformity inspection of all first-time-manufactured LSA models, including standards, any regulatory required documentation and records review, along with an SLSA conformity inspection. Airworthiness certificates should not be issued until all issues are resolved.

In the area of oversight, the FAA found that many assessed LSA facilities did not fully comply with ASTM consensus standards in the area of continuous oversight. Manufacturers, their extensions and distributors could not show that they adhere to all consensus standard requirements. The FAA said that the industry should continue assessments of LSA manufacturers, extensions, and distributors.

And finally, many LSA facilities showed weaknesses in written procedures, knowledge, or experience related to the design, manufacture and continued airworthiness of LSA. The FAA determined that LSA manufacturers need advisory material describing basic elements of manufacturing, design, quality, and continued airworthiness systems. But it also put some of the onus on itself, concluding that FAA should update existing policy (Advisory Circulars and Orders) pertaining to airworthiness certification requirements, registration marking, and designee management.

The report concludes that 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. 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. On the distribution side, the FAA said 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.

To continue to improve the safety of the LSA industry, the FAA recommends that it:

• 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.

For its part, the FAA acknowledges that it should:

• 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.

FMI: www.faa.gov