Boeing, under intensifying regulatory scrutiny after the fatal MAX crashes, has been directed by the Federal Aviation Administration to rework its flight manuals for both the 777X and MAX 10 to include detailed emergency pilot procedures.
The FAA has told Boeing to incorporate into the Airplane Flight Manuals, formal documents that are required for certification of both jets, precise details of the procedures and checklists the crew must follow to handle the kind of emergencies that killed 346 people in the MAX crashes in Indonesia and Ethiopia.
Those procedures had previously been detailed in other documents customized by individual airlines to train pilots. However, those airline documents are not overseen by regulators during the initial airplane certification process and may vary at airlines around the world.
The FAA is tightening control to ensure that for Boeing’s two current airplane development programs — the latest and largest version of the narrowbody MAX, which had its first flight in June; and the giant new derivative of Boeing’s widebody 777, which first flew in January 2020 — this information goes out in a certification document provided to all airlines worldwide.
Boeing doesn’t see this new requirement adding further delay because certification of both jets has already been pushed far out until late 2023.
In May, the FAA cited a serious flight test incident and lack of design maturity for slowing certification of the 777X. And certification of the MAX 10 is similarly delayed as Boeing works to develop further safety updates for flight control and crew alerting systems required by the European air safety regulator.
Procedures critical to safety
In the latest development, spelled out in a July 12 FAA letter to Tom Galantowicz, head of the internal Boeing organization that handles certification of new jets, the FAA requires Boeing to rework the airplane flight manuals for both jets to include more detail in checklist format on the emergency pilot procedures.
The letter also demands that the pilot manual explicitly refer to how these emergency pilot procedures relate to two other key certification documents for each of the jets — the Functional Hazard Analysis and the System Safety Assessment — that analyze potential failures in the airplane systems design.
These analyses take account of flight crew reactions to an emergency and presume that the pilots will correctly implement recovery procedures.
The FAA wants Boeing to explicitly state in its flight manuals that these formal risk assessments depend upon pilots correctly and smoothly executing the emergency pilot procedures.
This will underline for airline pilots across the globe that these procedures are central to the certified safety of the airplane.
“They are making sure the pilots understand the criticality of the procedures,” said an FAA safety engineer, who cannot be named because he spoke without authorization from the federal agency. “That makes perfect sense.”
Asked about the new FAA requirements, Boeing said in a brief statement that “we are committed to continue to work with the FAA to meet all certification requirements.”
The FAA declined to discuss details of its decision, saying only that it “will not approve any aircraft unless it meets our safety and certification standards.”
Justifying its position to Boeing in an earlier letter in May, the FAA cited safety recommendations from the final investigation report by the Indonesian air safety authority following the 2018 Lion Air crash and from a damning 2019 report compiled by an international panel of air-safety regulators, as well as the requirements of the Aircraft Certification, Safety and Accountability Act passed by Congress at the end of 2020.
That legislation requires the FAA to “ensure that an airplane flight manual … contains … flight crew procedures for responding to a failure” of flight control systems.
Boeing’s original certification plan proposed that the FAA should delegate to Boeing all the decisions on what details will be in the airplane flight manual. The FAA rejected that proposal.
In its letter to Galantowicz, the FAA cites the 2019 report by the panel of international air-safety regulators — the Joint Authorities Technical Review — in noting that Boeing and other airplane manufacturers along with their airline customers have developed separate flight crew operating manuals for onboard use, that can include additional information, such as succinct cockpit checklists, systems descriptions, and detailed procedures.
However, different airlines may develop variations of these flight crew operating manuals for their own pilots. Only the information in the certified Airplane Flight Manual is mandatory.
And though U.S. airlines would have to have any such operating manuals approved by the FAA, foreign airlines would not.
Given these alternative sources of information for flight crews, the FAA issued regulatory guidance in 2012 stipulating that the content in the Airplane Flight Manual for initial certification could be reduced and “should be limited to the smallest practicable amount of material … that which is uniquely related to airplane safety or airworthiness.”
The JATR report called this guidance “contradictory” and said it “has allowed Boeing Airplane Flight Manuals to minimize the content of operating procedures that are subject to FAA scrutiny and approval.”
In light of the MAX crashes, that’s no longer acceptable to the FAA. The FAA letter instructs Boeing to modify its certification plan for the pilot manuals and resubmit it.
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