A new FAA regulation is tentatively slated to hit the streets in early 2013. It is the proposed FAA 14 CFR 25.1302 Installed systems and equipment for use by the flightcrew and is the first general applicability FAA regulation to include explicit requirements for design attributes related to avoiding and managing flight crew error.
While FAA 14 CFR 25.1523 and corresponding Appendix D have addressed some related design attributes, this proposed FAA regulation represents a much more global approach to human factors on the flight deck and will require system and equipment designers to consider human error and feedback in their design and testing of flight deck interfaces.
The FAA 14 CFR 25.1302 was initially developed as a harmonized regulation with the EASA CS 25.1302 regulation. Since the release of the EASA regulation in 2006, several manufacturers have had projects that required demonstrating compliance with the EASA CS 25.1302 regulation, while other aircraft and avionics manufacturers have integrated human factors-related practices into their design and testing processes in preparation for EASA CS 25.1302 and the likely future release of the proposed FAA 14 CFR 25.1302. All of these experiences can provide useful information for others to help them prepare for the release of the proposed FAA regulation in the U.S.
We just completed a research project for the FAA to gather information about the state of industry and FAA understanding and practices that may impact the effective implementation and compliance with the proposed 14 CFR 25.1302 regulation. The research findings from this project are intended to help the FAA better understand what they can do ensure that the implementation of the proposed 14 CFR 25.1302 is a smooth one.
In this blog series, I will talk about some of the things that we learned in the course of this project. In this post, I’m going to share some information that is already out there that you should read to get ready for the proposed 14 CFR 25.1302. So let’s dig in.
1. Text of the proposed 14 CFR 25.1302 regulation
First of all, you’ve got to read the proposed regulation as it is currently published in the Federal Register as a Notice to Proposed Rulemaking (NPRM). Some of the wording of this text as it was published in the Federal Register may change as the FAA addresses comments, but my best guess is that it is likely pretty close to its final form. The proposed 14 CFR 25.1302 regulation falls in Subpart F – Equipment.
Link to the NPRM in the Federal Register containing the preamble and regulation for the proposed 14 CFR 25.1302: http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgNPRM.nsf/0/4366D39205C350158625782C00534461?OpenDocument&Highlight=faa-2010-1175;%20notice%20no.%2011-02
2. Preamble to the proposed 14 CFR 25.1302
Once you’ve read the text of the proposed regulation several times and all those questions about how this or that will be interpreted when it is out in the wild, it’s time to read the Preamble as published in the Federal Register to accompany the Notice to Proposed Rulemaking (NPRM) for the proposed 14 CFR 25.1302 regulation. The Preamble provides background information about the 14 CFR 25.1302 regulation and the reasons why the regulation has been proposed. The Preamble can be one of the most valuable hunks of information for really understanding a regulation that is most often overlooked. When in doubt, try to find a regulation’s Preamble.
Use the link to the proposed 14 CFR 25.1302 regulation provided above to read the Preamble.
3. EASA Acceptable Means of Compliance AMC 25.1302
While it would be great to be able to read the draft FAA Advisory Circular AC 25.1302-X, it is no longer out for comment and, therefore, no longer available until it is published in its final form. So, the next best thing is to read EASA’s Acceptable Means of Compliance AMC 25.1302, which provides guidance for showing compliance with EASA CS 25.1302 and several other rules in Certification Specification CS-25 that relate to the installed equipment used by the flight crew in the operation of the aircraft. This AMC describes acceptable approaches to compliance and also provides recommendations for the design and evaluation of controls, displays, system behavior, and system integration, as well as design guidance for error management.
As of the date of this post, this is the latest Amendment to CS-25 is amendment 12 which you can find here: http://www.easa.europa.eu/agency-measures/docs/certification-specifications/CS-25/CS-25%20Amdt%2012.pdf
The AMC is located in CS-25 – Book 2 – Acceptable Means of Compliance > AMC – SUBPART F section in the PDF document.
Note: If you have trouble navigating EASA’s regulations and advisory material, take a look at my post “Navigating EASA’s Airworthiness Certification Specifications” for a description of the organization of EASA Certification Specifications to help you find your way.
4. 14 CFR 25.1301 regulation
It is important to realize that the number of the proposed 14 CFR 25.1302 was deliberate so that it would fall right after the regulation 14 CFR 25.1301, Function and Installation. The intention is for 14 CFR 25.1302 to build on 14 CFR 25.1301, so it’s a good idea to read 14 CFR 25.1301 to really understand the context of the proposed 14 CFR 25.1302. The 14 CFR 25.1301 regulation is a general applicability regulation in subpart F of 14 CFR part 25 that provides requirements related to function and installation of equipment.
Link to 14 CFR 25.1301 in the FAA’s online Regulatory and Guidance Library: http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgFAR.nsf/0/1A42288111847ABC862573980074B292?OpenDocument&Highlight=25.1301
5. FAA Policy Statement ANM-99-02
Now that you have read all those other documents, it’s time to move on to a couple of FAA Policy documents that will provide a better understanding of the FAA’s approach and guidance to addressing human factors in flight deck certification. The first one is FAA Policy Statement ANM-99-02, Guidance for Reviewing Certification Plans to Address Human Factors for Certification of Transport Airplane Flight Decks. This Policy provides guidance to FAA Certification Teams that will enable them to conduct an effective review of an applicant’s Human Factors Certification Plan or the human factors components of a general Certification Plan. This guidance describes the sections of a Human Factors Certification Plan and the information that should be included in each section.
Link to Policy Statement ANM-99-02 in the FAA’s online Regulatory and Guidance Library: http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgPolicy.nsf/0/4684b8382b57f18e8625774500705cb7/$FILE/PSanm992.pdf
6. FAA Memorandum ANM-01-03A
The next policy document is FAA Memorandum ANM-01-03A, Factors to Consider when Reviewing an Applicant’s Proposed Human Factors Methods of Compliance for Flight Deck Certification. This Policy provides guidance to FAA Certification Teams that will enable them to conduct an effective review of an applicant’s Human Factors Certification Plan or the human factors components of a general Certification Plan. The information provided in the policy statement covers general information on methods of compliance for regulations related to human factors, the identification of design-specific human factors issues, and the identification of regulation-specific human factors issues.
Link to FAA Memorandum ANM-01-03A in the FAA’s online Regulatory and Guidance Library: http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgPolicy.nsf/0/4b68cf2dfb0ed36586256d6400548cf5/$FILE/ANM-01-03(A)-FINAL.pdf
Reading these six documents should give you leg up on understanding the proposed 14 CFR 25.1302 regulation. Check back for my next installment in this series to learn more about the proposed regulation and what you can do to get ready for it.