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Proposed 14 CFR 25.1302 regulation coming to a Cert Basis near you: Why has this regulation been created?

2nd post in the series

As you may have read in the first post of this series, 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.

You may be asking: Why has this regulation been created?  Haven’t we already covered everything important in the regulations of 14 CFR Part 25?

Well, let me give you my answer (which obviously is not an official FAA response … cue announcers voice: “the views and opinions expressed in this post are those of the author and do not necessarily reflect the FAA, its employees, or the Screen Actors Guild. No animals were harmed during the writing of this post.”).

A little history

Where has the proposed regulation come from and why was it created? It all traces back to something that many refer to as the “Human Factors Team Report.” Back in 1996, the FAA published the results of study that evaluated the flightcrew/flight deck automation interfaces of transport category aircraft.  This report was called The Interfaces Between Flightcrews and Modern Flight Deck Systems (you can get it from the FAA’s website here: http://www.tc.faa.gov/its/worldpac/techrpt/hffaces.pdf).

The impetus of this study was a recognition that a number of aircraft incidents and accidents (including the China Airlines accident in Nagoya, Japan on April 26, 1994) appeared to highlight challenges flightcrews were having interacting with flight deck automation.

Based on the investigation and examination of evidence, the Human Factors Team who conducted the study determined that:

“these concerns represent more than a series of individual problems with individual, independent solutions. These concerns are highly interrelated, and are evidence of aviation system problems, not just isolated human or machine errors. Therefore, we need system solutions, not just point solutions to individual problems. To treat one issue (or underlying cause) in isolation will ultimately fail to fundamentally increase the safety of airplane operations, and may even decrease safety.”

Therefore, the Human Factors Team developed a set of recommendations to effectively address the vulnerabilities and deficiencies that they had identified.  One of these recommendations was:

Recommendation Criteria-1: The FAA should require evaluation of flight deck designs for susceptibility to design-induced flightcrew errors and the consequences of those errors as part of the type certification process.

In 1999, the U.S., Canada, and Europe tasked the Human Factors Harmonization Working Group (HF HWG) to provide advice and recommendations on Flight Crew Error/Flight Crew Performance Considerations in the Flight Deck Certification Process.  The HF HWG was composed of experts in both civil aviation regulatory authorities and industry. We at Research Integrations were part of the HF HWG, so that’s when we enter and actually become one of the players in the history of the 14 CFR 25.1302 regulation.

After getting a good understanding of the problem, the HF HWG came to the conclusion that the best way to address it was to recommend that both new advisory material and regulatory material be developed to address the design-related vulnerabilities of flight crew performance and the management of flight crew error.

The HF HWG considered how best to implement changes that would most effectively and efficiently do the trick. They considered a number of alternative approaches including:

  • Changes to multiple existing rules. And while no new rule would need to be developed, nearly every system specific rule would need to be changed – yikes! Can you imagine having to do this? And another down-side would be that this method would not adequately address new technologies.
  • Provide advisory material only.  The problem with this approach is that there would be no clear regulatory basis to hang this advisory material on, so it may not be effective since it wouldn’t be enforceable.
  • Develop a new rule with flight crew error as the central safety objective. At first it seems like this would do the trick, but it has a number of problems, including: it would regulate crew behavior rather than design; it could involve excessive use of subjective opinion for compliance determination; it would be really difficult to appropriately and clearly limit the scope; and suitable methods of compliance could be difficult or impossible to completely define. It was recognized that human errors cannot be controlled, predicted, or calculated like equipment failures can and that errors will occur, even with well-designed systems and well-qualified flight crews.
  • Develop a new rule focused on design attributes related to error. Ah, now this is the ticket. The rule would regulate design (not crew behavior) by providing explicit requirements for design attributes related to flight crew performance including the avoidance and management of flight crew errors.  As a general applicability rule, it would apply to all equipment with which the flight crew interacts.  Throw in some advisory material and I think we have our approach.

So, the HF HWG recommended that a new general applicability regulation be developed that was focused on design attributes related to avoiding and managing error and drafted proposed text of the regulation and companion Advisory Circular.

To learn the details of the HF HWG work, check out the HF HWG Final Report: http://www.faa.gov/regulations_policies/rulemaking/committees/documents/media/TAEhfhT1-072299.pdf

(And, if you want even more information such as status reports and other behind the scenes information, you can check out the HF HWG website that we continue to host: http://www.researchintegrations.com/hf-hwg/index.htm)

Safety Rationale of the Proposed Rule

As required by the Transport Aircraft and Engine Group (TAEIG) of the Aviation Rulemaking Advisory Committee tasking, the HF HWG described the underlying safety rational for the proposed 14 CFR Part 25.1302 rule.  Here’s what they said:

“This requirement is intended to help to prevent the certification of unsafe design features that may lead flight crews to make errors, not detect errors, or recover too late from errors that may have serious safety consequences. Current requirements address the design of various features of specific flight deck equipment in a manner intended to assure that the crew can operate that particular device safely; however, there is no guidance or existing requirement that addresses the prevention and management of flight crew error in a comprehensive or integrated manner across the various flight deck components. The proposed requirement addresses in a comprehensive fashion those design characteristics that affect the occurrence and management of flight crew error. It applies across all flight deck equipment that provides information to the flight crew or that the crew uses to control the operation of the airplane.”

So, the proposed 14 CFR 25.1302 rule presents requirements that address design attributes related to the prevention and management of flight crew errors. These requirements should help prevent the certification of aircraft with design features that are unsafe and may lead to flight crews either making errors, not detecting that an error has been made, or not being able to recover from errors that could have serious safety consequences.

There you have it. In a nutshell, operations seemed to be telling us that there was a need to ensure that that design attributes that impact flight crew error were needed, and this design attributes-based regulation was developed as a way to meet the challenge and improve safety in our skies.

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.

Special thanks to Dr. Kathy Abbott FAA Chief Scientific and Technical Advisor for Flight Deck Human Factors for her presentation on the proposed 14 CFR 25.1302 from which I gained a better understanding of the history of the proposed rule.

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