SCR process in place to correct certification oversights

 - October 1, 2008, 9:46 AM

One of the tools in the FAA’s kit is the special certification review (SCR). According to the agency, the post-certification evaluation provides “a way to evaluate the type certification project and potentially unsafe design features on previously approved products.” The FAA initiates an SCR based on a variety of issues, one of which is service experience pointing to safety problems. The official list of safety problems that may generate an SCR includes:

• complex or unique design features;

• advanced state-of-the-art concepts in design or manufacturing;

• potentially unsafe features used on similar previous designs requiring further analysis and evaluation;

• compliance areas critical to safety and operational suitability that require evaluations;

• unsafe operational or maintainability characteristics;

• ELOS [equivalent level of safety] determinations with potential major effects on safety;

• complicated interrelationships of unusual features.

The FAA has conducted SCRs on a variety of aircraft and systems, usually following a series of accidents that highlight safety issues. According to a spokeswoman for the FAA’s Engine and Propeller Directorate in Burlington, Mass., the SCR team process wasn’t put “in place until the early 1980s [roughly 1982], when the FAA transitioned from the lead region organization structure to the directorate system.”
The FAA does not keep a current list of all the SCRs that it has done, so information about historical SCRs is difficult to obtain. AIN submitted a Freedom of Information Act Request to the FAA to try to compile such a list, and the FAA’s response was to farm out the request to each FAA region in an attempt to put a list together. As of press time, AIN was awaiting the results of that request.

SCR History
In researching SCRs, AIN found one dating back to June 17, 1980, when the FAA launched a certification review of the Learjet, according to an old NTSB report on Learjet high-speed upset accidents. Learjet 35/36s were the subject of another SCR that began on Nov. 4, 1999, following the Oct. 25, 1999 Payne Stewart depressurization accident. This SCR focused solely on Learjet 35/36 oxygen and pressurization systems and found no issues with those systems that would lead to an unsafe condition.

A 1998 in-flight fire involving a Swissair MD-11 precipitated another SCR. The FAA team investigated the design, installation and certification of the MD-11’s in-flight entertainment system. This SCR lasted almost three months, in contrast to the recent 30-day Eclipse 500 SCR.

Other aircraft subject to SCRs, according to the FAA, include the Robinson R22 (three times); Mitsubishi’s MU-2 (three times, although the last review focused primarily on training issues); Beech Bonanza (V-tail structure); Piper PA-46 Malibu (in-flight structural breakups); Cessna 208 Caravan (icing); Cessna 400 series; Raytheon (now Hawker Beechcraft) 390 Premier; Beechcraft T-34; and most recently the Eclipse 500 VLJ.

Do SCRs help? While the MU-2 was never found deficient with regard to certification regulations in any of its reviews, the fleet continued to experience accidents after the first two SCRs in 1983 and 1997. It wasn’t until the FAA conducted another MU-2 review in 2005 that the accident picture for the aircraft changed.

According to the FAA, “The [2005 MU-2] evaluation is performing a detailed review of accidents, incidents, airworthiness directives, service difficulty reports, safety recommendations and safety reports. It is also examining pilot training requirements, the history of the aircraft’s commercial operators and possible engine problems. The goal is to identify the root causes of MU-2 accidents and incidents and determine what, if any, additional safety actions are needed.”

As a result of the 2005 review, the FAA imposed new regulations in the form of an MU-2 special FAR for mandatory initial, recurrent and requalification pilot training. The MU-2 fleet has not suffered a single accident since the SFAR took effect. This raises the question of whether the SCR process is effective and if more focus on pilot training could have a more positive effect on certain aircraft types. Pilots who fly turboprops are not required to obtain a type rating, and in fact Mitsubishi had asked the FAA for many years to impose a type rating requirement on the MU-2. The training SFAR is more stringent than a type rating because it mandates recurrent training, something that is not required once a pilot earns a type rating.

The accident rate for the Robinson R22 experienced a similar turnaround after the SFAR process highlighted some training issues. The Robinson helicopter series is also subject to a training SFAR, and that requirement appears to have had a positive effect on the Robinson accident rate.

If there is anything notable about the Eclipse SCR, it is that it came so swiftly–about two years–after the airplane was certified and without any fatal accidents as a catalyst. The Eclipse SCR appears to have taken place sooner after certification than any other aircraft without a history of accidents, although this is difficult to confirm without access to historical FAA data.