A confluence of technology, curiosity on the part of a Gulfstream Aerospace quality director, and FAA open-mindedness has opened the door to a unique way to conduct inspections, remotely via live video.
The implications of this capability are extraordinary, not only offering savings of huge amounts of travel time and expenses but also enabling more comprehensive inspections of parts and components.
Gulfstream is the first to put this technology—called remote witnessing and remote inspection—to work, beginning with conformity inspections of supplier parts and moving on to maintenance-related inspections. Ron Witkowski, Gulfstream director of quality-regulatory compliance, came up with the idea and led the effort to prove that this works and to gain the FAA’s blessing. In August, the FAA agreed to develop a draft advisory circular to provide “guidance for using remote connectivity technology and tools,” and final publication of the circular is expected in October 2019.
The idea for remote inspection came to Witkowski when he realized that medicine has been using live video for many years. “If the medical industry can do this,” he wondered, “why can’t we?”
In addition to his job at Gulfstream, Witkowski is an independent designated airworthiness representative (DAR) specializing in the manufacturing and maintenance arenas. As a DAR, he represents the FAA’s interests, so he has a deep understanding of inspection requirements for manufacturing and maintenance from both the FAA and OEM perspective.
During development of Gulfstream’s latest models, the G500 and G600, Witkowski and his team once again faced the ever-present challenge of conforming inspections of vendor-supplied parts and components. The problem isn’t the actual inspection, but it is the time needed to send an inspector airworthiness representative (IAR) to the vendor’s location to perform a detailed conformity inspection of the part. This ensures that the part conforms to the engineering drawings and specifications, that it is exactly what the OEM specified, and that it meets all the requirements for FAA certification. Sometimes conformity inspections can involve more than one inspection event for a particular item. And the inspections must be done at the point of manufacture, Witkowski explained. The costs and time involved in this process can be enormous.
Remote Inspection Trials
What if, Witkowski wondered, the conformity inspection could be done using live video at the vendor location, viewed by the IAR back at Gulfstream’s headquarters in Savannah, Georgia? He set out to prove that this could be done safely and efficiently.
The proof took the form of two double-blind tests, comparing a traditional live conformity inspection with what came to be known as a virtual presence conformity (VPC) inspection where the IAR did the work remotely. These tests, done in sterile environments, were run twice and the results compared to ensure that they delivered exactly the same results. Witkowski then wrote a white paper to describe the tests and the results. During the second test, FAA personnel observed the action.
Gulfstream selected Onsight software developed by Librestream Technologies for transmission and management of the live video. The software works with any type of hardware and operating system, such as Apple and Android tablets and various types of computers. Gulfstream elected to use cellular networks for data transmission because this is far more secure than Wi-Fi networks.
The video and audio from the VPC process is not stored because such a recording is not part of the normal conformity process. Conformity requires filling out certain FAA forms, such as the statement of conformity. “That’s the record,” Witkowski explained. “You don’t record what you physically did.” And that is why it isn’t necessary to save the video from the VPC.
The FAA clearly found that VPC works and approved the process in a remarkably short 90 days, in August 2017. Since then, Gulfstream has used VPS to conform 700 different parts.
The next step was to prove that remote inspection works for maintenance inspections. Another set of tests was run and witnessed by FAA Flight Standards personnel during a window change on a Gulfstream airframe, along with some other activities.
An interesting result of the window inspection was that the virtual inspection proved that this process could be better than an on-site inspection.
When replacing a window, a step in the process is an “okay to proceed” inspection after the old window is removed. This step is important because the inspector and technician need to determine if there is any damage that needs to be repaired before installing the new window. There are other steps that a quality control inspector must sign off on before the work can proceed, for example, after the fasteners are torqued and marked with torque stripe paint.
As anyone who has inspected aircraft knows, some areas are difficult if not impossible to see without radical contortions or the aid of special equipment such as borescopes. During the window virtual inspection, Witkowski said, they found that the inspector could do a much more comprehensive inspection using the video equipment than they could with normal inspection processes.
“During a window change, you have a hard time getting your head in there,” he said. “But you can get a phone in there [to shoot video].”
The FAA signed off on Gulfstream’s maintenance virtual inspection process in December 2018. Next, Gulfstream is working on using the remote witnessing process for engineering test witnessing, for example, for burn testing interior materials, as well as to aid in troubleshooting problems where a supplier needs to be involved. Doing this all remotely offers big opportunities to save on costs.
The cost savings aspect is interesting because it doesn’t just mean saving on travel expenses. A quality inspector has to be available for multiple jobs, and even when performing inspections in one service center, could be far more efficient doing these inspections remotely via video. In many cases, an inspector isn’t available, for example, when a technician is fixing an aircraft away from home base. A remotely based inspector could save the day and help get the airplane back in the air quickly.
Witkowski acknowledged that a company like Gulfstream could save a lot of money using virtual inspection, and the company does track these savings but doesn’t wish to reveal the precise amount. However, on travel costs for conformity inspections alone, Gulfstream has already saved $80,000. “That doesn’t even begin to represent schedule savings,” he said, referring to the time saved on conformity inspecting required in the development of a new jet. A real benefit of VPC is removing the risks involved with travel, that an inspector could be delayed due to weather or other problems. Designees such as DARs and IARs are also scarce, and sending them hither and yon is not the best use of their valuable time.
Gulfstream is not keeping remote witnessing and virtual inspection to itself and is sharing the processes with industry. Gulfstream president Mark Burns, Witkowski said, “challenged employees to advocate for the industry.”
When Witkowski first started discussing this with the FAA, he suggested that industry partners could help draft a policy statement that companies could use until the advisory circular takes effect. He enlisted the help of the Aeronautical Repair Station Association’s executive director Sarah MacLeod as well as 15 other associations and companies, including Boeing and Moog. “Sarah was helpful on developing this and bringing everyone together,” he said.
The FAA helped by sending a letter confirming the legality of remote witnessing and virtual inspection and supporting the development of the policy statement and ultimately the circular. There is no FAA regulation prohibiting these processes, but gaining FAA support via an advisory circular helps companies that want to implement the processes understand the best practices they can use when implementing new methods of doing their work.
“Collectively we can get something together that benefits all of this industry,” Witkowski said. “This has whet lot of peoples’ appetites. [Especially] for maintenance purposes, small and big companies will have a benefit.”