What are Streamlining Processes?

This blog is a little different from my past ones. I was invited to participate in the “Streamlining Assurance Processes Workshop” (which internally we called the “Meta Objectives working group”). The idea behind this was to provide an “alternative means of compliance” to DO-254DO-178C, and ARP 4754A, such that at all levels of development, any team on any project at any level of design could demonstrate compliance to a consistent set of development assurance objectives. (Of course, the activities associated with meeting those objectives would vary depending on the program and level of design).

After three meetings, several web meetings, online commenting and much heated discussion, the committee came up with three Overarching Properties that should be met at any/all levels of design. Each Overarching Property contains the following:

  • statement capturing the property
  • definition
  • pre-requisites
  • constraints
  • assumptions.

That’s about all I can say about it in this forum as its being officially rolled out at the upcoming FAA Streamlining Assurance Workshop (being held September 13 -15, 2016).

Tammy Reeve has been involved in the certification of hardware (DO-254), software (DO-178C), and systems (ARP 4754A and related) for nearly 20 years.

Tammy Reeve
DER/Founder
Patmos Engineering Services, Inc.

NOTE: See below for notes from this event, which were added after this blog was first published.

If you’d like help understanding more about how to adopt streamlining processes in your program, Patmos Engineering Services offers custom consulting to assist you with your program. We can provide a package of training, guidance and/or auditing that can assist you at every step of your program.

FAA Streamlining Assurance Processes Workshop

What follows is a recap of what was presented to introduce this topic at this workshop. For further information, please contact the author himself or the FAA.

Streamlining Framework

Peter Skaves, Chief Scientist AEH, Security FAA
Peter covered a variety of topics at a high level, foreshadowing the contents of the conference. He mentioned that “streamlining” has been a goal and theme for 20-25 years, but has a newfound focus. The FAA, working with other authorities, is trying to 1) Reduce duplicate approvals across the authorities, 2) Reduce number of audits and stages of involvement, 3) Allow meeting of “Meta Objectives” (uniting objectives for 178C, 254 and ARP 4754A), 4) Use a risk-based approach when creating new policy for SW/HW/Systems.

In terms of the “risk-based” approach, this means doing things that prevent accidents – identifying areas where there have been systematic design escapes and focusing there (potentially relaxing other areas). So they are trying to use this rationale when modifying documents and guidance material. For example, up until five years ago, the focus was on software and hardware, with little policy at the system level. There were escapes in software and hardware, but these sorts of problems would have showed themselves earlier in the systems development process. Thus the need and invocation of ARP 4754A.

He discussed different aircraft types, with potentially different criteria for each type.
One of the more interesting things he discussed was the notion of new “00” advisory circulars. These will be published to provide examples and what was previously considered “prescriptive” guidance. (These were referred to later frequently, as an example of where some info currently in Order 8110.105 may move).

He mentioned streamlining SOI audits for software (which was covered in a later session in more detail).

He also talked about two types of focus for AEH: Programmable (custom microcoded components) and COTS. He talked about the questions and challenges surrounding COTS and how/where to address these concerns.

He then spent time talking about the effort to harmonize with EASA on AC 20-152(A), which has been in the works for a while, while getting rid of Issue Papers and Orders and putting content in ACs where they belong.

Tool Controlled Artifacts and Evidence

Section 7 of DO-254 tells us “The configuration management process is intended to provide the ability to consistently replicate the configuration item, regenerate the information if necessary and modify the configuration item in a controlled fashion if modification is necessary.” What do you do if you are using a tool to control some or all of your program data? This is becoming more and more common as the industry has delivered a number of tools that assist with various aspects of DO-254 (and DO-178C) compliance. This automation may be extremely helpful in many cases, but it introduces a new paradigm of tool based data control that requires understanding and exploration.

The inside scoop on what to do and what not to do in your DO-254 program, direct from the expert.

For example, you may have a tool that helps you with compliance by including checklists for various processes. These checklists might be modifiable, they must be reviewed by a team, actions may come from the review, and these actions need to be tracked. This is all done within the tool and all that data needs to be controlled and available, and subject to the pertinent requirements for Life Cycle Data (DO-254 Section 10.0 and DO-178C Section 11.0). So do we meet the content/retention requirements if the artifacts remain embedded in the tool? Or what if you are using Clearcase and you just have a path to a Version Based Object (VOB) for some compliance artifact? Does that meet data configuration and control requirements for that artifact? And what if your auditor doesn’t have access to the tool?

The underlying concern of the DO-254 configuration management requirements are to ensure that the data is always available and always modifiable. So you must ensure this happens even if the tool is not used again in the future. Because of the obligation to continued airworthiness, the applicant must maintain the data for the lifetime that the product flies. This may be far longer than a tool lifetime. Therefore long-term (20+ year) archive/data recovery is the responsibility of tool user, who must be able to extract, archive and potentially resurrect this data for their project. So ensure that whatever tool you are using allows you to do this, that you capture this as part of your plans and execute appropriately as part of your program.

If you need help understanding how to manage tools in your program, this is covered in the Patmos Engineering Services “DO-254 Airborne Electronic Hardware Certification” training.

Tammy Reeve has been involved in the certification of hardware (DO-254), software (DO-178C), and systems (ARP 4754A and related) for nearly 20 years.

Tammy Reeve
DER/Founder
Patmos Engineering Services, Inc.

The Implications of Order 8110.105A

The regulatory world is in constant flux. This is due to ongoing change in technology as well as advancement and better understanding of safety related aspects for aviation. You might think that the authorities have free reign over this policy. But in reality, industry has a voice with regard to the oversight and regulatory process through FAA public comment, lobbying with congress, and regulatory committee participation. Many of the changes we’re seeing in new policy is due to industry.

The newly published FAA order 8110.105A, which provides guidance to the FAA, DERs and ODAs for regulatory information surrounding DO-254, is just one of the changes in regulatory compliance coming from the FAA. FAA Order 8110.105A is written to supplement RTCA/DO-254, and to provide additional guidance in approval of both simple and complex custom micro-coded components. Here is a summary of the main changes:

  • It removes Chapter 3 “Determining FAA Involvement in Hardware Projects”, and all references to the FAA Airborne Hardware Job Aid. These changes were made due to industry pressure to allow for a more flexible approach for conducting FAA oversite reviews such as Stage of Involvement audits (SOIs).
  • Chapter 2 “SEH/CEH Review Process” was restructured and removes references to the SOI #1-#4 audits and job aid.
  • Newly added Appendix C “Level of Involvement Worksheets” contains the worksheets for determining the Level of FAA involvement (LOFI), which is aligned with the FAA risk-based directives in Order 8040.4A.

These changes allow for a less prescriptive method for involvement for FAA, DER and ODA personnel. However, coordination and agreement on the appropriate level of involvement should be documented in the PHAC and submitted early in the program to ensure sufficient oversight and to avoid issues later. It is a good idea to review the LOFI worksheet in Appendix C of this Order, together with your FAA or ODA representative, and to include this evaluation in the appendix of your PHAC to show justification for the level of involvement reviews and schedule defined in your plan.

If you need help understanding the latest requirements of DO-254 (or DO-178C for that matter), check out the offerings of Patmos Engineering Services. We can consult with you in a number of different ways to assist you in jump starting your program.

Tammy Reeve has been involved in the certification of hardware (DO-254), software (DO-178C), and systems (ARP 4754A and related) for nearly 20 years.

Tammy Reeve
DER/Founder
Patmos Engineering Services, Inc.