Improved Surveillance Needed Over Production Of Critical Parts For Civil Aircraft B 76449717) Federal Awatlon Admtnlstratlon Department of Transportation BY THE COMPTROLLER GENERAL - OF THE UNITED STATES L ” * COMPTROLLER GENERAL OF THE UNITED STATES WASHINGTON D C 20548 B- 164497( 1) To the President of the Senate and the Speaker of the House of Representatives This 1s our report on the need for the Federal Avla- tlon Admmlstratlon, Department of Transportation, to lm- prove surveillance over production of crltlcal parts for clvll alrcraft The review was made pursuant to the Bud= get and Accounting Act, 1921 (31 U S C 53), and the AC- countmg and Auditing Act of 1950 (31 U S C 67) Copies of this report are bemg sent to the Director, Office of Management and Budget, the Secretary of Trans- portation, and the Admmlstrator, Federal Avlatlon Admmls tratlon Comptroller General of the United States - 5OTH ANNIVERSARY 1921- 1971 - Contents Page DIGEST 1 CHAPTER 1 INTRODUCTION 4 2 IMPROVED SURVEILLANCE NEEDED OVER PRODUCTION OF CRITICAL PARTS FOR CIVIL AIRCRAFT 7 Expanded productlon surverllance needed for crltlcal alrcraft parts 8 Quality control systems approach would benefit expanded production survell- lance 11 Agency comments and our evaluations and conclusrons 14 Recommendatron to the Admlnrstrator 16 3 SCOPE OF REVIEW 17 APPENDIX I Letter dated September 28, 1970, from the Department of Transportation to the Gen- eral Accounting Office 21 II Principal officials of the Department of Transportation responsrble for the ad- mrnlstratron of activities discussed in this report 24 ABBREVIATIONS FAA Federal Avlatron Admlnlstratlon GAO General Accounting Office PC production certificate COMPTROLLERGENERAL'S IMPROVED SURVEILLANCE NEEDED OVER I REPORTTO THE CONGRESS PRODUCTION OF CRITICAL PARTS FOR CIVIL AIRCRAFT I Federal Aviation Admlnlstratlon Department of Transportation B-164497(1) I I DIGEST ------ WHYTHE REVIEW WASMADE The Federal Aviation Admlnlstratlon (FAA) 1s required to prescribe l standards, rules, and regulations to promote flight safety of clvll I aircraft. Toward this end FAA promulgates standards governing air- I craft design, materials, workmanship, construction, and performance. I It also provides surveillance over manufacturers which it certificates I I as capable of producing aircraft, parts, and equipment. These manu- I facturers are commonly referred to as production certificate holders I I I The General Accounting Offlce (GAO) reviewed this surveillance pro- gram because of the program's significance in assuring flight safety I I of civil alrcraft I I I I FINDINGS AND CONC'LUSIONS i I Certain parts critical to the flight safety of clvll aircraft, which I are furnished by suppliers to aircraft manufacturers, aIrline com- I I panies, and other aircraft owners, generally are not subJected to pro- I duction surveillance by FAA or by the production certificate holders The parts not presently under surveillance are known as proprietary parts because neither FAA nor the certificate holders have design con- trol over them, and inspection ordinarily 1s restricted to verlflca- tion, at receiving points, that they function properly (See p. 8.) I FAA officials in Washington had been aware of this lack of surveillance but had not determined the scope or magnitude of the problem. They in- dicated that some critical aircraft parts classified as proprietary parts, previously not subJect to production surveillance, were under production surveillance at the time of GAO's review. In these instances the parts had been placed under surveillance subse- quent to the occurrence of an aircraft accident or incident that had been caused by the malfunction of the part One accident had been fa- tal to the pilot of the aircraft. (See p, 10 ) In October 1967, FAA in-r-t-rated a comprehensive program to reexamine, on a one-time basis3 the overall quality control systems of production Tear Sheet I I l - c I I certlflcate holders The reexam7natlon, however, d7d not Include I I proprietary parts not previously under FAA surveillance. (See p. 7.) I I I In April 1970, shortly before GAO completed its review, the Aerospace I Industries Association of America, Inc ) agreed to undertake, at FAA's I suggestion, a study to evaluate on a natlonal basis the control over : critical proprietary parts An FAA official stated that the assocla- tlon's study would be completed by the spring of 1971. (See p, 10.) I I i Under the FAA's existing program fan* productlon surveillances a number of standard conformity inspections are made covering numerous manufactur- I lng control areas, such as heat treatment, laboratory testing, and I I metal surface treatment. The FAA program provides comparable levels I of production surveillance over the manufacturing activities of both I I production certificate holders and their suppliers, except for manufac- I turing of proprietary parts I Surveillance coverage under this program 1s llmlted by the avallabll- ; lty and location of FAA lnspectlon staffs and the continued increase I I in the number of manufacturing fac7'llQes subJect to surveillance. I (Seep 11) One of the FAA regional offices has proposed that the production sur- I veillance be dlrected or llmlted on the basis of an evaluation of the I adequacy of manufacturers' quality control systems over critical air- I craft parts GAO believes that the proposed system could provide the I I expanded production surveillance capability necessary to cover critical I aircraft parts, such as proprietary parts, that do not now receive such I I coverage by FAA or by the production certificate holders. (See p. 12 ) I I I RECOMMENDATIONS OR SUGGESTIONS I I The Administrator of FAA should provide for I I --Immediate action to ensure that all critical proprietary aircraft I parts are subJected to production surveillance by either FAA or I I the responsible production certificate holders. (See p. 14 ) I I --Modlflcatlon of the existing production surveillance program to pro* vlde for greater reliance upon the adequacy of production certlfi- I cate holders' quality control systems as the basis for directing I I or limiting FAA surveillance over production operations. I I I AGENCYACTi-ONSAND UNRESOLVEDISSUES I I The Department of Transportation advlsed GAO that it was aware of the I problems noted by GAO during its review The Department advised GAO I I I I I I I 2 I I I ! that, upon completion in July 1971 of its overall revlew currently In process, specific procedures will be established to ensure that all critical proprietary aircraft parts will be subJected to production surveillance and that FAA plans to place greater reliance on the ade- quacy of production certificate holders' quality control systems. The actions planned by the Department, if effectively Implemented, should improve the surveillance over the production of aircraft and related aircraft parts (See p. 14 ) GAO believes, however, that, sfnce the Department IS aware that the production of certain parts cntlcal to alrworthlness of aircraft IS not now under surveillance and since in the past similar parts have contributed to accidents and incidents, prompt action should be taken to bring the production of such parts under surveillance MATTERSFOR COiUSIDERflTIONBY TBE CONGRESS This report IS being issued to advise the Congress of the need for lmmedlate measures by FAA to implement production surveillance over cntlcal proprietary aircraft parts and of the corrective action being taken by FAA Tear Sheet 3 COMPTROLLERGENERAL'S IMPROVED SURVEILLANCE NEEDEDOVER REPORTTO THE CONGRESS PRODUCTION OF CRITICAL PARTS FOR CIVIL AIRCRAFT Federal Avlat~on Admlnistratlon Department of Transportation B-164497(1) DIGEST ------ WHYTHE REVIEW WASMADE The Federal Aviation AdminIstratIon (FAA) IS required to prescribe standards, rules, and regulations to promote flight safety of clvll aircraft. Toward this end FAA promulgates standards governing air- craft design, materials, workmanship, construction, and performance. It also provides surveillance over manufacturers which It certlflcates as capable of producing aircraft, parts, and equipment. These manu- facturers are commonly referred to as production certjflcate holders. The General Accounting Office (GAO) reviewed this surveillance pro- gram because of the program's slgnlflcance in assuring flight safety of civil aircraft FINDINGS AND CONCLUSIONS Certain parts critical to the flight safety of clv11 aircraft, which are furnished by suppliers to aircraft manufacturers, airline com- panies, and other aircraft owners, generally are not subJected to pro- duction surveillance by FAA or by the production certificate holders. The parts not presently under surveillance are known as proprietary parts because neither FAA nor the certlflcate holders have design con- trol over them, and Inspection ordlnanly IS restricted to verifica- tion, at receiving points, that they function properly. (See p. 8 ) FAA offlclals in Washington had been aware of this lack of surveillance but had not determined the scope or magnitude of the problem. They In- dicated that some crltlcal aircraft parts classified as proprietary parts, previously not sUbJeCt to production surveillance, were under production surveillance at the time of GAO's review In these Instances the parts had been placed under surveillance subse- quent to the occurrence of an alrcraft accident or Incident that had been caused by the malfunction of the part One accident had been fa- tal to the pilot of the aircraft (See p. 10 ) In October 1967, FAA lnltlated a comprehensive program to reexamine, on a one-time basis, the overall quality control systems of production 1 certificate holders The ueexamlnation, however, did not Include proprietary parts not previously under FAA surveillance. (See p. 7 ) In April 1970, shortly before GAO completed its review, the Aerospace Industries Assoclatlon of America, Inc , agreed to undertake, at FAA's suggestion, a study to evaluate on a national basis the control over critical proprietary parts. An FAA off-rclal stated that the assocla- tlon's study would be completed by the spring of 1971. (See p, 10.) Under the FAA's existing program for production surveillance, a number of standard conformity InspectTons are made covering numerous manufactur- ing control areas ) such as heat treatment, laboratory testing, and metal surface treatment. The FAA program provides comparable levels of production surveillance over the manufacturing activities of both product-ron certlflcate holders and their suppliers, except for manufac- turing of proprietary parts Surveillance coverage under this program IS llmlted by the avallabll- Ity and location of FAA inspection staffs and the continued increase in the number of manufacturing facilities subJect to surveillance. (Seep 11) One of the FAA regional offlces has proposed that the productton sur- veillance be directed or limited on the basis of an evaluation of the adequacy of manufacturers* quality control systems over crltlcal air- craft parts GAO believes that the proposed system could provide the expanded production surveillance capablllty necessary to cover crrtical aircraft parts, such as proprietary parts, that do not now receive such coverage by FAA or by the production certificate holders. (See p. 12 ) RECOMMENDATIONS OR SUGGESTIONS The Admlnlstrator of FAA should provide for --Immediate action to ensure that all critical proprietary aircraft parts are subJected to production surveillance by eTther FAA or the responsible production certlflcate holders. (See p. 14 ) --Modlflcatlon of the existing production surveillance program to pro- vtde for greater reliance upon the adequacy of production certlfl- cate holders' quality control systems as the basis for directing or limittng FAA surveillance over productIon operations. AGENCYACTIONS AND UNRESOLVEDISSUES The Department of Transportation advlsed GAO that it was aware of the problems noted by GAO during tts revJew. The Department advised GAO 2 that, upon completion in July 1971 of its overall review currently In process, speclflc procedures ~111 be established to ensure that all critical proprietary aircraft parts ~111 be subJected to production surveillance and that FAA plans to place greater reliance on the ade- quacy of production certificate holders' quality control systems. The actions planned by the Department, if effectively implemented, should improve the surveillance over the productIon of aircraft and related aircraft parts. (See p. 14.) GAO believes, however, that, since the Department IS aware that the production of certain parts cntlcal to airworthiness of aircraft 1s not now under surveillance and since in the past similar parts have contributed to accidents and incidents, prompt action should be taken to bring the production of such parts under surveillance. MATTERSFOR CONSIDERATIONBY THE CONGRESS This report IS being Issued to advise the Congress of the need for lmmedlate measures by FAA to implement production surveillance over critical proprietary alrcraft parts and of the corrective actlon being taken by FAA 3 CHAPTRRl INTRODUCTION The General Accounting Offlce has reviewed the Federal Aviation Admlnlstratlon's surveillance program concerning the production of parts for civil aircraft. Cur review evaluated the effectiveness of the existing production sur- veillance program In meeting FAA objectives for air safety. We did not make an overall evaluation of all aircraft cer- tiflcatlon programs, nor drd we make any determinations con- cerning the airworthiness of aircraft affected by the sur- veillance program. The scope of our review is discussed on page 17. The Federal Aviation Act of 1958, as amended (49 U.S.C. 14211, authorizes the FAA Administrator to prescribe mini- mum standards, rules, and regulations to promote safety of flight of ~1~x1 aircraft. To accomplish thrs objective with respect to the auworthiness of aircraft, FAA pre- scribes minimum standards governing aircraft design, mate- reals, workmanship, construction, and performance and pro- vides surveillance over manufacturers engaged in the produc- tion of aircraft and/or related aircraft parts and eqyuip- ment Responsiblllty for the aircraft certificatzon program has been delegated by the Administrator to the eight FAA regional offices, five of which are within the continental United States where almost all Jet transports that must be approved as airworthy by FAA are manufactured In the re- gional offices the responsibility for this program has been assigned, in most cases, to the Flight Standards Dlvlslon. Under the aircraft certlficatlon programs, FAA issues three categories of certificates; they are (1) type cer- tificates, which are normally issued to manufacturers for new aircraft, aircraft engines, and propellers after FAA determines that the parts included in these items are of proper design and material and that the parts meet FAA specifications for safe operation; (2) production certifi- cates, which are discussed below; and (3) airworthiness certificates, which attest to the fact that an aircraft 4 conforms to the approved type design (type certificate) and is In condition for safe operation. The production certification program LS intended to provide approval of and confxnued surveillance over manu- facturers' facilities for duplicating aircraft parts that have been included in aircraft, aircraft engines, or pro- pellers previously type-certificated by FAA. Under this program FAA issues production certlfrcates to manufacturers that intend to produce in volume a part to be included in type-certificated aircraft, aircraft engines, or propellers after the manufacturers' facilities, methods, personnel, and procedures are found by FM to be adequate to duplicate such parts. In addition FM provides continual surveillance over these manufacturers and their suppliers In order to review the quality control maintained by the manufacturers of these parts. The actual surveillance work is performed by FAA manufacturing inspectors generally located In Engl- neerlng and Manufacturing District Offices within a re- gion's geographic area of responsibility In the past FAA relied mainly on two methods of sur- veillance over production certificate holders and their suppliers-- surveillance by FAA triennial Production Certl- flcatlon Boards and by Manufacturing Control Area Surveys TriennialBoardsusually are comprised of several FAA inspection teams, supervisory inspectors, and the Chief of the region's Engineering and Manufacturing Branch who is Chairman of the Board The Boards are convened periodi- cally to determine whether manufacturers that have been issued production certlfxates have continued to comply with FAA's certification rules and are eligible to retain their production certificates The Boards are responsible for making broad reviews of manufacturers' quality assur- ance efforts rather than comprehensive in-depth investiga- tions of the manufacturers' production processes The Control Area Survey system is used to determine whether the production certificate holders and their sup- pliers are complying with specifrcatlons and procedures that have been approved by FAA The system functions as a periodic recheck of the systems and procedures of manufac- turers in the interim period between triennial Board 5 meetings --at which time the manufacturers' quality control systems are subject to reapproval. Under the Control Area Survey system, the facilities of prime manufacturers and their suppliers are divided into manufacturing control areas on a functional basis, such as heat treatment, metal surface treatment, and laboratory testing. FAA inspectors try to visit manufacturers' and suppliers' plants at least annually and try to make, at that time, inspections of as many materials, parts, ap- pliances, and assemblies as possible to assure their con- formity with originally approved items L Conformity inspections are made by FAA to ensure that aircraft parts passing through critical manufacturing pro- cesses conform to FAA-approved processing standards or specifications for the parts. To accomplish this obJec- tive, FAA inspectors apply a series of tests and procedures deemed appropriate for the particular parts. In fiscal year 1968, FAA initiated, on a one-time ba- sis, the reexamination of production certificate holders' quality control of products considered by the FAA to be critical to the airworthiness of aircraft. FAA designated this reexamination a "critical characteristics audit" and assigned the responsibility for the reexamination to its regional offices The objectives, as stated in an FAA order, were (1) to reexamine, on a one-time basis, all FM- approved manufacturer quality control systems (practices and procedures) that affected the critical characteristics of parts to determine whether parts with critical defects could go undetected through manufacturers' systems and (2) to prepare a report on the results of the reexamination, including any appropriate recommendations for corrective action As of November 30, 1970, FAA Washington headquar- ters had received most of the region reports and expected to complete a review of the results of the critical char- acteristics audits by July 1971. The principal officials of the Department of Transpor- tation responsible for the administration of activities discussed rn this report are listed in appendix II CHAPTER 2 IMPROVED SURVEILLANCE NEEDED OVER PRODUCTION OF CRITICAL PARTS FOR CIVIL AIRCRAFT FAA needs to rmprove the surveillance over the produc- tron of parts critical to the airworthiness of civil air- craft, because certain of these parts, referred to as pro- prietary parts, are not subJected to production surveillance. Although FAA had been aware, at the time of our review, of the lack of surveillance over critical proprietary parts, it had not acted to bring all such parts under surveillance. In some instances proprietary parts had been placed under productron surveillance, but only after the malfunctroning 1 of that part caused the occurrence of an accident or inci- dent. In one instance the accident had been fatal to the pilot of an aircraft. FAA's existing productron surveillance system is dr- rected primarily toward selected functional areas rather than toward the overall quality control systems of manufac- turers holding FAA production certificates. FAA's system coverage 1s limited, however, by the availability and loca- tion of Its lnspectlon staffs and by the contlnulng Increase in the number of manufacturing facilities that must be in- spected. In October 1967, FAA lnltiated a comprehensive program to reexamine, on a one-trme basis, the overall quality con- trol systems of production certlflcate holders, The pro- gram, however, did not provide for consrderation of crltr- cal proprietary aircraft parts. In May 1970, one FAA re- gion proposed that FAA's production surveillance system be directed or limited on the basis of overall evaluations of the adequacy of manufacturers' quality control systems over critical aircraft products. We believe that such a system could include surveillance over the production of many critical aircraft parts that are not currently being sub- Jetted to inspection by FAA or by the production certifi- cate holders. In vrew of the limrted number of FAA person- nel available for surveillance activities, we believe that FAA should place greater emphasis on requiring production certificate holders to maintain production surveillance over their suppliers. 7 EXPANDED PRODUCTION SURVEILLANCE NEEDED FOR CRITICAL AIRCRAFT PARTS We found that certain parts critical to the airworthi- ness of cavil arrcraft generally were not being subjected to production surveillance by FAA or by the production cer- tificate holders. FAA defines a critical arrcraft part as one that does not have a backup system and the failure of which could cause a fatal alrcraft accident. The critical parts not being subjected to production surveillance are off-shelf items which are purchased by production certificate holders from suppliers and which may be suitable for use in more than one type of aircraft. These parts are referred to as proprietary parts because neither FAA nor the production certificate holders have design control over them, and the suppliers are generally reluctant to permit surveillance over the production of these parts by FAA or by the production certificate holders. Under such circumstances, production certificate holders are limited to verifying the functional aspects of propri- etaryparts at the receiving lnspectlon points. Such parts may also be purchased by an aircraft owner directly from the supplier for use on his aircraft, in which case the parts would not be subJected to inspection by the production certlflcate holder or by the FAA prior to their use on the aircraft. We visited the facilities of a production certificate holder in FAA's Eastern Region to determine the nature and extent of proprietary parts that were not under production surveillance by either the cognizant FAA Engineerrng and Mknufa+urlng District Offlce or by the production certlfl- cate holder. Representatrves of this productron certificate holder provided us with a listing of 30 proprietary parts which they consxdered, for the most part, to be of a crit- ical nature and whrch were not under productron surveillance by the company or by FAA. Discussions with the cognizant FAA inspector confirmed that many of these parts were crrtl- cal to the operation of an aircraft. We obtained additional listings of critical proprietary parts from other drstrict offices in the Eastern Region. We were advised by Eastern Region officials that the 8 maJority of these parts were not subJected to either FAA's or the manufacturers' surveillance. Following are examples of these proprietary parts and a description of the effect that their failure or malfunction might have on the opera- tion of certain aircraft. Flexible propeller coupling used in the DC-7--Failure or malfunction could result in the loss of use of a propeller and engine power. Engine fuel valve used in DC-9 turbojet--Failure or mal- function could result in the loss of engine power and create a fire hazard. Flexible drive coupling for engine transmission assem- bly used in the FH-1100 helicopter--Failure or malfunc- tion could result in complete loss of power to drive the main rotor assembly. With respect to these and other proprietary parts not subJected to production surveillance, District Office offi- cials stated, in a memorandum to us, that tNalfunction and/or failure of the above noted parts, and the resultant propeller and/or engine malfunction, under certain conditions, could be catastrophic. *** It should be further noted that proprretary items can be ordered as replacement parts from the manufacturer of the item without going through the P.C. [production certificate] holders receiving inspection and functional test procedures." In February 1970, while our field review was in prog- ress, we discussed the need for expanded production surveil- lance over critical proprietary parts with an official in FAA's Washington headquarters. The official stated that there were probably a number of critical proprietary parts which were not under production surveillance by FAA but that he was unaware of the extent to which this condition existed. Subsequent to completion of our fieldwork, we discussed our findings with FAA officials in Washington who concurred 9 in the need for expanded productlon surveillance of crltlcal proprietary parts. The officials stated that there were some critical parts classlfled as proprretary parts, previously not subJect to production surveillance, that were later placed under productron surverllance by FAA. They stated that, In some instances, these parts had been placed under productIon surveillance subsequent to the occurrence of an aircraft. accident or lncrdent which had been caused by the malfunction of that part. The officials stated further that, in accordance with FAA's suggestion, the Aerospace Industrres Assoclatlon of America, Inc., had agreed In April 1970 to evaluate on a national basis the control over crrtical proprietary parts and that the results of the study would provide them with addltronal insight into the problem. According to an FAA official, the association's study had not been InItrated as of October 1970 but would be completed by the spring of 1971, 10 QUALITY CONTROL SYSTEMS APPROACH WOULD BENEFIT EXPANDED PRODUCTION SURVEILLANCE FAA's current policy is to subJect the manufacturing activities of both the production certificate holders and their suppliers to comparable levels of production survell- lance. To implement this policy, district offices are re- quired to maintain surveillance over the parts and processes of all suppliers with the exception of certain parts which are subjected to detailed inspection after receipt at pro- duction certificate holders' plants. In effect, FAA con- siders suppliers to be extensions of the production certifl- cate holders' facilities and exercises the same degree of surveillance over suppliers' facilities. In addition, pro- duction certificate holders are required by FAA to maintain adequate quality control systems over their own production operations and the production operations of their suppliers, Under the production certification program, FAA uti- lizes the triennial Production Certification Boards and Man- ufacturing Control Area Surveys to maintain surveillance over production certificate holders and their suppliers. Although FAA's existing system of production surveillance is intended to provide considerable inspection coverage, it is limited by the availability and location of inspection staffs and by the continuing increase in the number of manufactur- ing facilities subject to inspection. For example, at the district office with the largest staff in the Eastern Region, eight manufacturing inspectors are responsible for surveil- lance over facilities of eight manufacturers and 114 sup- pliers. One manufacturer has five separate large facilities in the district office's area of responsibility, numerous major part suppliers and process and service suppliers, and a vast number of small subcontractors throughout the Nation. The five remaining district offices in the Eastern Region have smaller staffs and also have comparatively heavy work loads. We noted that, as a result of a recent reexamination of the quality control systems of production certificate hold- ers, officials in FAA's Eastern Region concluded that one of the major failures of the existing production surveillance system was that it directed district office manpower toward accomplishing a number of standard conformity inspections, 11 such as those made under Control Area Surveys, rather than toward the adequacy of the production certificate holders' overall quality control system. The Eastern Region found In its reexamlnatlon that FAA inspectors, in certain cases, had overlooked entrre segments of a manufacturer's quality control system during past in- spections. For example, previous FAA lnspectlons did not disclose that one productloncertificateholder had not es- tablished procedures for qualifying or auditing surveillance over nondestructive testing, such as X-ray, and material process suppliers. In another case the Eastern Region found that the outside laboratories used by a productron certlfl- cate holder for analyzing and quallfylng raw material re- ceived from suppliers had never been Inspected. Adequacy of performance in each of the above areas materially affects the quality of aircraft products. These deflclencles in the manufacturers' quality con- trol systems should have been detected by FAA during trien- nlal Board reviews of the production certlflcate holders' facllltles and quality control systems. An Eastern Region offlclal stated, however, that In the 3 or 4 days during which these reviews were conducted the Boards made confor- mity lnspectlons to test the production certlflcate holders' lmplementatlon of their quality control systems. Due to the pressures of time, the Boards did not make a comprehensive evaluation of the manufacturers' quality control system but assumed that the quality control systems were In general conformance with FAA regulations because the systems were approved by FAA prior to lssulng the production certlflcates. Eastern Region officials, in a special report dated May 1970 on the existing surveillance system, recommended to Washington headquarters that the quality and coverage of surveillance over critical parts, wrthin available manpower limitations, would be improved by placing increased emphasis on overall evaluations of the production certificate holders' quality control systems as a basis for directing or limiting its production surveillance efforts. The FAA had not acted to implement the Eastern Region's recommendations at Decem- ber 1970. We are of the view that such evaluations could 12 provide needed surveillance over crItIca proprietary air- craft parts that are not Inspected by FAA or by the produc- tlon certificate holders. 13 AGENCY COMMENTS AND OUR EVALUATIONS AND CONCLUSIONS In a draft of this report submltted to the Secretary of Transportation for comment, we proposed that the FAA Ad- minlstrator take appropriate action to ensure that all crlt- lcal proprietary arrcraft parts are subJected to production surveillance by either FAA or by the responsible production certificate holders. We proposed also that the Adminlstra- tor modify the existing production surveillance program to provide for greater reliance upon the adequacy of productlon certificate holders' quality control systems as the basis for directing or limiting FAA's surveillance over both pro- duction certificate holders' and suppliers' production operations. In commenting on our proposals, by letter dated Sep- tember 28, 1970 (see app, I>, the Acting AssIstant Secretary for Admlnistratlon, Department of Transportation, acknowl- edged the existence of the problems discussed in our report. He stated that FAA recognized the need to assure that the production certificate holders' quality control systems would extend to all suppliers of parts that would be incor- porated into a product and, as a result, inltlated the crlt- ical characterlstlcs audit program in October 1967. Fur- thermore, he said that FAA's Eastern Region was selected In 1968 to study the overall program and to submit recommenda- tions for improvements in the production and surveillance system. He further stated that: "Upon completion of our review of both the CCA [critical characteristics audit] and the Eastern Region proposal, specific procedures will be es- tablished to ensure that all critical proprietary aircraft parts will be subJect to production sur- veillance and that greater reliance will be placed on the adequacy of PC holders' quality control systems. We expect to complete our re- view by July 1971." The action planned by the Department, if effectively implemented,should rmprove the surveillance over the pro- duction of aircraft and related aircraft parts. 14 Regarding the Eastern Region's study of FAA's produc- tlon surveillance system, we noted that Its report, which mentioned proprietary parts as an area needing attention, was presented to Washington headquarters informally in Octo- ber 1969 and again formally in May 1970. It was not until July 1970 after receiving our draft proposals, however, that the Dlrector, Flight Standards Service, appointed a task force to accelerate the development of a new surveillance system intended to include proprretary parts. During December 1970, FAA Washington headquarters was In the process of reviewing the results of the critical characterlstlcs audit which had been received and the East- ern Region's report on the production surveillance system. Generally, the Eastern Region did not include crltlcal proprietary alrcraft parts under the critical characterls- tics audit. Also, a FAA Southwestern Region offlclal, in reporting on the final results of the critical characterls- tics audits in September 1970, stated that. "The real shortcoming of the program was the fact that It did not take into account all critical parts. I refer specifically to the parts clas- sified as proprietary items. In our present modern-day aircraft, many of the most critIca items are proprietary and from all lndlcatlons It appears they will continue to be Ignored, only to remain as the topic of a now and then conversa- tion that every one agrees something should be done about but never quite gets done." We believe that, since the Department has been aware for some time that certain parts crltlcal to the alrworthl- ness of aircraft are not under production surveillance and that, In the past, slmllar parts have contributed to or caused accidents, action should have been taken to bring such parts under FAA or production certificate holder sur- veillance. We believe that such action should be taken as soon as possible and should not be delayed further while the crltlcal characterlstlcs audits are being reviewed and revlslons of exlstlng surveillance procedures are being completed. 15 RECOMMENDATION TO THE ADMINISTRATOR Accordmgly, we recommend that FAA Issue, as soon as possible, rnstructlons requlrmg that crltxal proprietary aircraft parts be subJect to production surveillance by el- ther FAA personnel or by production certlflcate holders. 16 CHAPTER 3 SCOPE OF REVIEW Our review included an evaluation of selected aspects of FAA's production certification program and was directed toward determining whether these aspects were meeting FAA objectives for air safety. We conducted our review at FAA headquarters in Washington, D.C.; at the FAA Regional Office in New York, New York; and at selected FAA engineering and manufacturing district offices within that region. We examined pertinent laws, regulations, policies, pro- cedures, correspondence, inspection reports, and other re- lated documents. We discussed matters pertinent to our re- view with FM headquarters and Eastern Regional Office of- ficials. We also held discussions with representatives of the aircraft manufacturers and the parts suppliers located within the geographic area of responsibility of one district office concerning the production surveillance over critical proprietary parts. 17 APPENDIXES 19 APPENDIX I Page 1 OFFICE OF THE SECRETARY OF TRANSPORTATION WASHINGTON, D C 20590 ASSISTANT SECRETARY FOR ADMINISTRATION September 28, 1970 Mr. Bernard Sacks AssIstant Dlrector Clvll Dlvlslon General Accounting Office Washington, D C. 20548 Dear Mr Sacks This 1s In reply to your request for comments on the draft report concerning Improved Surveillance Needed Over Pro- duction of Critical Parts for Civil Aircraft, Federal Aviation Admlnlstratlon (FAA). In this report you conclude that FAA needs to improve surveillance over the production of parts which are critical to the alrworthlness of clvll aircraft In that (1) certain of these crltlcal Items are not presently subJected to production surveillance and (2) the current surveillance system tends to focus on selected functional areas, rather than on the overall quality control system of manufacturers with FAA production certlflcates (PC). Accord- ingly, you recommend that the FM Admlnlstrator (1) ensure that all critical proprietary aircraft parts are subJected to production surveillance by either FAA or the responsible PC holder and (2) place greater reliance upon the adequacy of the PC holders' quality control system as a basis for directing or llmltlng FAA's surveillance over PC holders' and suppliers' productlon operations. Our own awareness of the problems noted by your report led us to take certain steps to improve our surveillance system. The FAA has put considerable effort rnto revising agency procedures for surveillance over aircraft parts, and In expediting the development of a more complete systems approach which will ensure that all crltlcal proprietary parts will be sublect to appropriate production surveillance and that greater reliance will be placed on the adequacy of the manufacturer's quality control system APPENDIX I Page 2 In the past, the FAA’s method of assuring the alrworthlness of alrcraft provided for an evaluation of the adequacy of the PC holder’s quality control system used in the production of clvll aircraft (lncludlng any purchases from the supplIers) and was supplemented by spot checkrng the effectiveness of the system With the growth and increased complexity of the aircraft pro- duction system, the FAA recognized the need to evaluate Its own surveillance system in an effort to increase its effec- tlveness, One of the main problems recognized was the need to assure that the PC holder’s quality control system would extend to all suppliers of parts that would be incorporated into the product As a result, the agency lnltlated the Crltlcal Characterlstlcs Audit (CCA) program in October 1967 to reexamine, on a one-time basis, those systems and procedures being used to control the quality of the crltlcal aircraft parts, installations, and procedures. This program, which 1s currently In Its final stages, placed emphasis on the evalua- tion of the manufactldrer’s quality control system The FAA 1s presently studying the results of the CCA program as a basis for improving Its existing surveillance program In conJunctlon with the CCA program, the FAA’s Eastern Region was selected In 1968 to study the overall program and submit recommendations for improvement In the production approval and surveillance system. The region has submitted a proposal and this report 1s presently under conslderatlon at the Washlngton headquarters Upon completion of our review of both the CCA and the Eastern Region proposal, speclflc procedures will be establlshed to ensure that all critical proprietary alrcraft parts will be subject to production surveillance and that greater reliance will be placed on the adequacy of PC holders’ quality control sys terns We expect to complete our review by July 1971, Making improvements In avlatlon safety 1s an ongoing actlvlty with the FAA As aircraft become more numerous and complex and performance Increases, we have to change our techniques and procedures. The changes are themselves complex and require mature conslderatlon before adoptlon Often the development and lnstallatlon cycle must extend over several years Such 1s the sltuatlon In this area in which a change has been In process since 1967 and IS now near completion 22 APPENDIX I Page 3 We appreciate the opportunity to comment on your draft report Sincerely, Actmg Assls tant Secretary 23 APPENDIX II PRINCIPAL OFFICIALS OF THE DEPARTMENT OF TRANSPORTATION RESPONSIBLE FOR THE AD?IIINISTRATION OF ACTIVITIES DISCUSSED IN THIS REPORT Tenure of offxe From To DEPARTMENT OF TRANSPORTATION SECRETARY OF TRANSPORTATION. John A. Volpe Jan. 1969 Present Alan S. Boyd Jan. 1967 Dec. 1968 FEDERAL AVIATION ADMINISTRATION ADMINISTRATOR: John H. Shaffer Mar. 1969 Present David D. Thomas (acting) Aug. 1968 Mar. 1969 Gen. Wllllam F. McKee July 1965 July 1968 ASSOCIATE ADMINISTRATOR FOR OPERATIONS: George S. Moore Apr. 1967 Present Arvln 0. Basnlght July 1965 Apr. 1967 DIRECTOR, FLIGHT STANDARDS SER- VICE: James F. Rudolph Oct. 1967 Present James F. Rudolph (acting) June 1967 Oct. 1967 Clifford W. Walker Apr. 1966 June 1967 George S. Moore Apr. 1963 Apr. 1966 U S GAO, Wash , D C 24
Improved Surveillance Needed Over Production of Critical Parts for Civil Aircraft
Published by the Government Accountability Office on 1971-02-25.
Below is a raw (and likely hideous) rendition of the original report. (PDF)