Wild West approach to allow new products such as autonomous cars to build up a market even before there is a market and keep governments at bay. Remotely piloted drones are a precursor to fully autonomous drones, which are already being tested. I challenge anyone to convince me that we have overregulated either of these products. Both areas require MORE scrutiny by new technically- savvy eyes and not less due to safety concerns.


TECHNOLOGY SHIFTS The problem for new products or ones that depend upon new technologies which are safety critical such as a passenger aircraft is not enough regulation. And perhaps regulation is the wrong term, and this needs to be modernized to something along the lines of ‘safety oversight’ or quite simply, modify how certifi cation is performed. Perhaps the FAA needs to be split

into several organizations, one of which concentrates on the business of certifi cations only. This follows upon the stillborn privatization of the FAA air traffi c management debate not long ago, but in an entirely diff erent way. Such a move would alleviate governments (taxpayers) who are either unwilling or unable (due to political reasons and the inability of various special interest to compromise on an approach) to fund this type of role, perhaps taking the model of the Underwriters Laboratory (UL) may be something to consider. Many of you may recognize this from the label UL on your electronics and other consumer products. UL and other competing labs are approved to perform safety testing by the U.S. federal agency Occupational Safety and Health Administration (OSHA).

OSHA’s Nationally Recognized Testing Laboratory (NRTL) Program “…recognizes private sector organizations to perform certifi cation for certain products to ensure that they meet the requirements of both the construction and general industry OSHA electrical standards. Each NRTL has a scope of test standards that they are recognized for, and each NRTL uses its own unique registered certifi cation mark(s) to designate product conformance to the applicable product safety test standards. After certifying a product, the NRTL authorizes the manufacturer to apply a registered certifi cation mark to the product. If the certifi cation is done under the NRTL program, this mark signifi es that the NRTL tested and certifi ed the product, and that the product complies with the requirements of one or more appropriate product safety test standards.” Why not expand this to aviation?

Perhaps splitting the FAA into several groups or agencies could benefi t aviation.

The Underwriters Laboratory

started as a non-profi t back in 1894 and participated in the safety analysis of many of that century’s new technologies. For more background on UL, read its Wikipedia page. It has since transitioned to a for- profi t global safety certifi cation headquartered outside of Chicago and has a global presence. If the certifi cation portion of the FAA was spun off into a legal entity, and brought in one or more of the current industry standards organizations to provide greater integration with industry and standards into this new entity (Aviation Laboratory (AL)… just call me Al), and the government would require that all signifi cant aircraft parts, avionics, and aircraft acquire an AL certifi cation, this would alleviate

20 | june 2019

the FAA from this task. And such a change would also take some pressure off of OEMs when certifying products. Governments could initially

provide partial funding, and the AL would directly charge per product as the UL does for safety testing (and perhaps cybersecurity testing for products containing software). Competing labs would emerge in the EU, China, Australia, and the newly Brexited-UK. Competition would drive down costs for such services, and also provide a higher quality of testing (with proper oversight to ensure no corners were being cut…). Such an organization would require one heckuva insurance policy to cover itself, and by doing so, the insurers would be motivated to ensure that more testing of a 737 Max would occur, since they have more oversight over the lab performing such tasks. This could be a win-win for

industry, governments and the fl ying public.

Who do I call to make this happen?

John Pawlicki is CEO and principal of OPM Research. He also works with Information Tool Designers (ITD), where he consults to

the DOT’s Volpe Center, handling various technology and cyber security projects for the FAA and DHS. He managed and deployed various products over the years, including the launch of CertiPath (with world’s fi rst commercial PKI bridge). John has also been onic FAA 8130-3 forms, as well as in defi ning digital identities with PKI. His recent publication, ‘Aerospace Marketplaces Report,’ which analyzed third-party sites that support the trading of aircraft parts, is available on as a PDF download, or a printed book version is available on

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