Safety of Aerospace Products
Demands Freedom to Select Most Appropriate Standards
In March, the Strategic Standardization Forum for Aerospace published a position paper that points out the danger posed by policies that would force companies to select and use standards based not on technical merit, but on the governing body that releases them.
The SSFA paper warns that potential policy changes regarding standards could result in sub-par construction of important industry products and components, threatening reliability and consumer confidence.
The paper addresses a growing concern that policies and legislation are being set that require the use of “international” standards, which would limit selection to those produced by certain organizations that happen to have the word “international” in their name. This would preclude the use of technologically advanced standards produced by many globally relevant developers simply because of semantics, according to the SSFA.
The Strategic Standardization Forum for Aerospace is a cooperative organization that collaborates and determines best solutions on high-level strategic standardization issues. The group consists of key leaders from aerospace companies, standards developing organizations, airlines, and government (procurement and regulatory) who work together to improve aerospace standardization. The SSFA has been chartered by the Aerospace Industries Association’s board of governors.
The full text of the SSFA position paper is reproduced below and can be found here.
Position of the Strategic Standardization Forum for Aerospace (SSFA)
The aerospace industry is dedicated to producing safe, reliable, and technically excellent products. In order to do so, the industry will select and use standards based on their suitability to meet safety, regulatory, and other technical needs appropriate to their products. This principle is critical and essential to ensure safe and efficient design, build, operation and maintenance of the products of our industry. This requires selecting and using standards based on technical merit, which contain the data necessary to ensure quality aircraft. The aerospace industry urges governments, legislators, and contractors to avoid arbitrarily imposing laws or policies that mandate the use of certain standards based on which organization developed them, and inhibiting the selection of the best standards based on technical merit. Actions taken or advocated to limit or influence selection based on any factor other than suitability for the purpose potentially incur grave risks to the safety and public confidence in the aerospace industry.
Government Restrictions on Standards Selection Threatens Aircraft Safety
Increasingly government policies, legislatures, and even contracts are requiring the use of “international” standards to define and assess products, and then defining “international” standards as only those produced by certain specific bodies, most often ISO [International Organization for Standardization], IEC [International Electrotechnical Commission], and ITU [International Telecommunications Union]. U.S. aerospace products are defined and built using a vast range of standards including company, government, and industry standards, and are selected on the basis of merit, not source. Acceptability of standards from alternate sources is still controlled by a regulatory process that focuses on demonstrated safety and performance, rather than the source of the documents. The industry’s goal is to ensure the delivery of safe, reliable, and durable aerospace products to customers worldwide. Accordingly, regulatory authorities and legislatures must recognize that adoption of an arbitrary definition of what constitutes an acceptable “international standard” risks the safety and potential for service, as well as capability improvement in the aerospace industry.
The Need to Choose Standards Based on Technical Merit
Companies, governments, and industries select and use standards for a variety of reasons to establish product superiority; to facilitate trade; to ensure quality, reliability, repeatability, interoperability; to comply with local, state, regional, national, or international regulation; and for many other reasons. The aerospace industry is no different in this regard. Arbitrarily forcing aerospace designers, regulators, and customers to select standards from certain standards developing organizations based on their location or name, or on the process used to create the standards, would impose a radical change seemingly unrelated to any clear objective. The industry has always chosen standards considering the myriad factors that influence such selection in order to meet or exceed a wide range of requirements that include performance, safety, and quality, as well as national and international regulation and certification.
Aerospace Must Protect the Right to Choose the Best Standards to Ensure Safety
The aerospace industry needs to communicate the value of designers being able to choose the most appropriate standard for the application. The safety and technical excellence of aerospace products, as well as the specific requirements levied upon the industry by its military and commercial customers and regulatory agencies, require that the industry use standards from a wide variety of sources with the most important criteria being the technical suitability and acceptability of the standard. The industry encourages the development of global standards (as defined in the Future of Aerospace Standardization Report, 2005)1 in global venues with the involvement of all stakeholders, and supports the tenets of the World Trade Organization’s definition2 for developers of international standards.
SSFA Recommendations to Mitigate the Arbitrary Limitation of Standards Choices for Aerospace
The aerospace industry must continue to communicate the importance of designers, customers, and regulators selecting and using the appropriate standards based on technical merit, suitability for use, and integration with legacy data. The industry must solicit support of government agencies in the United States, including the U.S. Department of Commerce and the International Trade Administration, and from agencies around the world to understand and accept these standards selection principles for the aerospace industry. The industry must also solicit support from standards developers at home and abroad, national and global trade and industry associations representing the entire supply chain, other national governments and international regulators, and where appropriate, other industries besides aerospace to support this aerospace position. And if necessary, the industry must solicit support of the U.S. government to assist in identifying and opposing legislation or regulation that would frustrate these principles which are essential for safety, reliability, national and international certification of aircraft, and, ultimately, protection of the public good. //
1 “Global standards are those that are recognized throughout the world as technically suitable, accepted as meeting the design and certification requirements, and used throughout the industry. The aerospace industry needs to assert the right to choose its standards based on technical merit and suitability for use regardless of whether the document was developed by an organization with the word ‘International’ in its name.”
2 Annex 4 of the 2nd Triennial Review of the World Trade Organization’s Agreement on Technical Barriers to Trade (TBT) establishes six basic attributes of an International Standards Developer: (1) transparency, (2) openness, (3) impartiality and consensus, (4) effectiveness and relevance, (5) coherence, and (6) development and dimension. These principles were developed to assist the global marketplace in a determination of whether or not a standards developing organization could be considered “International.”