[SystemSafety] Report on Risks of UAVs in US NAS

Tom Ferrell tom at faaconsulting.com
Thu Aug 9 13:23:20 CEST 2018


While not UAS-centric specifically, I would note that the FAA is moving rapidly (at least for them) toward a risk-based oversight regime and away from prescriptive enforcement of standards.  As an example of this, the oversight of software development and verification in accordance with DO-178B (and then C) has been driven over the years, first by an extensive set of FAA Notices, and then a rather lengthy FAA Order (8110.49).  This order had evolved over time to include sixteen chapters on various topics including an extensive chapter on review activities to be accomplished for each project.  In March of this year, that order was revised and now includes only three chapters.  The review chapter remains but its invocation of what was referred to as the Software Job Aid has gone away along with the specific direction for four reviews covering different facets of the development.  Those of us who have worked in this area for a while would say that’s not all bad since the Job Aid had led to a bit of a checklist mentality that tended to take the focus off of safety aspects in favor of a more simplified process check.  It’s also fair to note that many of the items removed from the order have found (or are planned to find) a home in less prescriptive guidance from the FAA (e.g., FAA AC 00-69, Best Practices in Software Development).  However, taken together, these changes represent a pretty significant swing in how the FAA oversees projects.  I would say it is far too early to see whether  industry, relieved of much of the prescriptive aspects of FAA direction, will still practice the same level of development assurance we have come to expect and rely upon to help address software complexity and its overall contributions to system safety.  My personal concern with regards to this is not from the big players (e.g., Boeing, Airbus, Honeywell, Thales) but from the smaller companies and startups where the safety culture may not be well established and the overarching goal can often be simply time to market.

From: Martin, BJ [mailto:BJ.Martin at novasystems.com]
Sent: Thursday, August 9, 2018 2:51 AM
To: Tom Ferrell; Peter Bernard Ladkin; The System Safety List
Subject: RE: [SystemSafety] Report on Risks of UAVs in US NAS

Thanks Tom,
That clarifies the question of authoritative weight. I’m still keen to hear how the recommendations are ‘going down’ in the old school.  Or is it too soon to know.


Cheers,
BJ

--
BJ Martin
Safety and Certification Capability Lead
Nova Systems


From: systemsafety <systemsafety-bounces at lists.techfak.uni-bielefeld.de> On Behalf Of Tom Ferrell
Sent: Thursday, 9 August 2018 7:30 AM
To: Martin, BJ <BJ.Martin at novasystems.com>; Peter Bernard Ladkin <ladkin at causalis.com>; The System Safety List <systemsafety at techfak.uni-bielefeld.de>
Subject: Re: [SystemSafety] Report on Risks of UAVs in US NAS

Just a clarification.  Although this report was requested by the FAA, it was not published by the FAA.  The FAA can choose to implement the recommendations or ignore them at their discretion.  Within the US, there is significant pressure to enable UAS technology to the greatest extent practicable without eroding public safety.  In some cases, this pressure is coming from industries where the use of UAS is actually seen as a potential sea change in safety.  An example of this is the use of UAS for high-power line inspection.

From: systemsafety [mailto:systemsafety-bounces at lists.techfak.uni-bielefeld.de] On Behalf Of Martin, BJ
Sent: Tuesday, August 7, 2018 10:02 PM
To: Peter Bernard Ladkin; The System Safety List
Subject: Re: [SystemSafety] Report on Risks of UAVs in US NAS

Does anyone know if there has been any reaction or acceptance of the recommendations in this study report by the FAA?
It seems an inevitable but considerable shift from their historical approach to safety management at the air vehicle level.

--
BJ Martin
Safety and Certification Capability Lead


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From: systemsafety <systemsafety-bounces at lists.techfak.uni-bielefeld.de<mailto:systemsafety-bounces at lists.techfak.uni-bielefeld.de>> On Behalf Of Peter Bernard Ladkin
Sent: Tuesday, 19 June 2018 2:24 PM
To: The System Safety List <systemsafety at techfak.uni-bielefeld.de<mailto:systemsafety at techfak.uni-bielefeld.de>>
Subject: [SystemSafety] Report on Risks of UAVs in US NAS

New from National Academies Press. PDF is free download.

https://www.nap.edu/catalog/25143/assessing-the-risks-of-integrating-unmanned-aircraft-systems-uas-into-the-national-airspace-system


PBL

Prof. Peter Bernard Ladkin, Bielefeld, Germany
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