Many of you have read about the situation around the Boeing 737 MAX. Our own ttyymmnn put together a good primer on the subject. You may have also have read some opinion pieces saying how the FAA is too cozy with the airlines and OEMs and that is how we ended up here. I’m not going to comment on any of that. I am going to tell you how big things can get certified on an airplane and why it isn’t always the FAA who does that.

There are basically two ways you can get things approved for use in commercial aviation. Your organization can develop the necessary engineering data (instructions, drawings, engineering substantiation, criticality or major/minor determinations, reports, allowances, specifications and potentially test articles) and submit them directly to the FAA for review and approval. The FAA typically has in its ranks folks who are qualified to review and approve this information. If they don’t like it they will send it back and you can do it again.

The challenge here is that the FAA only has so many of these people. That can mean long lines and considerable delay. Also, for many subjects that are on the more advanced end of technology the FAA may not have the expertise on staff to adequately judge the merits of a submitted item. The folks who work Aircraft Certification Offices are generally pretty sharp and willing to learn (the ones I typically deal with anyway), but they can’t be experts in everything.

The other method is Delegated Authority. In this situation, an organization builds procedures to allow them meet very stringent FAA requirements that allow for select individuals within the organization to act on the FAA’s behalf for review and approval. The FAA reviews the org’s process and procedures and then vets out those who be allowed to wield approval authority. It is a huge responsibility for those who take on this authority. They work closely with the FAA on training, approval plans for complex issues and are regularly audited. They are held accountable for compliance to the FAA regulations and guidance.

It is a good program generally. The approvals are reviewed by subject matter experts. There is clear process and procedure. People and organizations are held accountable. The FAA doesn’t need to have giant engineering teams and can focus on what is important to their mission. It works and it has helped get us to the safest mode of transportation in human history. That doesn’t mean it can’t be improved upon or that it is not without flaws. It is the best thing going though.

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There is much, much more to it than what I have put down here. I could go on about how regulations come together, air worthiness directives, advisory circulars and all that, but it gets to be a lot. Some of the local subject matter experts can chime in if they feel like it. I do hope this helps educate you a bit about what is being said about the MAX. Boeing is a Delagated Authority. I don’t know if this came into play with the two crashes or not. What I do know is that the calls that the FAA is to cozy with anyone need to be justified by people who understand the process and not just armchair pundits.