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07/23/01
07/23/01
Date
07/23/01
LIST OF ACTIVE PAGES
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TABLE OF CONTENTS
1.0
PURPOSE ............................................................................................................................. 5
2.0
EFFECTIVITY...................................................................................................................... 6
3.0
3.1
General ............................................................................................................................... 7
3.2
3.3
3.3.1
PSP Maintenance....................................................................................................... 8
3.3.2
3.3.3
3.3.4
3.3.5
3.3.6
3.4
Delegation ........................................................................................................................ 13
3.5
4.0
CONTINUOUS IMPROVEMENT..................................................................................... 15
4.1
4.2
Performance Measures..................................................................................................... 15
4.2.1
General...................................................................................................................... 15
4.2.2
4.2.3
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PURPOSE
The purpose of this Partnership for Safety Plan (PSP) is to define a working relationship
between the Aircraft Certification Services of the Federal Aviation Administration (FAA)
and Company-X that provides a foundation for building mutual trust, leadership, team
work, and efficient business practices. This PSP also provides the framework for the
development of standardized Project Specific Certification Plans (PSCP) that can be used
for preplanning of projects between the FAA and Company-X. The results of these
efforts will enable the FAA and Company-X to expedite certification projects by focusing
on safety significant issues. It is the mutual goal of the FAA and Company-X to meet or
exceed the expectations of this agreement to achieve the following vision:
Vision of the Product Certification Process
A credible and concise product certification process that results in:
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EFFECTIVITY
This PSP shall become effective upon approval by the FAA and Company-X Signatories
on the cover page of this PSP. It shall continue in effect until it is superseded, revised, or
terminated in writing by either the FAA or Company-X. The PSP may be amended only
by mutual consent of Company-X and the FAA. Any changes in the services furnished or
in other provisions of this PSP shall be formalized by an appropriate written amendment
signed by both parties, which shall outline the nature of the change. It is recommended
that a yearly meeting be held to review this PSP and make any changes that would
improve the process.
3.0
3.1
General
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This Partnership for Safety Plan (PSP) provides the framework for the FAA and
Company-X to use for all type design, production, and installation certification activities
related to Company-X aircraft seating systems. These certification activities primarily
lead to TSO-C127a authorization and 14 CFR 25.562 installation approvals for the
seating systems, but are not limited to these areas.
This PSP is a living document developed jointly by the FAA and Company-X as an
important prerequisite to specific seating system certification projects. It defines the
working relationships the FAA and Company-X will follow to assure a high level of
mutual trust and commitment to work as a team in the timely completion of each
certification project. This PSP establishes the guidelines to be followed for effective
planning, communication, delegation, and issue resolution on all aspects of Company-X
seating system type design, production, and installation certification efforts. These basic
guidelines and working agreements will be carried forward in the creation of all Project
Specific Certification Plans (PSCP) that may be developed in conjunction with this
agreement. Appendix B contains the suggested format for PSCP creation agreed to by the
signatories of this document.
The PSP establishes ownership of the process and a commitment by FAA and CompanyX certification specialists and senior management to significantly improve the
certification process by completion of all certification activities in a timely and efficient
manner. The PSP will be managed and maintained by the FAA and Company-X
management focal points identified in Section 3.3.1 and Appendix A.
3.2
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These activities will ensure early insight to future potential Company-X projects and
future proposed FAA initiatives/regulation or policy changes.
Audit processes that are employed will be used as a method for improvement. The
lessons learned will be discussed and incorporated into this PSP. Redrafts of this
agreement will be based upon these discussions.
3.3
3.3.1
PSP Maintenance
Communication and coordination for all certification issues shall be directed through the
PSP Certification Activities focal points. The focal point for Company-X will be
Somebody(?) and for the FAA will be Someone(?). The focal points will be responsible
for being informed of all critical communications, facilitating conflict resolution, and
continual maintenance of the PSP.
The focal points will also be responsible for updating their respective management on the
health of the partnership and stakeholder accountability. If issues arise that require
management involvement, the focal points will be responsible for providing briefing
information to them.
3.3.2
3.3.3
Approval Procedures
3.3.3.1 Dynamic Test Plans
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This section will outline the procedure used to approve Dynamic Test Plans
prepared by Company-X in support of the following activities: TSO-C127a
certification efforts, and TSO-C127/127a minor change substantiation efforts. It
is intended that data collected will support 14 CFR 25.562 installation approval
efforts and will be used by the Type Certificate holder to show compliance. That
is, the design requirements addressed by the TSO should not require further
review upon installation provided the part is installed within the limitations of the
approval.
Dynamic Test Plan approval will be documented by .
Company-X must maintain all approved Company-X Dynamic Test Plans for
FAA review until Company-X no longer manufactures the product.
Seat designs that fall outside of Company-X experience based on previous
approvals, installation requirements, or dynamic testing procedures that affect
compliance with the TSO or 14 CFR 25.562 requirements shall be discussed and
agreed upon by the local Aircraft Certification Office and other stakeholders as
required prior to test plan approval. A PSCP will be used to coordinate this
information between stakeholders (installer, installing and TSO project ACO,
etc.). The installer has the responsibility to contact and initiate discussions with
the installing regulatory authority where necessary. Individual ACOs will be
responsible for coordination within the FAA and with other regulatory authorities.
3.3.3.2 TSO MINOR CHANGES (Excluding Flammability Changes)
This section will outline the procedure used to approve all TSO minor changes per
14 CFR 21.611 for all Company-X seat models certified to TSOC39b/C127/C127a and for all flotation cushions certified to TSO-C72c. This
authority does not include approving burn tests in support of minor changes
subject to the requirements of 14 CFR 25.853.
As part of the TSO Minor Change approval process, the impact of the minor
changes on all aspects of the TSO shall be evaluated. The impact of the minor
changes on 14 CFR 25.562 installation approvals shall also be evaluated. This
evaluation can be done using engineering rationale and judgment, analysis, or
static/dynamic testing. Minor changes that might impact 14 CFR 25.562
installations shall be coordinated with the seat installer prior to implementation of
the changes into production seats. It is the responsibility of the seat installer to
obtain approval for the modified installation. The data required to obtain approval
for the modified installation will be coordinated with the installer.
The minor change approvals for each Company-X seat model certified to
TSO C39b/-C127/-C127a shall be documented in a Company-X Modification
Report. The Modification Report shall also include an assessment of the impact
of the minor changes on 14 CFR 25.562 installations. The format of the
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Modification Report shall be approved by the local ACO. For seat models
certified to TSO-C127 or to TSO-C127a, the Modification Report must be
updated at least every six months unless no minor change activity has occurred on
that seat model during that time period (which shall be noted on an approved
tracking spreadsheet as described later in this section). For seat models certified to
TSO-C39b, the Modification Report must be updated at least annually unless no
minor change activity has occurred on that seat model during that time period.
Copies of the Modification Report will be provided to the seat installers upon
their request. The installer is responsible for documenting 14 CFR 25.562
compliance findings in a process that is acceptable to their ACO.
Prior to approving the Modification Report, any non-typical minor changes that
affect compliance with the TSO or 14 CFR 25.562 requirements are coordinated
with the local ACO for guidance. If necessary, the local ACO will initiate
discussion with the installing ACO or other regulatory agency for 14 CFR 25.562
issues. Identification of non-typical minor changes is the responsibility of
Company-X.
Modification Report approval shall be documented by ...
All approved Company-X Modification Reports must be maintained for FAA
review until Company-X no longer manufactures the TSO article.
Company-X shall develop and maintain a summary of minor change activity using
spreadsheet software acceptable to the FAA. The format of the spreadsheet will
be approved by the local ACO. At a minimum, the Minor Change Summary
spreadsheet shall contain the following information:
1.
2.
3.
4.
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approval of burn tests in support of minor changes to a seat model that must show
compliance to 14 CFR 25.853.
.
Prior to approval the Burn Test Activity Report, Company-X shall insure that any
non-typical minor changes that affect compliance with the TSO requirements are
discussed and agreed to by the local ACO. Identification of non-typical minor
changes is the responsibility of Company-X.
The approval of each burn test will be documented by ...
The minor change burn test approvals for each Company-X seat model certified to
TSO-C39b/-C127/-C127a shall be documented in a Company-X Burn Test
Activity Report (BTAR). The format of the BTAR shall be approved by the local
ACO. A BTAR must be prepared at least every six months unless no minor
change burn test activity has occurred during that time period (which shall be
noted on the tracking spreadsheet). The BTAR will summarize burn test activity
only for the six-month period that has elapsed since the preparation and approval
of the previous report.
Burn Test Activity Report approval shall be indicated by ...
Company-X must maintain all approved Company-X Burn Test Activity Reports
for FAA review until Company-X no longer manufactures the product.
Company-X shall develop and maintain a summary of flammability minor change
activity using spreadsheet software acceptable to the FAA. The format of the
spreadsheet will be approved by the local ACO. At a minimum, the Burn Test
Summary spreadsheet shall contain the following information:
1. Company-X Seat Model Number
2. Company-X Fireblock Test Report Number
3. Test Kit Part Number
4. Color Code for the Cushion & Cover Combination
5. FAA Form 8110-3 Approval Date
6. Company-X Part Number for Foam Material Tested
7. Foam Material Description
8. Company-X Part Number for Fireblock Material Tested
9. Fireblock Material Description
10. Company-X Part Number for Upholstery Material Tested
11. Upholstery Material Description
12. Test Facility Test Number for 14 CFR 25.853(c) Tests Conducted
13. Date of Test Facility Tests
14. Company-X/Test Facility Upholstery Test Number for 14 CFR
25.853(a) Tests Conducted
15. Date of Company-X/Test Facility Upholstery Tests
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The Burn Test Summary spreadsheet shall be submitted to the local ACO at least
every six months. Submissions in electronic format are recommended.
3.3.5
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Continued Airworthiness
The details of how the FAA and Company-X will handle continued airworthiness issues,
after delivery of the first seating system will be consistent with the 14 CFR 21.3 and FAA
policy on TSO authorization management, reporting, self-disclosure and the requirements
for implementing corrective actions in both the type design and production systems.
Company-X will document all minor change activity using the procedures outlined in
Sections 3.3.3.2 and 3.3.3.3 of this document.
3.4
Delegation
The FAA and Company-X ASP are committed to the development and support of an
effective designee system that includes both organizational and individual delegations.
The FAA will maximize the degree of delegations to the extent practicable and will
include appropriate oversight safeguards as defined in the Aircraft Certifications
Services delegation management process. Section 3.3.3 of this PSP provides the
framework for the delegation system agreed to by Company-X and the FAA by outlining
the delegation, communication, and reporting responsibilities to be used for design
certification efforts, production, and continued airworthiness. The Project Specific
Certification Plans (PSCP) will reaffirm these responsibilities for each new project.
The designee system must be based on an environment where honesty, open
communication, mutual respect, and trust are the norm. This environment should
encourage the Designees, within the scope of their delegation, to openly communicate
certification issues with the FAA. Company-X agrees to create a working environment
where Designees can make compliance findings free from undue pressure and with the
support and knowledge of the FAA. It must be clearly understood by the FAA and the
designees that their objective is to find compliance with the regulations and not to dictate
design.
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Be sufficient in detail to ensure that all of the parts of the product being certified
conform to the type design.
Define conformity requirements consistent with 14 CFR 21.33 and 21.53(b).
Address the use of ODAR and/or FAA designees and will be referenced in the
PSCP.
Address conformity of products and parts at subcontractor and partner facilities
both in the United States and at foreign locations.
Each PSCP, as appropriate, will outline international requirements related to the project.
The outline will define or address as a minimum:
The existing Company-X Quality System will be used for management of external
suppliers.
The PSCP will establish communication links, responsibilities, and
accountabilities.
To enhance communication, the PSCP will require the Company-X as well as the FAAs
Certification Standards, and Manufacturing Inspection staffs, to coordinate/agree upon an
as of configuration for a seat system prior to certification. Existing issue papers will be
clarified or resolved prior to these reviews/evaluations. In addition, scheduled meetings
will be established between the FAA and Company-X to monitor issues and plans and to
initiate actions that may be required. These meetings will be held on an as needed basis.
Finally, agreed to forms and methods of communication will be identified in the PSCP.
The reporting of failures, malfunctions, and defects will be in accordance with CompanyX procedures and in compliance with 14 CFR 21.3.
4.0
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CONTINUOUS IMPROVEMENT
The objective of this process is to identify and resolve issues and disagreements as early
as possible at the team working level and facilitated by the PSP focal points. Ideally this
will occur during PSCP development. If there are issues the focal points will jointly
maintain an issues tracking list. When agreement is reached on an issue, the resolution
will be documented (actions, decisions, and outcomes) in the project records. Should any
problems arise where resolution is not proceeding according to the agreed upon PSCP,
the focal points will utilize issues resolution process outlined in Section 4.1.
4.1
4.2
Performance Measures
4.2.1
General
Early communication between Company-X and the FAA in the conceptual stages of
product development is critical to assure adequate planning and flexibility. Priority must
be placed on:
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The above guidelines should focus on producing quality deliverables that evidence an
efficient and credible certification process.
4.2.2
Operating Norms
Operating norms that are agreed to by the FAA and Company-X are required to guide the
timeliness and quality of deliverables and services provided by the FAA and Company-X.
These norms are intended to meet the needs of both Company-X and the FAA, but
should be reevaluated for each PSCP and agreed upon during sign-off. Clear objectives
and metrics need to be established in a PSCP that are based on quantifiable gauges
(schedule, certification time flow, etc.) and agreed to by all stakeholders. This will help
determine the effectiveness of participating parties and establish consequences for
performance.
4.2.2.1 Product Certification Process Norms
The following operating norms are agreed to for selected key deliverables.
Within 4 weeks after receipt of a preliminary certification plan, the FAA and
Company-X focal points will identify all significant stakeholders and transmit
the PSCP to the stakeholders for their review.
Within 4 weeks after receipt of the PSCP, all stakeholders will either concur
with the content of the PSCP or identify issues that require resolution and
provide a written summary of those issues to the FAA and Company-X focal
points.
Within 2 weeks after receipt of the issues summaries from the stakeholders,
the FAA and Company-X focal points will initiate stakeholder discussions if
outstanding issues have been identified that require coordination through the
conflict resolution process.
Otherwise, the Company-X focal point will
finalize the PSCP and provide copies to the stakeholders.
Within 1 week after a dynamic test discrepancy, the Company-X focal point
will notify the FA focal point and, if deemed necessary by the FAA focal
point, prepare a briefing paper that discusses the issue and proposed
resolution.
Within 4 weeks after receipt of a TSO application package, the FAA focal
point will respond with the TSO approval letter.
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On a quarterly basis, the FAA focal point will update the FAA TSO index
database.
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SUBJECT
FAA
FOCAL POINT
COMPANY-X
FOCAL POINT
EXECUTIVE
MANAGEMENT
CERTIFICATION
MANAGEMENT
CERTIFICATION
ACTIVITIES
PROJECT SPECIFIC
CERTIFICATION PLANS
DER ACTIVITIES
PRODUCTION QUALITY
OTHER
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Each Project Specific Certification Plan (PSCP) will be unique, but the outline shown below will
form the basis for each plan. This outline should be considered flexible in that it is expected that
Company-X ASP and the FAA will identify improvements over time as additional experience is
gained in its use.
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ENDORSEMENT
Keep in or delete????
OF THE
Original Date:
July 2, 2001
Current Revision:
NC
Revision Date:
N/A
1.0
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STATEMENT OF AGREEMENT
The FAA Seattle ACO (SACO) and The Boeing Company have reviewed the contents of the
Company-X-FAA Partnership for Safety Plan, PSP-1, dated July 2, 2001, and endorse its
contents. It is agreed that all Company-X seating system certification activities that involve
SACO and Boeing may be conducted using the guidelines outlined in the PSP, except as
noted in Section 2.0 of this document.
2.0
3.0
SIGNATORIES
The FAA SACO and The Boeing Company agree to the provisions of the Company-X-FAA
Partnership for Safety Plan, PSP-1, Revision NC, except as noted in Section 2.0 of this
document. The following signatures of the FAA SACO and Boeing Company duly authorized
representatives indicate concurrence with the provisions of PSP-1. This agreement is
effective August 9,2001.
Agreed by:
_________________________________ ____________
Dan Freeman
Date
Manager
The Boeing Company
_________________________________ ____________
Tim Erhardt
Date
Lead Engineer
The Boeing Company
_________________________________ ____________
Rick B. Baggette
Date
Lead Engineer
The Boeing Company
________________________________ ____________
Lirio Liu Nelson
Manager, ANM100S
FAA Seattle ACO
Date