ASTM formally announced on 12 April 2016 that Adam has been named chairman of ASTM International Committee F37 on Light Sport Aircraft. Officers are elected to committee every two years. Previously Adam had served as the vice-chairman of Committee F37.
Another ASTM Standards for Light Sport Aircraft course is in the books and it was a great one. In early February attendees from two manufacturers attended the two day course in Vacaville, CA.
Since first being offered officially in 2009, 64 people have taken this class in three different countries. Currently there are two opportunities to take the course in person before the October 2016 deadline for receiving compliance training. An electronic version of the class is in the works and should also be available soon. Check out the ASTM website for details.
Over the last several years there has been a great deal of back and forth over F2245 (Standard Specification for Design and Performance of a Light Sport Airplane). The Committee on LSA has always been viewed as a poster child for rapid development and flexibility, being “able to accelerate their standards writing activities and respond efficiently and effectively to marketplace needs.” But the downside of flexibility is the frustration of manufacturers at the mercy of a changing standard, who are sometimes required to make alterations to their aircraft and ultimately, their businesses. We’ve coined the term ‘ballot fatigue’ to capture the sentiment that some manufacturers are expressing regarding the pace of change.
How many changes have there actually been? And of what significance are they? What was the driver for the change initially? Given how frequently these questions are being asked, we set out to help provide some perspective for the answer—at least for the most frequently revised standard, F2245.
As seen in the figure, there is a consolidation process that occurs as ballots are approved, get published by ASTM, and the ultimately get accepted or recognized by Civil Aviation Authorities (CAAs). In the United States, for example, the twenty-seven approved change over the five-year period became real to aircraft manufacturers just four times through the FAA Notice of Availability process—a little less than once per year.
The categories of changes fall into six different categories, each outlined below.
Authority Request (33%)
Nine of these changes were made under the first and most common category, the Authority Request. One-third of the changes made were requested by a CAA. Seven of those ten were a direct result of the Zodiac CH 601 XL investigation. These standards changes included the addition of Operating Maneuvering Speed (VO), calibration of Airspeed Indication System and the elimination of inconsistencies in never-exceed speed (VNE) definition. The other authority requests were made for improving international applicability of the standard (consideration of variable pitch propellers and a new appendix for related requirements when an aircraft is equipped with a variable pitch prop).
There were seven instances when the standards’ existing content was clarified or improved. Some of the items affected by this category of change include minimum useful load, glider towing operational and structural cone angles, and clarification of permanent deformation of structures at limit load. These changes were made to reduce and eliminate confusion.
Four safety changes included: IFR/IMC placard or kinds of operation, fuel tank fuel strainers, engine/airframe/propeller vibration interaction, and enhanced safety belt requirements stemming from NTSB fatal accident investigations.
Four of the changes were made to adjust content between standards and/or sections for organizational purposes, often in light of the whole body of standards. When making an administrative change, the committee was diligent to look at all of the standards, not just F2245, when considering content. Sometimes one standard affects, clarifies or confuses another. Administrative changes are made to keep the body of standards running smoothly together. One of those changes involved references to Federal Aviation Regulations (FAR) and European Aviation Safety Agency (EASA) specifications. Two others resulted in harmonizing the information on nose gear loads and firewall thickness.
New Developments (7%)
Periodically new subjects or issues are brought to committee which are deemed appropriate and important enough to be included in the body of standards. When that happens, the change is categorized as a New Development. In the case of F2245 there have been two new developments in the past five years: the integration of electric propulsion and the requirement to use an approved propeller on LSA airplanes.
Editorial changes are made when a correction or clarification of existing content doesn’t affect the meaning or technical aspects of the item at all. The lateral mass ratio equation in the appendices was corrected as an editorial change.
There have been a lot of ballots over a five year period which has created ‘ballot fatigue’. This is certainly unhealthy for the overall industry because people that are tired of reviewing ballots tend to take less care in commenting and voting. The committee leadership is regularly discussing this, putting tools in place, and deliberating carefully in selecting work each year. We have cataloged over one-hundred suggested changes across all of the F37 standards and spend significant time in each committee meeting reviewing the pros and cons of each item. Many items haven’t been pursued due to a lack of positive impact on the industry overall and a recognition of ‘ballot fatigue’. Some other observations follow below:
There have been between five and six successful ballot topics per year that have translated to a little less than one required change per year for US manufacturers and a total of two changes for European LSA. Other countries like China accept the ASTM-published changes immediately for Type Certificate and Production Certificate applicants. In frameworks like this, close attention to standards changes is important as a manufacturer nears the point of certificate issuance.
Fatal accidents have driven well over one-third of total balloting activity and about one-third of all accepted ballots. One key strategy for reducing ‘ballot fatigue’ is to design, produce, and support aircraft that are safe through true compliance to the standards.
Due to the nature of the ASTM process, there is ballot activity related to changes that do not pass through the voting process. In addition, there are subcommittee ballots for each item as it is being developed. This significantly increases the total number of ballots and adds to ‘ballot fatigue’. It also can become difficult to understand why the same ballot items seem to appear multiple times. For those where this causes problems, one strategy is to retract participation at the subcommittee level. This will eliminate almost half of the total ballots while still having an opportunity to review and vote on every item at the main committee level (final vote).
Requiring periodic manufacturer training for compliance to ASTM standards exists in many industries. From environmental compliance to flammability requirements for clothing, many standards-regulated groups agree globally that a culture of trained personnel is beneficial for actual compliance and the peace of mind that comes from it.
Last January, Light Sport Aircraft (LSA) ASTM Subcommittee F37.70 on Cross Cutting issues, voted on the addition of section 12 to F2972, Standard Specification for Light Sport Aircraft Manufacturer’s Quality Assurance System, which requires periodic manufacturer training. Section 12 requires those individuals who sign statements of compliance, within the Quality Assurance Administration (QAA) of an organization, to have taken and passed a training program which meets the requirements of Practice E2659 (E2659-09ε1 or the Standard Practice for Certificate Programs, which provides guidance for developing and administering quality certificate programs) and F2972-14. Despite the passage of this standards change, there seems to still be a great deal of controversy surrounding it within the LSA industry.
Currently there is no required ‘check point’ in the self-certification process that verifies a baseline level of understanding of compliance. Some nominal, industry-wide standard will be helpful. This is part of a larger, two-pronged approach to improve education about compliance and help the industry retain as little formal oversight as possible from authorities. The training requirements ensure that any individual signing a Statement of Compliance has an understanding of the standards and how they apply to aircraft.
A Brief History
For those not familiar with the history of this new requirement, it was 2010 when the F37 Executive Committee first recommended the development of a training program, and there was quite a bit of resistance to it. Required training was just one item in a prioritized list presented at the July ASTM meetings in Oshkosh, WI in response to FAA concern over the industry as a whole. Later that year, the FAA recommended the development of a third-party training program. Over the next two years the FAA became increasingly insistent that the industry demonstrate consistent and competent self-regulation before they (the FAA) had to take additional action, which was unlikely to be beneficial for light aviation. The ballot including a training program was first introduced at the September 2013 meeting and would be brought to vote four times over the course of the next year.
Over the course of the ASTM consensus process, there were persuasive negatives in four key areas on the ballot. First, there were concerns about the course cost, sustainability and complexity. The second persuasive negative was over the frequency of recurrent training. Third was a concern related to the scope of the standard itself, and the final persuasive negative was a desire to see the allowance of additional methods of compliance.
Each of these were discussed at meetings and carefully reworked by the task group until the ballot passed in 2014 October with only two non-persuasive negatives.
If the vast majority of aircraft delivered are truly compliant to the standards, then the industry will be much more healthy long-term. This will be especially true under the scrutiny of governments and media when fatal accidents occur. In addition, the FAA has given the industry a pretty long leash already, but we haven’t stepped up adequately. We can choose to shape our own future through engaging the standards-making process for what we do, or we can let regulators try to do it for us through their bureaucracy.
The ASTM standard allows for anyone to offer a training course that fits the bill, including manufacturers developing courses internally. There is one course available through ASTM as well. Currently the course is two full days with certificate testing for an additional fee.
Adam Morrison of Streamline Designs recently led a class of 15 through the ASTM Technical & Professional Training Course on the ASTM Standards for Light Sport Aircraft (LSA) in Sunriver, Oregon. The training course, offered through ASTM, is recommended for anyone who is manufacturing Light Sport Aircraft, as well as management, engineers, distributors, and other personnel who would benefit from understanding compliance to the governing body of ASTM standards.
This particular class was unique in that several different manufacturers were represented including: ICON Aircraft, Synergy Air, Van’s Aircraft, Kitfox Aircraft, Cub Crafters and Glasair. Two auditors from the FAA also participated and spoke favorably about the experience. Not only did the FAA feel good about the class but the majority of participants shared that the information was relevant and had high value for them in their role within their company, the industry, and their own professional lives.
An ASTM-proctored, LSA Training Certificate is part of the industry’s continuous improvement of self-regulation practices. Recent changes to the quality standards for those signing declarations of compliance requires that signatories be trained. The new standard states that “Any member of the Quality Assurance Administration, identified in the Quality Assurance Manual, must have completed, with documented records, a standards training program within the preceding four years. The training program must leave the student with understanding of [requirements, methods, means, and verification of compliance to the ASTM standards.” The ASTM class, led by Adam, is one way for manufacturers to comply to this requirement. In the next 12-18 months, as additional regulatory bodies adopt the new policy, certified training in compliance will become mandatory, which is especially important in countries where manufacturers self-declare compliance. The training program, which has been offered for several years now, has been modified in a direct response to a push from authorities for people who are signing declarations of compliance to know exactly what their signature means.
In the fall of 2012 Adam Morrison and Severin Kempf of Streamline Designs, LLC were recognized for their service to the light aircraft community.In September, Adam was presented with a Service Award for his performance on the Committee on Technical Committee Operations (COTCO) for 2010-2012. As stated in the committee’s scope, “COTCO develops and maintains the Regulations Governing ASTM Technical Committees and acts upon recommended changes.” Kenneth F. Yarosh, the 2012 Chairman of the Board for ASTM International, recognizes members of COTCO for their contribution to the “legislative arm” of standards development for ASTM.In October at the 10th Anniversary Meeting of ASTM International Technical Committee F37 in Atlanta, GA, both men were recognized for their contributions and service to the committee.Severin was presented with a Standards Excellence Award 2012. This award was presented for effective leadership of the task group which developed the first audit program standard specifically for Light Sport Aircraft.* Severin said about receiving this award, “It is always great to see work turn into something useful for the industry and I am humbled by the award from the committee regarding this work.”Adam was recognized with the first annual Daniel A. Schultz Award. This award, named in honor of Daniel Schultz and his contributions to ASTM, is given in recognition of his leadership on committees and contributions to standards development, and is awarded for significant and outstanding contributions to global standardization by the Light Sport Aircraft community. This highest- recognized F37 Committee Award was presented to Adam for his long time devotion to standards development in support of light sport aircraft.
Adam responded to the recognition by saying it was an honor to be recognized by the Light Sport Aircraft committee on it’s 10th Anniversary during Streamline Design’s own 10th Anniversary year.
Technical Committee F37 addresses issues related to design, performance, quality acceptance tests and safety monitoring for light sport aircraft (LSA). While in Atlanta the committee also passed F2972, a new standard for light sport quality assurance. www.astm.org/standardization-news
Sebring, FL Just prior to the 2010 LSA Expo in Sebring, Florida, Adam Morrison and Severin Kempf of Streamline Designs led ASTM meetings related to Light Sport Aircraft standards. Adam serves as Chairman of the fixed-wing subcommittee as well as overall committee Vice-Chairman and Severin serves as Task Group Technical Contact for the development of a new audit standard for LSA. The meetings covered subject matter such as Electric Propulsion Units (EPU), IFR/IMC operations, audits, integrity of engine installations, and improved internationalization of the standards.
Just prior to the 2010 LSA Expo in Sebring, Florida, Adam Morrison and Severin Kempf of Streamline Designs led ASTM meetings related to Light Sport Aircraft standards. Adam serves as Chairman of the fixed-wing subcommittee as well as overall committee Vice-Chairman and Severin serves as Task Group Technical Contact for the development of a new audit standard for LSA. The meetings covered subject matter such as Electric Propulsion Units (EPU), IFR/IMC operations, audits, integrity of engine installations, and improved internationalization of the standards.
Severin had the following to say after these meetings, “Although there are many interests represented on the ASTM LSA standards committee, the ASTM process has proven to be very robust. At the end of the day, there was consensus to do the right things. I was also pleased to see that there is general agreement within the community as it relates to the developing audit standard for LSA.”
Adam noted following the Sebring meetings, “There are some very exciting things happening within the LSA industry. Aircraft designs and manufacturers are maturing and the industry is beginning to appreciate the value of high-quality consensus standards. We are on the forefront of electric propulsion and are actively developing standards to help assure that these systems can be safely operated. Developments are happening quickly, and the consensus standards process is proving well-suited to support the safety of significant innovations. Streamline Designs is ready, as always, to continue supporting this growing industry.”
Streamline Designs has been involved with the LSA industry since its inception and provides affordable, high-quality engineering services ranging from detailed design and analysis to setup of manufacturing quality systems to management and execution of complete compliance programs for LSA. For more information on these and other services, please contact us.