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.