Boeing 737 Max Recertification Testing - Finally.
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New input to FAA's proposed requirements for returning the aircraft to service, in the form of comments to FAA. From Aviation Week (not paywalled, it appears):
https://aviationweek.com/air-transpo...6d7e442eee4218
On the subject of engineers and obligation to question and/or object to management decisions or other questionable situations, with the strong push that is looming in the Congress to reform the FAA processes, what changes to make to the DER or ODA scheme probably will be a difficult question. (NYT reported several months ago on a variety of lobbying inputs made by Boeing in the last reauthorization measure by which the latitude given to the manufacturer was increased; paring it back and setting up a better process - one more faithful to the concerns expressed in-thread - won't be as easy as a dink-and-dunk for short yardage over the middle.)
https://aviationweek.com/air-transpo...6d7e442eee4218
On the subject of engineers and obligation to question and/or object to management decisions or other questionable situations, with the strong push that is looming in the Congress to reform the FAA processes, what changes to make to the DER or ODA scheme probably will be a difficult question. (NYT reported several months ago on a variety of lobbying inputs made by Boeing in the last reauthorization measure by which the latitude given to the manufacturer was increased; paring it back and setting up a better process - one more faithful to the concerns expressed in-thread - won't be as easy as a dink-and-dunk for short yardage over the middle.)
SLF3
That's great, but you say you are a Senior engineer. The original statement was 'engineers without supervisory authority'. i.e. junior engineers.
Should engineers have resigned rather than fit the MCAS modules?
I think that most workers have to rely on their Union and their employer and their contract to prevent them doing unsafe work?
That's great, but you say you are a Senior engineer. The original statement was 'engineers without supervisory authority'. i.e. junior engineers.
Should engineers have resigned rather than fit the MCAS modules?
I think that most workers have to rely on their Union and their employer and their contract to prevent them doing unsafe work?
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One very important aspect to the MAX doing much flying even if recertified and that is the ability or indeed desire for those who have the aircraft or indeed those who have yet to take delivery of those they ordered. I suspect a lot of carriers will not want to accept their ordered aircraft and most likely will cancel any that they have options on.
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Longtimer,
Covid19 aside, at some point fleet aircraft will become uneconomic and require replacement. Traditional Boeing buyers have the choice of 737 Max, which would reduce type training/conversion costs (Don't go there!), A320Neo, or, the Irkut MC-21 and Comac 919.
Russian or Chinese, got have balls of steel to go with that, Airbus have a considerable backlog of orders (for the A320) and Boeing will be discounting heavily, they need Max's in the air clocking up reliable air miles.
This will be a win for the bean counters, if, the MCAS saga is finally put to bed.
Covid19 aside, at some point fleet aircraft will become uneconomic and require replacement. Traditional Boeing buyers have the choice of 737 Max, which would reduce type training/conversion costs (Don't go there!), A320Neo, or, the Irkut MC-21 and Comac 919.
Russian or Chinese, got have balls of steel to go with that, Airbus have a considerable backlog of orders (for the A320) and Boeing will be discounting heavily, they need Max's in the air clocking up reliable air miles.
This will be a win for the bean counters, if, the MCAS saga is finally put to bed.
Uplinker
fair challenge, but junior engineers report to senior engineers. The guys who fit MCAS modules are technicians, not engineers. If the junior design engineers have reservations they enlist the support of their seniors. And if the case is well argued the senior will (Should) back them. If they don’t a train wreck will follow.
i have never had to threaten to resign to kill a bad idea. A documentation trail to decision makers has always been enough. Most non technical managers are cowards at heart!
fair challenge, but junior engineers report to senior engineers. The guys who fit MCAS modules are technicians, not engineers. If the junior design engineers have reservations they enlist the support of their seniors. And if the case is well argued the senior will (Should) back them. If they don’t a train wreck will follow.
i have never had to threaten to resign to kill a bad idea. A documentation trail to decision makers has always been enough. Most non technical managers are cowards at heart!
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Input On Proposed MAX Changes Spotlight Broader 737 Fleet Issues
https://aviationweek.com/air-transpo...aa1f0cc4ecce30
https://aviationweek.com/air-transpo...aa1f0cc4ecce30
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SLF3
At my place stuff like FMEAs (Failure mode and effect analysis) and release documents for software and hardware are signed at team lead and head of department level.
So, if there are any conflicts, head of departments decides, team leads signs - if he wants to keep his variable payment - and the engineer - be it junior or senior - can do nothing but blow the whistle or jump the hierarchy with his doubts and look for an new job.
So basically you are stuck between a rock and a hard place. Best you can do is document that you spoke up. This is why I still keep emails from the LotusNotes era.
At my place stuff like FMEAs (Failure mode and effect analysis) and release documents for software and hardware are signed at team lead and head of department level.
So, if there are any conflicts, head of departments decides, team leads signs - if he wants to keep his variable payment - and the engineer - be it junior or senior - can do nothing but blow the whistle or jump the hierarchy with his doubts and look for an new job.
So basically you are stuck between a rock and a hard place. Best you can do is document that you spoke up. This is why I still keep emails from the LotusNotes era.
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More concerncs about archaic crew alerting system:
https://www.seattletimes.com/busines...can-fly-again/
https://www.seattletimes.com/busines...can-fly-again/
Union for FAA’s safety engineers urges more changes to Boeing 737 MAX before it can fly again A union representing Federal Aviation Administration (FAA) airplane safety engineers who work on certifying new aircraft called Monday for substantial upgrades to the flight crew alerting systems and other changes on Boeing’s 737 MAX before the plane is allowed to return to the air.
During the original certification of the 737 MAX, Boeing successfully argued to the FAA that the jet shouldn’t have to meet all the latest certification requirements governing how cockpit warnings tell the pilots that something is wrong.
The MAX was duly granted exemptions to five of the regulatory stipulations so that it could retain the legacy 737 instrument panel and crew alert system.
The FAA technical staff union argued Monday that those exemptions should be rescinded and the crew alerting system on the re-certified MAX updated accordingly as a condition of the jet’s return to service.
If accepted, that would require major revisions to the instrument displays on the airplane as well as more pilot training on the revised systems, and would likely further delay the MAX’s return.
In early August, the FAA published its final list of required design changesto the Boeing 737 MAX and invited public comment. The comment period ends Monday and last-minute responses came in from various parties with substantial expertise.
The National Safety Committee of the National Air Traffic Controllers Association (NATCA) — a union that represents air traffic controllers and about 600 aircraft-certification technical experts at the FAA — submitted a detailed response with a series of recommendations for additional changes to the MAX, including rescinding the crew alerting exemptions.
The NATCA comments follow closely the critique of Boeing whistleblower Curtis Ewbank, a safety engineer who filed an ethics complaint internally at Boeing after the second MAX crash in Ethiopia.
In a letter to the U.S. Senate this summer, Ewbank publicly repeated his charge about safety issues on the MAX, especially with regard to the inadequacy of the crew alerts. On Friday, covering much of the same ground, he submitted his own comment on the FAA return to service plan.
The changes the FAA plan mandates will fix the flight control system — the Maneuvering Characteristics Augmentation System (MCAS) — that activated erroneously in the two crashes and brought both planes down. It also moves some wiring to ensure proper separation of wires controlling the horizontal tail. And it switches the avionics architecture of the airplane so that it uses both flight control computers on a given flight instead of only one.
However, the FAA return to service plan leaves the instrument panel displays and the pilot warning systems largely untouched. Updating them would require a major remake of the 737’s human/machine interface that would be both expensive and lengthy.
In the original certification of the MAX, in arguing for the exemptions, Boeing estimated the cost of full compliance in terms of new training for pilots worldwide at more than $10 billion.
In its submission Monday, NATCA declared that argument not valid.
“The cost of the two accidents that resulted in worldwide grounding of the 737 MAX fleet has well exceeded the stated $10 billion flightcrew training costs,” NATCA states.
During the original certification of the 737 MAX, Boeing successfully argued to the FAA that the jet shouldn’t have to meet all the latest certification requirements governing how cockpit warnings tell the pilots that something is wrong.
The MAX was duly granted exemptions to five of the regulatory stipulations so that it could retain the legacy 737 instrument panel and crew alert system.
The FAA technical staff union argued Monday that those exemptions should be rescinded and the crew alerting system on the re-certified MAX updated accordingly as a condition of the jet’s return to service.
If accepted, that would require major revisions to the instrument displays on the airplane as well as more pilot training on the revised systems, and would likely further delay the MAX’s return.
In early August, the FAA published its final list of required design changesto the Boeing 737 MAX and invited public comment. The comment period ends Monday and last-minute responses came in from various parties with substantial expertise.
The National Safety Committee of the National Air Traffic Controllers Association (NATCA) — a union that represents air traffic controllers and about 600 aircraft-certification technical experts at the FAA — submitted a detailed response with a series of recommendations for additional changes to the MAX, including rescinding the crew alerting exemptions.
The NATCA comments follow closely the critique of Boeing whistleblower Curtis Ewbank, a safety engineer who filed an ethics complaint internally at Boeing after the second MAX crash in Ethiopia.
In a letter to the U.S. Senate this summer, Ewbank publicly repeated his charge about safety issues on the MAX, especially with regard to the inadequacy of the crew alerts. On Friday, covering much of the same ground, he submitted his own comment on the FAA return to service plan.
The changes the FAA plan mandates will fix the flight control system — the Maneuvering Characteristics Augmentation System (MCAS) — that activated erroneously in the two crashes and brought both planes down. It also moves some wiring to ensure proper separation of wires controlling the horizontal tail. And it switches the avionics architecture of the airplane so that it uses both flight control computers on a given flight instead of only one.
However, the FAA return to service plan leaves the instrument panel displays and the pilot warning systems largely untouched. Updating them would require a major remake of the 737’s human/machine interface that would be both expensive and lengthy.
In the original certification of the MAX, in arguing for the exemptions, Boeing estimated the cost of full compliance in terms of new training for pilots worldwide at more than $10 billion.
In its submission Monday, NATCA declared that argument not valid.
“The cost of the two accidents that resulted in worldwide grounding of the 737 MAX fleet has well exceeded the stated $10 billion flightcrew training costs,” NATCA states.
woka, #317,
A similarity with these events - human behaviour, could be 'failure to intervene' as in CRM.
This could be lack of awareness, or choosing a poor option.
The 'good' option is doing what is expected - regulators must not expect that this will always happen.
A poor - incorrect option involves judgement of risk; a balance in the perceived outcomes.
If the risk of FAA criticism and monetary penalty is lower than the loss which be suffered by a higher aircraft price, late delivery, etc, then gamble.
One intervention in these managerial scenarios is to have very stringent penalties - it will more expensive to get caught - shareholders wrath and company collapse, vs financial loss in fines. The balance of these is continually changing; more profit, fines may be less concerning. This is further complicated by national culture, economic basis, and an overly complex legal system.
Risk management in an uncertain world; heed expertise of the workforce:
'Deference to expertise' https://blog.lowersrisk.com/5-principles-hros/
A similarity with these events - human behaviour, could be 'failure to intervene' as in CRM.
This could be lack of awareness, or choosing a poor option.
The 'good' option is doing what is expected - regulators must not expect that this will always happen.
A poor - incorrect option involves judgement of risk; a balance in the perceived outcomes.
If the risk of FAA criticism and monetary penalty is lower than the loss which be suffered by a higher aircraft price, late delivery, etc, then gamble.
One intervention in these managerial scenarios is to have very stringent penalties - it will more expensive to get caught - shareholders wrath and company collapse, vs financial loss in fines. The balance of these is continually changing; more profit, fines may be less concerning. This is further complicated by national culture, economic basis, and an overly complex legal system.
Risk management in an uncertain world; heed expertise of the workforce:
'Deference to expertise' https://blog.lowersrisk.com/5-principles-hros/
It's been, what, 18 months now since the type was grounded. That in itself must be a record. And there still is no sign of a definitive return to service date, or a plan for that. Based on the past experiences of various other aircraft recovered from desert storage after such a period of inactivity, they are going to have to work hard not to have a fleet of hangar queens.
I wonder what Luis Gallego, new Chief Exec at IAG, will make of Willy Walsh's option for 200 of the aircraft, placed during the grounding. Interesting early decision for him.
I wonder what Luis Gallego, new Chief Exec at IAG, will make of Willy Walsh's option for 200 of the aircraft, placed during the grounding. Interesting early decision for him.
WHBM, It's only an option
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Willy Walsh's option for 200 of the aircraft
BDAttitude
If you are not happy you refuse to sign, and make it known why. Everywhere I have worked that raises a big red flag, and the fact that it has happened goes viral instantly. I have seen people overidden (for good reason, and only after an exhaustive 'off project' review) but I have never seen an unsafe (as opposed to bad) design pushed through by one individual against the collective opposition of a design team. Yes, at the limit you have to be prepared to resign. But you likely won't have to, and you have to be able to sleep at night.
If you are not happy you refuse to sign, and make it known why. Everywhere I have worked that raises a big red flag, and the fact that it has happened goes viral instantly. I have seen people overidden (for good reason, and only after an exhaustive 'off project' review) but I have never seen an unsafe (as opposed to bad) design pushed through by one individual against the collective opposition of a design team. Yes, at the limit you have to be prepared to resign. But you likely won't have to, and you have to be able to sleep at night.
SLF3,
In the first instance what you describe is a good safety culture; if that doesn't exist then individuals could feel threatened.
The second point is that the majority of decisions relating to the 737 Max MCAS were subjective, even some hazard categories. Because these situations rarely have well defined boundaries it is not immediately obvious whether to sign or not sign; nor where the line is - who draws the line - management or expertise.
Furthermore the judgement of pilot contribution in the event of a failure could be critical, thus expert opinion from several sources has to be combined; e.g. technical shortcomings could be offset by pilot action, but if judgement of the pilot's contribution was an over estimate then the effect of a failure could be larger.
In the first instance what you describe is a good safety culture; if that doesn't exist then individuals could feel threatened.
The second point is that the majority of decisions relating to the 737 Max MCAS were subjective, even some hazard categories. Because these situations rarely have well defined boundaries it is not immediately obvious whether to sign or not sign; nor where the line is - who draws the line - management or expertise.
Furthermore the judgement of pilot contribution in the event of a failure could be critical, thus expert opinion from several sources has to be combined; e.g. technical shortcomings could be offset by pilot action, but if judgement of the pilot's contribution was an over estimate then the effect of a failure could be larger.
wrt whether an engineer should say no when told to sign off as safe a system that he/she knows to be unsafe, what is the point of calling yourself an engineer if you could even consider doing such a thing? This isn't about you, it's about your duty to those who depend upon you with their very lives that you do the right thing.
UK engineers in the MOD forgot this when ordered to suborn the UK Military Airworthiness Regulations and sign them off as having been complied with, when they knew that to be false. The result has been a series of airworthiness related fatal air accidents that litter the military aviation forum, a dysfunctional Military Air Safety System, a compromised Military Air Regulator, and the loss of two entire fleets. Over a 100 deaths resulted as well as the loss of Chinook, Sea King, Nimrod, Hercules, Tornado, and other aircraft and systems. We have one member who defied that order, faced persecution, poor health, and loss of a career. He has campaigned for UK Military Airworthiness Reform ever since.
Never mind about Trade Unions or blaming others, at the end of the day you have to face yourself in the mirror every morning, you have to sleep at night, you have to do the right thing whatever the personal cost.
....or don't pretend to yourself that you are an engineer. You are not!
UK engineers in the MOD forgot this when ordered to suborn the UK Military Airworthiness Regulations and sign them off as having been complied with, when they knew that to be false. The result has been a series of airworthiness related fatal air accidents that litter the military aviation forum, a dysfunctional Military Air Safety System, a compromised Military Air Regulator, and the loss of two entire fleets. Over a 100 deaths resulted as well as the loss of Chinook, Sea King, Nimrod, Hercules, Tornado, and other aircraft and systems. We have one member who defied that order, faced persecution, poor health, and loss of a career. He has campaigned for UK Military Airworthiness Reform ever since.
Never mind about Trade Unions or blaming others, at the end of the day you have to face yourself in the mirror every morning, you have to sleep at night, you have to do the right thing whatever the personal cost.
....or don't pretend to yourself that you are an engineer. You are not!
Thread Starter
I doubt the engineers who signed off on MCAS recognized it as an 'unsafe system'. I've never met an engineer - or even a manager - who would knowingly sign off on something they believed was 'unsafe'. As Safetypee pointed out, much of the issue with MCAS was related to subjective judgements - especially the assumptions of pilot reactions and reaction times. Those judgements in turn lead to the assessment that an MCAS malfunction would be no worse than 'MAJOR' - systems with 'MAJOR' failure consequences don't get close scrutiny because they are not judged to be that serious.
Shortly after the Ethiopian crash, I was at a fancy dinner event where I happened to sit with a group of retired Alaska Airlines 737 pilots. To a man, they agreed that the first thing they'd do if the stab trim started doing something they didn't understand would be to turn it off. But these were old school, high time pilots - some experience dating back to the 737-100/200 series aircraft - and not taking account that at the same time the stick shaker and other alarms would be going off.
Shortly after the Ethiopian crash, I was at a fancy dinner event where I happened to sit with a group of retired Alaska Airlines 737 pilots. To a man, they agreed that the first thing they'd do if the stab trim started doing something they didn't understand would be to turn it off. But these were old school, high time pilots - some experience dating back to the 737-100/200 series aircraft - and not taking account that at the same time the stick shaker and other alarms would be going off.
I'm also reminded of the book written by a US engineer who posts here: 'Cowardice in Leadership - A Lesson in Harassment, Intimidation and Reprisals'.
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tdracer
I am guessing this was before the ET FDR traces were released, be interesting if you asked now and they all said that the first thing they'd do was get the a/c back in trim and then turn it off. Which is actually what the ET crew tried to do but when they turned it off they were still too far out of trim to move it with the too-small trim wheel. The 100/200s had a bigger trim wheel (and smaller stab I think) of course...
BALPA have already come out saying the trim wheel issue needs fixing, I don't think they will be the only ones saying that.
I am guessing this was before the ET FDR traces were released, be interesting if you asked now and they all said that the first thing they'd do was get the a/c back in trim and then turn it off. Which is actually what the ET crew tried to do but when they turned it off they were still too far out of trim to move it with the too-small trim wheel. The 100/200s had a bigger trim wheel (and smaller stab I think) of course...
BALPA have already come out saying the trim wheel issue needs fixing, I don't think they will be the only ones saying that.
The wheel got smaller again compared to the NG and is not intended be changed now AFAIK.
The 737 Max saga is what can happen under a laissez faire Regulator and a Manufacturer run by bean-counters. Suddenly you are left with no defence in depth and have to rely on individuals to stand up and be counted. If they don't then people die, as they did here. No amount of jargon can alter that.
tdracer, if as you say the engineers who signed off MCAS as safe did not know otherwise then it says little for their professional judgement. The system was a turkey from the word go, particularly in its standard form with a single AoA input. As tuc says, we have had similar issues in the UK where the military air regulator (aka the MOD) knowingly released into service a grossly unairworthy aircraft. People died as a result. If the FAA didn't know the Max was unairworthy they were derelict in their duty, if they did then they were criminal in their action. Either way doesn't end well for Boeing or the Airlines. All that could have been prevented if the engineers involved had just said NO!
tdracer, if as you say the engineers who signed off MCAS as safe did not know otherwise then it says little for their professional judgement. The system was a turkey from the word go, particularly in its standard form with a single AoA input. As tuc says, we have had similar issues in the UK where the military air regulator (aka the MOD) knowingly released into service a grossly unairworthy aircraft. People died as a result. If the FAA didn't know the Max was unairworthy they were derelict in their duty, if they did then they were criminal in their action. Either way doesn't end well for Boeing or the Airlines. All that could have been prevented if the engineers involved had just said NO!
Last edited by Chugalug2; 24th Sep 2020 at 12:51. Reason: Words, dear boy, words!