and also to add, the FAA is typically outbid by corporate dollars and perks when it comes to "highly qualified" in new technology in aviation. The FAA is thus placed in a "catch-up" mode regarding equivalent means of compliance and certification. For sure the FAA learns a lot in their review of the "proposed means" of compliance but some bad assumptions still get through especially when it comes to assumptions about human error.

It is almost impossible to run an ultimate load test on ' only' the wings or 'only' the fuselage except for some ' partial conditions ".. For example over 60 years ago, the 707 fuselage section was immersed in a large water tank and pressurized hundreds- or thousands of times- this the result of Comet disaster re fatigue of window frames. But when it comes to an ultimate test of factory production assembled wings at least part of the fuselage ( above the wingbox ) is involved. -This since to bend the wings up one has to hold something down and if a way was figured out to simply hold the assembled fuselage ONLY above the wing box, it would then call into question about how various loads were distributed, etc. So it is much more realistic ( not discussing regulations for the moment ) to include the whole fuselage (cockpit- above wingbox- fuselage section aft of wingbox - and tail section including aft pressure bulkhead, etc )

Most of the regulations- requirements - were/are the result of the comet disaster- and no doubt further enhanced by the Electra ' whirl mode' disasters. I'm sure a more qualified person than myself can- could expand on my overview above .:oh:

BTW then 767 ultimate load test on wings etc failed due to loads on the aft section and a missing stringer- circumferential near the rear door. result was a approx 10 degree twist of the aft section from normal visible later by the cocked from vertical vertical stabilizer section.

As part of the transition to becoming an ODA, Boeing put in place a number of protections against "undo pressure" - something that didn't exist previously. This included training of management, and most importantly a clearly defined process for reporting incidents of undo pressure. At least in my experience (nearly 30 years, pretty much evenly split between the old DER system and the delegated AR system), I was far better protected as an AR - literally all I had to do was mention that I felt management was approaching 'undo pressure' and they'd immediately back down. In fact, as an AR, I once had my chief engineer tell an engine company to back off when they started pressuring me to approve a flight test result that I was unhappy with.
OTOH, as a DER I was clearly retaliated against when I made a finding of non-compliance (which resulted in an AD). Not only was I removed from the team working the issue (replaced by a DER who later had his delegation pulled by the FAA due to unethical behavior :rolleyes:), I went from retention 1 (hardest to layoff) to a retention 3 (easiest to layoff) and didn't get a raise for two years (at a time when raises went out every six months). When I mentioned this episode to my FAA mentor, I was told it wasn't their problem - it was an internal Boeing issue :ugh:

ODA isn't perfect, but neither was the old system.

There is no perfect system, not in aircraft certification, nor any other discipline in aviation (nor any other industry, for that matter). Events of this past year will serve to remind the delegate community, and those who employ delegates, to discharge the responsibilities with the greatest dedication. I expect that if, in the past, there had been pressures to find compliance from management, management will now be tripping over themselves to demonstrate their patience for the process.

I think the resources / costs, time factor has been succesfully used by Boeing to convince and push congress into increasingly demanding further delegation by the FAA to "industry" since the 2011 FAA re-authorization.

At some point in time we need to be strong enough to recognize this delegation and independent oversight has crossed lines (https://www.barrons.com/articles/boe...tr-51571064129).

We have to implement corrective actions. At this moment this movement is to driven by non US authorities.https://www.businessinsider.nl/boein...onal=true&r=US

The real problem is the management chain. The delegated engineers from the company should have a completely different management chain to the project that they are the delegated certification engineer for. This removes them from the dual pressure of meeting performance targets _and_ the certification targets. Also any manager raising a complaint on a non-compliance finding cannot directly retaliate on 'their' reporting certification engineer, but has to go to another manager in another chain of command to say what their problem is often requiring raising the issue up the project team management chain then across to the certification management and down again. This is normally enough to prevent retaliation or undue pressure to meet performance rather than quality targets.
In most organizations the Quality Assurance system has a completely separate management chain and this can often go up to board level to ensure QA is not put under delivery timescales pressures.

The problem with that is that the DER/AR job is not 'full time' - it's more of a subset to your normal job responsibilities. That's a big part of why the DER/AR system usually works - the DER/AR is very familiar with the system he/she is certifying because it's what they've been working on, and the certification needs are known and implemented into the design early on rather than some last minute bandaids to meet the regs. This is fundamentally different than how the QA system works (on more than one occasion, I had to explain to a QA person what they were looking at and why it was acceptable - they simply don't have detailed system knowledge). The Boeing ODA is already a separate group - with it's own reporting chain (part of the protections put in place for ARs under the ODA), but the ARs still fall under the normal management system for accessing work quality, performance, etc.
Besides, the Boeing management structure is already quite complicated and difficult to understand - adding another management chain might cause it to collapse under it's own weight :rolleyes:

Yes - it still puts the individual in the difficult position of competing aims - so working in a team trying to meet tight deadlines while also insisting on creating 'delays' for specific testing/regression etc. I have been in the position of being an acceptance manager AND tasked with meeting deliverable times - leads to a lot of cognitive dissonance.

On the organization it becomes 'span of command' and 'unity of control' :rolleyes:

See my post today dec 4 15:21 num 4251 on below thread re seattle times and retirement of Chief engineer Hamilton

When it comes to safety, management shouldn't be making the decisions. The decisions should be made in a process based environment. This way there is less chance of being over-ruled by a tier level. I don't know where the problem was at Boeing in this case. I've worked with John Hamilton and found him to be a straight shooter.

Agreed, with introduction of dadoe vents there is little chance that a floor collapse will ever happen again.