All pilots should fight this change to the ASTM standards. 231 SW Bonanza Gln 269-209-1466 Lake City, FL 32025 386-269-0469 fax kimojim@aol aerosports.org To: All Small Aircraft Manufacturers, 12/31/14 (If you agree, please forward to others) Urgent notice – you need to act now. The ASTM Standard F2972 has been changed and it will impact you! If you are a current Special Light-Sport Aircraft manufacturer or ever hope to be one, this affects you. F2972 is a Quality Assurance standard that you are required to meet to have a SLSA or ELSA inspected for airworthiness. This standard has now been changed to version F2972-14e1. It is in the process of being accepted by the FAA. When it is approved, you will have to have documented proof that all personnel assigned responsibilities in your Quality Assurance manual have completed a required class. The class is a week long and there is currently no known class schedule. The class costs a thousand dollars per student. The class will probably be in a major city and, therefore, will take time and money to attend. You probably have at least three identified personnel in your QA Manual. This means a reasonable estimate of cost is about $6,000 and 6 man-weeks of time. Yet, there will also be delays collecting the classes. Think ahead: Know when this becomes a hard requirement (FAA accepted standards will show F2927-14e1) – go to faa.gov, search on ‘accepted standards’, pick FAA Accepted ASTM Consensus Standards [PDF] Fight against: 1) There will be a ballot through F37.7 to modify this requirement. Vote. 2) You can help by: 3) Joining ASTM. a. Go to ASTM.org and join ($75 a yr), you also get standards access. b. Ask to be a member of committee F37.7 and F37.3 c. Ask for voting rights 4) Contacting FAA, Terry Chasteen ( 816-329-4147) (Express concern and ask for short term relief) 5) Contacting Adam Morrison (317-888-1026) Chairman of the F37.2 Airplane committee (supporting the release and approval of the ballots to remove paragraph 12 of F2972-14e1.) Call me if you have questions. Jim Stephenson Chief Engineer SAFE LLC From F2972-14e1 12. Competence and Training 12.1 Any member of the QAA, identified in the QAM per 4.3.2, must have completed, with documented records, a standards training program within the preceding four years. The training program must leave the student with an understanding of: 12.1.1 Whether there is adequate substantiation to show compliance to the applicable standards set forth in the ASTM standards for LSA. Note that there is no requirement for the training to train personnel to validate every compliance element of every category of aircraft. 12.1.2 The requirements to obtain LSA certification, inclusive of design, performance, quality, and continued operational safety. 12.1.3 The various materials that must be provided with the sale of an ASTM compliant aircraft. 12.1.4 The responsibilities and duties of an ASTM compliant aircraft manufacturer. 12.2 Acceptable means of compliance to these requirements are: 12.2.1 The Light Sport Aircraft course and personnel certificate training program offered by ASTM International. 12.2.2 Another training program, either internal or external, meeting the requirements of Practice E2659 and the requirements given in this section and audited by an accredited third party. 12.2.3 Another program equivalent to 12.2.1 or 12.2.2. NOTE 3—Equivalency per 12.2.3 may include programs such as: (1) Internal training programs embedded within an ISO 9001 or AS/EN 9100 approved system; (2) training programs developed under the supervision of a relevant CAA. Ballot Item F2972-14e1 change ballot. Rationale: In 2003, a significant group of people interested in light aircraft, gathered in Oshkosh to start what would become Light Sport Aircraft Standards. Many of us were skeptical that it was even possible. Could we even get the diverse community to agree on standards? Most significant to the effort was a strong desire to keep the standards simple and possible for even very small manufacturers. We also had a positive and supportive FAA who shared that desire. Committee F37.3 completed its standards in just 9 months. With a total of only 18 pages of work in 5 standards, it epitomized the simplicity and directness needed for the whole community. It seems one cannot divert ones attention even when it appears to be “all done”. The paragraph 12 requirements of F2972-14e1 will (and may already, as of this writing.) require each manufacturer to get documented training for each major officer of the company that is assigned work in their Quality Assurance standard. The training will be $1,000 per person, take a week of class time, be in a major city (read travel, lodging and food), and may have to be delayed until a number of students can be gathered. If not acquired early the requirement could delay completion of aircraft (maybe starting today). FAA audits all new planes and new models. This audit provides assurance that the documentation is complete. When data is missing, FAA should withhold Airworthiness until the deficiencies are corrected. Once data is complete and verified by FAA, it should not just “slip away”. That makes Paragraph 12 redundant. Imagine the impact to a manufacturer who sells $19,000 aircraft to have to spend $6,000, man-weeks effort, and weeks of delays for the class to be able to sell their next ship. Aircraft size, between $19,000 aircraft and $130,000 airplanes, has impacts on funds. The manufacturers have everything they need to comply with the standards. It is not that many pages (Powered Parachutes are only 18 pages total.) and by design they were written as clearly as possible. To comply with the Standards the manufacturers need only write down (document) how they comply with each action paragraph. In cases where manufacturers are confused or need recommendations, there are several knowledgeable subcontractors immediately available to help manufacturers handle any questions. Some have already helped as many as seven manufacturers comply. The new paragraph 12 required classes will impact new manufacturers just when they need to be moving quickly. It will cost more than 6 man-weeks in work effort and $6,000 in direct costs. The number of people needing the class at “any one time” will be small. (We have seen this effect in the Repairman Inspection classes.) That means manufacturers will have to wait up to 6 months to have a chance to get the class. No manufacturer can delay “first sale” 6 months without major impact. The added load to a new manufacturer will be a significant “barrier to entry”. The community has already lost a significant number of manufacturers (I can name several) who have decided to remain kit manufacturers rather than try SLSA, and that is before the redundant paragraph 12 requirement. There are many major issues with the paragraph 12, as written: small-company impact, schedule impacts, type differences, personnel change impacts, lacking communication, foreign manufacturer impacts, excessive controls on the classes. The ballot seeks to reduce the impacts, yet respect the intent. Costs remain an issue. Please vote affirmative on this ballot. F2972 Ballot request. Add the following: 12.3 Special conditions, for each of the following conditions/situations, the manufacturer, meeting the associated status, may have a vehicle inspected for airworthiness. 12.3.1 New manufacturer with new aircraft, if the required personnel are signed up for the next accessible class. 12.3.2 Times of personnel change, if the existing staff has at lease one trained member and the new staff members are signed up for the next accessible class. 12.3.3 Foreign manufacturers that can submit comparable documentation. 12.3.4 Manufacturers of a type not covered by the accessible training.(i.e. PPC, WSC, LTA) 12.3.5 Where costs are a major issue, (some PPCs sell for a little as $19,000) the manufacturer may seek relief from the CAA by documenting use of a supporting third party compliance subcontractor. 12.3.6 Where the manufacturer has completed a compliance audit documented by a third party compliance subcontractor. 12.3.7 Other unique conditions may exist and apply.
Posted on: Wed, 07 Jan 2015 03:37:18 +0000
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