The FAA's “comprehensive review” of the design, production and quality assurance of the Boeing 787 departs, at least in name, from legacy processes that are in place for cases when a certified aircraft exhibits significant safety problems.

Under FAA type certification regulations (Transportation Department Order 8110.4C), a Special Certification Review (SCR) is the only remedy listed for “post-certification evaluations” of a design.

Though FAA officials contend that an SCR would not be broad enough to cover all of the 787 areas of concern, the rules reveal flexibility that allows the agency to delve into “complex, controversial or potentially unsafe” designs or components post-certification,

And while a thorough review is certainly the FAA's goal, avoiding the SCR stigma could be a plus for Boeing.

SCRs have been used sparingly in the FAA's 50-plus years as an agency, but are often perceived as a “black eye” to the aircraft and manufacturer involved. SCR rules direct officials to “thoroughly explore every significant aspect and ramification of the potential safety problem in question,” which would appear to include the production and quality assurance areas.

Earlier SCRs include an investigation of the McDonnell-Douglas DC-10 after a fatal engine-breakaway crash in Chicago in 1989, a review of the MD-11 after an inflight upset killed several passengers in 1993, and analysis of the ATR 72 certification after an icing-related crash in 1994.

Fatalities are not essential to trigger an SCR. The most recent notable SCR targeted the Eclipse 500 very light jet, an aircraft that pushed the boundaries for traditional Part 23 light aircraft certification standards in terms of the avionics and other innovative features.

In that case, the FAA appointed a team of “experienced technical and managerial personnel . . . with no prior involvement in the Eclipse 500 type-certification program” to perform a 30-day review to determine if the aircraft was certificated “in conformance with [regulations] in four areas—cockpit displays/screen blanking, stall speeds, trim and flaps.” The SCR team followed a flow diagram that started with a review of the certification basis for the very light jet—including special conditions, policy memos and ELOS papers—and ended with an assessment of reported anomalies based on the system safety assessment prepared by Eclipse during the certification. Along with interviews, the group reviewed service difficulty reports before coming up with eight “findings” and six recommendations to improve the aircraft.

For the 787, the FAA and Boeing released few details about the specifics of their joint inquiry into the certification, production and quality control aspects of the aircraft when launching the comprehensive review of the new twinjet, prompted in large part by a series of battery problems.

FAA Administrator Michael Huerta on Jan. 11 said the emphasis would be on the widebody's electrical system, which depends on lithium-ion batteries as its primary power storage medium, as well as the power-distribution system and interaction between various mechanical and electrical systems.

The agency added key details on Jan. 16, however when it grounded the U.S. fleet of six 787s owned by United Airlines, via an emergency airworthiness directive.

The action was prompted by an inflight emergency on an All Nippon Airways (ANA) 787 after the crew received warning lights and detected an odor. Though the incident ended in a safe landing with passengers evacuating to the runway on slides, a preliminary investigation revealed a failure of the lithium-ion battery. Dots were connected between the ANA incident and a battery failure on a Japan Airlines 787 on the ground at Boston Logan International Airport on Jan. 7. Both aircraft had battery failures that “resulted in release of flammable electrolytes, heat damage and smoke,” states the FAA.

As a result, the U.S. airline safety agency is now saying the comprehensive review will also include a validation “that 787 batteries and the battery system on the aircraft are in compliance with the special condition the agency issued as part of the aircraft's certification.”

The new details more tightly couple the FAA to both the problem and the solution since the agency, by regulation, must be “directly involved” in safety and compliance decisions for special conditions, meaning the work cannot be outsourced to designated engineering representatives at Boeing.

In this case, FAA had approved “special conditions” for certifying the lithium-ion batteries, a required step as legacy type-certification rules do not cover the advanced technologies. Other companies, including Airbus and Gulfstream Aerospace have received similar approvals for lithium-ion batteries for use on the A380 and G650, respectively. Airframers will generally demonstrate that proposed new technologies will have an equivalent level of safety (ELOS) to traditional systems through analyses and “issue” papers that the FAA must approve.

The FAA has not set a timeline for its 787 review to be wrapped up. “We'll see where the data take us,” says Huerta.

As for the grounded 787s, the FAA states: United “must demonstrate . . . that the batteries are safe, but that the agency will “work with the manufacturer and carriers to develop a corrective action plan to allow [the] fleet to resume operations as quickly and safely as possible.”