We've become used to explaining the difference between qualification and certification to newcomers to the industry: but are also still often surprised how some people already in the industry get the terminology wrong. TDM press releases, LinkedIn, and highly respected trade publications are frequently guilty of reporting newly ‘certified’ FSTDs. But this blog isn't all about that, if there is one thing we’ve found that there is a groundswell of opinion on it is that certification would be a good thing. But we’re not so sure so we thought we'd take a look at the debate.
Just to be sure we're all in the same place let's just do a quick recap on the difference. A product line such as an aircraft is certified, when a new model or variant of an aircraft is proposed it has to go through a rigorous process, sometimes taking years, whereby every aspect of it is tested and demonstrated to the certifying authority. At that point a type certificate is issued and subsequent aircraft are produced under that certification and the manufacturer’s quality system ensures compliance.
For a unique product such as an FSTD they are all individually qualified, every single FSTD produced has its own qualification process (well almost all FSTDs, we’ll come back to that later). The qualification certificate defining the training that particular FSTD is qualified to deliver.
So would Certification be the best thing since sliced bread?
There are certainly some very enticing gains to be had from certification, it would undoubtedly speed up the entry into service of new devices. The TDM would just need to bolt the FSTD together and do some verification checks then issue the operator a certificate of conformity, no tedious onsite evaluations to stress about. What could possibly go wrong, who has ever heard of an FSTD having outstanding discrepancies after Ready For Training (RFT)?
Then of course comes the question of what exactly will be certified. In order to take advantage of the reduced testing on subsequent devices presumably a certification would need to cover the complete FSTD; hardware and software. Then there would need to be the options, just as on an aircraft. Add a HGS, change the visual IG, have a new visual database, change the IOS etc etc and the certification changes.
Hence, when buying a new FSTD one can foresee a conversation along the lines of…. Yes you can choose that visual system and change the IOS to be more like your existing FSTDs, however that will need us to certify that configuration. Unfortunately that will add to the schedule and would you leave your shirts at reception.
We can also envision a discussion whereby a buyer doesn't believe the supplied simulation is correct, or wants a “tweak” only to be told by the TDM that they would love to help them but that is the certified software load and their hands are tied, sorry.
However, in this Valhalla world where certification has been implemented, we come on to updates. At the moment when updating (or upgrading) an FSTD the operator has the responsibility to contact their supervising authority who will decide if a special evaluation is required or, as is most often the case, they will choose to assess the update at the next scheduled recurrent evaluation. Note, this is entirely between the operator and the authority; it doesn't matter who physically did the changes.
Move to a certification world and this would have to change, in short we would enter the world of Supplementary Type Certificates (STC). Any deviation from the certified design would need to be pre-approved and, importantly, the company undertaking the work would need to have the authorities’ approval to issue a STC. Would that be a problem? Depends on whose vantage point you're looking from. We've a sneaky suspicion that the major TDMs would be delighted, they could certify changes on their latest deliveries and offer them as costed updates under that certification, the smaller independent companies would have a dilemma and might well decide it was uneconomical to go for a STC based on likely sales. For the operators they would see reduced competition and, we suspect, another reason for increased prices.
So, that's why we're not so sure. On the face of it there seems a massive advantage in having the TDMs obtain a type certificate for their FSTDs and just provide certificates that the devices they provide are compliant. But as we've indicated it's not that easy. For us the proof it wouldn't work (at least at the moment) is that it hasn't happened. If we were, as an industry, ready we think the regulators would be the ones promoting this. They would be going to initial qualifications and basically wasting their time, each follow on device from a given TDM would be identical, the technical inspectors would never find any issues and the flight inspector would, likewise, find no issues; very quickly the authorities would be the ones saying they were wasting their time looking at each FSTD produced. From what we see, repeat devices are still nowhere near perfect.
We also wonder if there isn't an elephant in the room! If FSTDs were to be treated by the regulators in the same way as certified aircraft, would this, or could this, not open the door to approved maintenance procedures and approved or licenced simulator engineers? We can't see that being a cheap or easy exercise, but possibly something the major TDMs would relish!
Oh and the exception! We hinted above there was an exception to the rule that every single FSTD has to have an individual qualification. Under both EASA and FAA there are classes of FSTD, named Basic Instrument Training Devices (BITD) by EASA and Basic/Advanced Aviation Training Device (BATD/AATD) by the FAA. For these, the TDM does indeed have the responsibility to effectively type certify them; each model is initially certified by the TDM and all serial numbers of the same model are automatically certified. An under utilised niche market that does add low cost training value.
How can Sim Ops help?
Sim Ops is here to expertly guide you through the intricate process of FSTD qualification. With a deep understanding of the industry standards and regulations, our team offers specialized support to ensure your training devices meet all qualification requirements. Contact us for dedicated assistance tailored to your specific needs.