FAA Authorizes Remote Inspection/Testing for FAA Employees, Designees, and Manufacturers

The FAA has issued policy permitting FAA employees and FAA designees (including ODAs) to use remote technologies to accomplish certain inspection and testing tasks.  The policy also permits PMA holders to issue 8130-3 tags using remote technology.  The FAA policy is identified as PS-AIR-21-1901.

Tasks that are authorized to be performed remotely under the policy statement include:

• prototype conformity inspections,
• engineering and ground tests,
• engineering compliance inspections,
• production conformity inspections,
• inspections for the issuance of an Authorized Release Certificate, FAA Form 8130-3, Airworthiness Approval Tag

The policy provides extensive guidance on factors to consider when developing a process for the use of remote technology in support of inspections and testing.

For MARPA members, this specifically authorizes remote conformity inspections, and provides standards for an ACO to consider a request for such a remote inspection.  When the FAA is asked to perform a remote test, they will assess the request by using a three step formula:

“1. Determine if the requested use of remote technology will ensure that the FAA or
designee can properly perform their duties.

2. Discuss the request with all FAA authorized test witnesses, manufacturing inspectors,
or designees, as appropriate.

3. Make a determination whether the remote technology can be used to conduct the
inspection or test and inform the applicant of its determination.”

Many MARPA members have authority to issues 8130-3 tags for their articles under 14 C.F.R. 21.137(o).  This policy also permits use of remote technology to perform the inspections necessary to issue an 8130-3 tag.  The PMA holder will need to include the new procedures for such use of remote technologies in its quality manual; these changes should be submitted to the FAA in accordance with your normal procedures for quality system changes.  The procedures should describe (this text is quoted from the policy):

1. How remote technology will be used in real time (not pre-recorded) so that the inspector may direct the inspection as if conducted in-person, on-premises, with the aid of the equipment or the personnel supporting the inspection at the remote location.
2. Procedures for conducting a re-inspection if the equipment malfunctions or the process fails to yield acceptable results. A re-inspection using remote technology may be accomplished after correcting the malfunction or process, or by an actual on-site inspection.
3. How the inspector should record and communicate any difficulties or concerns regarding the process so that the PAH can improve its program.
4. How use of remote technology will be documented on required records.
5. How the remote technology procedures should be audited.
6. For production conformity inspections, the use of remote technology should be agreed to in the Partnership for Safety Plan (PSP), Project Specific Certification Plan (PSCP), or Conformity Plan, or be contained in a prescribed process, or manual, as applicable.

MARPA will be issuing further guidance to its members on how to comply with this policy in a 21.137(o) environment.