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Letter: Isn't it really about certification, bureaucracy?

by Tim Bradshaw | posted on 30 April 2003


Tim's take on this is that it's about insurance and certification. He thinks that the airline industry is, like most industries that deal with safety in a big way, very interested in having things certified as safe - which really means certified as insurable. Tim writes:

So a lot of work will go into making sure that an airliner is certifiable - all the bits it's made out of will be made to precise, documented, and verifiable standards (all the screws won't be ordinary screws, they'll be specially made certified screws, all the aluminium will be of known purity and have documents describing how it was made and so forth). This is all hugely expensive, of course.

Finally, when the whole thing is put together for the first time all sorts of tests will be done which make sure that if another plane is put together the same way it will be safe. Then finally someone will sign off on this whole thing, and other planes can be made, following all these documented procedures, and can also be certified. After they are made, they then have to be maintained with similarly documented procedures and so on.

The aim of all this is to make sure that the planes actually are safe, or at least that if they aren't no one who looked at the certification process could spot that. But more importantly, the purpose of all this is that, if the plane is certified, then the plane is *insurable* while, if it isn't, it's not - the certificate is the document that the insurers insist on having. This is terribly important to an airline, because without insurance they can't fly - the cost of a serious crash could bankrupt them, *especially* given worries about negligence - so long as they can produce the certificate, and demonstrate that their maintenance procedures adhered to its requirements, then they aren't in danger of being done for negligence (and I suppose, possibly, manslaughter of hundreds of people).

So why does all this matter. Well, certification is very expensive to get, because you have to do a lot of elaborate tests. It's even more difficult and expensive to get retrospectively, because by that time you've taken all the test beds to bits and so on. And a lot of planes flying today will have been certified in the 80s or earlier, because planes have long lives and the design and production of them takes a long time.

The avionics of these planes will all have been certified, but when it was done, in 1985 or something, it will have been done in a context where no one had any idea that people would have personal wireless transmitters. So of course no tests like that were done - there would have been lots of tests concerning stuff *outside* the plane, but that's a completely different case. The manufacturers of the avionics are obviously not going to say that they are safe in the presence of wireless transmitters inside the plane without testing them, because if they do that they make themselves liable for any possible problems.

In order for these planes to be certified safe for wireless devices *inside* them then, firstly, the whole certification process for the avionics needs to be redone, which means a lot of seriously expensive tests. But it may be much worse than that: all the individual planes will have drifted apart, as they get new seats and interior fittings and so on, and it doesn't follow that because the original plane was safe, the modified ones are. One reason it doesn't follow is that all the furnishings &c will absorb RF in varying ways, and people sit in different places &c, and no one thought about people with transmitters when the modifications were done. You might need to test almost every plane, individually. Ouch.

But it's even worse: all the wireless devices people have are manufactured to much lower safety standards than plane avionics, and it's possible that they can do really random things. Just because your phone says 100mW at 1800MHz (or whatever), who knows whether some glitch - possibly a software glitch - might cause it suddenly to spit out 5 watts of random noise for a few seconds while it ate its battery? No one cares about that in the context of a phone, but put it inside a plane and suddenly it matters.

Of course, everyone `knows' that it's not actually a problem, but I think it's a huge gap from that to being able to sign a certificate which will cause an insurance company to pay out a huge sum of money if a plane crashes. To get from here to there is a huge amount of money.

I think the current situation is extremely unsatisfactory: the airlines say you shouldn't use phones/WiFi/whatever, presumably to make themselves insurable, but they don't actually enforce it. If anything bad happens then the insurance company could turn around and say `you should have enforced it', and I don't know what happens then - either the airline pays (and likely dies as a result), or they punt it onto the passengers, who are probably already dead ...

This is going to get worse in the presence of more and more wireless-enabled devices - I read recently about some phone which is also a PDA, and the people glibly said `but of course, you can turn off the wireless bit and use it in a plane'. But this turning off is done by *software* and, worse, software written by Microsoft: do you really trust it to *stay* turned off? In the presence of viruses? Hmm.

As you say, the airlines need to get their act together, but I think it's not simple for them. Getting all their planes certified might be more than they can afford, and the other alternative is probably *no* electronics in the plane. Being open about the issues would be a start (I'd like to know if I'm right, apart from anything).

Tim Bradshaw, Cley Limited


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