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SR 111 Investigation Report

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2.14.5  IFEN STC Project Management

Swissair's decision to acquire a state-of-the-art IFE system for its MD-11 fleet was a business decision. Historically, the airline relied on its MD-11 maintenance provider, SR Technics, to manage any modification work on its MD-11 aircraft. However, after SAir Group was restructured and SR Technics became a separate business entity, Swissair also had the option of acquiring modification services from contractors other than SR Technics. For the IFEN project, Swissair elected to enter into a contract with Interactive Flight Technologies (IFT) to provide all the necessary design, certification, and integration services required to install the system. Because this type of arrangement was not provided for in SR Technics' existing contract with Swissair, the airline entered into a separate agreement with SR Technics to furnish IFT with all necessary support to allow IFT to accomplish the MD-11 IFEN modification. Therefore, while Swissair regarded IFT as the overall IFEN project manager, it considered SR Technics as the sole agency responsible for the continuing airworthiness of its MD-11 fleet.

IFT met its contractual arrangements to Swissair by subcontracting significant portions of the IFEN project. Although subcontracting did not relieve IFT of its overall project management responsibilities, the subcontracting created a project management challenge because IFT did not have the expertise to verify the work of its subcontractors. This situation was compounded by the fact that IFT's prime subcontractor, HI, further subcontracted the delivery of the IFEN project certification services. Consequently, the critical portion of IFT's contractual responsibilities to Swissair became twice-removed from it, further complicating its ability to oversee the delivery of an FAA-approved STC.

Typically, a prime contractor would select a subcontractor based on the subcontractor's reputation, and on the fact that it is certified by the FAA or an equivalent government authority. The expectation exists that a certified company will be able to adequately perform the duties for which it is engaged, and that certified companies are subjected to an effective oversight program by the applicable government authority.

The FAA is the ultimate authority, and therefore is responsible for ensuring that an STC project does not compromise the type certificate of an aircraft certificated under its jurisdiction. In fulfilling this responsibility the FAA relies extensively on its DAS delegate system. The FAA holds the DAS accountable as the primary authority with respect to certification services on any STC project. At the same time, the FAA does not expect a DAS to conduct the same level of surveillance on companies performing STC work as would be required by the FAA in its certification of those companies. The FAA accepts that the DAS can expect that an FAA-certified company will be able to meet the minimum required FAA performance levels, even if that company is not required, by contract, to use its FAA certification directly in a given project.

The project management of the IFEN project did not follow the typical pattern used in the FAA delegation process. SBA was not in charge of the project and did not provide project management. Instead, SBA was contracted by HI, which the FAA would view as working under the authority of SBA. To a large extent, SBA relied on the reputation and FAA's certification of HI to ensure that the IFEN system was properly designed and integrated.

Along with HI and IFT, SBA also relied on SR Technics to provide a level of QA during each IFEN installation. SBA certified the IFEN system based on its assessment of the documentation provided by HI.

The overall result was that the IFEN STC project management structure did not ensure that all the required elements were in place to design, install, and certify a system that would be compatible with the MD-11 type certificate.

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Updated: 2003-03-27

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