NASA safety panel reviews commercial crew, tries to justify its paperwork demands

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Link here. The article describes the results from the quarterly meeting of NASA’s safety panel, which occurred last week, including its concerns about the recent test problems during a launch abort test of Boeing’s Starliner capsule. It also describes the panel’s general satisfaction at the status of SpaceX’s Dragon capsule.

The article however ends with a long screed by one panel member, explaining that the heavy paperwork requirements they are imposing on the two companies is not really paperwork.

“It needs to be noted by everyone, and we’re especially interested in making sure that all of the external stakeholders realize this, that while the concluding process of certification has sometimes been described as a paper process, that is really just a shorthand clarification and in reality it could not be further from the truth,” noted Dr. McErlean.

In reality, the process is as follows. “In a certified design, the design agent – the contractor or partner in this case – performs the design and in the certification plan, the design agent and the certification agency (NASA) agree on the submittal of certification evidence.

“This could be measurements, it can be test data, it can be analysis, but it almost always involves the submittal of detailed technical data, not simply paper descriptions or forms. Sometimes it involves witness testing and sometimes it involves physical inspection. But it almost always wraps around important technical submittals.

Can I translate? The safety panel requires a lot of testing so that a lot of paperwork can be filled out. And while much of this testing is likely to help make the capsule’s safer, most of it seems to me to be make-work, and designed to justify the existence of NASA and its safety panel.



  • Edward

    I suspect that Dr. McErlean does not realize the true extent of what is and is not paperwork.

    Paperwork is far, far more than just “simply paper descriptions or forms.” Measurements, test data, analyses, and detailed technical data are all part of the paperwork. Witness testing and physical inspections require documentation, which is also paperwork. Although they are generated before the reports are written, they are paperwork that are used to support the report.

    As an engineer, I discovered that engineers are pretty much paperwork people. They don’t often (but I loved it when I got such opportunities) cut metal, turn screws, mix epoxy, or run tests — although tests require a lot of paperwork during the run in order to document the results, so I consider my time executing tests as mostly doing paperwork. Even as a test engineer, running tests took a minor percentage of my time.

    Mostly, engineering is drawing designs (paperwork), analyzing designs (more paperwork), writing plans and procedures (yes, paperwork), tracking and documenting progress (see a pattern?), reporting to management (often in writing), and meetings (often the preparation and post meeting work is also paperwork). Even supervising technicians requires paperwork in order to document that the procedures are followed or in order to document solutions to technical problems that arise.

    The main product of an engineer is paper. The documentation (paperwork) for making a satellite outweighs the satellite. We may have flown satellites, but paper was our product — contractually deliverable to the customer with the satellite. The good news: the industry is starting to go electronic rather than cellulose, so that should save trees and shelf space.

    From Dr. McErlean: “submittal of certification evidence.

    All of this evidence is paperwork, such as test reports (the test flights are tests, requiring written reports), construction records, designs, etc. NASA, the certification agency, only has paperwork to rely upon to certify the spacecraft, and even their certification report is another paperwork submittal to the manufacturer, the user, and the public.

    In short, we want everyone to realize that this is not a paper sign off process. It involves considerable detailed technical activity by both the certifying agency – NASA in this case – and the design agency or the contractor or partner as well.

    The process results in an approval document. Dr. McErlean may be trying to suggest that it is not a rubber stamp approval process, because it requires reviews and analysis, but paper is the product of the process.

    Should reviewing test data and writing a test report then reviewing the test report and writing a certification report take a year, as has been suggested? I don’t think so, but NASA seems to have a different idea on that:
    Based on NASA’s ‘schedule risk analysis’ from April, the agency estimates that Boeing will reach this [certification to become ready for operational flights] milestone sometime between May 1, 2019, and August 30, 2020. For SpaceX, the estimated range is August 1, 2019, and November 30, 2020. The analysis’ average certification date was December, 2019, for Boeing and January, 2020, for SpaceX.

  • David

    I really need to find it again, but I read an article a while back by a shuttle maintenance supervisor that was talking about how insane the processes were, and how they got that way. Every single step of the process was reasonable, and usually derived from a past failure, eg “an Atlas blew up because this wasn’t done in the right order. This is the process to make sure that doesn’t happen again.” But then he described one example of what that led to: the process for bolting a single shuttle main engine back onto the orbiter, just the simple process of moving it into place and attaching eight bolts, had become a multi-shift exercise involving over 100 people at various steps of the process. And if it got interrupted at any step of the way, god help your schedule as you had to go all the way back to zero, re-certify your starting point, and start over. Just the single step of taking the eight bolts out of secure storage involved 4 people and usually took two hours or more.

  • Douglas Ferguson

    I worked for a defense contractor. We shipped a 2 lb product with 25 lbs of paper.

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