faa perspective federal aviation administration and regulatory update on …€¦ · ·...

Federal AviationAdministrationFAA Perspective

and Regulatory

Update

on Aircraft RFID

Applications

IATA 2nd RFID & Paperless Technical

Operations Conference

November 17, 2015

Brian Verna

Federal Aviation Administration

Avionics Maintenance Branch (AFS-360)

2Federal AviationAdministration

IATA 2nd RFID & Paperless Technical Operations Conference

November 17, 2015

Presentation Topics

• Current Policy

• Examples of RFIDs and their Operational

Uses

• Certification of Installed RFID Devices

• Operational Allowance Considerations

• Conclusion



November 17, 2015

Current Policy (1 of 2)

• FAA AC 20-162, “Airworthiness Approval and

Operational Allowance of RFID Systems”

– Information, guidance, and methods for an acceptable way to

use RFID devices, readers or interrogators installed on

aircraft

• FAA AC 91.21-1C, “Use of Portable Electronic Devices

Aboard Aircraft”, dated May 7, 2015

– Use of “portable” RFID devices on baggage, mail containers,

cargo devices and galley/service carts

– Guidance on design (e.g., RF emissions, transmission

function, and battery qualification)



November 17, 2015

• Draft AC 20-162A expected to be published for

public comment Dec. 2015

– Limits scope to installed, passive RFID devices only

– Active and battery assisted passive RFID tags addressed

in AC 91.21-1C and future AC

– RFID operational considerations removed from AC 20-

162 and addressed in new AC

– Incorporates SAE Aerospace Standard (AS) 5678A for

functional and environmental qualification requirements.

Current Policy (2 of 2)



November 17, 2015

13.56 MHz 915 MHz 2.45 GHz

Passive RFID Tag Examples

Active RFID Tag Examples



November 17, 2015

Air Data Inertial

Reference UnitSmoke Detector



November 17, 2015

Examples of Operational Uses



November 17, 2015

• Airworthiness concerns about RFID devices installed on aircraft include—

– Integrity, accuracy, and authenticity of both safety-related

and identification data from RFID devices

– Fire and electrical safety, crashworthiness, and

environmental effects

– RFID device-generated RF intended transmissions or

spurious emissions, both of which can interfere with

aircraft electrical and electronic systems and components

– Maintenance required for RFID devices and readers.

Certification of Installed RFIDs (1 of 6)



November 17, 2015

• Performance

– Meet the performance standards in SAE AS5678A

– Meet the requirements of ATA Spec 2000

• Configuration control

– Document RFID device(s) make, model, and part number

in the product or equipment Instructions for Continued

Airworthiness (ICA)

– Specify how the device is mounted, located, oriented and

used where configuration control is required.




November 17, 2015

• Software and complex hardware

– If the application uses software, determine software level per

AC 20-115C and RTCA/DO-178B

– If the application uses complex electronic hardware, determine

hardware level per AC 20-152 and RTCA/DO-254

• Environmental qualification

– Follow SAE AS 5678A, Section 6.3.5, for other environmental

qualifications of RFID devices.




November 17, 2015

• Flammability and fire safety.

– RFID device itself, must meet the flammability

requirements

• Larger tags - meet of 14 CFR § 25.853(a) and

appendix F, part I(a)(1)(ii)

• Smaller tags - meet of 14 CFR § 25.853(a) and

appendix F, part I(a)(1)(v)

– Flammability consideration must consider also the

means of attachment to the article.




November 17, 2015

• Mounting and attachment integrity

– The RFID installation must be permanent.

– Installation of RFID devices must comply with 14 CFR

certification requirements.

• ICA

– State service life limit

– State if and when the RFID device requires battery

replacement, recharging, or other periodic maintenance.

– State whether the RFID device, if malfunctioning, must be

removed from the aircraft and replaced with one of the

same type and configuration.




November 17, 2015

• Installed on a non-interference basis.

– Comply with 2X.1301 – Must perform its intended

function.

– Comply with 2X.1309 – Must not impact the

operation of required equipment.

• Alterations per 14 CFR 43.13(b)

– Installer must ensure that “ ...the condition of the

aircraft, airframe, aircraft engine, propeller, or

appliance worked on will be at least equal to its

original or properly altered condition…”




November 17, 2015

Operational Allowance of RFIDs (1 of 4)

• Installation of RFID tags has lead to

innovative uses to take credit for required

maintenance and inspection actions.

• This changes installation from “non-

interference” only to performing required

functions.

• As such, additional requirements must be

applied when considering RFID tags for

these functions.



November 17, 2015

• Use of RFIDs to convey information

required for maintenance programs share

many of the same considerations of any

electronic record keeping system.

• AC120-78 outlines many of the basic

requirements.

– Uniqueness

– Reliability

– Security

– Traceability




November 17, 2015

• Each RFID tag must retain information and

possess the same qualities as the printed

identification tag.

– Identify a specific part including the basic

information necessary to identify individual parts.

– Information must be permanently retained.

– Information must be difficult to alter or change.

• To accomplish this, the tag’s basic

information must be locked.


Uniqueness and Reliability



November 17, 2015

• As a system, the RFID program being used

must be evaluated for security vulnerabilities.

– Must include the tags, readers and the back-end

support systems.

– Use a risk based approach to identify risks and

necessary mitigations.

– Restrict unauthorized alteration of a record, record

entry, or document.

– Readily identify person doing initial data entry or

making changes to data


Security and Traceability



November 17, 2015

Conclusion…

• RFID systems have the potential to provide great innovations on data collection.

• RFID systems must provide equal or better information integrity as the program requirements it replaces.

• RFID systems must be dependable and complete to readily allow airworthiness determinations.

• We are working to develop policy and guidance to ensure continued operational safety.



November 17, 2015

Contact Information

Address: FAA Flight Standards Service

Brian Verna

Aerospace Engineer, AFS-360

Avionics Maintenance Branch

950 L’Enfant Plaza S.W.

5th floor, suite 5100

Washington, DC 20024

Phone: (202) 267-1710

E-mail: [email protected]

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