NASA Safety Panel Pushes Back Against Commercial Crew “Paperwork” Complaints

Crew Dragon for DM-1 mission with Falcon 9 booster. (Credit: SpaceX)

by Douglas Messier
Managing Editor

In its annual report issued last week, NASA’s Aerospace Safety Advisory Panel (ASAP) pushed back against complaints that the space agency has bogged down the Commercial Crew Program (CCP) with unnecessary bureaucratic paperwork.

“It should be recognized by all parties, both internal and external to NASA, that the certification process is not merely a ‘paperwork’ process; it involves considerable detailed technical activity by both NASA and the partners,” ASAP said.

“It is the completion of NASA’s technical certification of the design, combined with a mission-specific flight readiness review, that assures the crew will fly on an adequately risk-managed spacecraft,” the report added.

The document goes on to describe the certification process that NASA is using for Boeing’s Starliner and SpaceX’s Crew Dragon spacecraft, which are each scheduled to fly uncrewed and crewed flight tests to the International Space Station (ISS) this year.

The comprehensive certification process includes the submission of test data, measurements and analysis by the companies to NASA for review and validation, the report stated. In some cases, NASA employees witness tests or conduct physical inspections of hardware.

ASAP said the process is more limited than the ones NASA has used for previous crewed vehicles.. The space agency was much more involved with design and development in the past, giving it more control over the process and insight into the vehicles.

The commercial crew process is “limited to accepting the vehicles for use by NASA astronauts on a specific mission profile rather than a general safety certification process typically used by the Federal Aviation Administration (FAA) for aircraft.

“Unlike previous human-capable spacecraft developed for NASA missions (ISS, Shuttle, Apollo, etc.), NASA does not own or control the commercial crew vehicle designs,” the report stated.

The certification process is required for the space agency to understand system designs, operational margins and operational envelopes for Crew Dragon and Starliner, the report added.

“While NASA has some experience with qualifying vehicles in this manner, having used a similar process with Evolved Expendable Launch Vehicles for high value payloads as well as its experience with the Commercial Cargo Program, the CCP will for the first time be certifying commercially developed vehicles for human space flight,” ASAP said.

“The Panel again wants to emphasize the importance of a strong, robust certification process that will ensure that data submitted to validate the design meets the stated requirement with the expected margins and that the hardware delivered reflects that design,” the report added.

ASAP said the space agency needs a clear set of guidelines for proceeding when a certification condition is inadequate. “What defines ‘inadequate’ needs to be specified and communicated to the workforce,” the report said.

The panel also made two recommendations to NASA concerning commercial crew.

Required Actions for Crewed Flight Test Risk Reduction: NASA should confirm and then clearly communicate the required content and configuration for the upcoming CCP test flights-Demo-1 and Orbital Flight Test (OFT)-specifically, those items that must be successfully demonstrated prior to the first crewed flights.

Action to Ensure U.S. Access to the International Space Station Given Commercial Crew Program Schedule Risk: Due to the potential for delays in the schedule for the first Commercial Crew Program (CCP) flights with crew, senior NASA leadership should work with the Administration and the Congress to guarantee continuing access to ISS for U.S. crew members until such time that U.S. capability to deliver crew to ISS is established.

NASA had not responded to either recommendation by the time the annual report was printed.

The last American astronaut to fly to the space station is set to return to Earth in January 2020. NASA needs to have at least one of the providers up and running by then to avoid a gap in U.S. occupants on the orbiting facility.

NASA is planning to have Boeing’s second flight test, which will include crew aboard Starliner for the first time, become a long-duration mission to the station. That plan depends upon both the uncrewed and crew flights not experience serious failures.

The current planning dates for commercial crew flight tests to ISS are:

  • SpaceX Demo-1 (uncrewed): March 2, 2019
  • Boeing Orbital Flight Test (uncrewed): NET April 2019
  • Boeing Pad Abort Test: NET May 2019
  • SpaceX In-Flight Abort Test: June 2019
  • SpaceX Demo-2 (crewed): July 2019
  • Boeing Crew Flight Test (crewed): NET August 2019

The schedules for both vehicles have been slipping for years. Additional delays are possible.

Each vehicle and its launcher will need to be certified to carry astronauts on a commercial basis after the crewed flight test. That process is expected to take several months as NASA and the providers comb through data and make any required changes to their systems.

  • Robert G. Oler

    it is an important part of the process. As a software company SpaceX does not grasp that

  • Larry J

    There’s an old saying in aviation that “when the weight of the paperwork equals the weight of the plane, the plane is ready to fly.” For a spacecraft, the paperwork can be multiples of the vehicle weight. It doesn’t really add much to safety but it keeps the gatekeepers employed.

  • Robert G. Oler

    that is really not true…I am just barely familiar with the issues (sorry I am working on the 77X program with a side jab at looking at the Lion Air Crash and still pursueing my PBN assignment…) but they are reasonably serious issues

    as a test pilot they would concern me

  • redneck

    Professional box checkers have CYA as a goal. Preventing any activity is one way of accomplishing that goal.

  • Robert G. Oler

    so you are happy with lion air like operation where the maintenance was all on paper and the paper never reflected reality

  • ThomasLMatula

    The NASA bureaucratic mindset in its glory. The paperwork they required didn’t save the Challenger or Columbia crews did it?

  • redneck

    I’m very unhappy with a process that buries the real problems under mounds of paperwork. Specifications by incompetents cause safety problems. Competence is not promoted by excessive paperwork, and competence is what creates safety. A safety check list is essential for a flight, a safety book, is not. Paperwork is a way of avoiding personal responsibility which is another component of real safety.

  • P.K. Sink

    None of this endless paper shuffling is as useful as one uncrewed test flight to check the systems and shake out the bugs. There is some serious OCD on display here.

  • redneck

    I think the OCD is spelled CYA. They wouldn’t actually care if it augers in as long as they can’t be held responsible.

  • Jeff Smith

    Take all the time that’s needed. Every loss of life in spaceflight can be traced back to a problem that was known before they even got into the spacecraft. Usually the externally imposed scheduled meant everyone was in too much of a rush to fix the problems they knew about.

  • Douglas Messier

    From what I’m hearing, the first uncrewed Starliner flight is going to be an all-up test. The first Crew Dragon isn’t going to test everything. Therein lies the difference.

  • ThomasLMatula

    Old Space Strikes Back as well for USAF launches…

    https://www.bloomberg.com/news/articles/2019-02-12/spacex-launch-certification-to-face-review-by-pentagon-watchdog

    SpaceX Launch Certification to Get Review by Pentagon Watchdog
    By Anthony Capaccio

    February 11, 2019, 9:22 PM CST
    Updated on February 12, 2019, 11:53 AM CST

  • ThomasLMatula

    So what is SpaceX not testing?

  • Douglas Messier

    Good question. I’ll try to find out more.

  • voronwae
  • ThomasLMatula

    Thanks!

  • ThomasLMatula

    Something that Preston Tucker and Howard Hughes would identify with… My worries about the Starship is not the technology, but the political attacks that will be directed against it.

  • Jeff2Space

    That’s going to be a curious investigation. I’m guessing that they will find fault with both SpaceX and USAF. But, one of those almost certainly caused the lion’s share of the problems with the process and will hopefully be smacked down a bit.

  • Jeff2Space

    You keep calling SpaceX a legacy software company. That’s simply not true as SpaceX doesn’t sell software. It sells launch services as well as ISS cargo and ISS crew services.

  • ThomasLMatula

    Looks like that level has been achieved for Stratolaunch 🙂

    https://www.geekwire.com/2019/stratolaunch-will-perform-15-test-flights-faas-experimental-airworthiness-certificate/

    FAA certificate offers new details on Stratolaunch’s plans for test flights of world’s largest aircraft

    by Mark Harris on February 11, 2019 at 3:08 pm

    “The Federal Aviation Administration has cleared the world’s largest airplane for takeoff — but it’s not yet clear exactly when Stratolaunch, the aerospace venture founded by the late Microsoft co-founder Paul Allen, will put the plane in the air.”

  • Kenneth_Brown

    One of the issues right now with Stratolaunch is their divert runway at Edwards AFB is not currently a “dry” lake bed. Another batch of rain is on the way and it could take a couple of months for the lakebed surface to be able to support the plane.

  • Kenneth_Brown

    It’s been a while since the US has had a manned space program. It’s been nearly 8 years and while NASA hasn’t gone anywhere, the people have. NASA also isn’t the design center so they have to understand the design decisions that both SpaceX and Boeing have used to come up with their craft as built. NASA doesn’t want another set of highly trained astronauts made famous by something bad happening.

  • Andrew Tubbiolo

    The industry has to have a discussion with itself over the nature of risk and resultant casualties it’s willing to accept. As others have pointed out, the current safety culture has a casualty rate all its own. Compounding that it seems that depending on the Russians has the benefit of deferring to a state player and NASA uses that as a spiritual crutch to convince themselves that a rated safety culture is adhered to. The past 20 years says otherwise, but to some degree appearances matter more than substance. If SpaceX spawns a maritime branch of space travel, we can expect a maritime casualty rate probably from 100 years ago. So far only Rand Simberg has expounded on the subject in a academic manner. The institutions are going to have to do some spiritual self reflection and consider what kind of organization they want to be. Compounding this will be the military’s reluctance at a subconscious level of having Americans upset their Encapsulated Earth model of national security and accept the chaos of the Caribbean Sea circa 1600’s. The established space policy is very clean and has closed fixed boundary conditions to constrain the solution set with a small number of forcing functions. It’s going to be tough to have them accept unrestrained boundary conditions with even more forcing functions.

  • Robert G. Oler

    there is zero evidence that what you are saying applies here…and lots that says you are wrong.

    ” A safety check list is essential for a flight, a safety book, is not”

    I dont know what a safety book is…but it is essential that one have 1) a process to deal with safety issues that 2) documents the entire procedure so 3) independent analysis can be done on both the process and the actual fix

    I htink SpaceX is with help putting this together now

  • Robert G. Oler

    the problem is that a “maritime” safely level requires maritime levels of operation…and a goal that make such an operation worthwhile

  • Robert G. Oler

    as I have been saying they are very concerned with the safety system at SpaceX

  • Robert G. Oler

    they act like a software company not an aviation one

  • Vladislaw

    They act like the early days of aviation .. not today .. where the Joint strike fighter has a projected average annual cost of something like $12.5 billion, So are they are supposed to act like that?

  • Vladislaw

    “They” can you provide a name for they .. so that it can be verified? I can say “they” are just doing it to so SpaceX down.. without any proof a “they” exists .. you keep saying things like this Robert without ever actually providing a name of anyone. Like you boys in blue comments.

  • ThomasLMatula

    Yes, like Kelly Johnson and the P-80. From the AAF showing him a jet engine asking him to build a plante for it to flying in 180 days with only 130 workers. Today it would take more workers, and time, to do the Power Point for it. 😄

  • redneck

    So you are saying that paperwork is more important than competence and personal responsibility.

  • Mr Snarky Answer

    Indeed old school Skunk Works is how SpaceX operates. Small groups, remove red tape and let them rip.

  • duheagle

    If that’s defined as routinely seeing multiple departures and arrivals per day per port, then, yes, that’s what has to be built toward. If all – or most – goes well, we might be seeing that by the end of the next decade.

  • duheagle

    Yes. The system at SpaceX is proving very unsafe for its legacy competitors. Something Must Be Done.

  • duheagle

    They act like aviation companies used to act, not like the ossified dinosaurs they’ve now become.

  • duheagle

    The “process” has been carefully designed to keep out competition and inconvenient new approaches. The last genuine breakthrough technology in civil aviation was the jet airliner – 60 years ago. The last genuine breakthrough technology in military aviation was stealth – 40+ years ago. “Safety” is just an excuse. Stasis is the goal.

  • ThomasLMatula

    Yep, the ICC had the railroads cling to cabooses for safety reasons for decades after the technology eliminated and need for them anymore.

  • Robert G. Oler

    exactly, there are some significant “no workies” in the first Dragon 2 test

  • Robert G. Oler

    no its op tempo

  • Robert G. Oler

    “they” are friends. and I dont burn friends particularly when well they are good friends 🙂

  • Robert G. Oler

    No. I didnt say that.

    they are fairly equal but the key thing is that the “paperwork” is how you verify competence and personal responsibility

    when I go to the airplane and read the mech who signed off the day check…that is a signature of personal responsibility and competence…now if my plane starts having trouble…that is who we find out why things were missed. It is why I also sign the logbook.

    they are “keys”

  • Robert G. Oler

    it all depends on how you are using that “phrase” …”the early days of aviation”

    the early days of aviation were filled with endless deaths and crashes because the tools to operate airplanes safely were still being developed. Boeing invented the checklist, not because they found that a good idea in a standards meeting but because two people died when the 299 crashed due to pilot error in configuration

    as my first flight instructor told me about “the golden days” …”30 minutes after you left Seattle for Hawaii you had no real idea where you were, the weather ahead and you were waiting for one of the engines to quit”

    I dont recall how many people died as the Brits tried to work their issues out with pressurization on the Comet

    are these the days you are thinking of?

  • Robert G. Oler

    really? then they have been spectacularly bad at it. they have not gotten Dragon 2 along any faster then say Boeing has gotten the 100.

    there is nothing rapid about Falcon series

    where do you see the SR71?

  • Robert G. Oler

    how exactly?

  • Robert G. Oler

    exactly.

  • Robert G. Oler

    silly and not true. airliners from all the western manufactors are evolving in massive ways constantly. you dont understand “breakthroughs”

  • redneck

    What you just described are the rational acts of people on the sharp end.

    What this thread has been about is paperwork imposed by bureaucrats that wouldn’t know an aileron from a trim tab. The kind of people that would have you read a large book for a check list before each flight instead of a list that you can keep track of. And have no concept of the idea that the bird would be grounded by the excessive process, and would be less safe because the incentive for skipping chapters increases.

  • Andrew Tubbiolo

    That will be the nature of the growing pains that maritime space operations will face. They’ll struggle economically and against their own safety culture and lack there-of.

  • Andrew Tubbiolo

    That’s not what’s going on. The process that you are rebelling against is the one that sets up the process that applies checks and certification to how parts enter the program and are used. It also helps write the operations guidelines and checklists that are followed in each step to flight and during flight. The process you consider is rational for flight is also applied to the design, construction, and maintaining of the vehicle not just the operation.

  • redneck

    In my field I have witnessed a steady drop in the quality of contractors, inspectors, and engineering as additional certification requirements are piled on. The more credential-ism required, the less likely they are going to know what really happens in the field. I am having to field redesign projects on a regular basis now when the blueprints don’t match reality. It is quite annoying to have to explain to well paid engineers that they have to redo their work so the project can be done properly. An increasing percentage of contractors don’t know how to actually build. Inspectors have reached the point that it is surprising to get a competent one.