For some of us, it seems like the order always existed, but this paper reminds us that FAA’s test safety guidance is relatively young, at least in its current form.

David Downey remembers the travail and birth of the Federal Aviation Administration’s (FAA) Order 4040.26. He describes them in his own words below.

There were many contributors to the FAA Order. Kudos to Rod, Mike White, Eric Bries, Pete Levoci, Jim Richmond, Jim Webre, George Ladane, Pat Morris, Ed Kalano, Tom Archer, Don Armstrong, Rick Simmons…and I am sure I have forgotten several other names. When Order 4040.26 was proposed after a fatal FAA accident the stuff hit the fan both from industry and within the FAA. However, many had the experience from the USN, USAF, and US Army, and other sites–our experience was not welcomed by many.

Many of us knew we did not have a handle on FAA flight test, and we wrote that lesson the hard way with a human toll. For example, I had FAA Type Inspection Authorization (TIA) handed to me that I had never reviewed, and when I asked about review by SMEs was told, “just go fly the test.” In others words, “We do not want to hear your opinion.” 

However, Eric Bries with support from Jay Pardee and others put hard work into the new Order. The Bombardier accident in Wichita was also a catalyst. There was a lot of angst and hard words over who would be doing flight test within the FAA given some other lessons learned. The bottom line is that the culture shifted. It was ugly but every birth has it ugly moments. Rod was a champion and got grief that was unwarranted but he was “spot-on” to use the Brit phrase.

Greg Lewis, Sean Roberts and Nadia Roberts were also keen to support more structure as they (and the subsequent NTPS team) conducted the FAA training. NTPS won the rebid of the contract in the late 2000s. That coupled with their insights into the FAA personnel really called to those of us in the FAA that we needed a course correction. 

It is easy to rest on laurels. That to me is a warning claxon of the need to raise the flag. I also think it is time, to your credit, to re-raise the awareness. 



David Downey is an Associate Fellow in the Society of Experimental Test Pilots, a retired member of the US Air Force, and former manager of the FAA Rotorcraft Directorate.

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