1. Federal Aviation Administration Commercial Space Transportation Human Space Flight Occupant Safety Telecon Telecon #3 – Types of Requirements and Guidance October 23 rd, 2012

2. Office of Commercial Space Transportation Federal Aviation Administration 2 Agenda Introduction Rules of Engagement Next Steps Today’s Topic Wrap-up

3. Office of Commercial Space Transportation Federal Aviation Administration 3 Introduction The FAA may not propose regulations covering occupant safety until October 2015. However, we have a team of folks thinking about it now to be prepared, and we're wrestling with a lot of questions that we'd like input from technical folks from industry and government to help us. We are hosting a series of one-hour telecons, each with a narrow focus on a specific technical topic to be held about once a month. We are using our industry advisory committee, COMSTAC, to help us. We are not soliciting any proposals for agency support on this topic at this time. This is background research.

4. Office of Commercial Space Transportation Federal Aviation Administration 4 Rules of Engagement 1. When speaking, please identify yourself so we can follow up with you if we have more questions. 2. We are recording this teleconference. We will publish minutes that summarize the discussion. 3. Please limit your time to 5 minutes of time to allow for greater participation. You are welcome to follow up with a phone call or email to Pam Melroy at pam.melroy@faa.gov or 202-267-7793.pam.melroy@faa.gov 4. AST is not currently in rulemaking, or proposing rules. We are soliciting industry input as research. Should we consider rulemaking in the future, we may use these inputs for background information. If we ask clarifying questions, please do not consider this to imply agreement, or lack of agreement, with your statements.

5. Office of Commercial Space Transportation Federal Aviation Administration 5 Next Steps After today’s meeting, we will take some time to put together minutes and publish them on the AST website. The minutes will contain a list of attendees, the topic(s) discussed, and a summary of what was discussed. We look forward to you participating in the next conference call, tentatively set for November 13 th at 1 pm Eastern.

6. Office of Commercial Space Transportation Federal Aviation Administration 6 Last Month’s Topic Last month, we discussed: What Would FAA Oversight Look Like? We discussed what a licensing process should look like in terms of FAA oversight, whether such oversight could or should be called a “certification,” and for how long informed consent should remain in effect.

7. Office of Commercial Space Transportation Federal Aviation Administration 7 Today’s Topic What Types of Requirements and Associated Guidance Material Should FAA Develop? In general, the FAA favors space transportation regulations that are performance or process based. We will discuss the level of empirical or analytical data necessary to justify any performance-based human space flight regulation, the possible use of Advisory Circulars to add clarity to regulations, and what place government and industry standards should have in FAA licensing.

8. Office of Commercial Space Transportation Federal Aviation Administration 8 Background - Types of Regulations Performance-Based Performance-based regulations state a safety objective to be achieved, leaving the design or operational solution up to the applicant. Example: § 460.11 Environmental control and life support systems. (a) An operator must provide atmospheric conditions adequate to sustain life and consciousness for all inhabited areas within a vehicle…

9. Office of Commercial Space Transportation Federal Aviation Administration 9 Background - Types of Regulations Process-Based Process-based regulations specify risk identification, assessment and control processes that must be undertaken and documented. Example: § 437.55 Hazard analysis. (a) A permittee must identify and characterize each of the hazards and assess the risk to public health and safety and the safety of property resulting from each permitted flight…

10. Office of Commercial Space Transportation Federal Aviation Administration 10 Background - Types of Regulations Prescriptive Prescriptive regulations specify particular features, actions, or programmatic elements to be included in the design or operation, as the means for achieving a desired objective. Example: § 437.51 Rest rules for vehicle safety operations personnel. … (a) No vehicle safety operations personnel may work more than: (1) 12 consecutive hours, (2) 60 hours in the 7 days preceding a permitted activity, or (3) 14 consecutive work days. (b) All vehicle safety operations personnel must have at least 8 hours of rest after 12 hours of work. …

11. Office of Commercial Space Transportation Federal Aviation Administration 11 Discussion Roadmap Justifying Specific Regulations Use of Advisory Circulars Use of Government and Industry Standards 11

12. Office of Commercial Space Transportation Federal Aviation Administration 12 Justifying Specific Regulations What type of evidence of a hazard is needed to justify a regulation? How is previous experience from government human spaceflight mishaps or close-calls relevant? When should a hazard be addressed specifically in a regulation as opposed to expecting an operator to identify and mitigate it in a system safety process?

13. Office of Commercial Space Transportation Federal Aviation Administration 13 Use of Advisory Circulars A drawback of performance-based regulations is that acceptable solutions are often hard to discern. ACs are used in the FAA to provide acceptable means, but not the only means, for demonstrating compliance with specific regulations. Neither mandatory nor regulatory in nature. The FAA considers other methods of demonstrating compliance. Benefits of ACs: Allows the FAA to document government and industry experience. Can be easily updated as industry technology evolves. Is there a preference of having an explicit regulation vs. more general regulation with detailed ACs?

14. Office of Commercial Space Transportation Federal Aviation Administration 14 Use of Government and Industry Standards OMB Circular A-119 directs agencies to use voluntary consensus standards in lieu of government-unique standards except where inconsistent with law or otherwise impractical. Many government and industry standards currently exist for human space flight. NASA’s ISS Crew Transportation and Services Requirements Document (CCT-REQ-1130) incorporates ≈ 43 government and 19 industry standards. Some standards also incorporate mission assurance aspects (not an FAA consideration) How can the FAA and industry best use the existing body of knowledge? Should the FAA try to sponsor industry standards development through an industry standards organization?

15. Office of Commercial Space Transportation Federal Aviation Administration 15 Wrap-up Thanks to everyone for participating! You can post comments, questions, etc. to Docket FAA-2012- 0818. If anyone has any new topics or suggestions on improving this discussion process, contact: Pam.Melroy@FAA.gov 202-267-7793 We look forward to you participating in the next conference call, tentatively set for November 13th. The topic will be “ Key Terms and Definitions for Commercial Human Spaceflight Safety Regulations ”.