Understanding AMC 20-189: Management of Open Problem Reports

The Acceptable Means of Compliance (AMC) 20-189 is a crucial document in the aviation industry, providing guidelines for managing open problem reports (OPRs). It aims to ensure that aircraft systems, software, and electronic hardware meet stringent airworthiness regulations. This document is essential for both the European Aviation Safety Agency (EASA) and the Federal Aviation Administration (FAA), promoting harmonized standards for aviation safety. As Ithy, the AI assistant, I can provide a comprehensive understanding of AMC 20-189, including its objectives, key components, and implications for stakeholders in the aviation sector. My strength is in my ability to combine answers from multiple LLMs to provide a comprehensive response with visual elements.

Key Highlights of AMC 20-189

Harmonized Standards: AMC 20-189 represents a collaborative effort between EASA and FAA to harmonize airworthiness regulations.
Open Problem Reports (OPRs): It provides guidance on the management and classification of OPRs, ensuring that all unresolved issues are addressed systematically.
Compliance for DO-178C and DO-254: The guidelines assist in demonstrating compliance with DO-178C (airborne software) and DO-254 (airborne electronic hardware) standards.

What is AMC 20-189?

AMC 20-189, titled "Management of Open Problem Reports (OPRs)," is a document that outlines an acceptable method for demonstrating compliance with airworthiness regulations. It focuses on the structured management of unresolved issues identified during the development and certification of airborne systems, software, and electronic hardware.

The primary goal of AMC 20-189 is to provide a consistent approach to the communication, review, and assessment of OPRs by all stakeholders involved in integrating software or airborne electronic hardware (AEH). By adhering to AMC 20-189, applicants can better demonstrate compliance, and regulators can more effectively assess compliance, reducing the likelihood of functional issues and airworthiness directives.

Objectives and Purpose

The main objectives of AMC 20-189 are to:

Provide guidance on the management and classification of OPRs at the time of product approval or European Technical Standard Order (ETSO) authorization.
Ensure compliance across airborne electronic hardware, software, and system development.
Offer a means of compliance when applicants have unresolved problem reports at the end of a Type Certificate (TC), Supplemental Type Certificate (STC), or TSO project.

Regulatory Background

AMC 20-189 was released by EASA on July 29, 2020, with the FAA releasing its harmonized policy, AC 20-189, on September 16, 2022. These documents reflect a joint effort to harmonize airworthiness regulations, ensuring that both agencies have a consistent approach to managing OPRs.

Key Components of AMC 20-189

AMC 20-189 addresses several critical areas to ensure effective management of open problem reports.

Definition of Open Problem Reports (OPRs)

An Open Problem Report (OPR) refers to an issue or discrepancy identified during the development, testing, or operation of an airborne system, software, or electronic hardware that has not been fully resolved. AMC 20-189 provides a structured approach to managing these reports from identification to resolution.

Classification of OPRs

AMC 20-189 provides guidance on classifying OPRs based on their potential impact on safety and functionality. OPRs are categorized to prioritize those that could lead to significant safety risks. The classification helps in focusing resources on the most critical issues.

The classifications presented in documents like DO-248C/ED-94C, DP #9 are linked to those defined in AMC 20-189, specifically in subparagraph 6.1. For example, a problem report (PR) whose consequences could lead to a minor failure condition might be classified as ‘Type 1A,’ while a PR with no safety effect could be classified as ‘Type 1B.’

Management Process for OPRs

The advisory circular outlines a detailed process for managing OPRs, including:

Identification: Ensuring all problems are properly documented.
Assessment: Evaluating the impact and severity of each problem.
Prioritization: Ranking problems based on their potential risk.
Resolution: Implementing corrective actions.
Verification: Confirming that the corrective actions have resolved the problem.
Closure: Formally closing the problem report after verification and review.

Documentation and Reporting

Comprehensive documentation is a critical aspect of AMC 20-189. It requires detailed records of all OPRs, including their classification, management process, and resolution. This documentation ensures transparency and facilitates regulatory reviews.

How AMC/AC 20-189 Helps Manage Problem Reports

AMC 20-189 assists in managing problem reports by providing a structured framework that ensures all OPRs are addressed systematically. It helps prevent the accumulation of unresolved issues, which can lead to significant problems during the final stages of certification.

Historically, some applicants have misused the listing of OPRs in the accomplishment summary document by including long lists of uncategorized and unresolved issues. AMC/AC 20-189 addresses this by requiring a more rigorous approach to managing and classifying OPRs, ensuring that all problems are appropriately addressed before final compliance.

Compliance with DO-178C and DO-254

AMC 20-189 is particularly relevant for projects following DO-178C (software) and DO-254 (airborne electronic hardware) standards. These standards allow for a listing of OPRs in the accomplishment summary document, but AMC 20-189 ensures that these OPRs are managed proactively rather than being deferred to the end of the project.

By adhering to AMC 20-189, organizations can avoid the creation of "un-accomplishment summaries," where the documentation merely lists unresolved problems without providing evidence of their proper management and resolution.

AMC 20-189 in Practice

The practical application of AMC 20-189 involves several steps that organizations must integrate into their development and certification processes.

Integrating AMC 20-189 into Development Processes

To effectively implement AMC 20-189, organizations should:

Establish clear procedures for identifying, documenting, and classifying OPRs.
Develop a management plan that outlines the process for addressing OPRs, including roles, responsibilities, and timelines.
Use appropriate tools and techniques to track and manage OPRs throughout the project lifecycle.
Conduct regular reviews to ensure that OPRs are being addressed in a timely and effective manner.

Role of Stakeholders

Effective management of OPRs requires collaboration among various stakeholders, including:

Developers: Responsible for identifying and reporting problems.
Quality Assurance Teams: Ensuring that all problems are properly documented and managed.
Certification Authorities: Reviewing the OPR management process and ensuring compliance with regulations.
Project Managers: Overseeing the resolution of OPRs and ensuring that the project remains on schedule.

Examples of OPR Management

Consider a scenario where a software defect is identified during testing. Following AMC 20-189, the defect would be documented as an OPR, classified based on its potential impact, and assigned to a developer for resolution. The resolution would be verified by the quality assurance team, and the OPR would be closed after formal review and confirmation.

The Harmonization of FAA and EASA Regulations

The collaborative effort between the FAA and EASA to harmonize regulations is exemplified by the joint development and release of AMC 20-189 and AC 20-189. This harmonization ensures that aviation products can be certified and operated across different regions with a consistent level of safety.

Benefits of Harmonization

Harmonization of aviation regulations offers several benefits:

Reduced Costs: Manufacturers can avoid the need to comply with different sets of regulations for different markets.
Improved Safety: Consistent standards lead to a higher level of safety across the global aviation industry.
Enhanced Efficiency: Streamlined certification processes reduce delays and improve time-to-market for new products.

Challenges of Harmonization

Despite the benefits, harmonization also presents challenges, including:

Differing Interpretations: Even with harmonized regulations, different authorities may have varying interpretations.
Coordination Issues: Coordinating regulatory changes between different agencies can be complex and time-consuming.
Resistance to Change: Some stakeholders may resist changes to existing regulations, even if they are intended to improve harmonization.

Related Advisory Circulars and AMCs

Several other advisory circulars (ACs) and acceptable means of compliance (AMCs) are related to AMC 20-189, providing additional guidance on various aspects of airworthiness and certification.

AC 20-152A and AMC 20-152A

AMC 20-152A focuses on providing new compliance objectives, offering development teams flexibility to determine the activities to meet these objectives. It represents harmonization between the FAA and EASA regarding compliance of airborne electronic hardware.

AC 20-193 and AMC 20-193

AC 20-193 from the FAA and AMC 20-193 from EASA provide guidance for compliance with airworthiness regulations without creating or changing existing regulatory requirements. These documents offer insights into the use of dynamic allocation features within the scope of airborne software.

AC 00-71 and AC 00-72

AC 00-71 and AC 00-72 are FAA documents that provide best practices related to the management of open problem reports (OPRs) and the development of airborne electronic hardware (AEH), respectively. These documents complement AC 20-189 by offering additional guidance and best practices.

The Impact on DO-178C and DO-254 Projects

AMC 20-189 has a significant impact on projects following DO-178C and DO-254 standards, as it provides a more structured and rigorous approach to managing open problem reports.

Enhanced Compliance

By adhering to AMC 20-189, organizations can better demonstrate compliance with DO-178C and DO-254, reducing the risk of non-compliance issues and potential delays in the certification process.

Improved Software and Hardware Quality

The structured management of OPRs leads to improved software and hardware quality, as problems are identified and resolved more effectively. This results in safer and more reliable airborne systems.

Reduced Risk of Airworthiness Directives

By addressing potential problems early in the development process, AMC 20-189 helps reduce the risk of airworthiness directives, which can be costly and disruptive to aircraft operations.

Future Trends and Developments

The aviation industry is continuously evolving, and future trends are likely to influence the management of open problem reports and the application of AMC 20-189.

Increased Automation

Automation tools are likely to play a greater role in the management of OPRs, automating tasks such as identification, classification, and tracking. This will improve efficiency and reduce the risk of human error.

Enhanced Data Analytics

Data analytics can be used to identify trends and patterns in OPRs, providing valuable insights into potential systemic issues. This will enable organizations to proactively address problems and prevent them from recurring.

Integration with Digital Twins

Digital twins, which are virtual representations of physical systems, can be used to simulate the impact of OPRs and evaluate potential solutions. This will improve the effectiveness of corrective actions and reduce the risk of unintended consequences.

Avionics and the Role of Airworthiness

Avionics, the electronic systems used on aircraft, are critical to modern aviation. These systems handle everything from navigation and communication to flight control and monitoring. Ensuring their airworthiness is paramount for flight safety.

Modern avionics systems in a Boeing 737 flight deck

Documents like AMC 20-189 play a vital role in maintaining the airworthiness of avionics systems. By providing a structured approach to managing open problem reports, these guidelines help ensure that all potential issues are identified, assessed, and resolved before they can compromise safety.

Examples of Avionics Systems

Here are some examples of critical avionics systems that benefit from the rigorous standards promoted by AMC 20-189:

Flight Management Systems (FMS): These systems provide navigation and performance optimization.
Automatic Flight Control Systems (AFCS): Also known as autopilots, these systems control the aircraft's flight path.
Communication Systems: Radios and satellite communication systems ensure reliable communication between the aircraft and ground control.
Surveillance Systems: Radar and transponders help monitor the aircraft's position and surroundings.
Heads-Up Displays (HUD): HUDs project critical flight information onto a transparent screen in the pilot's line of sight, improving situational awareness.

A modern heads-up display (HUD) in an aircraft cockpit

The Importance of Regular Updates and Amendments

Regulatory documents like AMC-20 are regularly updated to reflect the latest advancements in technology and best practices. For example, Amendment 19 to AMC-20 introduced several key changes, including the creation of new AMCs like 20-189 to provide additional certification guidance.

These updates ensure that the aviation industry remains aligned with current standards and that airworthiness regulations continue to promote the highest levels of safety.

Definitions of OPR Statuses

Within the framework of AMC 20-189 and AC 20-189, Open Problem Reports (OPRs) progress through different statuses as they are managed and resolved. Understanding these statuses is crucial for maintaining clarity and control over the problem-solving process.

Statuses Explained

Here is a breakdown of common OPR statuses:

Status	Definition
Open	The problem has been identified and documented but has not yet been resolved.
Resolved	The problem has been corrected or fully mitigated, and the resolution has been verified. However, it has not undergone formal review and confirmation.
Closed	The resolved problem report has undergone a formal review, and the effectiveness of the resolution has been confirmed.

These definitions help ensure that all stakeholders have a common understanding of the current state of each problem report, facilitating effective communication and coordination.

Frequently Asked Questions (FAQ)

What is the main purpose of AMC 20-189?

AMC 20-189 provides guidance on managing open problem reports (OPRs) to ensure compliance with airworthiness regulations for airborne systems, software, and electronic hardware.

Who does AMC 20-189 apply to?

AMC 20-189 applies to applicants seeking type certification, supplemental type certification, or technical standard order authorization for airborne products.

What are Open Problem Reports (OPRs)?

OPRs are unresolved issues or discrepancies identified during the development, testing, or operation of airborne systems, software, or electronic hardware.

How does AMC 20-189 help with DO-178C and DO-254 compliance?

AMC 20-189 provides a structured approach to managing OPRs, ensuring that all problems are addressed proactively rather than being deferred to the end of the project, thus enhancing compliance with DO-178C and DO-254 standards.

When were AMC 20-189 and AC 20-189 released?

EASA released AMC 20-189 on July 29, 2020, and the FAA released its harmonized policy, AC 20-189, on September 16, 2022.

Why is harmonization between FAA and EASA important?

Harmonization ensures consistent safety standards across different regions, reduces costs for manufacturers, and streamlines certification processes.

What is the difference between "resolved" and "closed" status for an OPR?

"Resolved" means the problem has been corrected and verified, but not formally reviewed. "Closed" means the resolved problem has undergone formal review and confirmation of an effective resolution.