Boeing Seeks FAA Time-limited Exemption for 737 MAX 7 and 737 MAX 10 Certification

Boeing has requested a time-limited exemption from the Federal Aviation Administration (FAA) to certify and deliver the Stall Management Yaw Damper (SMYD) systems on the 737 MAX 7 and 737 MAX 10 aircraft. Neither model has been certified by the FAA to date, and the exemption aims to address specific provisions in the Code of Federal Regulations (CFR) related to the SMYD systems.

Post-Certification Projects Development

On January 21, the FAA published Boeing’s request for an exemption concerning the SMYD systems on the 737 MAX 7 and MAX 10. Boeing stated that the SMYD systems and the enhanced angle of attack (EAOA) certification project for all 737 MAX models, including the 737 MAX 8 and MAX 9, are not fully compliant with two CFR provisions. The company has proposed a timeline to rectify this.

Boeing 737 MAX Exemption
Photo by Manuel Negrerie

Boeing is seeking an exemption to allow the certification and delivery of the SMYD systems through October 31, 2028. This timeframe would facilitate the completion of certification activities and the retrofitting of delivered aircraft to ensure compliance with the relevant regulations.

SMYD System Role

The SMYD is an electronic unit responsible for stall warning, stall identification, and yaw damper functions. Boeing has modified the software for the SMYD system to suit the unique fuselage lengths of the 737 MAX 7 and MAX 10, ensuring consistent performance across these models. Additionally, the software integrates EAOA safety features to improve system integrity and reduce pilot workload during air data or angle-of-attack (AOA) failures.

These failures were contributing factors in two tragic 737 MAX 8 crashes in Indonesia (October 2018) and Ethiopia (March 2019), which resulted in 346 fatalities. Boeing emphasized that the upgraded EAOA system would enhance safety across the entire 737 MAX fleet once the MAX 10’s SMYD system is certified.

Changes in Certification Requirements

Boeing 737 MAX Exemption
Photo by Dave Potter

Historically, the SMYD system has been certified to ‘Level B’ according to Radio Technical Commission for Aeronautics (RTCA) guidelines. However, updated analyses during the certification of the 737 MAX 7 prompted a shift to ‘Level A’ (DAL A) requirements, which the current system does not yet meet. Boeing plans to address this through post-certification projects, including EAOA certification.

The company argues that the exemption is in the public interest as it would enable the certification and entry into service of 737 MAX aircraft with critical safety enhancements. Boeing has reassured that the exemption would not compromise safety and highlighted additional benefits, such as environmental and operational improvements.

SMYD System Reliability

Boeing pointed out that the SMYD hardware in the 737 MAX series remains identical to that in the 737 Next Generation (NG) aircraft, which have accumulated over 25 years of service with high reliability. Updates to the SMYD software are minimal, with less than 10% of the code modified and no changes to the system’s architecture.

Boeing 737 MAX Exemption
Photo by royalscottking via Flickr

The company stated that extensive testing, including simulator evaluations, confirmed the SMYD system’s functionality and verified that software changes did not adversely impact performance. Boeing believes the exemption would enable faster implementation of EAOA features, benefiting safety and operational timelines.

Previous Exemption Requests

In November 2023, Boeing sought another exemption from the FAA for the 737 MAX 7, addressing eight CFR provisions related to the engine nacelle inlet structure and engine anti-ice (EAI) systems. This exemption was withdrawn in January 2024 following an incident involving an Alaska Airlines 737 MAX 9 door plug failure and pressure from stakeholders.

Boeing has since been working on solutions for the EAI system and remains hopeful that both the 737 MAX 7 and MAX 10 will achieve certification by 2025.

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