Nobody likes to wait for things they need. Waiting can be a waste of time, and time is money. So some folks jump into their DO-254 or DO-178C programs blindly, trying to figure it out and doing the best they can on their own. And they figure they’ll just deal with the FAA directly, later on, when they need to. This is usually not the best approach.
Designated Engineering Representatives (DERs) are those certification experts approved by the FAA to work on their behalf to consult with and/or audit applicants’ programs. These people are highly experienced and have to jump through a lot of hoops to get and keep these prized credentials.
DERs can be your greatest nightmare or your greatest ally. It depends on how you use them. In short, if you wait until late in your process, and go into audits blindly, your experience with a DER may not be pleasant. If, on the other hand, you seek out their expertise to guide you early on in your program, they can be the wisest investment you make in your program.
A key value of working with a DER is that they can quickly answer your questions and get you started in your program on the right path. They can also help quickly get you “unstuck” when you encounter problems. While technically you don’t need a DER in your DO-254 or DO-178C process, the FAA can authorize and typically will encourage your use of FAA approved DERs for your project. The FAA has this system of “representatives” because as a government agency, they have limited resources. If you want to work directly with the precious few employees of the FAA, expect long wait times. Working with a DER can help you avoid the long wait that is typical of interactions with the FAA. These benefits will save you a lot of time.
Even for projects that are not FAA certification programs or are TSOs, if you are being asked to comply with DO-254 or DO-178C, working with an FAA authorized Airborne Software /Electronic Hardware DER will definitely save you time. Unlike FAA auditors, as mentioned previously, DERs can provide you with training, advice, and audit preparation. This knowledge, advice, and preparation can save tremendous time, effort, and ultimately cost in avoided rework arising from audit findings.
Also, consider having an FAA DER involved even before you start a program. DERs can be very valuable allies in the bidding process. DERs can help you understand what it’s going to take to meet the compliance requirements that you may not understand in the contractual wording. The last thing you want is to win a program and realize you severely underestimated the work involved!
DO-254/DO-178C compliance is complicated and costly. That’s the truth and there is no way to fully avoid it. But a savvy business will look at ways to cut costs the smart way – avoiding program stumbles and rework by leveraging experienced support. In other words, investing a little more upfront to work with a DER can save significantly in terms of reducing missteps not to mention audit scheduling wait times. Using a DER can make your whole compliance experience run much more smoothly and efficiently.
But…also be aware that not all “consultants” or “certification experts” are DERs. It’s best to screen folks closely, check multiple references, and verify their credentials by checking the FAA consulting directory, which we have posted on our site : Click Here. Note that you’ll see me and all my credentials on pages 44 (Electrical, which includes SW and HW), 60 (which covers Engines) and 229 (which includes mechanical).
Here is another good starting point to search for an FAA credentialed DER: Designee Locator Search (faa.gov)
Need help finding a credentialed DER? I’m happy to take on your project if I am able and have time, or to point you to someone else if I cannot. Just email me at: firstname.lastname@example.org.