EASA policy on passive RFID devices

1. EASA policy on passive RFID devices Markus GörnemannCertification Manager Parts & Appliances

2. Overview • Identification of Issue • Definition of RFID Devices • Current Experience with RFID Devices • Draft EASA Policy • Further Considerations • European Standards

3. Identification of Issue • Passive RFID devices have been used in the Industry for several years now and first requests from Aviation Industry have been received. They can be used in a wide field, ranging from • simple labelling, • to storage of maintenance records, • cargo identification and positioning, • passenger identification and counting. • The use could lead to a reduction in human errors, safeguard against bogus parts, and better determination of the modification status for used parts and as such could improve safety if properly implemented. In addition this could lead to a reduction of costs.

4. Definition of RFID Devices • Basically there are three possible options for RFID devices which can be defined as follows • Passive: Employs no on-chip power source. This passive type of RFID device provides information purely by the backscatter of radiation from an interrogator device or via inductive coupling; • Battery Assisted Passive (BAP): These are RFID devices with batteries, but they communicate using the same backscatter technique as passive devices (devices with no battery). They use the battery to run the circuitry on the microchip and sometimes an onboard sensor. They have a longer read range than a regular passive tag because all of the energy gathered from the reader can be reflected back to the reader. They are sometimes called "semi-passive RFID devices."; and,

5. Definition of RFID Devices • Active: Employs an integrated or aircraft onboard power supply to provide information rather than solely the backscatter energy of the interrogator. This type of an RFID device can transmit at a predetermined periodic polling rate or when activated by an interrogator device.

6. Current Experience with RFID Devices • Several NAAs within Europe have received requests for use of these devices onboard aircraft. Their review was made on the basis of “Non-Interference” of the device with airborne systems. The reviews included environmental testing of passive RFID devices according to EUROCAE ED-14D/RTCA DO-160D Sections for • Temperature, • Vibration • Shock • Humidity • Fluids • Electromagnetic Compatibility, as well as Flight Tests on board of commercial airliners. These entire tests have indicated that the passive RFID devices worked according to their intended function and without interference of aircraft systems.

7. Current Experience with RFID Devices • No knowledge has been gained at the Authority level with “battery-assisted passive” and “active” RFID devices yet from an airworthiness point of view. Both kinds need to be assessed separately and are not covered by the EASA Policy.

8. Draft EASA Policy • The following conditions should be considered for the use of passive RFID devices onboard of aircraft: • The RFID devices must not radiate (back-scatter) characteristics with harmonics above a level of 35 dBuv/m. This limit is established to prevent any unwanted signals from becoming a possible source for interference to, or intermodulation with, required critical or essential aircraft equipment or systems.;

9. Draft EASA Policy • The frequency assignment for passive devices must remain outside of the published aviation frequency bands in order to prevent their radiation from affecting critical or essential aircraft systems; • The generation of harmonic frequencies from the RFID devices will be maintained such that the fundamental through the 4th harmonic frequencies do not impinge upon any assigned aviation communication or navigation frequency;

10. Draft EASA Policy (cont.) • The use of passive devices is restricted to ground operations only, i.e., aircraft not-in-motion, where the intended interrogation of any passive RFID device is not conducted while the aircraft is positioned on an active taxiway or runway; • The RFID devices must function properly when installed as required by EASA Certification Specifications 23, 25, 27 and 25.1301/1309 as appropriate;

11. Draft EASA Policy (cont.) • The passive RFID devices must be designed to operate, on ground, in an aircraft operational environment with robust radio frequency stability; • Passive RFID devices comply with applicable regulations and do not impact form, fit, or function of installed systems and equipment;

12. Draft EASA Policy (cont.) • If the “installation/attachment” of the RFID device is done as a post approval action and not part of the initial approval, only companies with knowledgeable personnel are allowed to carry out the task, e. g. approved Design, Maintenance or Production Organisations, approved Operators.

13. Draft EASA Policy - Remarks • The labelling/identification of parts with passive RFID devices can be accepted under certain conditions, as listed above and is not considered as a change to e.g. an already approved ETSO article and does not invalidate the existing ETSOA.

14. How to apply the policy? • EASA cannot approve the RFID devices itself as as part of the aircraft or as equipment. • Best option from EASAs perspective is via an operational acceptance. That is the reason for this proposal to the OST. A JAA TGL adressing the operational needs and taking into account the conditions mentioned above would be the easiest way to allow the use of passive RFID devices onboard aircraft. • Yours views are welcome

15. Further Considerations • The EASA Policy Memorandum does not constitute an operational approval for air operators, as this remains the responsibility of the NAAs. • EASA is working together with the FAA to develop guidance material pertaining to the development of criteria and performance specifications for active and battery-assisted RFID technologies, including the pass/fail criteria for these types of device architecture.

16. Questions