Design Organisations Desing Engineer, Head of Office of Airworthiness (acting) 2016
EASA design organisation approval (DOA) legal basis is EU legislation Regulations are legally binding, hard law European Parliament and Council EU Commision Decisions are legally not binding, soft law EASA (Agency) Design Organisations 1 Slide 2
Regulation 216/2008 (Hard law) Defines EASA Annex II defines article 4(4) aircraft for which 218/2008 is not applicable Annex II aircraft are under Competent Authority jurisdiction (Trafi in Finland) Design Organisations 1 Slide 3
Regulation 748/2012 (Hard law) Part 21 Part 21 is Appendix I to Regulation 748/2016 Part 21 lays down implementing rules for: 1. the airworthiness and environmental certification of aircraft and related products, parts and appliances 2. Certification of design organisations 3. Certification of production organisations Design Organisations 1 Slide 4
EASA Decisions (soft law) Accepted Means of Compliance (AMC) & Guidance Material (GM) to Part 21 AMC are not the only means! The AMC issued by Agency (EASA) shall neither introduce new requirements nor alleviate the requirements of the Part 21 General Means of Compliance for Airworthiness AMC 20 Certificaton Specifications CS-LSA, CS-VLA, CS-23, CS-25 etc. Accepted Means of Compliance & GM to these CS Design Organisations 1 Slide 5
Initial airworthiness Design Organisations 1 Slide 6
Why Design Organisation Approval? Design organisation approval is not required in every case! Design Organisations 1 Slide 7
Typical Design Organisation tasks Type Certification (Part 21 subpart B) Changes to Type Certification (Subpart D) Supplemental Type Certification (Subpart E) Repairs (Subpart M) Design Organisations 1 Slide 8
Type Certification Eligibility (Part 21.A.13) Any natural or legal person that has demonstrated it s capability in accordance with point 21A.14 Design Organisations 1 Slide 9
Type Certification Demonstration of capability (Part 21.A.14) a) Design Organisation Approval (Part 21 Subpart J) b) Alternative means agreed with EASA (ADOA) ELA2 airplanes (non-complex, MTOM < 2000 kg) An engine or propeller installed in ELA2 aircraft c) By providing Certification Programme to EASA. No DOA nor ADOA required! ELA1 airplanes (non-complex, MTOM < 1200 kg) only Design Organisations 1 Slide 10
Minor Changes Part 21.A.91 Classification of changes to a type-certificate A minor change is one that has no appreciable effect on: Mass, balance, structural strength, reliability, operational characteristics, noise, fuel venting, exhaust emission, operational suitability data (OSD) or other characteristics affecting the airworthiness of the product. Any natural or legal person can apply for Minor Change. Design organisation is not a requirement. Approved Design Organisation can approve and certify Minor Changes as priviledge. EASA approves Minor Changes if no DOA. Design Organisations 1 Slide 11
Major Changes All changes which cannot be classified as Minor are Major Changes. Only Type Certificate holder can apply for Major Change. o Other applicants have to apply for Supplemental Type Certificate Only Agency (EASA) can approve Major Changes. Design Organisations 1 Slide 12
Repair Design Repairs are classified as Minor or Major Any natural or legal person can apply for Minor Repair No DOA nor ADOA requirement For Major Repairs demonstration of capability can be done via: DOA ADOA Applicant may seek the agreement of the Agency for the approval of a certification programme. No DOA nor ADOA required! Design Organisations 1 Slide 13
Supplemental Type Certification STCs are Major Changes to Type Certification designed by other than TC holder Demonstration of capability DOA ADOA Demonstration of capability through Agency approval of a certification programme. No DOA nor ADOA required! Design Organisations 1 Slide 14
DOA requirement summary EASA Design Organisation Approval is strictly needed only for Type Certification of complex aircraft! (non ELA1, ELA2) Other design tasks can be done with either Alternative means (ADOA) or with Certification Program agreed with EASA. Design Organisations 1 Slide 15
Annex II aircraft changes Annex II aircraft changes (modifications) fall under Competent Authority (CA) jurisdication. Trafi is the CA in Finland Old national rules (AIR T1-3) are followed for the type change (modification) design and certification Major changes are certified much like the EASA non-(a)doa: a Certification Program is provided to and agreed withtrafi. A design organisation is required for Major Changes no formal approval given nor required(!) for DO in practice DO accepted on case by case basis as part of the Certification Programme Design Organisations 1 Slide 16
Privileges Design Organisation Approval can include privileges Approval of Minor Changes Approval of Minor repairs (also Major if TC holder) Permit to Fly issuance for own aicraft ADOA and non-doa have no privileges! EASA (Agency) level of involvement is lower with DOA Agency shall accept without further verification compliance documents Design Organisations 1 Slide 17
Questions? Design Organisations 1 Slide 18
Part 21 Subpart J Design Organisation Desing Engineer, Head of Office of Airworthiness (acting) 2016
Eligibility as an applicant for DOA Part 21.A.233 Any natural or legal person ( organisation ) is eligible as an applicant for an approval of a) Type Certification b) Supplement Type Certification c) Repairs d) European Technical Standard Order authorisation Design Organisations 2 Slide 2
Application for Minor only Design Organisation Approval can be applied also for Minor changes and repairs only Approval as privilege Typical for small organisations Design Organisations 2 Slide 3
Design Organisation requirements Part 21.A.245 Approval requirements Design Organisation Handbook (Part 21.A.243) Design assurance system (Part 21.A.239) AND staff of sufficient numbers and experience Full and effective coordination between and within departments in respect of airworthiness, operational suitability and environmental protection matters Design Organisations 2 Slide 4
Design assurance system (Part 21.A.239) Ensure compliance with Type Certification basis, OSD and environmental protection requirements Ensure proper functioning of the Desing Organisation Independently monitor procedures of the DO system Head of Independent System Monitoring (HISM) Design assurance system must include an independent checking function regarding compliance statements Compliance Verification Engineer (CVE) Design Organisations 2 Slide 5
Design Assurance system components Design Organisations 2 Slide 6
DOH Design Organisation Handbook (Part 21.A.243 Data) Organisation must prepare handbook describing: Organisation Relevant procedures Products or changes to products to be designed Desing subcontractor activities and assurance of compliance of their work Handbook must be kept up to date and supplied to Agency (EASA) Design Organisations 2 Slide 7
Design Organisation (EASA template) Office of Airworthiness must be established! Design Organisations 2 Slide 8
DO human resources Design Engineers Prepare desíng and compliance documents, instructions etc. and sign them Compliance Verification Engineers (CVE) CVE together with HOA prepares Certification Programme CVE is very important part of independent checking function Checks that technical content of compliance documents is correct Verification of compliance of Certification Specifications CVE cannot check his own work (independency) Aircraft structural design 2016 Design Organisations 2 Slide 9
DO Management Staff Chief Executive (CE) Provides the necessary resources for DO Head of Desing Office (HDO) Unlimited responsibility and liability of the DO work Ensures that Handbook is followed Overall technical responsibility for the company s Design Engineering deliverables Etc. HDO and CE can be one person Aircraft structural design 2016 Design Organisations 2 Slide 10
DO Management Staff Head of Office of Airworthiness (HOA) Liaison between the DO and the Agency with respect to all aspects of Type Investigation Ensuring that a handbook is prepared and updated Preparation of the Certification Programme and co-ordination of all tasks related to Type Investigation Plus 20 other tasks... Head of Independent System Monitoring (HISM) Plan all activities related to the Independent System Monitoring Perform (internal) audits Etc. Aircraft structural design 2016 Design Organisations 2 Slide 11
Example a small organisation Design Organisations 2 Slide 12
Terms of approval Design Organisation terms of approval shall identify: Type of design work Categories of products, parts and appliances Duties the organisation is approved to perform Aircraft structural design 2016 Design Organisations 2 Slide 13
Investigations Design Organisation must allow the Agency (EASA) to make any investigation, including investigations of partners and subcontractors, necessary to determine compliance and continued compliance... Design Organisation shall allow the Agency to review any report and make any inspection and perform or witness any flight and ground test necessary Aircraft structural design 2016 Design Organisations 2 Slide 14
Findings Finding is non-compliance of requirements Level one finding is any non-compliance with Part 21, which could lead to uncontrolled non-compliance with requirements and which could affect the safety of the aircraft Level two finding is any non-compliance with Part 21 which is not classified as level one. Level three finding is potential problem Level one and two finding may cause suspension or revocation of the approval! Aircraft structural design 2016 Design Organisations 2 Slide 15
Duration and validity of DOA Desing organisation approval is unlimited validation unless: DO fails to demonstrate compliance with the requirements of Part 21 subpart J Agency is prevented to perform investigations on DO DO design assurance system cannot maintain satisfactory control and supervision The certificate is surrendered or revoked Aircraft structural design 2016 Design Organisations 2 Slide 16
Privileges (Part 21.A.263 a) and b) ) a) DOA entitles to perform design activities under Part 21 and within scope of approval a) Agency (EASA) shall accept without further verificaiton following compliance documents for obtaining: 1. Approval of Flight Conditions 2. Type Certificate or approval of major change to TC 3. Supplemental Type Certificate 4. ETSO authorisation 5. Major repair design approval Aircraft structural design 2016 Design Organisations 2 Slide 17
Privileges (Part 21.A.263 c) ) DOA can include following privileges (they are not automatic): 1. To classify changes ot type certificate and repairs as major or minor 2. Approve minor changes and repairs 3. To issue information or instructions containing statement under authority of DOA ref EASA.21J.xxx 4. Approve minor revisions to Flight Manual 5. To approve the design of Major repairs to own TC 6. To approve Flight Conditions for Permit to Fly issuance 7. To issue Permit to Fly for own TC or STC Aircraft structural design 2016 Design Organisations 2 Slide 18
Questions? Aircraft structural design 2016 Design Organisations 2 Slide 19