PRELIMINARY ANALYSIS OF RESPONSES TO INDUSTRY QUESTIONNAIRE

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• PRELIMINARY ANALYSIS OF RESPONSES TO INDUSTRY
  QUESTIONNAIRE
• David Haddon
• Initial Airworthiness
• EASA Rulemaking Directorate

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Background

• WHY A QUESTIONNAIRE?
• Acknowledgement that moving from JAR 21 to Part
  21 (EC 1702/2003) have created some difficulties
  in some areas
• Recognition that industry practices are changing
• To seek out stakeholders views and to build on
  previous discussions to generate specific ideas
• To listen to our stakeholders and to help ensure
  that regulations are developed that are
  appropriate and proportional to the safety risks

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Industry Response

• 3 Associations
• Aerospace Defence Association of Europe (ASD)
• European Council of General Aviation Support
  (ECOGAS)
• European Glider Manufacturers Association (EGM)
• 23 DOA holders
• 16 Non-DOA holders
• Total 42 responses

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The Good News (Advantages of the current DOA
system)

• Clear lines of responsibility
• The level of safety remains very high
• DOA privileges to classify and approve compliance
  with EASA standards
• DOA has contributed to an increased level of
  trust between holders and EASA
• International recognition

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Stakeholder Satisfaction
Only 26 of those who responded said they were
satisfied with the current DOA concept.

• Reasons given for dissatisfaction included
• Part 21 is seen as being inferior to JAR-21/
  National system
• Loss of JB approval
• Framework does not cater for a consortium of
  major companies
• DOA system is not suitable for GA and
  recreational aircraft manufacturers.

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Meeting Future Needs

• 83 of respondents (92 of those who expressed an
  opinion) felt that the existing DOA will be
  ineffective/uneconomic in meeting the future
  needs of Industry.

• Areas for improvement include
• Recognition and distribution of responsibilities
  to suppliers and centres of excellence
• Workshare between the EASA and DOA holders
• De-regulation for GA and recreational aircraft
• Etc, etc.

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Meeting Future NeedsSome Industry Ideas

• Allow TC/STC holders to distribute
  responsibilities and privileges.
• Harmonisation of design assurance rules.
• Recognition of industry standards (e.g.
  EN 9100)
• A single design and production approval.
• Enhanced EASA oversight of NAAs.
• New and/or extensions to DOA privileges
• Simpler rules for GA and recreational aircraft

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Meeting Future Needs Recognising Sub-Contractors

• 67 were in favour of recognising design
  expertise at sub-contractor/supplier level.

• Against were manufactures of non-complex aircraft
  and equipment, who retained expertise in-house.
• A TC/STC applicant will generally not have
  expertise for the complete design.
• Already today, the TC applicant relies on
  sub-contractors/suppliers to support compliance
  declarations.

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Recognising Sub-Contractors

• PROS (for)
• Serves the needs of industry.
• Specialist firms can retain their expertise and
  know-how.
• Post TC work would be more efficient if done by
  the OEM.
• Aid acceptance of European parts in a global
  context.
• Aid standardisation of implementing rules.

• CONS (against)
• Privileges could only be granted if associated
  with a dedicated CS.
• Must not lead to uncertain or ambiguous
  interfaces and responsibilities.
• Determination of the effect a system change has
  on an aircraft could not be made without the TC
  holder, even for the approval of minor mods.

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Meeting Future NeedsNovel Concepts of
Certification

• A modular approach to certification
• 31 generally in favour - 40 against
• Those against were generally the large
  aircraft/engine TC holders and existing DOA
  holders, who felt that this would blur
  responsibilities and create system integration
  issues.
• Extension to ETSO?
• Small aircraft manufacturers would like to keep
  both options open.

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A modular approach to certification

• PROS (for)
• Clearer allocation of responsibilities/liabilities
  .
• TC applicant could accept certification documents
  and data without further verification.
• PMA type approval could help European industry to
  compete.
• For GA applications, plug and play equipment
  could have a unique approval.
• Any generic system with potential multiple
  applications could be considered.

• CONS (against)
• Responsibility should be retained in a single
  org.
• Experience shows that interfaces are problematic.
• An aircraft is not a sum of its parts.
• Developing cert. specs. would be a huge effort.
• Integration of parts could result in dual
  certification.
• Each approval would add additional costs.
• Most systems are adapted for each specific
  aircraft.
• Recognition outside Europe.

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Meeting Future NeedsNovel Concepts of
Certification

• Industry self-certification
• 31 generally in favour - 43 against
• GA and DOA holders (modification/repair),
  generally in favour, Large aircraft/engine TC
  holders and suppliers, against.
• Could be linked to experience or Agency
  confidence.
• A distinction should be made based on the
  criticality of the item.
• Adopt a system of Designees similar to the FAA
  ODA system.

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Industry Self-certification

• PROS (for)
• Product developer is fully responsible/accountable
  .
• Existing DOAs could focus on integration issues.
• Could formally adopt AS EN 9100.
• Would reduce admin., provide flexibility and
  lead to cost/time savings.
• Clearer planning of resources and activities
  would be possible.

• CONS (against)
• Recognition by foreign authorities?
• Decrease in the level of safety?
• Loss of Agency expertise.
• Experience with other self regulating bodies is
  poor.
• Loss of uniformity.
• Insurance?
• Introduction of new technology/processes requires
  independent technical oversight.

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Meeting Future NeedsNovel Concepts of
Certification

• 3rd Party Certification
• Could be on a voluntary basis.
• 3rd party organisation would need to be cheap,
  independent and constant.
• Use existing NAAs in this role, subject to
  control.

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3rd Party Certification

• PROS (for)
• Could increase safety and reduce costs by
  enabling a greater focus on safety rather than
  continually preparing for different audits.
• Would harmonise with FAA ODA.

• CONS (against)
• Will add another tier of bureaucracy.
• Issues of finance may cloud cert. requirements.
• A single independent body should be retained.
• International recognition?
• Impact of insolvency and loss of traceability of
  3rd party organisation.
• Aviation safety is a state function to be
  controlled by the people, for the people.

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Questions

• Please feel free
• to ask any question