PRELIMINARY ANALYSIS OF RESPONSES TO INDUSTRY QUESTIONNAIRE - PowerPoint PPT Presentation

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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 Background WHY A QUESTIONNAIRE? – PowerPoint PPT presentation

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Title: PRELIMINARY ANALYSIS OF RESPONSES TO INDUSTRY QUESTIONNAIRE


1
  • PRELIMINARY ANALYSIS OF RESPONSES TO INDUSTRY
    QUESTIONNAIRE
  • David Haddon
  • Initial Airworthiness
  • EASA Rulemaking Directorate

2
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

3
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

4
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

5
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.

6
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.

7
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

8
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.

9
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.

10
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.

11
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.

12
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.

13
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.

14
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.

15
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.

16
Questions
  • Please feel free
  • to ask any question
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