PRELIMINARY ANALYSIS OF RESPONSES TO INDUSTRY QUESTIONNAIRE David Haddon Initial Airworthiness
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Transcript of PRELIMINARY ANALYSIS OF RESPONSES TO INDUSTRY QUESTIONNAIRE David Haddon Initial Airworthiness
7th November 2006 1
The Future of DOA Workshop
PRELIMINARY ANALYSIS OF RESPONSES TO INDUSTRY
QUESTIONNAIRE
David HaddonInitial Airworthiness
EASA Rulemaking Directorate
7th November 2006 2
The Future of DOA Workshop
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
Background
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The Future of DOA Workshop
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 Future of DOA Workshop
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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The Future of DOA Workshop
Stakeholder Satisfaction
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.
Only 26% of those who responded said they were satisfied with the current DOA concept.
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The Future of DOA Workshop
Meeting Future Needs
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.
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.
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The Future of DOA Workshop
Meeting Future Needs:
Some 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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The Future of DOA Workshop
Meeting Future Needs: Recognising Sub-Contractors
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.
67% were in favour of recognising design expertise at sub-contractor/supplier level.
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The Future of DOA Workshop
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.
7th November 2006 10
The Future of DOA Workshop
Meeting Future Needs:Novel 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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The Future of DOA Workshop
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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The Future of DOA Workshop
Meeting Future Needs:Novel 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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The Future of DOA Workshop
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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The Future of DOA Workshop
Meeting Future Needs:Novel 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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The Future of DOA Workshop
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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The Future of DOA Workshop
Questions
Please feel free to ask any question