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Proposal to the MDM.032 Working Group. Y Morier Meeting 3 19.05.06. Purpose of the presentation. Individual proposal relative to the possible adaptation to the EU New and Global Approach Possible model to further stimulate discussions. Content of the presentation.
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Proposal to the MDM.032 Working Group Y Morier Meeting 3 19.05.06
Purpose of the presentation • Individual proposal relative to the possible adaptation to the EU New and Global Approach • Possible model to further stimulate discussions.
Content of the presentation • EU New and Global approach • US Light Sport Aircraft rule • ICAO Annex 8 • Proposed adaptation of EU new and global approach to MDM.032 • Concluding remark
EU New and Global approach • Principles: • Harmonisation limited to essential requirements (ER) • Compliance with ER necessary to place on market and put in service • Published harmonised standards are presumed to conform to ER • Application of harmonised standards is voluntary • Manufacturers may choose different conformity assessment procedures. • Safeguard clauses exist
EU New and Global approach • Essential requirements: • ER lay down necessary elements for protecting the public interest • ER are mandatory • ER must be applied as a function of the hazards inherent to a given product.
EU New and Global approach • Conformity assessments: • Eight basic modules which comprise a limited number of different procedures applicable to the widest range of products • Module H: full quality assurance. Notified body responsible for approving and controlling the quality system for design, production and testing of the manufacturer • Relates to design, production or both • As a general rules a product is subject to conformity assessment during design and production • Each new approach directive describe the range and content of conformity assessment procedures
EU New and Global approach • Conformity assessments: • May involve notified bodies • Notified body must have expertise. • Member States are responsible for their notification • Assessment procedures, surveillance procedures for notified bodies.
Example of the light sport aircraft rule in the US • Adopted in 2004, address design, manufacture, operation, maintenance of light sport aircraft and licensing of their pilots and mechanics. • Light sport aircraft: below 1320 lbs
Example of the light sport aircraft rule in the US • For design and manufacture: • Create a new special airworthiness certificate (light sport) • Manufacturers must: • manufacture in accordance to airworthiness standards developed by consensus of FAA and Industry. (consensus standards) • Attest that each aircraft conform to consensus standards • Test each aircraft as described in consensus standards • Develop system for monitoring and correcting safety of flight issues in accordance with consensus standards • Issue pilot operating handbook and training manual
Example of the light sport aircraft rule in the US • For the light sport aircraft consensus standards are developed by ASTM (American Society for testing and material) Committee F-37 • 17 standards available. For example: • Standard specification for the design and performance of light sport airplane • Standard practice for QA in the manufacture of light sport airplane • Standard practice for continued operational safety monitoring of a light sport airplane
ICAO Annex 8 • TC is included in Part II chapter 1 • Applicable after 2 March 2004 • Airworthiness requirement used by States shall comply with Annex 8 • Annex 8 Part V applies to small aeroplanes with a MTOW between 750 and 5700 Kg type certificated after 13.12.2007
Proposed adaptation • Scope: first attempt! • Propeller aeroplanes and gliders below e.g. 2000Kg and above minimum weight TBD but say 70kg • E.g. VFR/IFR; 6 seats; modern and classic technology; piston and turbine • Two sub-categories: • Below 750 Kg • Above 750 Kg • Could be further discussed: • but not very keen to include helicopters
Proposed adaptation: above 750 KG • EASA issues TC and Airworthiness Directives • Use of an adapted module H in particular for Special Conditions and continuing airworthiness • EASA approves Assessment (notified) Bodies • Need to adapt ER: • Taking into account ICAO and improvements already identified
Proposed adaptation: above 750 KG • Standards developed by Standardisation bodies agreed by EASA (e.g. OSTIV; EUROCAE): • Adapt module H • Adapt/Maintain existing CS • Work programme would be agreed by EASA
Proposed adaptation: below 750 KG • Simpler approach: • Similar to light sport aircraft rule? • Industry standards/ self-certification
Rationale for the proposal • Compatible with EU New and Global Approach used for medical equipments, high speed rail system, marine equipment, Single European Sky. • Similarity with light sport aircraft rule but different scope • Safety studies (CAA, NTSB, AOPA, French AIB) tend to show that design and manufacture is not the main cause for accidents in general Aviation
Concluding remark • If agreeable need to be further developed: • This is just a crude concept in particular for aeroplanes below 750kg.
Thank you for your attention Questions/comments are welcome