Information for Delegation Holders

1. Information for Delegation Holders Peter Gill Airworthiness Engineer Design Delegation Holder’s Seminar - 30 March 2012

2. Topics to be covered: • Delegation Changes since 2009 • Major Design Change Authorisation Process • Manufacturing Considerations • STC’s • AC’s • Other Miscellaneous Topics Design Delegation Holder’s Seminar

3. Delegation Changes since 2009 • No approval of modification classified as “major design change” (schedule One) without CAA authorisation • CAA undertook to give authorisation for appropriate “one-off” modifications where not contrary to CAA policy • All delegations which included modifications were re-issued August 2010 Design Delegation Holder’s Seminar

4. Authorisation Process Design Delegation Holder’s Seminar

5. Authorisation Requests • 2010 10 Yes 0 No • 2011 54 Yes 5 No Reasons for No: 1 – Unusual design features 1 – HEC (CAA Policy – STC) 1 – 21.303 (later authorised) 1 – Operational Concern 1 – TCDS Change • 2012 10 Yes 0 No Design Delegation Holder’s Seminar

6. Manufacturing Considerations • Part 146 organisations approve data – do not authorise manufacture • CAA expect part 146 organisations to promote compliance with Rules where possible • CAA has publicised compliance with 21.303 to industry (Vector magasine article Nov/Dec 2010) • Factor in authorisation process Design Delegation Holder’s Seminar

7. Manufacturing Considerations Contd • CAR 21.303 – be manufactured “by a person performing maintenance on the product…” • No subcontracting (can supervise) • NOTE: “Subcontracting” term here is used in the manufacturing sense where the manufacturer takes responsibility for the subcontractors work. • Where the “subcontractor” has an organisation certificate of its own and can issue a release certificate, that is acceptable (they are then a “supplier” rather than a ‘subcontractor”.) Design Delegation Holder’s Seminar

8. Manufacturing Considerations Contd • How to approved “existing” equipment (where origin unknown)? • Should be a document (Form One or Two) identifying part and origin • Part 21Q has always required part marking Design Delegation Holder’s Seminar

9. STC’s • See later presentation from Beth • Small number of “New” STC’s • Large number started, stalled • Time delays – CAA extra assessment • Certification Basis – Determine iaw FAR 21.101 Changed Product Rule • Requirement for any STC where FAA validation is likely to be sought • Should always specify why you can’t/don’t use the latest requirements Design Delegation Holder’s Seminar

10. Advisory Circulars • Advisory Circulars to be revised or written by ACU (we welcome comments or suggestions): • AC 146-1 - Clarify CAA position on “one-man-bands”; Clarify Delegation Issue Process; General Update • AC 148-1 – General Update; Remove Extraneous material; Clarify CAA position on Subcontractors, senior person qualifications, Critical Parts, Design Data. Design Delegation Holder’s Seminar

11. Advisory Circulars Contd • AC 43-9 (Mods, Repairs, 337) – Complete re-write and update • AC 91-5 (PEDS) – General update • New AC on aircraft Electrical Load Analysis - Probably an AC 91-X – detailing how the owner should maintain an ELA for his aircraft Design Delegation Holder’s Seminar

12. Miscellaneous Topics • Where making a minor change to a “major design change” – is this major? • Original approver? • Effect of change? • Continuation of Class A/B delegation classifications? • Not yet determined Design Delegation Holder’s Seminar

13. Miscellaneous Topics Contd • Delegation of Part 146 activities: • Testing • Data (eg Weight & Balance data) • Electrical/Mechanical demarcation • 1309 training – Seen by CAA as essential Design Delegation Holder’s Seminar

14. Miscellaneous Topics Contd • Surveillance – effect of new policy • Increased preparation • More targeted audit • No change to delegate monitoring Design Delegation Holder’s Seminar

15. Questions? Design Delegation Holder’s Seminar