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Regulatory Reform Program Proposed Design Approval Rules CASR Parts 21 and 146 Ian Kearsley Manager Engineering Support

Regulatory Reform Program Proposed Design Approval Rules CASR Parts 21 and 146 Ian Kearsley Manager Engineering Support Section . New Zealand CAA Design Delegation Holders Seminar Auckland 20 October 2005. CASR Parts related to design approvals.

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Regulatory Reform Program Proposed Design Approval Rules CASR Parts 21 and 146 Ian Kearsley Manager Engineering Support

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  1. Regulatory Reform ProgramProposed Design Approval Rules CASR Parts 21 and 146Ian KearsleyManager Engineering Support Section New Zealand CAA Design Delegation Holders Seminar Auckland 20 October 2005

  2. CASR Parts related to design approvals • Part 21 – Certification and airworthiness requirements for aircraft and parts • Parts 22-35 and 90 Airworthiness standards • Part 146 - Engineering representatives • Part 43 – Maintainer’s responsibilities

  3. CASR Part 43 Maintainer’s responsibilities • Set out the performance rules for modifications and repairs • A person must carry out a major modification or a major repair using approved technical data: • approved by or for the State of Design, or • approved by or for CASA under Part 21. • Minor modifications or minor repairs can be done using acceptable data, e.g. ACs, military/industry standards, manufacturer data • New rule is different from current CAR 42U

  4. Major Modifications and Repairs • Are defined similar to FARs – a major modification means a design change: (a) that might appreciably affect the weight and balance limits, structural strength, performance, powerplant operation, flight characteristics or other qualities affecting its airworthiness or environmental characteristics; or (b) that will be embodied on the aircraft according to non-standard practices. • Require a CASA Form 337 for return to service and maintenance record • CASA Form 337 is not to be used as FAA field approval system.

  5. CASR Part 21 • Type certification of aircraft, aircraft engines and propellers • Introduce new provision for approval of technical data for application of TCs, amended TCs, STCs • Approval of parts and appliances e.g. APMAs, ATSO authorisations • Approval of designs of modifications and repairs • Introduce new Subpart 21.M

  6. Approval of technical data • Design data • Drawings and specifications • Information on dimensions, materials and processes • Airworthiness limitations section • Operating limitations • Engineering reports including test plans and test reports that substantiate that the design complies with the applicable airworthiness standards • Approval is issued on CASA Form 979 – similar to FAA Form 8110-3

  7. Subpart 21.M • Provide the rules for approvals of designs of modifications and repairs • Replace CARs 35 and 36 and CAO 100.6 • Limit to a modification or repair of specific aircraft, aircraft engines, propellers, or appliances by serial numbers • Two forms of approval: • for a major change to type design - a Limited STC, or • otherwise - a modification/repair design approval.

  8. Major changes to type design • CASR 21.093 definition: • A minor change is one that has no appreciable effect on the weight, balance, structural strength, reliability, operational characteristics, or other characteristics affecting the airworthiness of an aircraft, aircraft engine or propeller. All other changes are major changes. • MOS Part 21 provides a list of modifications which are major changes and require a Limited STC • similar to FAA Order 8300.10, Vol 2, Chapter 1

  9. Current rule for approval of a design of a modification or repair

  10. Proposed rule

  11. Limited STC • Can only be issued for specific aircraft, engines or propellers specified by serial number(s). • Aircraft must be operated by the same registered operator. • Can be issued by certain Part 146 Organisation Engineering Representatives. • Required a similar process to the issue of an STC • but simplified certification program, data requirements etc. • With additional data, can be converted into an STC for the type.

  12. Grant of Subpart 21.M approvals • Design complies with the airworthiness standards referred to in the type certificate (or equivalent) or latter standards • CASA can agree to equivalent level of safety, impose special conditions, or exempt inappropriate standards for restricted category aircraft • Applicant submits technical data and documents • Applicant carries out required inspections and tests • Applicant can comply with the obligations in the CASRs if the approval is granted

  13. Subpart 21.M other features • Include CAR 36 approval for replacement parts • Provide head of power for approval of technical data (drawings and specifications etc.) • Specify obligations of the holder of the approval: • To provide instructions for continued airworthiness, flight manual supplement as required • To retain design data and records • To report defects as required under CASR 21.003

  14. Part 146 Engineering Representatives • Rules for certification and operation of ERs • Replace current administrative rules for certification of CAR 35 and design approval authorised persons • Individuals and organisations who meet the criteria of Part 146 may be granted an ER certificate • A generic instrument of delegation gives persons who hold an ER certificate the power to perform ER’s functions iaw the certificate • MOS Part 146 sets out Part 21 functions that CASA may delegate to ERs

  15. ER’s delegated functions • Approve or recommend approval of technical data – viz. make findings of compliance to airworthiness standards • CASA may accept findings for the issue of TCs, amended TCs, STCs, APMAs and ATSOAs • Issue design approvals: • Modification/repair design approvals • Limited STCs (restricted to certain OERs) • Minor changes to type design

  16. Part 146 Engineering Representatives • Two types of ERs: • Individuals - Designated Engineering Representatives (DERs) • Organisations - Organisation Engineering Representatives (OERs)

  17. DERs • An individual can apply for a DER certificate • Applicant must meet the qualifications and experience set out in MOS Part 146 • A DER must have: • a Procedure Manual • an airworthiness control system, including the procedure for independent verification of compliance data • a document and record control system

  18. Core DER qualifications and experience • Qualification eligible for graduate member of IEAust, or knowledge and experience acceptable to CASA • At least 8 years relevant experience - each year of completed tertiary course, up to a maximum of 4 years, taken to be 1 year experience. • Thorough knowledge of CASRs and related materials • Familiar with CASA procedures for issuing design approvals • At least 12 months working experience with CASA on aircraft certification matters in the last 3 years

  19. DER Certificates • Consist of a certificate and a function schedule • The function schedule will set out the scope of the delegated functions: • Particular Part 21 provisions e.g. issue modification/repair design approval, approve data for APMA • Airworthiness standards e.g. CASR Part 23, particular FAR 23 provisions • Engineering specialities e.g. structures, systems • Any conditions or limitations • Can be perpetual

  20. Structural Material and Process System & Equipment (Mechanical) System & Equipment (Electrical) System & Equipment (Avionics) Software Power plantinstallation Engines Propellers Flight analyst Flight test pilot General(Modification & Repair) DER Engineering SpecialtiesDefined in MOS Part 146

  21. Organisation Engineering Representatives (OER) • An individual or a body having legal personality can apply for an OER certificate • OER must have: • Suitable organisation, personnel and facilities • Head of Design Approval • Authorised representatives • Internal audit systems • Systems and procedures as for DERs • OERs to have a wider scope of delegated functions than DERs

  22. Authorised representatives • Employed by the OER • Perform the delegated functions for the OER • Must meet the same qualifications and experience as DERs • Are identified in the function schedule of the OER certificate • Will have individual scope of functions similar to DERs

  23. Head of Design Approval • Is responsible to the organisation for : • Managing the design approval functions • Ensuring that delegated functions are performed iaw the regulations • Nomination of authorised representatives • Liaising with CASA on operational matters • Must meet the qualifications for a DER plus • management experience • additional 4 years working experience on similar certification projects

  24. Procedures Manual (PM) • Certain changes to the PM will require approval by CASA prior to implementation: • Items specified in the certificate e.g. scope of delegated functions, company DERs • Procedures to carry out the delegated functions • ERs must provide to CASA any amendments to the PM within 14 days.

  25. ERs to comply with procedures • With regard to the performance of the delegated functions, an ER must comply with the ER’s procedures manual • CASA may also: • Direct an ER in writing to amend the ER’s PM • Give a written direction to an ER setting out a procedure or instruction to be complied with

  26. Project Status • Final drafts of regulations and MOSs will be subjected to CEO Directive 16 review for: • Risk assessment for contribution to aviation safety • Outcome based regulations if possible • Two tiers legislation if possible. • Part 146 is planned for making in the 4nd quarter 2005. • Subpart 21.M will be introduced with Part 146 as a consequential amendment. • New rules to commence 1 year after making.

  27. Transitional provisions for CAR 35 • CAR 35/36 will be repealed when Part 146 and Subpart 21.M commence • A CAR 35/36 approval continues to be in force and has the same effect as the original approval • A pending application for a CAR 35 approval is taken to be an application for a modification/repair design approval made under Subpart 21.M • A new Subpart 21.M application is required for any pending CAR 36 approval.

  28. Transitional provisions for authorised persons • The holder of an IoA for CAR 35/36 or CASR design approval provisions is taken to be the holder of a DER certificate until the shorter of: • the expired date of the IoA, or • 3 years after the commencement of Part 146 • The holder of an IoA for CAR 35/36 may approve technical data or issue modification/repair design approvals iaw the conditions and limitations in his/her IoA.

  29. Transitional Provisions • New entrants, existing IoA holders for design approval provisions or CAR 30 approved design organisations can be certified as consultant DER/OERs after the commencement of Part 146. • All CAR 30 approvals for design organisations will expire 3 years after the commencement of Part 146.

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