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Changed Product Rule Aircraft Certification Workshop

Changed Product Rule Aircraft Certification Workshop. John McColl. Topics. Conference Objectives Background (including TOR, Schedule & Status) Issues/Debate/Progress & Agreements to date Proposed Changes to AC(J) & Examples Training & Implementation. Conference Objectives for CPR.

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Changed Product Rule Aircraft Certification Workshop

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  1. Changed Product RuleAircraft Certification Workshop John McColl

  2. Topics • Conference Objectives • Background (including TOR, Schedule & Status) • Issues/Debate/Progress & Agreements to date • Proposed Changes to AC(J) & Examples • Training & Implementation

  3. Conference Objectives for CPR • To explainthe current direction of CPR activity. • Clear Understanding of CPR within Authorities & Industry. • Unambiguous Advisory Text. • Agree Upon Implementation & Training.

  4. Background – General • Lack of Adequate Guidance and harmonisation (level playing field for old and new products) on change aspects of aeronautical products. • Task Force Established 1990 , International Certification Procedures Task Force (ICPTF)). • Report issued May 1990 proposing changes to JAR/FAR21 (21.19 & 21.101) to move from a ‘bottom up’ to a ‘top down’ approach to certification of changes. • JAAC Adopted NPA 21-7 (rule) on 30 May 1999 • NPA 21-7 Published in Amendment 2 of JAR-21, 1st March 2001. • FAA Published rule in amendment 21-77 on 7th June 2000.

  5. Background • Advisory material prepared by JAA/FAA/TCCA • This addressed the process and examples for transport category aeroplanes only. • JAA Circulated NPA21-28 on 1st September 2000. • Adopted by JAAC (after some revisions in March 2001). • NPA 21-28 Published in amendment 3 to JAR-21 on 1st November 2001. • FAA Similarly published AC 21.101 August 2001 • TCCA will publish their advisory material based on the harmonized AC(J).

  6. Background • Effectivity Dates; 10 December 2001 for transport category aeroplanes 9 December 2002 for all other products • Ad Hoc Groups & Steering Committee formed to develop examples for other products. • Autumn 2001 – Industry & Authority concerns raised regarding implementation & interpretation of ‘significant change’. • JAA/FAA & TCCA agreed to delay implementation of CPR on all products and continue the revision activity onthe advisory material.

  7. Background • Revised Effectivity Date; 10 June 2003 for all products • JAA CST in consultation with FAA / TCCA & Industry created another Ad Hoc Group with Specific Terms of Reference.

  8. TOR – CPR – All Products • TOR Agreed @ CST Meeting January 2002 • Pre-TOR Discussion CST & CMT wrt Rule change • TOR only Address ACJ • Objective – Implement CPR (Efficiently & Practically) + Harmonise ACJ • Tight Timescale to coincide with 18 month delay (allows for 6 month training and brings all products together)

  9. TOR Deliverable • Harmonise Red/Blue/Green text • Add Rotorcraft Examples • Identify Discriminators (criteria/fast track) Also:- Develop guidance on ‘extent of change’ ‘cumulative effects’ Other Issues:- Assumptions Service Experience Big Reg’s

  10. TOR – 2002 Schedule • Jan 2002 TOR Agreed & Ad Hoc Group Formed • 25 February 1st Meeting @ CJAA • 5 March CMT (Open & Closed Presentation) • 29 March Draft ACJ circ to Ad Hoc Group CST & RST • April CST & RST Agreement Required (RST presentation 17/18 April) (CST presentation 23/25 April)

  11. • End May Issue Draft NPA (2 month comment period for ACJ) • Beg Aug Consultation closed for draft NPA (Reg Div pass comments to Ad Hoc Group) • End Aug Ad Hoc Review late August (meeting 27 to 29 August) • Mid Sep Presentation of the draft AC(J) to RST (12 September)

  12. • End Sept Presentation of draft AC(J) to CST (25/26 Sept) • End Sept Final NPA & Support Material to CST & RST for final agreement • End Oct NPA and support material sent to JAAC for adoption by 30 October 2002. • End Nov JAAC Agreement & Adopt NPA 21-32

  13. FAA Status • Draft AC Change 1now on Public Display • AC Published 23 April + FAA Web Site • Industry & ACO comments by 5 June • Chartered Team meeting 11-13 June • Comments to JAA early August • Review with Ad Hoc Group late August • Publish Dec 2002

  14. TCCA Status • TCCA advisory material will be based on the harmonized ACJ/AC Change 1. • Canadian industry invited to participate in the public comment process of FAA/JAA on draft Change 1 pending issuance of Canadian CPR final rule. • TCCA to remain involved with the FAA and JAA in finalizing ACJ/AC Change 1 • TCCA expects to publish their CPR final rule and advisory material by 1st quarter of 2003.

  15. Ad Hoc Gp Mtg • 28 Participants (Chairman as opposed to St Com) • 3 1/2 Days (JAA/FAA/TCCA/CTA/AECMA/AIA) • Several original ICPTF members • JAA/FAA/TCCA Presentations • AIA Presentation • 1 ½ Days debate on Philosophy and issues • Criteria & Examples agreed – Consensus • Consensus on Major Issues – Agreements • Post Meeting Note; • Approx 6 additional conference calls & final draft @ issue 20.

  16. Issues • Industry recommended rule re-write because flawed, stop ACJ, not agreed, outside TOR • Rule is not clear on change (TC amendments or everything) • Perception of Added Cost, Time & Bureaucracy • Significant Criteria Set Too Low • ‘Significant’ = Amended TC was intent of ICPTF • If threshold too low: Considerable Number of Significant Changes Configuration Issues make it unworkable Configuration Issues could add risk

  17. Issues • Setting Criteria too low 95% added effort for 5% benefit • Industry already complying with 21-7 (21.101) for derivatives • Industry / Authorities could not cope with paperwork • Rule / ACJ is transferring work from FAA to Industry • Large Number of Major Changes • Production line changes should be excluded • DER Delegation may not work (inconsistent interpretation)

  18. Issues • Examples/Tables; Set Too Low and therefore distort intent Cannot capture all changes ‘Conditional’ is of no use ‘Too much wiggle room’ Regulations column is retroactive application • Declaration of Not Significant is not value added • Flow chart is not helpful or logical • DOA Classification of Not Significant required • If Criteria is required, the rule Criteria are not appropriate

  19. Debate • TOR is for ACJ only • ACJ & training can accommodate issues with the rule • ACJ needs to clarify CPR wrt TC & Type Design • Review of FAA data suggests actual unique major changes are relatively low; Part 25, ~ 300 (from 3,000 in a 2 year period) Part 23, ~ 80 Part 27/29 ~ 60 Part 33/35,~ 60 Total ~ 500 • Number of Significant Changes very small • If threshold correct additional effort and paperwork is negligible.

  20. Debate • The design change should drive “Significant”, not the rule • “Significant” should be based on Criteria and not driven by amended TC • Production line changes would normally be not Significant • Examples / Tables approximate to amended TC in most cases • Setting the threshold too high adds risk of getting it wrong • Classification of not Significant would normally be obvious • Additional admin burden would be minimal

  21. Progress • Criteria set at Product Level • Assumptions, examples added to help understanding • Cumulative Effect, examples added, weight & thrust • Agreed to delete requirements column • Agreed that Examples / Tables are required to supplement Criteria • Particular debate on assumptions • Product Group Consensus • Excluded examples will be used for training database

  22. Agreements - Consensus • The design change should drive “Significant’’, not the rule • The change should be at Product level (not component) • Automatic Criteria for Significant • Tables of Examples that validate Criteria Attempt to have Not Sig examples set at high level • Classification / Delegation of Not Significant • Threshold approximates to Amended TC / Derivative • AC(J) to be drafted reflecting the above

  23. Changes to AC(J) • Major re-write & Includes all Products • Minimise confusion (Added an applicability, define) Minor, Major, STC’s, TC, Type Design • Added a General Overview • Updated flowchart with steps that relate to text • Concentrates on the determination of Significant • Addresses classification of changes - Delegation • Clearly stated that threshold normally approximates to derivative (Product Level) • 3 Automatic Criteria defined • ‘Fast Track’ replaced with more obvious classification

  24. Changes • Appendix 1, changed from Process to Examples Criteria Supplemented by Examples; 168 Part 23, 25 Significant, 43 Not Significant Part 25, 17 Significant, 13 Not Significant Parts, 27&29 14 Significant, 9 Not Significant Parts, E&P 14 Significant, 33 Not Significant 70 98 • Appendix 2, Impracticality (minimum change (23&25) examples) • Appendix 3, Service Experience (minimum change (25 & 29 examples))

  25. Part 23 Only The following are examples for significant changes: Description of Product Level Change 21.101(b)(1)(i) Is there a Change to the General Configu-ration? 21.101(b)(1)(i)Is there a Change to the Principles of Construction? 21.101(b)(1(ii) Have the assumptions used for Certification been invalidated? Notes Conventional tail to T-tail or Y-tail, or vice versa Yes Examples – Significant Changes

  26. Typical Examples of Significant Changes • Large Aircraft Conf. Const. Assu.

  27. Typical Examples of Significant Changes Small Aircraft Conf. Const. Assu.

  28. Typical Examples of Significant Changes Rotorcraft Conf. Const. Assu.

  29. Typical Examples of Significant Changes Engines Conf. Const. Assu.

  30. Typical Examples of Non Significant Changes Large Aeroplanes Conf. Const. Assu.

  31. Typical Examples of Non Significant Changes Small Aeroplanes Conf. Const. Assu.

  32. Typical Examples of Non Significant Changes Rotorcraft Conf. Const. Assu.

  33. Typical Examples of Non Significant Changes Engines Conf. Const. Assu.

  34. Making the Classification The applicant for a change to type certificate makes a classification of significant/non-significant (the application of 21.101(b)(1)) in one of two ways; • By the authority agreeing to appropriate controls and procedures that enable the applicant to make a declaration of not-significant. In all cases the authority retains the option to become involved. An appropriate declaration by the applicant to the authority would be acceptable for this purpose. • By the authority accepting the determination of significance relevant to a major modification based on the applicant’s submission. Note for FAA & TCCA: 2. is replaced by .. 2. By delegation, where appropriate guidelines are in place to support a classification of not significant by the applicant. The Authority may accept the not significant determination without further showing and rely on the applicant’s design control system and the authority’s oversight system to monitor and validate decisions.

  35. Training • Training Material (some already available) (FAA Internal Awareness training was done & TCCA training inc Industry), Do not repeat, Go to Detailed. Agree common material Use draft AC(J) examples as a database for training • Training of Trainers ; Use Ad Hoc Gp Authority & IndustryMembers • Training of Authority & Industry Staff (Joint, if possible)

  36. FAA Training • 3 Meetings to update material to include all products and policy changes regarding the AC. • Lesson development meetings (July, Oct & Nov ’02) • Walkthrough meeting in Jan ’03 • Prototype class Feb ’03

  37. TCCA Training • Training Lesson development: Oct ‘02 – Jan ’03 • Awareness Level training: Satellite Broadcast • 2 sessions (Jan/Feb ‘03) • 1 day each • Specialist Level training; Classroom Delivery • 12 sessions (Feb through May ‘03) • 3 days each • Different locations across Canada • Canadian industry is an integral part of CPR training development and delivery

  38. JAA Training • Population to be trained: Authority (cert/val JAA teams) 250 (estimated) Authority (NAAs) Industry • Training sessions (only for the cert/val teams): 10 sessions (25 participants) • Trainers: 5 (JAA)

  39. JAA Training • Training for JAA trainers: Duration: 3 days (including preparation) Location: CJAA Dates: tbd Material: From jointly developed with FAA & TCCA.

  40. JAA Training • Training for JAA cert/val specialists Duration: 3 days (including preparation) Location: CJAA and NAAs (most suitable for each case) Dates: Not yet available Material: From jointly developed with FAA & TCCA. • Training for Authorities (NAA) (not yet defined) • Training for Industry (not yet defined)

  41. Implementation • Identify internal procedure changes (JAA/FAA/TCCA) • Process for PCM’s, Teams & Authorities to submit data to JAA (EASA) on CPR change applications / determinations (Sig & Controversial Not Sig changes) • Monitor Progress (Consistency) • JAA/FAA/TCCA update & review (initially every 6 months)

  42. Reviewing Objectives • Have we set the bar at the correct level for a Significant Change ? • Clear Understanding of CPR (Authorities & Industry) • Training (Timescales & Participation) • Implementation

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