2017 Review

Michael Greer

Principal Airworthiness Surveyor

28 March 2018

Workload

• Currently 158 EASA Part 21 Production Organisations

• 6 Pending / under initial investigation

Findings Analysis - 2017

Total 4322 Level 1

Findings Analysis – 2017 / 2016 Comparison

2017Total 4322 Level 1

0

10

20

30

40

50

60

2017 2016

2016Total 4022 Level 1

What have we been doing?

• New EASA Form 4

• Focus on Root Cause Analysis

• More “risk based” conversations with Accountable Managers

• Global Manufacturing Conference; EASA

• Regulatory Capture

• PAMG / SME working groups

New EASA Form 4

http://publicapps.caa.co.uk/docs/33/SRG1705(EASAForm4)Issue04.pdf

We recently updated the Form 4 as part of the postholder performance project. The changes to the form will allow the following to be captured:

• New Postholder positions within other regulation types

• Declaration from the applicant that they have the knowledge and experience as required in the regulation.

• Requirement to provide a man-hour/resource plan from the applicant to support he has enough capacity to perform the role.

• Declaration from the Accountable Manager that the applicant is competent to perform the role and he has capacity.

• Other minor amendments around giving examples for each of the sections for completion.

Root Cause Analysis

• We are producing a guidance document for organisations

• Initially all CAA Surveyors will be trained on RCA

Root Cause Analysis

• Many aviation organisations operate under Quality systems certified to standards such as ISO 9001, AS9100, AS13000 or participate in accreditation programmes such as PRI Nadcap or UKAS. These standards offer additional guidance on root cause and corrective action methodology to ensure compliance with their requirements.

• This document is intended to build on their documentation and offer some additional airworthiness guidance, as such there should be little or no additional burden to organisations as they should seek to follow one consistent internal approach to root cause.

The Performance Conversation

9

• Specific meetings with Accountable Manager established with Entities as part of the CAA Performance Based Regulation (PBR) process.

• As the prime purpose of the POA is to manufacture to the approved Design Data, a Quality Escape or Concession is an important indicator of performance.

• Includes specifics of company performance in complying to POA requirements, trends in Occurrence Reporting, Concessions, First Time Pass Rates, Scrap Costs etc.

• Entities concept currently restricted to larger organisations approvals with multiple approvals, but we need an understanding of overall POA performance in this area to support surveillance planning.

2017 Global Manufacturer’s Conference

10

• Global production oversightMethods for reducing duplication in oversight of organisations approved by multiple Authorities; Introducing a single Database for reporting the relevant Suppliers’ information.

• Innovative Production Methods - Challenges and Opportunities for Industry and Regulators (e.g. ALM).

New Developments

• Changes to Basic Regulation

• Embodiment of risk-based compliance verification into Part-21

• Opinion 08/2016 Halon - Update of Part-26 to comply with ICAO Standards (RMT.0560)

• Parts without a Form 1 (RMT.0018)

• Regular update of AMC/GM to Part-21

• Update of AMC-20 - In flight entertainment (IFE), lead-free soldering, harmonisation of safety and software criteria (RMT.0561)

Changes to Basic Regulation• Text agreed

• Currently being translated into EU languages

• Likely date for implementation August 2018

• This initiative is part of the 2015 European Commission’s 'Aviation Strategy to Enhance the Competitiveness of the EU Aviation Sector’.

• For this purpose the present initiative proposes to introduce a risk and performance based approach to safety regulation …….

• Safe integration of unmanned aircraft into the European airspace.

• The possibility to transfer responsibilities from Member States to the Agency (which today exists for production facilities and flight simulation training devices) is extended to all types of activities.

• Cyber security.

NPA 2017-19Installation of parts and appliances that are released without an EASA Form 1 or equivalent.https://www.easa.europa.eu/document-library/notices-of-proposed-amendment/npa-2017-19Extension for comments to 30/03/2018

Aim: More proportionate and efficient requirementsCurrent requirements all new spare parts except standard parts accompanied by an Easa Form 1in the airworthiness field, in particular to introduce commensurate manufacturing requirements for new spare parts and appliances. The requirement mandates that parts and appliances to be installed during maintenance need to be accompanied by a European Aviation Safety Agency (EASA) Form 1 to attest manufacturing in accordance with Annex I (Part 21) to Regulation (EU) No 748/2012, which is considered, in certain cases, disproportionate.The so-called commercial parts are an example of that. Since these parts are often not designed exclusively for aviation use, parts manufacturers are not necessarily interested in achieving manufacturing recognition in accordance with Part 21 manufacturing standards (e.g. production organisation approval (POA)). Not only for commercial parts, but also for other parts and appliances a release certificate other than an EASA Form 1 may also be sufficient to guarantee adequate manufacturing quality.In order to ease the manufacturing requirements for some of the parts, this NPA proposes to assign a criticality level (CL) for each part based on the safety consequences should the part fail to meet its design standards.This NPA proposes that only the design holder (for instance, the type certificate holder) can establish the CL for each part, with the default option of assigning the most stringent CL to all parts. In certain cases, the possibility to assign CLs is also given to EASA. This NPA also establishes minimum manufacturing and release certificate requirements based on industry standards depending on the CL assigned to each part. Different marking requirements also apply for each part depending on its assigned CL.Once the implementing rule and related AMC/GM are in place, by alleviating the effective requirements for the manufacture of parts not being critical, the manufacturing costs would decrease without affecting the safety of the air operations. The requirements proposed by this NPA may very positively impact on general aviation (GA), since often certain parts of the aircraft have not been designed with an aviation intent and not manufactured by a POA.

MORs

CAP 382

http://publicapps.caa.co.uk/modalapplication.aspx?catid=1&pagetype=65&appid=11&mode=list&type=search&search=CAP%20382

AVIATION REPORTING PORTAL

http://www.aviationreporting.eu/AviationReporting/

CURRENT BLOG

http://www.caa.co.uk/Blog-Posts/Mandatory-occurrence-reporting/

Thank you

SupplementarySlides

SMS

• Task RMT.0251 (ex MDM.055) will introduce SMS in the ‘airworthiness’ domain.

• Phase I – CAMO

• Phase II Part 21 & Part 145

• Minimum changes to Part-21.

• Human Factors requirements to be added.

SMSTerms of Reference for rulemaking task RMT.0251(b) (MDM.055-MDM.060)

Phase II - SMS for EASA Part-21 design organisations, EASA Part-21 production organisations and EASA Part-145 maintenance organisations’

DD.03.2017 2018/Q1 2019/Q22020/Q4 2020/Q4

SMS

• Nomination of a person or group of persons fulfilling the role of safety manager

• Documented processes for hazard identification

• Processes for safety risk assessment, analysis, including incident investigation, risk mitigation and follow-up of actions

• Implementation of an internal safety reporting scheme

• Safety action planning, including the establishment of a safety review board (SRB), composed of line managers, the accountable manager and the safety manager

ALM

• Additive Layer Manufacturing (ALM), also known as 3-D printing, refers to a range of manufacturing methods where the as-purchased material (i.e. metallic powder, wire, etc.) is consolidated by a machine into a near-finished part by deposition in layers then fused.I.e. the material is created at the same time as the part.

• There are 7 categories • Current CAA position is to adopt the EASA certification memo EASA CM No.: CM-S-008 Issue 01• https://www.easa.europa.eu/document-library/product-certification-consultations/easa-cm-s-008

• Process variability is currently an issue so each part is at present subject to individual qualification.• Implementation of an AM process by a POA holder is controlled through the applicable design data.• Implementation of ALM is considered a change and should be reviewed by the CAA.• Depending on part criticality such a change may not necessarily be a significant change.

• DO / PO Arrangement is key.• PO should submit Quality Plan / Project Plan for review and acceptance prior to

implementation of change.

Thank you

Commission Regulation (EU) No 744/20108 ICAO standards9

Purpose Type of

extinguisher

Type of

halon

Dates Dates

Cut-off10 End New

products11

Cut-off12

Normally

unoccupied cargo

compartments

Fixed 1301

1211

2402

2018 2040 N.A. N.A.

Cabins and crew

compartments

Portable

(Handheld)

1211

2402

2014 2025 2016 N.A.

Engine nacelles

and APU

Fixed 1301

1211

2402

2014 2040 N.A. 2014

Lavatory waste

receptacles

Fixed 1301

1211

2402

2011 2020 2011 2014

Opinion 08/2016 Halon - Update of Part-26 to comply with ICAO Standards (RMT.0560) Halon cut-off dates

• b) AMC 20-30 on lead-free soldering

• In 2003, the European Parliament and the Council issued Directive 2002/95/EC (later replaced by Directive 2011/65/EU6), which required that all new electrical and electronic equipment and systems put on the market after 1 July 2006 do not contain lead (Pb) or other environmentally hazardous materials. Lead was used as surface plating for soldering purposes (e.g. tin/lead solder alloys) on discrete electrical and electronic components, including integrated circuits, semiconductors, capacitors, resistors, and other electronic circuitry, widely used on aircraft.

• 6 Directive 2011/65/EU of the European Parliament and of the Council of 8 June 2011 on the restriction of the use of certain hazardous substances in electrical and electronic equipment (OJ L 174, 1.7.2011, p. 88) (http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1496308907074&uri=CELEX:02011L0065-20160715).

• Pb-free solders and finishes inappropriate to withstand the extreme aviation operating environment may decrease the reliability of systems or subsystems, and ultimately have a negative impact on safety and system performance.

• The objective of this NPA is hence to provide guidance for the transition to lead-free soldering, considering applications for new type certificates as well as changes to existing type certificates.

• (c) AMC 20-19 on IFE systems

• Aircraft IFE systems pose, due to their nature and the technologies used, several challenges which should be addressed in order to minimise safety issues during certification as well as operation of these systems. If these systems suffer a malfunction, this could lead to electrical arcing posing a fire hazard. The development of IFE systems towards open platforms interacting with portable electronic devices (PEDs), either deployed by the aircraft operator or carried on board by the passengers, also leads to more electromagnetic emissions than before.

• Since the first inception of IFE systems, technology has shifted away from simple systems towards more complex ones, which are now becoming increasingly mobile and interactive.

• As the IFE technology is constantly evolving, the regulatory framework should keep the pace and be updated accordingly. Therefore, the objective of this NPA is to provide guidance for the approval of installation of IFE systems.