the airworthiness review of military aircraft mawc cy...

The airworthiness review of military aircraft MAWC – CY 2012

26 Sep 2012 2

The airworthiness review of military aircraft DIRNAV

Reminder : some airworthiness documents

At the aircraft type level : Type Certificates (TC) :

- Aircraft

- Engine

- Propeller

Supplemental Type Certificates (STC)

For each individual aircraft in service : Certificate of airworthiness (CoA)

Certificate of registration (CoR)

Aircraft TC

Engine TC

Propeller TC

CoA

CoR

26 Sep 2012 3


CoA : Issuance (FRA 21 subpart H)

and validity (FRA M subparts G and I)

CoA

T0 T0 + 1 yr T0 + 2 yr T0 + 3 yr T0 + 4 yr

ARC n°1 1st extension

of ARC n°1

2nd extension

of ARC n°1

Renewal

ARC n°2

CAMO Request

for AR

Recommendation

for AR

Recommendation

for AR

Request

for AR

CNMAA

(DSAÉ)

- carry out the AR

- issues the ARC

Extend

the ARC

Extend

the ARC

- carry out the AR

- issues the ARC

CAMO(1)

CNMAA

(DSAÉ)

issues the CoA

& the CoR

(1) FRA M subpart G approved CAMO with privilege to carry out the AR

3 year cycle

26 Sep 2012 4


What is an airworthiness review (AR) ?

Objective : To make sure Of the conformity of an aircraft to the type definition approved by the CNMAA

Of the implementation of applicable ADs (Airworthiness Directives) issued by the CNMAA or

issued by a Primary authority recognized by the CNMAA

Of the continuing airworthiness of the aircraft

Content : review of the aircraft records

- Reference documentation (accessibility, integrity, updates…)

- Continuing airworthiness records (quality)

and in parallel

physical inspection of the aircraft

The AR is a photo of the state of the aircraft

an audit :

- Part of a thorough process

- Assessment and recognition of the work performed by the CAMO

- Continuing airworthiness responsibility remains within the CAMO

- The auditor shall be a SQEP (Suitably Qualified and Experienced Personnel)

- The auditor can use sampling techniques based on risk analysis

- Ethics, impartiality, conscientiousness, independence

- Factual assessment based on tangible and verifiable evidences

26 Sep 2012 5


Initial Airworthiness Review (AR) :

Legacy aircraft

Annual planning of

Airworthiness Reviews by

the CAMO Planned date

for the AR

1 month AR : 7 to 15 days

End of AR

Request

for AR

Inspection

report Form 153

Rejected

CNMAA

CAMO

Accepted

Confirmation

of the date for

the AR

OK

non OK

AR

report

Management of Level 1

findings

Deadline and

management

OK

ARC Form 15a

Valid 1 year

Management

of Level 2

findings +

observations

Recommendation for the AR

26 Sep 2012 6


Form 153 : Inspection report from the CAMO

(compliant with M.A.710 requirement)

a) To satisfy the requirement for an M.A.902 airworthiness review of an aircraft,

a full documented review of the aircraft records shall be carried out by the

approved CAMO in order to be satisfied that: 1. airframe, engine and propeller flying hours and associated flight cycles have been properly

recorded, and;

2. the flight manual is applicable to the aircraft configuration and reflects the latest revision status,

and;

3. all the maintenance due on the aircraft according to the approved maintenance programme has

been carried out, and;

4. all known defects have been corrected or, when applicable, carried forward in a controlled

manner, and;

5. all applicable airworthiness directives have been applied and properly registered, and;

6. all modifications and repairs applied to the aircraft have been registered and are approved

according to FRA 21, and;

7. all service life limited components installed on the aircraft are properly identified, registered and

have not exceeded their approved service life limit, and;

8. all maintenance has been released in accordance with this Part, and;

9. the current mass and balance statement reflects the configuration of the aircraft and is valid, and;

10. the aircraft complies with the latest revision of its type design approved by the CNMAA (DGA

Technical Authority).

26 Sep 2012 7


Form 153 : Inspection report from the CAMO

(compliant with M.A.710 requirement)

b) The approved continuing airworthiness management organisation's

airworthiness review staff shall carry out a physical survey of the aircraft.

For this survey, airworthiness review staff not appropriately qualified to FRA 66

shall be assisted by such qualified personnel.

c) Through the physical survey of the aircraft, the airworthiness review staff shall

ensure that: 1. all required markings and placards are properly installed, and;

2. the aircraft complies with its approved flight manual, and;

3. the aircraft configuration complies with the approved documentation, and;

4. no evident defect can be found that has not been addressed according to M.A.404, and;

5. no inconsistencies can be found between the aircraft and the paragraph (a) documented review

of records.

d) By derogation to M.A.902(a) the airworthiness review can be anticipated by a

maximum period of 90 days without loss of continuity of the airworthiness

review pattern, to allow the physical review to take place during a maintenance

check.

26 Sep 2012 8


Approved documentation

Data associated with the type certification Type Certificate Data Sheet (TCDS)

For legacy products, an “Airworthiness Reference Data Sheet” listing :

the CNMAA (DGA Technical Authority) decisions related to continued airworthiness

the approved modifications considered as mandatory modifications

Instructions for continuing airworthiness (ICA)

The “Airworthiness Reference Data Sheet” may have to be refined further to the first

airworthiness reviews

ADs and other decisions (limitations, approvals…) issued

by the CNMAA (DGA Technical Authority)

ICA associated with a modification, a repair or an evolution of the data

associated with the type certification

Approved maintenance programme derived from the recommended

maintenance programme issued by the OEM

ICA and SBs from FRA 21 Subpart J approved OEM with relevant privileges

26 Sep 2012 9


Form 153 : Inspection report

26 Sep 2012 10


Airworthiness review by the CNMAA

The AR is carried out by an airworthiness review staff (ARS) from the CNMAA

(DSAÉ) Review of the records of the aircraft

Physical inspection of the aircraft

The ARS shall have access to the aircraft, along with its documents and

maintenance logbook

The continuing airworthiness file is presented by a CAMO designated responsible

The aircraft, sheltered, with all doors and hatches open, is presented by a

qualified personnel

The inspection is limited to the accessible parts of the aircraft

A check flight may be requested if necessary

The AR should be carried out during a grounding (maintenance check,

configuration change…) but in a representative and flyable configuration

26 Sep 2012 11


M.A.905 Findings

a) A level 1 finding is any significant non-compliance with Part M requirements

which lowers the safety standard and hazards seriously the flight safety.

b) A level 2 finding is any non-compliance with the Part M requirements

which could lower the safety standard and possibly hazard the flight safety.

c) After receipt of notification of findings according to point M.B.903,

the person or organisation accountable referred to in point M.A.201 shall

define a corrective action plan and demonstrate corrective action to the

satisfaction of the CNMAA (DSAÉ) within a period agreed with this authority

including appropriate corrective action to prevent reoccurrence of the

finding and its root cause.

26 Sep 2012 12


Examples of findings

Level 1 findings : The aircraft is no longer compliant with its TC

Operating conditions not compliant with the approved maintenance programme

Modification or repair solution not approved

AD not implemented

Service limit of an equipment not respected

Release to service not compliant with the regulation (ex : no check flight after a

visit, no maintenance after a serious incident like a lightning…)

Approved maintenance programme not applied

Physical survey of the aircraft not feasible

Level 2 findings : Regulation related to operation and maintenance of the aircraft is not followed

- Documentation issue

- Release to service not compliant with the regulation

Observation : finding for information

There is no

formal decision

making support

table :

decision is

based on

experience

26 Sep 2012 13


Initial Airworthiness Review (AR) :

New delivered aircraft

Planned date

of delivery Planned date

for the AR

As short as

possible 1 to 2 days

End of AR

Request

for AR

CNMAA

CAMO

Accepted

Confirmation

of the date for

the AR

non OK

OK

AR

report

Management of Level 1

findings

Deadline and

management

OK

ARC Form 15a

Valid 1 year

CoR Form 5b

CoA Form 25 Permanent

documents

Management

of Level 2

findings +

observations

Certificate

of release to

service Form 53

Aircraft

statement of

conformity Form 52

OEM(1)

Aircraft

acceptance

(1) If DOA with

relevant privileges

No flights, eventually one ferry flight

26 Sep 2012 14


FRA 21 Subpart H requirements

FRA 21A.174 Each application for a CoA shall include :

- A statement of conformity Form 52 + Form 53 if applicable (i.e. if maintenance carried out prior to delivery)

- A weight and balance report with a loading schedule

- The flight manual and any other manuals required by the airworthiness Authority of the State of registry

FRA 21A.180 Access to the aircraft for which that airworthiness certificate is applied for shall be granted upon

request by the CNMAA (DSAÉ)

FRA 21A.182 Each applicant for an airworthiness certificate under this Subpart shall demonstrate that its

aircraft is identified in accordance with Subpart Q.

26 Sep 2012 15


Form 52 and Form 53

Form 52 : Aircraft statement of conformity Aircraft type + reference of the TC

Aircraft registration

Manufacturer identification

Engine/propeller details

Modifications and/or SBs

ADs

Concessions

Exemptions, waivers or derogations

Airworthiness certificate

Additional requirements

Form 53 : Certificate of release to service Reference of the work order

Brief description of work performed

If the OEM has not the relevant privilege to approve the Form 52, the CNMAA

(DGA Technical Authority) shall validate it by countersignature.

Equivalent documents issued by the OEM are acceptable as long as they contain

the same data and are validated by the CNMAA (DGA Technical Authority)

26 Sep 2012 16


Scope of the AR

The AR takes place after the transfer of property to the CAMO (further to the

acceptance) either in the OEM premises if feasible

or generally in the operational unit of the aircraft

after a ferry flight under PtF (Permit to Fly)

issued by the CNMAA (DGA Technical Authority)

The AR is limited to the review of the documentation not covered by Form 52

and Form 53 If the AR takes place several days after the transfer of property, the review shall address :

- The applicable Ads

- The logbook of the aircraft, engine, propeller

- The remaining service limit of equipment

- The compliance of the maintenance applied with the approved maintenance plan

- The verification of the identification of the accessible equipment

26 Sep 2012 17


Issues arisen from airworthiness reviews

Airworthiness reviews not well prepared by some CAMO units because of lack of

experience (CAMO units relying on airworthiness reviews to address findings) Requires airworthiness review complements to check corrective actions

Rely on transitional provisions in order not to ground aircraft with level 1 findings

Original schedule based on the assumption that the next 2 extensions of the

airworthiness review certificates are issued by CAMO under FRA M Subpart G

approval privilege : Very few CAMOs are FRA M Subpart G approved

Unexpected additional workload for DSAÉ to fill the gap

unless introducing a new transitional provision :

maximum 3-year validity of the first airworthiness review certificates

until FRA M Subpart G approval

26 Sep 2012 18


Issues arisen from airworthiness reviews

Aircraft with equipment unserviceable can no longer be authorized to fly with just

the green light of the chief of operations

Records of such unauthorized configurations in the aircraft logbook may lead to

level 1 findings during the airworthiness reviews

Introduce the civil principle of MMEL/MEL in the regulation MMEL : Master Minimum Equipment List

- Defined by the TCH and approved by DGA Technical Authority during the certification process

MEL : Minimum Equipment List

- Defined by the End User and approved by DSAÉ

- Cannot be less restrictive than MMEL

Already used on civil type certified aircraft, but not addressed on specific military aircraft like fighters

Mandatory for future aircraft types

Introduce also transitional provisions For legacy aircraft, in the absence of MMEL, define and validate

an Operating & Technical Tolerance List (OTTL) based on grandfather law

Until 31.12.2014, ARCs can still be issued and extended in spite of the absence of MEL or OTTL

26 Sep 2012 19


Conclusion

The Airworthiness Review constitutes the real job of the oversight of

the regulation enforcement

The Airworthiness Review of a new delivered military aircraft is quite

similar to Airworthiness Review of civil registered aircraft

The Airworthiness Review of a legacy aircraft for which the Type

Certificate was issued after the enforcement of the regulation is quite

challenging in terms of establishing and consolidating the reference

airworthy configuration

the airworthiness review of military aircraft mawc cy...

Documents