DRAFT CAAP 35-1(0)
DRAFT CAAP 42M-1(0)
Civil Aviation Advisory
Publication
September 2009
This publication is only advisory but
it gives a CASA preferred method
for complying with the Civil
Aviation Regulations 1988.
It is not the only method, but
experience has shown that if you
follow this method you will comply
with the Civil Aviation Regulations.
Always read this advice in
conjunction with the appropriate
regulations.
Design approval of
modifications and repairs
The relevant regulations and other
references
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Contents
1. Acronyms, terms &
definitions
2
2. Introduction
6
3. Technical data package 9
4. Approval of modification
design
13
5. Foreign designs of
modifications or repairs
22
6. Other approved
modifications or repairs
23
7. Responsibility of holder of
modification or repair
approval
23
8. Installer’s responsibility 24
9. Noise certification
24
10. Payment of fees
25
Appendix A –
Hints for data development 27
Appendix B –
Key activities associated with
the approval of a
modification
29
Appendix C –
Instructions for continued
airworthiness
32
Regulation 35 of Civil Aviation Regulations (CAR)
– Approval of design of modification or repair
Regulation 36 of CAR – Approval of aircraft
components for use as replacements
Regulation 42U of CAR – Modifications and
repairs
Part 4C of CAR - Flight Manuals
Part 21 of Civil Aviation Safety Regulations
(CASR) – Certification and airworthiness
requirements for aircraft and parts.
This CAAP will be of interest to
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Applicants seeking design approvals for
modification or repair of aeronautical products
Holders of design approvals for modification or
repair of aeronautical products
Approved design organisations
Approved maintenance organisations
Why this CAAP was written
This CAAP gives information and guidance to applicants
on development, format and content of a design of
modification or repair of an aeronautical product and
seeking approval of it from the Civil Aviation Safety
Authority.
Status of this CAAP
This is the first CAAP to be written on this subject.
For further information
Contact the CASA office closest to you on 131757.
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1. Acronyms, terms &
definitions
CAAP 35-1(0): Design approval of modifications and repairs
1.1
Acronyms
AFMS
APMA
ATSO
CAR
CAAP
CASA
CASR
EASA
ICA
IoA
MCTOW
NAA
STC
TC
1.2
Aircraft flight manual supplement
Australian Parts Manufacturing Approval
Australian Technical Standard Order
Civil Aviation Regulations 1988
Civil Aviation Advisory Publication
Civil Aviation Safety Authority
Civil Aviation Safety Regulations 1998
European Aviation Safety Agency
instructions for continued airworthiness
Instrument of Appointment
maximum certificated take-off weight
national aviation authority
supplemental type certificate
type certificate
Terms and Definitions
For the purpose of this CAAP the following definitions apply:
Aeronautical product. Means an aircraft, aircraft engine, aircraft
propeller, appliance or their parts.
Airworthiness standards. The detailed and comprehensive design
and safety criteria applicable to the category of the aeronautical
product that is acceptable to CASA. These design standards are
detailed in nature and cover aspects such as, but not limited to;
flight performance and characteristics, structural strengths and
durability, general design and construction, powerplant and
systems, aircraft and systems architecture, equipment
specifications, overall function and reliability criteria, tests and
inspections methods, and operating limitations and information.
Airworthiness standards for the class of aircraft, aircraft engine
and propeller are detailed in CASR Parts 22 to 35.
Airworthiness requirement. The collective requirement that
consists of, but not limited to, the approval or acceptance of the
type design to an airworthiness standard (see definition),
conformity to production or manufacturing standards,
performance of inspection, maintenance, repair and modification
in accordance with standards that ensure the continuing
airworthiness of the aircraft. Airworthiness requirements for
aeronautical products are set out in CASR Part 21.
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Approved design organisation means a design organisation
approved under regulation 30 of CAR. Only those design
organisations that have the privilege to issue a statement of
compliance listed on their certificate of approval can issue CASA
Form 979.
Certification plan - A document that clearly identifies:
• the means and methods by which an aeronautical product
will be shown to comply with the applicable airworthiness
requirements, where the airworthiness standards and
requirements are typically identified in a compliance
record document;
Note: This component of a certification plan is also known as
the ‘compliance plan’.
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the agreed level of delegation or authorisation granted to
the applicant for each applicable requirement;
the agreed level of involvement of certification team
members (CASA specialists and authorised persons) for
each applicable requirement;
communication plan, describing communication and
coordination responsibilities between applicant, CASA,
design organisation and suppliers, as applicable; and
project schedule, including major milestones and
deliverables.
Conformity means examination of an aeronautical product against
the relevant design, test and quality system data.
Certification basis. The applicable airworthiness standards
accepted by the NAA as the basis by which the type design of an
aeronautical product, or change to that type design, was approved
or accepted. The certification basis may also include Special
Conditions of Airworthiness, Findings of Equivalent Level of
Safety, and/or Exemptions when determined by the NAA to apply
to the type design.
Compliance summary. A compliance summary specifies the
airworthiness requirements that are applicable to the design and
how compliance with those requirements was shown. It is used to
ensure, systematically and comprehensively, that a design
complies with all applicable airworthiness requirements. A
compliance summary is also called a compliance check list.
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CAAP 35-1(0): Design approval of modifications and repairs
Finding of Equivalent Level of Safety. A finding where literal
compliance with a specific airworthiness requirement can not be
demonstrated but compensating factors exist in the type design
that can be shown to provide a level of safety equivalent to that
intended by the specific item of the applicable airworthiness
standard. Only CASA can make a finding of an equivalent level
of safety.
Flight manual for an aircraft is any manual or other document
(not being a placard) that must, under the relevant airworthiness
standards for the aircraft, be provided with the aircraft and
contain the following information and instructions about the
aircraft:
• the limitations within which, under the relevant
airworthiness standards, it is considered airworthy; and
• any other information, and any instructions, necessary for
its safe operation.
Instructions for continued airworthiness. A set of descriptive
data, maintenance planning and accomplishment instructions,
developed by a design approval holder in accordance with the
certification basis for the product, providing operators with the
necessary information for development of their own maintenance
program and accomplishment instructions.
Level of authorisation means the specific authorisation granted to
an authorised person, who has the appropriate scope of
authorisation to make a finding of compliance with a specific
requirement (or set of requirements) and to approve the associated
data.
Level of involvement means the specific involvement that CASA
specialists or authorised persons will have when making a finding
of compliance with a specific requirement (or set of requirements)
and approving the associated data.
Modification. A modification to an aeronautical product means a
change to the design of that product which is not a repair.
Repair means elimination of damage or wear/tear by replacement
of parts or restoration to an airworthy condition of an aeronautical
product through an approved design change. Elimination of
damage or wear/tear by replacement of parts without the necessity
for design activity is considered as a maintenance task and
therefore requires no approval under regulation 35 of CAR.
Registered operator – According to the transitional provisions for
CASR Part 47 (see CASR 202.222):
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A reference in CAR to the holder of a certificate of
registration of an aircraft is taken to be a reference to the
registered operator of the aircraft.
A duty imposed on the holder of a certificate of
registration of an aircraft is taken to be imposed on the
registered operator of the aircraft.
Special Conditions of Airworthiness. The technical requirements
added to the certification basis because of novel or unusual design
feature(s) that exists in a type design and the absence or
inadequacy of the applicable airworthiness standards to provide a
basis for the certification of such features.
Supplemental type certificate (STC). A stand-alone approval that
allows changes to a type certificated product. An STC is taken to
consist of: (a) the type certificate or type acceptance certificate
previously issued for the aircraft, aircraft engine or propeller; and
(b) each change in the type design of the aircraft, aircraft engine
or propeller described or identified in the STC.
Technical data for the design of a modification or repair to an
aeronautical product, means data that describes the design, such
as:
• the drawings and specifications necessary to define its
configuration and design features, and a list of those
drawings and specifications;
• information on dimensions, materials, and processes
necessary for making it;
• the airworthiness limitations section of the instructions for
continued airworthiness for it;
• the operating limitations and other information necessary
for its safe operation; and
• any other data necessary to determine its airworthiness.
Technical data also includes engineering reports, including test
plans and reports, used to establish that the design complies with
the applicable airworthiness standards.
Technical data is also called design data.
Type certificate. A document issued by CASA to define the
design of an aircraft type and to certify that the design meets the
appropriate airworthiness requirements.
Type certificate data sheet. A document that forms part of the
type certificate providing the technical details of the aircraft.
Type design. The set of data that defines a certificated
aeronautical product in terms of its engineering design, strength,
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CAAP 35-1(0): Design approval of modifications and repairs
manufacture, functions, characteristics, operations, and
limitations. It usually consists of:
• the drawings and specifications, and a listing of those
drawings and specifications, that define the configuration
and design features of an aeronautical product;
• the information on dimensions, materials, and
manufacturing processes used in the manufacture and
assembly of the aeronautical product;
• any airworthiness limitations resulting from compliance
with the applicable airworthiness standards, or as
otherwise required by the State of Design; and
• Any other data necessary for the definition of the
aeronautical product.
Type design is the basic design of a certificated aeronautical
product.
2. Introduction
2.1
All civil certificated aeronautical products are certificated
against a comprehensive set of airworthiness standards. These
standards take into account many parameters, such as the
structural strength, performance and flight characteristics,
powerplant and systems equipment operation, environmental
characteristics and other qualities affecting airworthiness,
including the weight and centre of gravity limitations that can be
dictated by any one of these parameters. Any design changes to
the approved type design, or modifications to an individual
aeronautical product, whether they be in form of repair,
installation of additional equipment, substitution of a part or
appliance, removal of already installed equipment require retest
or engineering analysis to measure the effect and reverify reliable
operation of that product.
2.2
While in service most aircraft, aircraft engines or
propellers have to be modified. These design changes or
modifications, may result from a variety of reasons, such as,
repairs, improved equipment, increase safety requirements,
different aircraft utilisation or for operators’ commercial
considerations. Incorporating a modification or repair to a
certificated aeronautical product will invalidate its conformity to
the type design, until such time that the modification is approved
and recorded as part of an approved design for that specific
product.
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2.3
Civil Aviation Regulations recognise the need for design
changes to aeronautical products and provide the regulatory
requirements that must be met. CASR Part 21 and regulation 35
of CAR provide certification basis and procedures for approval of
modified configurations of aeronautical products.
2.4
ways:
a)
b)
c)
d)
Aeronautical products can be changed in a number of
changes to type certificate (TC);
supplemental type certificates;
repairs;
modifications
and are discussed as follows:
Changes to type certificate (2.4.a). These changes are proposed
by the type certificate holder and affect the products at production
line. Changes to an approved type design of a certificated
aeronautical product are approved under Subpart 21.D of CASR.
If the proposed change is a major change to the approved type
design then it may result in a new model of the aircraft, aircraft
engine or propeller. In these cases, the basic process of type
certification is repeated. However, unchanged or unaffected items
of the basic design are not retested.
If a proposed change in design is so extensive that a substantially
complete investigation of compliance with the applicable
airworthiness standards is required, then application for an
amended type certificate is required under Subpart 21.B of
CASR. A design change at this level is generally viewed as
having a technical scope and nature that the affected product,
when modified, can be regarded as essentially a new product, i.e.,
there are differences in major design and/or production elements.
Supplemental type certificates (STC) (2.4.b). An STC is one
form of approval of the design of a major change to a type
certificated aircraft, aircraft engine or propeller. An STC is
supplementary to the original TC. It does not change the
previously issued TC. An STC consists of the approval of a
change in the type design of the product and the TC previously
issued for the product.
For design changes that are not significant enough to require a
change to the TC an STC may be required. STCs can be proposed
by anyone and would normally include those proposals that are
unusual in nature, require special installation conditions, or form
a kit to be sold for incorporation into a type certificated product.
For further information see AC 21.15 Supplemental Type
Certificates.
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CAAP 35-1(0): Design approval of modifications and repairs
Repairs (2.4.c). Repairs to an aeronautical product are design
changes intended to restore it to an airworthy condition after it
has been damaged or subject to wear. Where a repair is intended
to correct damage to an aeronautical product, the design is
generally unique to the specific damage. Repairs are to be treated
the same as modifications and must comply with the design
approval and embodiment requirements of the regulations. A
repair to an Australian Technical Standard Order (ATSO) or
Australian Parts Manufacturing Approval (APMA) article is
treated as a change to the ATSO or APMA design and must be
processed in accordance with CASR Part 21.
Modifications (2.4.d). Modifications are design changes that are
not changes to the type certificate nor supplemental type
certificates. Like repairs, modifications are normally individual
changes applicable to a specific in-service aircraft, aircraft
engine, propeller, appliance or part thereof. Although under
specific conditions a series of aeronautical products may be
modified in accordance with one modification package. If anyone
else wishes to make the same change on another product not
covered by the design approval of the modification, it will be
necessary for them to make application to CASA or an authorised
person. Alternatively, approval for an STC may be sought.
Replacement of a part of an aeronautical product with another
non-eligible or unapproved part constitutes modification of that
aeronautical product and must comply with the design approval
and embodiment requirements of the regulations. While an
approval of a part for use as replacement is granted under
regulation 36 of CAR, the technical requirements for approval are
identical to that of design approvals issued under regulation 35 of
CAR.
According to the maintenance regulations, all modifications,
major or minor, to Australian registered aircraft must be
approved.
2.5
This CAAP provides guidance on the process of applying
for approval of design of a modification or repair.
2.6
While regulation 42U of CAR requires that the design of
the modification or repair must be approved under regulation 35
of CAR, according to the general exemption issued by CASA,
limited category or experimental aircraft are exempt from this
requirement.
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However, if the modification or repair that is a major
modification or major repair to the aircraft (for the definition of
major change see CASR 21.093), the registered operator for the
aircraft must inform, as soon as possible, CASA or an authorised
person for the purpose of CASR 21.176, in writing about the
design change. If the modification or repair invalidates the
certificate of airworthiness of the aircraft, the registered operator
may operate the aircraft only if a new certificate of airworthiness
has been issued for the aircraft.
Note: Repairs are treated the same as modifications and must
comply with the design approval and embodiment
requirements of the regulations. To improve readability of
this CAAP the words ‘modification or repair’ have been
replaced with ‘modification’.
2.7
Often design of temporary modifications for ferry flight
installations can not fully meet the relevant design standards. To
overcome this problem, CASA has issued an exemption allowing
CAR 35 authorised persons to approve design of temporary
modifications that do not fully meet the relevant design standards
for an operation under the special flight permit provisions in
paragraph 21.197(1)(a) and (b) and subregulation 21.197(2) of the
CASR. For further information on special flight permits refer to
AC 21.09 Special Flight Permits.
3. Technical data
package
3.1
General
3.1.1 The modification design data package consists of; a)
descriptive data; b) compliance or substantiation data; c) other
data, such as, manufacturing data, maintenance data or
information on weight and balance etc.
3.1.2 Appendix A lists certain aspects that should be considered
while developing the data and features included to minimise any
potential problems.
3.2
Development of Technical Data
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CAAP 35-1(0): Design approval of modifications and repairs
3.2.1 Descriptive data
Descriptive data defines the design of the modification. It also
provides the details for the embodiment of the modification and,
if necessary, instructions for the continued airworthiness.
Descriptive data should be sufficient for the manufacture of parts
and the embodiment of the modification.
If the modification is limited to a single installation a reduction in
descriptive data may be acceptable. Descriptive data should
include, where applicable:
• the use and application of the design;
• the purpose of the design;
• maintenance, operating, and performance data including
any limitations for the use of the design;
• installation properties including any factors that affect the
interaction of the design with other equipment;
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•
references to standards and specifications used during the
development of the design;
drawings, diagrams, and other physical descriptions of the
design, including:
o
special processes and their required outcomes,
including:
− heat treatments;
− surface finishes;
− weld quality;
all dimensions including undercuts, fillet radii, fits and
tolerances;
o
wiring diagrams;
o
an equipment list that details the parts, including those
sourced complete from other places, that make up the
completed item by part number, location, and method
of attachment;
a summary of particular manufacturing considerations,
including:
o
pressures;
o
temperatures;
o
environments;
a reference to the applicable airworthiness requirements;
and
a list that details the substantiating data for ease of
reference.
o
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3.2.2 Substantiating data
This data substantiates that the design meets the applicable
airworthiness requirements. Substantiating data should include,
but not necessarily be limited to, where applicable:
• load analyses;
• failure analyses;
• the requirement and suitability of any special processes
chosen;
• installation considerations;
• methodology and results of test as to the interaction and
compatibility between existing units and the new items;
• for an avionics design:
o
an electrical load analysis;
o
a failure analysis ensuring that essential equipment are
sufficiently independent to prevent complete system
failure;
the layout and ergonomics of applicable units, in
particular instruments;
performance confirmation;
testing and inspection results;
crashworthiness assessments;
lightning protection.
o
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3.2.3 Other technical data
Other data in the modification package should include, but not be
limited to, where applicable:
a) inspections and tests;
b) weight and balance;
c) manufacturing data;
d) installation data;
e) instructions for continued airworthiness;
f) any required document amendments including flight
manuals, normal procedures, and emergency procedures
and are discussed as follows:
Inspections and tests (3.2.3.a)
To ensure that the modification embodied performs correctly,
inspections and tests are required. These inspections and tests
should be detailed in the data and should include procedures for
the confirmation that:
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CAAP 35-1(0): Design approval of modifications and repairs
•
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the modified item complies with the applicable
airworthiness requirements;
the materials used conform to the applicable
specifications; and
all components of the modification conform to the
drawings in the applicable design.
Weight and balance (3.2.3.b)
When assessing the proposed modification, the cumulative effect
of previous modifications in the areas related to the current
proposal should be considered. For example, previous relevant
aircraft modifications may address incremental increases in
weight or centre of gravity that, while individually negligible,
can, through a series of modifications, achieve a significant
product level change.
Unless the modification results in a negligible weight change the
weights and moment arms should be calculated and detailed in the
description of the change. Alternatively a complete reweigh of the
aircraft can be carried out after embodiment of the modification.
Manufacturing data (3.2.3.c)
The manufacturing details should ensure that the modification or
change can be produced within the design limits. Considerations
should include the application of special processes, particular
pressures, temperatures and environments, and the repeatability of
production standards if appropriate.
Manufacturing processes used to manufacture a developmental or
certification prototype may not be suitable to manufacture the
approved product from an airworthiness or economic standpoint.
Installation data (3.2.3.d)
For designs that progress to embodiment there should be some
installation data supplied to assist the person carrying out the
work. Although installation data is not required in all cases,
design packages should include considerations for maintenance
actions pre- and post-installation, performance testing when
installed, and subsequent operation instructions.
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Instructions for continued airworthiness (3.2.3.e)
Instructions for continued airworthiness (ICAs) provide guidance
to the operator about actions necessary to maintain the
airworthiness of the modified aeronautical product. The ICAs
provide recommended frequencies for maintenance activities and
specific criteria and intervals for inspection. These instructions
also provide information on equipment interfaces and methods for
testing and troubleshooting. ICAs provide the maintenance
support information necessary to ensure the condition of the
aeronautical product and the modification remains safe
throughout their lifetime.
ICAs are required to be acceptable to CASA. If a modification is
required to have an Airworthiness Limitation Section within an
ICA, that section must be CASA-approved.
Amendments (3.2.3.f)
An amendment to documents and manuals is an important aspect
of a complete design package. Maintenance manuals, illustrated
parts catalogues, aircraft wiring manual, and flight manuals (or
other approved aircraft specifications) are documents that may
require amendment as a result of a modification being
incorporated.
A design package may provide supplements to these types of
manuals that would subsequently be provided to the buyer of the
modification.
Aircraft flight manual or aircraft specification supplements can be
approved as part of the modification.
4. Approval of
modification
design
4.1
General
4.1.1 The main objective of the design approval process is to
determine the overall compliance of a proposed modification with
the applicable airworthiness standards, such that the affected
aeronautical product, when modified, will continue to have a
valid and approved type design.
4.1.2 There are five key activities associated with the approval
of a modification, namely:
• establishing a certification basis;
• establishing the means or methods of compliance;
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CAAP 35-1(0): Design approval of modifications and repairs
• demonstration of compliance;
• finding of compliance;
• approving the modification
and are discussed at Appendix B.
4.1.3 The applicant or applicant’s representative completes the
in-house product development and obtains, organises, and
submits the technical data for the design to CASA or an
authorised person for review and approval. Each section of the
technical data package should be clearly identified with
references to the applicable airworthiness requirements evident.
4.1.4 CASA does not question the source or the method by
which an applicant for a design approval obtains the technical
data. An applicant showing compliance to the applicable
requirements may obtain certification credit for previously
approved technical data without showing further compliance if
the applicant:
• provides sufficient evidence that the presented data were,
in fact, approved by CASA. The applicant does not need
to submit the data if they were obtained with the consent
of the original approval holder;
• establishes that the previously approved data are
applicable to the applicant’s design to the extent that any
design deviations will have no effect on the design’s
airworthiness or on showing compliance with the
applicable regulations;
• provides sufficient substantiation and descriptive data of
its own modification so that CASA can make a finding of
compliance;
• has sufficient engineering data necessary to provide
continued airworthiness information should the
modification be the subject of a service difficulty report or
an airworthiness directive; and
• has sufficient descriptive data to produce detail parts and
installations if multiple modification approval is
requested.
4.2
Options for seeking approval for a modification
4.2.1 Following are three possible options for the approval of
modification design data:
• Development of the modification by an approved design
organisation (see definition), a statement of compliance
issued by that design organisation, and subsequent design
approval by CASA or an authorised person;
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•
•
4.3
15
Development of the modification by the originator, a
statement of compliance issued by an approved design
organisation, and subsequent design approval by CASA or
an authorised person;
Development of the modification by the originator and a
statement of compliance issued during the design approval
by CASA or an authorised person.
Application for design approval
4.3.1 Any person may apply to CASA for approval of a
modification design. However, if the applicant does not have
training, qualification or experience for this class of work then the
applicant is strongly advised to engage the services of a person or
design organisation experienced and approved for this type of
certification activity. Information on such organisations and
persons can be obtained from the CASA office closest to the
applicant or the CASA website. The design organisation or
person selected by the applicant will act as the airworthiness
design coordinator for the project. CASA communications
concerning the project will be addressed to the applicant, and
copied to the coordinating design organisation or person. All
technical communication addressed to CASA should be routed
via the coordinating design organisation or person.
4.3.2 An application for a modification design approval should
contain the following information:
• name and contact details of the applicant;
• make, model and serial number(s) of the aircraft, aircraft
engine or propeller or appliance to be modified; and if
applicable the aircraft’s registration mark(s);
• title and description of the modification;
• proposed applicable design standards for the approval of
the modification and an outline of the means for
demonstrating compliance with the proposed standards;
and
• documentation provided or to be provided. The following
documents are required for a modification approval when
applicable to the design:
o
compliance summary;
o
master drawings and/or master drawing list;
o
engineering reports, such as structural analysis, fault
analysis, electrical load analysis;
o
ground and flight test reports;
o
production drawings and installation instructions;
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CAAP 35-1(0): Design approval of modifications and repairs
o
o
o
o
maintenance and repair manual supplements or
equivalent;
weight and balance data or report;
instructions for continued airworthiness;
aircraft flight manual supplement.
4.3.3 In addition to the documents specified above, an applicant
for a complex project should submit to CASA a proposed
certification plan. A certification plan should include the
following information:
• Project description, including identification of the
applicant and product involved;
• Certification basis, including applicable airworthiness
standards,
exemptions,
special
conditions
and
determinations for equivalent level of safety, as
applicable;
• A detailed explanation of the means and methods that will
be used to demonstrate compliance and documentation to
be provided;
• Project schedule, including major milestones and
deliverables;
• Proposed use of design organisation, including
identification of authorised person(s) and limitations on
authorisations; and
• Communication and coordination between applicant,
CASA, design organisation and suppliers.
4.3.4 The certification plan is a living document, continuously
amended during the certification program. The certification plan
is agreed by the applicant and CASA, and cannot be changed
except with acceptable notice and mutual agreement.
4.3.5 CASA’s response to the application will include the
following:
• The certification basis for the proposed modification,
including applicable airworthiness standards, exemptions,
special conditions and determinations for equivalent level
of safety;
• Instructions or remarks as to acceptable means of showing
compliance with specific aspects of the design standard;
and
• Identification of any aspects of the process that CASA
wishes to witness or inspect.
4.3.6 Either the applicant or CASA may call for a project
initiation meeting to establish the design standard and procedures
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to be used for showing compliance to minimise risk of doubt or
misunderstanding between CASA and the applicant.
4.3.7 If CASA considers the proposed design of a modification
or repair constitutes a major change to the type design, CASA
may require the applicant to apply for an STC approval under
Subpart 21.E.
4.4
Design approval process
4.4.1 Draft compliance plan
The applicant should prepare a draft compliance plan. The draft
compliance plan needs to indicate the proposed means of showing
compliance with all applicable airworthiness standards.
Note: For systems that contain software or complex electronic
hardware the plan for software or hardware aspects of the
certification should be submitted at this stage (RTCA/DO178B or later amendment or RTCA/DO-254 refers).
CASA will respond to the draft compliance plan, followed by any
amendment and agreement by both CASA and the applicant. This,
or the certification plan derived from the project initiation
meeting, constitutes an agreed plan of action and is the principal
guidance plan for the entire exercise.
Note: As the project progresses, the draft compliance plan or the
certification plan derived from the project initiation
meeting, will need to be continually revised. An ongoing
dialogue with CASA should be conducted during the life of
the project.
4.4.2 Evaluation of technical data
The applicant should submit the complete technical data in a
logical format. A complete, well structured and accurate data
package also assists in an efficient progress of the design
approval process to the benefit of the applicant.
Where drawings and data describing the modification has already
been approved by CASA or an authorised person, in relation to a
modification already approved under the regulations, CASA will
not investigate or re-evaluate the data.
Note: It may facilitate the prompt processing of the package if
more than one copy of certain areas of the package is
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CAAP 35-1(0): Design approval of modifications and repairs
provided. Advice should be sought from CASA as to which
parts of the package may be processed more rapidly by
the supply of duplicate copies.
Normally, CASA will accept the finding of compliance made by
an appropriately authorised person in accordance with the agreed
certification plan. CASA’s level of involvement in the project to
find compliance with the airworthiness requirements will be
reduced to the minimum necessary depending on the experience
and knowledge that CASA has of the person(s) who approved the
data.
Data submitted by an authorised person who has approval
privileges specified in his or her IoA, and/or as detailed under the
agreed certification plan, should be marked as approved prior to
submission. The data must be accompanied by a statement of
compliance with the applicable design standards (CASA Form
979).
For technical data submitted by a person whose IoA has only
recommendation privileges (i.e. not having approval privileges)
or an approved design organisation, the data should be
accompanied by a statement of compliance with the applicable
design standards marked as “recommended”. When CASA is
satisfied that compliance has been shown, CASA will either
approve the data or authorise the person, in writing, to approve
the data. Data not acceptable will be returned to the applicant
with a summary of the deficiencies, and a request for revision and
resubmission. It should be noted that CASA is not responsible for
the development of methods or the accuracy of calculations. The
applicant is thus strongly recommended to engage the services of
appropriate authorised person(s) for the range of activities, or a
suitable organisation holding a certificate of approval for design
under regulation 30 of CAR.
At the completion of the design approval process, the CASA
project manager will suitably annotate the top level drawing list
and document list as the lists of technical data accepted or
assessed by CASA as showing compliance with the applicable
airworthiness standards.
4.4.3 Test plans
The applicant must prepare a test plan for approval by CASA
when testing is necessary to show compliance with the applicable
airworthiness requirements, unless agreed otherwise in the
certification plan. The test plan must be prepared as early in the
approval process as possible, but as a minimum prior to the start
of each test.
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19
The test plan must at least contain the following items:
• Specific airworthiness requirement to be addressed;
• Description and configuration of the item(s) to be tested;
• List and description of all test equipment and facilities
necessary to conduct the test;
• Description of how the equipment will be calibrated prior
to the test;
• Description of how the results of the testing will show
compliance;
• Loads to be applied and any load cycling requirements;
and
• A test procedure written in a step-by-step format and
sequence, including the recording of test results.
A test is not to proceed until the test plan has been approved by
CASA and satisfactory conformity inspections of the test article
and test set-up in accordance with the relevant technical data and
the test plan have been completed. The conformity of the test
article and test set-up must be established per paragraph 4.4.4
(conformity inspections).
The applicant is to provide knowledgeable personnel capable of
performing and recording the results of the test.
The applicant must prepare a test report detailing the results for
each test and an explanation of the calculations necessary to
evaluate the data. The report must include conclusions and be
presented to CASA for approval.
4.4.4 Conformity inspections
Conformity inspections are required to ensure that the product
being tested conforms to the approved drawings and
specifications and test plans.
Before each test is undertaken the applicant must have determined
that:
• For the test article:
o
that materials and processes conform to the
specifications for the design;
o
that parts of the product conform to the drawings for
the design; and
o
that the manufacturing processes, construction and
assembly conform to those specified in the design;
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CAAP 35-1(0): Design approval of modifications and repairs
•
that the test equipment and all measuring equipment used
for tests are appropriately calibrated and conform to the
test plan. The calibration certificate must be traceable to
the national standard.
For a test performed or witnessed by CASA, the applicant is to
complete and submit to CASA a statement of conformity and to
request conformity inspections by CASA.
Note: Because of the complex nature of the conformity process
and the necessity for parts conformity inspections early in
the design approval process, CASA should be consulted
early in the program. This will ensure that necessary
inspections are requested and scheduled at appropriate
times.
Note: In certain circumstances CASA may designate a person
with appropriate qualifications and experience to carry
out conformity inspection on CASA’s behalf.
Parts procured from vendors that undergo qualification testing
will require conformity inspection by CASA prior to testing. To
avoid delays, it is imperative that the applicant identify the parts
that will be procured by vendors and present this information to
CASA early in the program.
4.4.5 Submission of test reports
The applicant should submit to CASA all test reports and
substantiating data (e.g. test equipment calibration reports) for all
certification testing, as well as any further data necessary to
demonstrate compliance with the applicable airworthiness
standards.
Any required weighing needs to be accomplished. If required,
suitable loading schemes need to be determined for any required
flight testing.
4.4.6 Conduct of the flight testing
The flight test schedule is to be submitted to CASA for evaluation
and approval, where required.
The applicant must apply for an experimental certificate for the
purpose of showing compliance with the regulations to cover the
intended flight testing. For further information refer to AC 21.10
Experimental Certificates.
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21
4.4.7 Compliance summary
The compliance summary (see the definition) must list the
following information for each applicable airworthiness
requirement:
• Section/paragraph number of the requirement. e.g. FAR
section 25.1303;
• Subject or title of the requirement, including the detailed
requirements. If the requirement is not applicable to the
design then the detail of the requirement need not be
provided;
• Mean of compliance, e.g. calculations/analysis, ground
test, flight-test, inspection, drawing review, process
specification, etc;
• Documentation, e.g. the report number that demonstrated
compliance to the subject requirement.
4.4.8 Aircraft flight manual supplement
The applicant should submit any proposed flight manual
supplement to CASA for assessment and approval.
4.4.9 Submission of final data
The applicant should compile a consolidated data set including a
final version of the compliance statement and submit to CASA,
the required engineering substantiation package for the
modification, for review and to enable CASA to issue the design
approval once satisfied.
The applicant should also submit to CASA any required revised
instructions for continued airworthiness. See appendix C.
4.4.10 Issue of the design approval
CASA will review all the submitted data, and if applicable the
AFMS and ICAs and will issue the design approval to the
applicant if:
• the areas of the type design affected by the modification
meet all the relevant airworthiness standards specified in
the certification basis, including Special Conditions of
airworthiness issued by CASA;
• all engineering inspections have been completed and the
modified product has been found to meet all applicable
airworthiness requirements;
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CAAP 35-1(0): Design approval of modifications and repairs
•
•
•
in the case of aircraft, the modified aircraft has been test
flown, as required, and found to comply with all the
performance requirements of the applicable airworthiness
standards;
there is no feature or characteristic of the changed product
that makes it unsafe for the intended use if it is operated in
accordance with the correctly amended flight manual or
other specified limitations; and
the cost recovery procedures (see Section 10) have been
complied with.
The design approval document will list the following:
• name of the design approval holder;
• make, model and serial number(s) of each aircraft, aircraft
engine or propeller or appliance covered by the approval;
• title and description of the modification and when it comes
into effect;
• certification basis listing the specific airworthiness
standards for which compliance were shown;
• conditions or limitations for the safe operation and
continued airworthiness of the aircraft, if any; and
• any other relevant information, such as installation and/or
maintenance instructions, etc.
An approval granted by CASA for the design of a modification
remains valid until otherwise specified or notified by CASA.
5. Foreign designs
of modification or
repair
5.1
A design of modification or repair is taken to have been
approved by CASA for the purpose of the regulations, if the
design is:
• approved by the NAA of a recognised country, (for
information regarding recognised countries, refer to CASR
21.012);
• in the case of an aircraft, aircraft engine or propeller
designed in a recognised country - published by the
foreign type certificate holder of the aircraft, aircraft
engine or propeller in service documents or issued in the
form of technical advice to operators under a system
approved by the NAA of the country in which the
aeronautical product was designed;
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•
•
23
in the case of an appliance designed in a recognised
country - published or issued by the manufacturer of the
appliance under a system approved by the NAA of the
country in which the or appliance was designed;
accepted by CASA under a technical agreement (however
described) between CASA and the NAA of a Contracting
State regarding modification or repair design approvals.
Note: Any reference in this CAAP to the NAA of a recognised
country also includes EASA.
5.2
Manufacturers’ letters to operators stating the
manufacturer has no “technical objection” to the operator’s
request do not constitute automatic approval, unless the document
is approved by an appropriate delegate of the TC holder or the
manufacturer authorised by the NAA. For example, FAA
authorises TC holders or manufacturers under 14 CFR Part 21
Subpart J to approve technical data.
6. Other approved
modifications or
repairs
6.1
A design for a modification or repair to an aircraft, aircraft
engine, propeller or appliance is taken to have been approved by
CASA, if the design is contained in a direction issued by CASA
or an applicable airworthiness directive.
7. Responsibility of
holder of
modification or
repair approval
7.1
The holder of a modification or repair approval, not the
owner/registered operator or CASA or the authorised person who
approved the design, remains responsible for the continued
integrity of the modification or repair to approved type design.
The holder of a modification or repair should report to CASA of
any failure, malfunction, or defect related to the modification or
repair that has resulted, or could result, in an occurrence. For
further information on reportable occurrences refer to CASR
21.003(4). This information is used to determine if an unsafe or
potentially unsafe condition exists.
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CAAP 35-1(0): Design approval of modifications and repairs
7.2
The holder of a modification or repair approval or it’s
representative must continue to be the CASA’s contact point for
resolving issues that may require corrective action. To fulfil this
responsibility, the holder should have the continued capability, or
access to a capability, of providing appropriate technical solutions
for service difficulties when service experience warrants it, or
when the CASA requires mandatory corrective action.
7.3
If the approval is transferred to another person by a
written agreement, the new holder assumes the responsibilities for
the modification or repair described herein.
8. Installer’s
responsibilities
8.1
It is the responsibility of the installer, not the registered
operator, to ensure that the modification or repair is approved and
can be installed in accordance with the supplied instructions.
Holders of modification or repair approvals should provide their
clients or customers with a copy of the approval document. The
installer must take into consideration that the particular aircraft
may have other modifications or repairs that impact upon the
incorporation of the modification or repair.
8.2
If the modification or repair cannot be incorporated in
accordance with the supplier’s instructions, or there is a
compatibility problem with other modifications and repairs, then
an assessment of the modification or repair or the aircraft or both
by CASA or a CAR 35 IoA holder is required. The basis for
compliance with the airworthiness requirements is not always
obvious and it cannot be assumed that a small change is trivial.
9. Noise
certification
9.1
Noise certification for individual aircraft is required in
Australia before the aircraft can legally operate in Australian
territory. If the modification would affect the existing noise
certification, then noise certification will be required. The
following paragraphs are only relevant if noise certification is
required.
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25
9.2
Aircraft noise is regulated through the Air Navigation
(Aircraft Noise) Regulations 1984, introduced under the Air
Navigation Act 1920. Noise certification, or lack of such
certification, has no legal impact on the design change approval.
However, if an individual aircraft does not meet the Australian
noise requirements, then it is illegal for that aircraft to operate in
Australian territory, even though the aircraft may have a valid
certificate of airworthiness.
9.3
For further information regarding noise certification
contact should be made with the Manager of Environment
Monitoring, Airservices Australia, GPO Box 211, Mascot, NSW
1460. or visit the Airservices Australia website at:
http://www.airservicesaustralia.com.au
10. Payment of
fees
10.1 Approval of design of modification or repair attracts a fee.
The total chargeable fee is based on the actual work hours
involved in assessing the application at the hourly rate published
in the Civil Aviation (Fees) Regulations. On receipt of an
application for approval of design of modification or repair
CASA will notify the applicant of an estimate of the fee for
assessment of the application. CASA will not initiate the
assessment process unless the applicant pays the estimated fee.
10.2 For major and complex modification projects, the
applicant may negotiate an initial payment, and progressive
payments, with CASA.
10.3 A reconciliation will be made just before the issue of the
design approval. If an overestimate has been made, a refund will
be paid to the applicant. If underestimated, a final payment from
the applicant will be required.
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CAAP 35-1(0): Design approval of modifications and repairs
Note 1:
The time spent by CASA staff in providing initial advice
to the applicant, setting the certification basis, and
preparing cost estimates, will not be charged, but that
the hourly flat rate for CASA staff in assessing data,
checking compliance, witnessing approval tests and
resolving problems, up to the point of completion of the
program, must be charged. Any research by or training
of CASA staff to progress the application will not be
charged to the applicant.
Note 2:
Where an applicant engages a CAR 35 authorised
person to assist with the approval of a modification,
any fees involved are a matter between the applicant
and the authorised person.
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27
Appendix A
Hints for data development
In developing the design data the following aspects should be considered and features included to
minimise any potential problems. This list is not exhaustive and should be adapted for each project:
•
Structural requirements
º
•
Hazards to the aircraft or its occupants
º
•
Is the wire gauge correct for the expected current draw?
Is the insulation type appropriate for the operating environment?
Are the looms supported adequately?
Are the layout and location of looms going to cause loom damage?
Are the terminations suitable for the circuit?
Electrical System
º
º
º
º
•
Have the particular airworthiness design standards been met, such as flammability,
vibration, noise, and evacuation provisions?
Wiring
º
º
º
º
º
•
Does the modification fulfil the operating requirement intended and has the integration of
any equipment or kits been tested to ensure there are no adverse affects?
Detail design standards
º
•
Is the equipment added, or any associated supporting features, likely to create a danger to
the safety of the occupants or the aircraft itself?
Operating aspects
º
•
If the structure is reduced, added to, or otherwise changed will its integrity be impaired?
Have tests for electromagnetic interference been considered (Victim/source est)?
Have functional test for the new equipment been carried out (Does it work?)?
Do individual items work on their own (Interdependence test)?
Is there sufficient residual equipment following a failure (Failure condition)?
Circuit protection
º
º
Have suitable fuse or circuit breaker been specified and installed?
Can each system be switched ON/OFF (Switches)?
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•
CAAP 35-1(0): Design approval of modifications and repairs
Pitot-static system
º
º
º
•
Lightning protection
º
º
•
Have lightning zones been considered for antenna locations?
Are loom layout and location suitable for lightning protection?
Mounting of equipment
º
º
º
•
Is there an adequate drainage for the pipes and water only collects at a lowest point
(Correct drainage)?
Are the layout and location of pipes going to cause pipe damage (Layout and position)?
Have leak checks been specified and carried out?
Are all new equipment visible and usable to the crew?
Have security and structural strengths been considered?
Are the new equipment maintainable?
Generating System
º
Is there sufficient electrical generation capacity (Electrical load analysis)?
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29
Appendix B
Key activities associated with the approval of a modification
There are five key activities associated with the approval of a modification, namely:
a)
b)
c)
d)
e)
Establishing a certification basis;
Establishing the means or methods of compliance;
Demonstration of compliance;
Finding of compliance;
Approving the modification.
These are discussed as follows:
Establishing a certification basis
In the application for a modification design approval, the applicant proposes the applicable
airworthiness standards to which they intend to demonstrate compliance. Depending on the nature
of the modification, CASA may impose additional airworthiness or operational requirements. All
these requirements are established collectively to become the certification basis for the
modification.
It should be noted that while the certification basis is established very early in the approval process,
the final certification basis of a modified product may, in some cases, end up being different from
that established initially. The difference(s) may come when CASA issues Special Conditions of
airworthiness (SC), Findings of Equivalent Level of Safety (FES), or an Exemption. The need for
the issuance of an SC, FES, or an Exemption as part of the certification basis is usually identified
by the applicant to CASA at the beginning of the application process. However, this need may not
be obvious at the beginning, and becomes evident only during the course of the actual approval
activities. At the conclusion of the approval activities, CASA shall identify all SC, FES,
Exemptions and other voluntary compliance that transpired during the approval period. These
activities are recorded as part of the final certification basis.
Establishing the means or methods of compliance
Demonstration of compliance of the proposed modification with the established certification basis
is the sole responsibility of the applicant. To manage this aspect during the modification design
approval process, and before an applicant commits to any compliance action, it is necessary to
agree on a compliance plan or certification plan with CASA that clearly identifies the types of
action to be applied against each item of the certification basis.
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CAAP 35-1(0): Design approval of modifications and repairs
The specific item of the certification basis usually dictates the means of compliance, and generally
fall into one or any combination of the following:
•
Test – is performed when the requirement explicitly calls for a demonstration by test
(physical, actual or simulation). Examples of test are flight test, ground test, fatigue test,
simulation, fire or flammability test, environmental test (e.g. salt spray), functional test, bird
strike test, and engine ingestion test.
•
Analysis – is performed when the requirement explicitly calls for a demonstration by analysis
(qualitative, quantitative, or comparative), or when the applicant can demonstrate, based on
previously accepted test results, the validity of using analysis in lieu of testing. Examples of
analysis are failure modes and effects analysis, flight performance data reduction and
expansion, structural loads analysis, and software evaluation.
•
Inspection or Evaluation – is performed against an item that does not require test or analysis,
but relies on observation, judgment, verification, evaluation, or a statement of attestation from
the applicant or its vendors/contractors.
Demonstration of compliance
The demonstration of compliance requires that the applicant submit substantiating data (design
data, reports, analysis, drawings, processes, material specifications, operations limitations, flight
manuals, instructions for continued airworthiness, etc). The data should be complete and in a
logical format for review by CASA. Where the demonstration of compliance involves a test, a test
plan should be developed and approved prior to any actual test being performed. Official
certification tests are witnessed by CASA or by an authorised person, when authorised in the agreed
compliance plan or certification plan.
The applicant should give CASA or the authorised person access to the product being modified in
order to make any inspections, test, and engineering assessment or conduct any flight or ground test
that is necessary to determine compliance with the specific item of the certification basis. However,
the applicant should perform his or her own inspection and test necessary to demonstrate
compliance prior to presenting the modified product to CASA or the authorised person for testing
or evaluation.
If the applicant elects to comply with optional certification items or later amendments of the
airworthiness standards for the purpose of obtaining credit in the certification basis, the
demonstration of compliance for both cases is mandatory, and is not subject to any Exemption.
Where a demonstration of compliance is to be made using a Finding of Equivalent Level of Safety,
the applicant should provide sufficient justification to CASA that describe the design feature, action
taken (i.e. compensating factor), and how such action provides an equivalent level of safety to that
intended by the applicable airworthiness standard.
Finding of Compliance
Findings of compliance are made against airworthiness standards, including Special Conditions of
airworthiness and request for equivalent level of safety. The finding of compliance can be made by
CASA, or by the authorised person, depending on the pre-defined levels of involvement in the
certification plan. Following a successful demonstration of compliance by the applicant on a
certification item, CASA or the authorised person makes a finding of compliance and subsequently
signs-off the item in the certification plan. The findings are usually accomplished through one or
any combination of the following actions:
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•
•
•
•
•
31
Acceptance of substantiating data. Reports, analysis, drawings, or similar documents are
usually produced against each certification item and reviewed and accepted. Specific attention
is paid to the methodology and assumptions, rather than the detailed calculations or analysis.
Witnessing of Test. Demonstration of compliance tests are performed by the applicant and
witnessed by CASA or an authorised person. These test should only be performed after the
test plan has been agreed to by CASA and the test articles, test environment and test
equipments have been conformed to the appropriate data. CASA or the authorised person
does not take part in the actual performance of the non-flight test, and remain impartial and
concentrated on the test objective. However, CASA or the authorised person may take part in
conducting flight testing to verify a claim of compliance after the applicant has competed
their flight testing program.
Engineering inspection. Any aspect of the design, for which compliance with the certification
item cannot be determined through review of drawings or reports, receives an engineering
compliance inspection. An engineering compliance inspection is to assure that an installation,
and its relationship to other installations on a product, complies with the design requirements.
Conformity inspection. Where required, CASA or the appropriately qualified authorised
person perform these inspections to verify conformity of the modified product with drawings,
specifications, and special processes. An engineering inspection should not be confused with
a conformity inspection. A conformity inspection is carried out to determine conformity to the
engineering data. Whereas, an engineering inspection is carried out to determine compliance
with the certification requirement.
Flight Test. For aircraft, an actual demonstration of flight capabilities and characteristics in
accordance with an approved flight test plan.
Finding of compliance against a specific item of the airworthiness standard should be documented
using CASA Form 979.
Approving the modification
The approval of the modification means that:
•
•
•
•
the areas of the type design affected by the modification meet all the relevant requirements
specified in the certification basis, including Special Conditions of airworthiness issued by
CASA;
all engineering and conformity inspections have been completed and the modified product has
been found to meet all applicable requirements;
in the case of aircraft, the modified aircraft has been test flown, as required, and found to
comply with all the flight and performance requirements of the applicable airworthiness
standards;
there is no feature or characteristic of the changed product that makes it unsafe for the
intended use if it is operated in accordance with the correctly amended flight manual or other
specified limitations.
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Appendix C
Instructions for continued airworthiness (ICA)
1.
Introduction
1.1
ICAs provide:
•
instructions for maintenance personnel to maintain and inspect the specific modifications
performed on the aircraft;
•
recommended frequencies and intervals for inspection;
•
information on equipment interfaces and methods for testing and troubleshooting; and
•
maintenance support information necessary to ensure that the condition of the
modification remains safe throughout its lifetime.
1.2 The attached checklist (see Attachment 1) may be used in developing ICAs. The checklist is a
tool for both the applicant and the authorised person to use for review. However, it is recommended
that the applicant should also refer to the ICA appendices in the applicable airworthiness standard,
as each one may have a subtle difference that may require consideration.
1.3 ICAs are required to be CASA-accepted when they meet all of the elements of the applicable
certification standards referenced “Appendix.” If a modification is required to have an
Airworthiness Limitation Section within an ICA, that section must be CASA-approved.
1.4 ICAs must be in the form of a manual or manuals, as appropriate, for the quantity of data to
be provided. As with other service documents, the ICA should indicate the number of effective
pages and the revision level so maintenance personnel can determine whether the aircraft is being
maintained in accordance with current information.
1.5 An ICA should be revised when experience with the product show the way that the product is
maintained or inspected needs to be changed.
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33
Attachment 1
INSTRUCTIONS FOR CONTINUED AIRWORTHINESS (ICA) CHECKLIST
A/C Make: __________ Model: ______________ S/N: ____________ Reg. Mark:VH- _______
Revision: __________ Date: ______________
System: ____________
Item
Subject
1.
Introduction: Briefly describes the aircraft, engine, propeller, or component that has been
modified. Include any other information regarding the content, scope, purpose, arrangement,
applicability, definitions, abbreviations, precautions, units of measurement, list of parts used,
referenced publications, and distribution of the ICA, as applicable.
Description: Of the modification and its functions, including an explanation of its interface with
other systems, if any.
Control, operation information: Or special procedures, if any.
Servicing information: Such as types of fluids used, servicing points, and location of access
panels, as appropriate.
Maintenance instructions: Such as recommended inspection/maintenance periods in which each
of the major modification components are inspected, cleaned, lubricated, adjusted, and tested,
including applicable wear tolerances and work recommended at each scheduled maintenance
period. This section can refer to the manufacturers’ instructions for the equipment installed where
appropriate (e.g., functional checks, repairs, inspections). It should also include any special notes,
cautions, or warnings, as applicable.
Troubleshooting information: Describes probable malfunctions, how to recognise those
malfunctions, and the remedial actions to take.
Removal and replacement information: Describes the order and method of removing and
replacing products or parts, and any necessary precautions. This section should also describe or
refer to manufacturer’s instructions to make required tests, checks, alignment, calibrations, centre
of gravity changes, lifting, or shoring, etc., if any.
Diagrams: Of access panels and information, if needed, to gain access for inspection.
Special inspection requirements: Such as X-ray, ultrasonic testing, or magnetic particle
inspection, if required.
Application of protective treatments: To the affected area after inspection and/or maintenance,
if any.
Data: Relative to structural fasteners such as type, torque, and installation requirements, if any.
List of special tools: Special tools that are required, if any.
For commuter category aircraft: Provide the following additional information, as applicable:
A. Electrical loads
B. Methods of balancing flight controls
C. Identification of primary and secondary structures
D. Special repair methods applicable to the aircraft
Recommended overhaul periods: Required to be noted on the ICA when an overhaul period has
been established by the manufacturer of a component or equipment. If no overhaul period exists,
the ICA should state for item 14, “No additional overhaul time limitations.”
Airworthiness limitation section: Includes any “approved” airworthiness limitations identified
by the manufacturer. If no changes are made to the airworthiness limitations, the ICA should state
for item 15, “No additional airworthiness limitations” or “Not Applicable.”
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
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CAAP 35-1(0): Design approval of modifications and repairs
INTENTIONALLY LEFT BLANK
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