“Global Safety Management: Revolution or Evolution”
Implementation of
Design Approval Holder
Rules
Certification/Maintenance Session
U.S./Europe International Aviation Safety Conference
By: Ali Bahrami, FAA; Martin Eley, TCCA; Yves Morier, EASA
Date: June 5, 2008
DAH Rule Implementation
• DAH rules are a new approach for facilitating
timely implementation of certain complex, fleetwide safety initiatives.
• DAH rules rely on a proactive, program
management approach.
– Requirements for compliance plans and draft
data/document submittals, in addition to final
data/documents
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FAA DAH Rules
• The FAA has issued two final rules containing
DAH requirements:
– Enhanced Airworthiness Program for Airplane Systems
(EAPAS)
• Final Rule published November 8, 2007
– Aging Aircraft Safety Rule (AASR)
• Final Rule published December 12, 2007
• The FAA expects to issue the Widespread Fatigue
Damage (WFD) and Flammability Reduction
Means final rules this year.
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Coordination – FAA/TCCA/EASA/ANAC
• The FAA, TCCA, EASA, and ANAC have been in
close coordination since early 2005 to:
– Share draft rulemaking and guidance documents to
facilitate harmonization
– Develop a joint Design Approval Holder (DAH) rule
implementation strategy
– Define a plan to support each other’s aging aircraft rule
implementation program
• TCCA, EASA, and ANAC intend to issue similar
rules.
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FAA DAH Rule Implementation
• To support the implementation of these DAH rules,
we took the following actions:
Pre-rule issuance:
– Issued an FAA Order and Advisory Circular
– Formed teams for compliance and standardization
activities within the FAA
– Developed and conducted internal training/workshops
on the technical and program management aspects of
these rules
• This material was also offered to TCCA, EASA and ANAC
– Coordinated with TCCA, EASA and ANAC
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FAA DAH Rule Implementation
• To support the implementation of these DAH
rules, we took the following actions (cont):
Post-rule issuance (to-date):
– Issued letters to affected DAHs
• informed them of the rule issuance
• offered training materials
• requested a meeting
– Conducted familiarization meetings with DAHs
• reviewed rule requirements and compliance expectations
• emphasized need for close coordination throughout program
– Worked closely with DAHs, EASA, TCCA, and ANAC
during compliance plan development activity
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FAA EAPAS Rule Summary
• EAPAS Requirements:
– New and revised safety standards for design,
installation, and maintenance programs related to
electrical wiring systems.
– DAHs to develop enhanced maintenance actions by
December 10, 2009.
• Supporting requirements:
– Compliance plans due March 10, 2008
– Draft data/documents due October 10, 2009
– Operators to incorporate those actions into their
maintenance programs by March 11, 2011.
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FAA EAPAS Rule Status
• Compliance plans due: 3/10/08
– Status: Almost 100% of required plans submitted (~1700)
– We are actively working to obtain compliance from the
few DAHs who have not yet completed this requirement
– We are reviewing compliance plans and formally
responding to DAHs
• FAA will continue to closely coordinate with DAHs,
TCCA, EASA, and ANAC as DAHs develop their
draft and final data/documents.
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FAA AASR Rule Summary
• AASR Requirements:
– DAHs to develop damage tolerance (DT) based
inspections by June 30, 2009.
• Supporting requirements:
– Compliance plans (TC Holders) due April 10, 2008
– Compliance plans (STC Holders) due July 9, 2008
– List of Fatigue Critical Baseline Structure (TC Holders) due
July 9, 2008
– List of Fatigue Critical Alteration Structure (STC Holders) due
January 5, 2009
– Draft DT based inspections due April 30, 2009
– Repair Evaluation Guidelines (TC Holders) due December 30, 2009
– Operators to incorporate those DT based inspections into
their programs by December 20, 2010.
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FAA AASR Rule Status
• Compliance plans (TC Holders) due: April 10, 2008
– Status: 100% of required plans submitted (~40)
– We are reviewing compliance plans and plan to formally
respond to DAHs by the end of May
• FAA is actively working with STC holders to prepare
for the 3000+ plans to be submitted by July 9,
2008.
• FAA will continue to closely coordinate with DAHs,
TCCA, EASA, and ANAC as DAHs develop their
draft and final data/documents.
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TCCA Regulatory Plan
• To propose change to CAR 521 (DAH rules) and
CAR 605 (operating rules):
–
–
–
–
per CARAC working group report approved Oct 4/07
to be technically similar to FAA, EASA and ANAC
action now to proceed through regulatory process
estimate 2012 timeframe for new rules
• In short term, coordinated with FAA/EASA/ANAC,
TCCA will use existing Canadian requirements,
where applicable.
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EASA: Cooperation with Other
Authorities
• Very good cooperation with ANAC, FAA and
TCCA both in rulemaking and certification
fields
– Rulemaking:
• In the context of the rulemaking cooperation procedures
with FAA and TCCA.
• Monthly teleconferences
– Certification:
• EASA is providing assistance to FAA to implement the
AASR and EAPAS rules.
• Workshop organised in 14 December 2007
• Regular (bi-weekly) teleconferences
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EASA: Rulemaking Framework for
Aging Aircraft Activities
• Design Approval Holder rules:
– Long term: included in the Basic Regulation 216/2008
• Revised article 5 request to create provisions into Part-21
with regard to:
– Syllabus for Maintenance certifying staff type rating training,
syllabus of pilot type rating training, MMEL, additional
airworthiness specifications for a given type of operations
• Task 21.039 of rulemaking programme: Incorporation of
‘operational’ issues in Type certificate.
– NPA scheduled 4 quarter 2008
– Opinion scheduled 3 quarter 2009.
– One of the options under consideration for DAH rule would be
a concept of Safety Enhancement Directive
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EASA: Rulemaking Framework for
Aging Aircraft Activities
• Design Approval Holder rules:
– In the meantime for Aging Systems:
• Use of Paragraph 21A.3B (c) (1) that broadly says:
– When an airworthiness directive has to be issued by the Agency,
the DAH shall propose the appropriate corrective actions or
required inspections and submit details of these proposals to the
agency for approval.
• The Agency would sent letters to request review of ICA to
incorporate results of EZAP by DAH holders.
– Airworthiness Directives would be issued only in case of noncooperation by a DAH.
• When ICA are amended by DAH, Operators are required by
Part-M to incorporate them into their maintenance
programmes.
• TCDS will record compliance to EWIS ICA provisions
(Appendix H.25.5)
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EASA: Rulemaking Framework for
Aging Aircraft Activities
– In the meantime for Aging Systems:
• Pending modification of TCDS, generic special
conditions quoting the relevant paragraphs of
CS-25 as modified by the EWIS NPA will be
systematically issued for approvals of
modifications affecting EWIS when application is
after the amendment to CS-25 (June 2008)
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EASA: Rulemaking Framework for
Aging Aircraft Activities
• Maintenance rules:
– Maintenance programmes
• Part-M M.A.302 requires maintenance programmes to be based
on data produced by TC holders, STC holders or organisations
required to by Part-21:
– (f)
The maintenance programme must be subject to periodic reviews
and amended when necessary. The reviews will ensure that the
programme continues to be valid in light of operating experience
whilst taking into account new and/or modified maintenance
instructions promulgated by the Type Certificate holder.
– (g) The maintenance programme must reflect applicable mandatory
regulatory requirements addressed in documents issued by the Type
Certificate holder to comply with Part 21A.61.
• Anything else requires the approval by the competent authority. In
the case of ALIs this is EASA.
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EASA: Rulemaking for Aging Systems
• NPA 2007/01 EWIS
(Electrical Wiring Interconnection Systems)
– Published February 2007
– CRD published March 2008
– Expected final rule June 2008
• Technically equivalent to FAA rules
• Vehicle for retroactive application different (see previous slides)
• Both TC holders and STC applications after final rule date will be
addressed
• Dates will be aligned with FAA
– TC holder to gain approval of enhanced ICAs by 10 Dec. 2009
(7 June 2010 for future STC)
– Operator implementation by 10 Dec. 2010 according to M.A.302
(7 June 2011)
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EASA: Rulemaking for Aging Systems
• CS-25
– New CS-25 Subpart H containing all wiring related
requirements in one place, titled Electrical Wiring
Interconnect System (EWIS).
– Amendments to existing CS-25 requirements that are
necessary due to the creation of the new subpart H.
– Amendment to appendix H of CS-25 Instructions for
Continued Airworthiness with associated AMC.
– Creation of new Advisory Material in CS-25 book 2 to
support the new Subpart H and CS 25.1357(f).
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EASA: Rulemaking for Aging Systems
• Others
– Amendment to part M to revise:
• AMC.M.A.302 for maintenance programmes, and
• M.A.706 for training requirements
– Amendment to Part 66 syllabus module 7.7 to
reflect EWIS training recommendations
– Introduction of three new AMC 20 leaflets:
• AMC 20-21 EZAP
• AMC 20-22 EWIS Training Programme
• AMC 20-23 Electrical Standard Wiring Practises Manual
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EASA: Rulemaking for Aging Structure
• Development of an aging aircraft structure plan:
– Rulemaking group MDM.028 put in place in October 2007 with
FAA participation.
• Three main tasks:
– Large aeroplanes
• NPA: 3rd quarter 2008
• Opinion/ Decision: 3nd quarter 2009
– Other aircraft
• NPA: 4th quarter 2008
• Opinion/ Decision: 4th quarter 2009
– Change of operational use.
• NPA: 4th quarter 2008
• Opinion/ Decision: 4th quarter 2009
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EASA: Rulemaking for Aging Structure
• Large aeroplanes: Develop the technical
elements for a plan (I):
– Review the 5 ageing aircraft issues:
• Corrosion prevention and Control
• Damage tolerance based inspections for all structure including
repairs and modifications
• Widespread fatigue damage
• Service bulletins review
• Mandatory Modification Programmes
– Identify options for implementation to both the existing and
future fleet. Consideration should be given to both mandatory
and non-mandatory actions and to which aircraft and
operations these actions would be applicable.
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EASA: Rulemaking for Aging Structure
• Large aeroplanes: Develop the technical
elements for a plan (II):
– Select options and justify proposed actions through
development of a Regulatory Impact Assessment.
– For issues deemed to be mandatory, develop the
following points, based on the technical work and
recommendations previously established:
• The actions needed to be accomplished by the TC/STC
holder and operators and the timescales necessary for
compliance
• Rule and AMC material for incorporation into maintenance
requirements
• New standards to be included in the CSs as necessary.
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EASA: Rulemaking for Aging Structure
• Other aircraft:
– Develop a Regulatory Impact Assessment (RIA) for identifying
the need to go beyond large aeroplanes
– Based on the results of the RIA, develop comparable technical
elements for a plan in a comparable manner as for task 1.
– Review and develop AMC 20-11, to reflect its wider
applicability, as necessary
• Change of operational use:
– Amend xx.1529 to add a requirement on the TCH to publish
key assumptions used in the structural analysis.
– Propose compatible changes to Part M as necessary to ensure
operators observe these assumptions.
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Summary
• Early coordination between the FAA, TCCA, EASA, and
ANAC helped:
– maximize harmonization of rules and guidance
– support standardized rule implementation
– define a plan for mutual support of our respective aging aircraft
rules and implementation programs
• Our proactive program management and collaboration
has facilitated timely DAH compliance with requirements.
• We look forward to our continued partnership with Civil
Aviation Authorities and industry to ensure compliance
with these important safety initiatives.
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