Post on 21-Aug-2020
DSAÉ (FR MAA) considerations
for the approval of industrial
Maintenance Organisations
MAWA Conference
2015
EINDHOVEN
Brigadier General Guy-Daniel MARY French Airworthiness Directorate
ICETA (Lt-Col) Richard DURIEZ Initial Airworthiness Adviser to the Directorate
Oct 2015 FR DSAÉ considerations for the
approval of industrial MOs 2
Overview
1. STRATEGIC APPROACH
• Reminder about DSAÉ presentations during previous MAWA Forum : • Sep 2011 _ EMARs and the A400M
• Sep 2012 _ DSAÉ strategic vision on EMARs implementation for E.U products
• Sep 2013 _ Preserving our capacity to operate defence RPAS MALE / HALE
• Sep 2014 _ The need to achieve effective military airworthiness
• LINK between these previous presentations and the current subject : • Military harmonized Regulation as a necessity in the context of SES
• Airworthiness = cornerstone of an European military regulation harmonization
• EMARs as standards for airworthiness
• Example of A400M Industrial in service support
How to maintain a reliable controlled airworthiness environment ?
2. PRAGMATIC CONSIDERATIONS
• Reminder about FR airworthiness regulation
• Regulation applicable to Maintenance Organisations
• Approval of industrial Maintenance Organisations • Contractual structure
• Types of approvals
3. Conclusion
Oct 2015 FR DSAÉ considerations for the
approval of industrial MOs 3
Overview
1. STRATEGIC APPROACH
• Reminder about DSAÉ presentations during previous MAWA Forum : • Sep 2011 _ EMARs and the A400M
• Sep 2012 _ DSAÉ strategic vision on EMARs implementation for E.U products
• Sep 2013 _ Preserving our capacity to operate defence RPAS MALE / HALE
• Sep 2014 _ The need to achieve effective military airworthiness
• LINK between these previous presentations and the current subject : • Military harmonized Regulation as a necessity in the context of SES
• Airworthiness = cornerstone of an European military regulation harmonization
• EMARs as standards for airworthiness
• Example of A400M Industrial in service support
How to maintain a reliable controlled airworthiness environment ?
2. PRAGMATIC CONSIDERATIONS
• Reminder about FR airworthiness regulation
• Regulation applicable to Maintenance Organisations
• Approval of industrial Maintenance Organisations • Contractual structure
• Types of approvals
3. Conclusion
French DSAÉ presentation to the MAWA Executive Level Forum September 21st, 2011
ITEMS • EMARs and the A400M
• Prioritise EMAR 145 implementation
• Mutual challenges for industry and pMS
CONCLUSION
• Successful implementation of EMAR 145 is paramount for the A400M in service support
• EDA / MAWA Forum credibility is at stake
• Industry is clearly willing to adopt an internationally recognised standard
• Let the A400M programme be the pathfinder for the continuing airworthiness of all current and future cooperation programmes
Oct 2015 FR DSAÉ considerations for the approval of industrial MOs 4
SUBJECT French DSAÉ strategic vision on EMARs implementation
for European programmes
CONCLUSION
Oct 2015 FR DSAÉ considerations for the approval of industrial MOs 5
French DSAÉ presentation to the MAWA Executive Level Forum September 21st, 2012
Defence Ministers' Political Declaration (EDA Document No. 2009/36) : political support for NMAAs to develop and implement the EMARs under the auspices of EDA MAWA Forum
Failure to implement EMAR 145 for the A400M would:
Be a failure for A400M pMS in achieving the Ministers’ objective
Result in economical losses (cost of the A400M’s support)
Result in reduced interoperability and thus decreased operational capabilities
Jeopardise EDA’s credibility and efforts to harmonise airworthiness standards
To perform the mission, we need to use the A400M programme as the pathfinder
of the implementation of EMARs, mainly EMAR 145 and associated AMC.
French DSAÉ presentation to the MAWA Executive Level Forum September 24th, 2013
SUBJECT
CONCLUSION
• In order to anticipate future operations, RPAS must be integrated into international exercises, using the European airspace.
• Airworthiness is not the only domain necessary for the RPAS insertion into the airspace, but is probably the main one.
• It is crucial for the European States to produce a common regulation, anticipating the implementation of the Single European Sky, and taking into account their own operational constraints but within entire secure conditions.
Oct 2015 FR DSAÉ considerations for the approval of industrial MOs 6
PRESERVING OUR CAPACITY TO OPERATE DEFENCE RPAS MALE / HALE
French DSAÉ presentation to the MAWA Conference September 23-24th, 2014
SUBJECT
CONCLUSION • AIRWORTHINESS is fully part of AVIATION SAFETY and Civil & Military AVIATION
SAFETY is more than ever a European point of interest with the Single European Sky Initiative.
• The implementation of European Military Airworthiness Requirements in national regulations will undoubtedly represents a success in the context of SES
BUT
• there is now a need, more than ever, to speed up the implementation of EMARs in each national regulation if we want to show to the EASA world that the European Military Airworthiness is effective, as one of the main pillars of a wider European Military Safety !!!
Oct 2015 FR DSAÉ considerations for the approval of industrial MOs 7
The need to achieve effective military airworthiness in the context of ensuring wider aviation safety
Oct 2015 FR DSAÉ considerations for the
approval of industrial MOs 8
Overview
1. STRATEGIC APPROACH
• Reminder about DSAÉ presentations during previous MAWA Forum : • Sep 2011 _ EMARs and the A400M
• Sep 2012 _ DSAÉ strategic vision on EMARs implementation for E.U products
• Sep 2013 _ Preserving our capacity to operate defence RPAS MALE / HALE
• Sep 2014 _ The need to achieve effective military airworthiness
• LINK between these previous presentations and the current subject : • Military harmonized Regulations as a necessity in the context of SES
• Airworthiness = cornerstone of a European military regulation harmonization
• EMARs as standards for military airworthiness
• Example of A400M Industrial in service support
How to maintain a reliable controlled airworthiness environment ?
2. PRAGMATIC CONSIDERATIONS
• Reminder about FR airworthiness regulation
• Regulation applicable to Maintenance Organisations
• Approval of industrial Maintenance Organisations • Contractual structure
• Types of approvals
3. Conclusion
SES Goal = Economic Competitiveness of EU ATM
Oct 2015 FR DSAÉ considerations for the
approval of industrial MOs 9
2014
10
ATM/ASM
AIRPORTS
CNS
MISSIONS:
•REGULATION
•OVERSIGHT
AIRCREW
TRAINING
&
OPERATIONS
MISSIONS:
• REGULATION
WATCH &
HARMONIZATION
INITIAL
CERTIFICATION
CONTINUED
AIRWORTHINESS
CONTINUING
AIRWORTHINESS
MISSIONS:
•REGULATION
•OVERSIGHT
Oct 2015 FR DSAÉ considerations for the
approval of industrial MOs
MAA pillars to ensure wider aviation safety
A military total aviation system approach like EASA
AIRWORTHINESS
AIR ACCIDENT
INVESTIGATION
MISSIONS:
•INVESTIGATION •RECOMMENDATIONS
Oct 2015 FR DSAÉ considerations for the
approval of industrial MOs
The Type Certificate Holder (TCH) is eg.:
- FR : DO - DE : MoD BAAINBw - UK : MoD DE&S (TAA)
DESIGN
A Certificate of Airworthiness (CoA) and a Certificate of Registration (CoR) are issued for each
individual aircraft
AIRWORTHINESS MANAGEMENT
The military operator has a Continuing Airworthiness Management
Organisation (CAMO) holding a EMAR-M approval
MAINTENANCE
TRAINING
The aircraft is maintained in a EMAR-145 approved maintenance organisation (MO),
manned by technicians holding a EMAR-66 licence
(mandatory for certifying staff)
Technicians are trained in EMAR-147 approved Maintenance Training Organisation (MTO)
The Design Organisation (DO) has a EMAR-21 J approval
A Type Certificate (TC) is issued:
- Aircraft TC - Engine TC - Propeller TC - STC
PRODUCTION
The Production Organisation (PO) has a EMAR-21 G approval
11
The Airworthiness Controlled Environment in the EU military world
Oct 2015 FR DSAÉ considerations for the
approval of industrial MOs 12
Overview
1. STRATEGIC APPROACH
• Reminder about DSAÉ presentations during previous MAWA Forum : • Sep 2011 _ EMARs and the A400M
• Sep 2012 _ DSAÉ strategic vision on EMARs implementation for E.U products
• Sep 2013 _ Preserving our capacity to operate defence RPAS MALE / HALE
• Sep 2014 _ The need to achieve effective military airworthiness
• LINK between these previous presentations and the current subject : • Military harmonized Regulation as a necessity in the context of SES
• Airworthiness = cornerstone of an European military regulation harmonization
• EMARs as standards for airworthiness
• Example of A400M Industrial in service support
How to maintain a reliable controlled airworthiness environment ?
2. PRAGMATIC CONSIDERATIONS
• Reminder about FR airworthiness regulation
• Regulation applicable to Maintenance Organisations
• Approval of industrial Maintenance Organisations • Contractual structure
• Types of approvals
3. Conclusion
Oct 2015 FR DSAÉ considerations for the
approval of industrial MOs
A400M ISS mapping
13
2011 2012 2013 2014 2015 2016 2017 2018 2019 2020
EMAR 145 EMAR M EMAR 66 EMAR 147 EMAR 21
EMAR(FR) 145
EMAR(FR) 147
EMAR(FR) M EMAR(FR) 66
A400M first deliveries :
ISS contracts : FRISS
TRISS
OCCAR long term objective (2020) : Global ISS contracts
EMAR approval by MAWA Forum
EMAR implementation in the FR regulation
Multinational ISS ?
Which nations ? When will they join ?
FR/UK SSE
DEISS
AMSL and EPI are not MOs
AD&S: PERAM 145 approval 10 Feb 2014 ITP: applying to Part 145 extension for TP400 Other MOs: pending AMSL declaration
Maintenance organisations:
AIA CF : EMAR(FR) 145 approval 11 Feb 2015 AIA BX : Part 145 approval Snecma: applying to Part 145 extension for TP400 Other MOs: pending AMSL declaration
MTU: applying to Part 145 extension for TP400 Other MOs: pending AMSL declaration
RR: applying to Part 145 extension for TP400 Other MOs: pending AMSL declaration
ITP: applying to Part 145 extension for TP400
other nations : ?
Other MOs: pending AMSL declaration
Oct 2015 FR DSAÉ considerations for the
approval of industrial MOs 14
Overview
1. STRATEGIC APPROACH
• Reminder about DSAÉ presentations during previous MAWA Forum : • Sep 2011 _ EMARs and the A400M
• Sep 2012 _ DSAÉ strategic vision on EMARs implementation for E.U products
• Sep 2013 _ Preserving our capacity to operate defence RPAS MALE / HALE
• Sep 2014 _ The need to achieve effective military airworthiness
• LINK between these previous presentations and the current subject : • Military harmonized Regulation as a necessity in the context of SES
• Airworthiness = cornerstone of an European military regulation harmonization
• EMARs as standards for airworthiness
• Example of A400M Industrial in service support
How to maintain a reliable controlled airworthiness environment ?
2. PRAGMATIC CONSIDERATIONS
• Reminder about FR airworthiness regulation
• Regulation applicable to Maintenance Organisations
• Approval of industrial Maintenance Organisations • Contractual structure
• Types of approvals
3. Conclusion
Oct 2015 FR DSAÉ considerations for the
approval of industrial MOs 15
French airworthiness regulation structure
Decree 2013-367 (superseding the decree 2006-1551)
Order
« Duties »
Order
« Conditions »
Order
« Registration »
Order
« Continuing airworthiness »
Order
« RPAS »
Interdepartmental level
Authorities level
Instruction
« Initial airworthiness »
Instruction
« Continuing airworthiness »
- Essential airworthiness requirements
- Regulations considered as acceptable
means of compliance
- FRA 21
- FRA Forms
- FRA M - EMAR(FR) M (provision)
- FRA 145 - EMAR(FR) 145
- FRA 147 - EMAR(FR) 147
- FRA 66 - EMAR(FR) 66 (provision)
- FRA Forms - EMAR Forms
AMC & GM for all FRA
Mementos and procedures
Internal documents
documents : - applicable to State organisations and personnel
- applicable to industry through contracts
DGA Technical Authority DSAÉ State Aviation Safety Authority
Instruction
« Report of
technical occurrences »
Instruction
« Civil ADs and TCH
technical directives »
Instruction
« Stores and equipment
excluded from continuing
airworthiness »
Oct 2015 FR DSAÉ considerations for the
approval of industrial MOs 16
FR regulation
Order continuing airworthiness
• Art 8 - Organisation approval
• The State Aviation Safety Authority or Technical Authority , in their respective remit, issues an approval to organisations involved in the airworthiness environment, as soon as they apply for and comply with the terms and conditions of the present order.
• DO and PO approvals
• CAMO, MO & MTO approvals
• Where the organisations are involved in the frame of a State contract or a framework agreement (= industrial MOs) , the approval is issued as per the terms and conditions of the contract or the framework agreement.
• The Technical Authority or the State Aviation Safety Authority may recognize the approvals and their associated privileges, issued by the French, the European or the foreign Civil Aviation Authorities or by foreign Military Authorities.
Oct 2015 FR DSAÉ considerations for the
approval of industrial MOs 17
FR regulation
Order continuing airworthiness
• Art 8 - Organisation approval (cont’d)
• The approved organisation may subcontract all or part of its activities.
• The State Aviation Safety Authority or Technical Authority may issue an approval to a subcontracted applicant, if it complies with the eligibility conditions defined in the contract between the organisation and the State.
• In particular, the subcontractor, which produces or maintains aircraft, engines, including auxiliary power units, and propellers may be eligible to apply.
• Until the approval is issued, the competent authority may, in the conditions specified in the contractual documents, authorize an organisation bound with the State by a contract to issue documents recognized as equivalent to acceptance documents, on the scope of the application.
Oct 2015 FR DSAÉ considerations for the
approval of industrial MOs
Release to service documents for aircraft components
• AMC of FRA 145
• FRA Form 1
• EMAR(FR) Form 1
• An equivalent document from another authority, e.g.
• EASA Form 1
• FAA Form 8130-3
• EMAR Form 1 from a recognized NMAA
• CLA “Certificat libératoire acceptable” = Acceptable Release to
Service Certificate
• Used for non-approved MOs
• Transitional provision until 31 Dec 2017 or until the end of the
ongoing contract
• Used for non-approved subcontractors and countersigned by the
contractor
18
Oct 2015 FR DSAÉ considerations for the
approval of industrial MOs
Challenge of approving industrial MOs
• The regulation is applicable to industry through contracts
• Organisation approvals cannot be a prerequisite
• Organisations to apply for approval once the contract is signed
• If no approval from a former contract, the applicant is granted a
deadline to get the approval
If change of MO further to a tender between several MOs,
specific provisions to meet the requirements for a controlled
environment
• Notion of provisional approval introduced in the regulation
19
Oct 2015 FR DSAÉ considerations for the
approval of industrial MOs
Challenge of approving industrial MOs
• About identified 80 MOs to approve before 31 Dec 2017 (end of
transitional provisions), probably more due to the A400M ISS
• Contract award forecast schedule offers limited visibility on long
term workload
• The workload relating to the approval of MOs anticipated at the
creation of DSAÉ did not take into account complex international
contractual structure
• Poor visibility on subcontractors to be approved
• About 15 equivalent full time auditors for EMAR/FRA 145 audits
• FR auditors acting on MOs located in France only
• Travel expenses budget limitations
• Language barrier
Is FR DSAÉ workforce adapted ?
20
The contractor is not an MO (e.g. AMSL, NHI, EPI)
Oct 2015 FR DSAÉ considerations for the
approval of industrial MOs 21
Contractual structure
Project management (incl. Procurement) :
Contractor:
DGA, SIMMAD, OCCAR, NAHEMA…
approved MO or applicant
Maintenance is subcontracted to one or several approved MOs or
applicants
Industrial organisation is sometimes more complex than expected, particularly for programmes in cooperation
• DGA for initial MRO together with aircraft procurement • SIMMAD (Joint Structure for the MRO of Aeronautical Products) for the next MRO
contracts • OCCAR : Tiger and A400M • NAHEMA : NH90
Eventually 2nd level subcontractors Eventually 1st level subcontractors
No direct contractual links with Procurement
Oct 2015 FR DSAÉ considerations for the
approval of industrial MOs
Types of industrial MOs • EMAR M.A.201 Responsibilities:
• (g) Maintenance of military aircraft, and components thereof shall be carried out by a EMAR 145 approved Maintenance Organisation (MO)
Several cases for subcontracting :
• For the maintenance of any aircraft component outside its capability list, the approved MO may outsource to another MO which is approved or able to apply with the said component in its capability list
• For the maintenance of any aircraft component within the capability list of the approved MO
• EMAR145.A.75 (b) An approved MO shall be entitled to arrange for maintenance of any aircraft or component for which it is approved at another organisation that is working under the quality system of the organisation. This refers to work being carried out by an organisation not itself appropriately approved to carry out such maintenance under this EMAR and is limited to the work scope permitted under EMAR 145.A.65(b) procedures.
• This work scope shall not include a base maintenance check of an aircraft or a complete workshop maintenance check or overhaul of an engine or engine module
Different types of subcontractors :
• approved MOs or
• not approved organisations under the quality control of an approved MO
22
Oct 2015 FR DSAÉ considerations for the
approval of industrial MOs 23
Types of FR MO approvals
- FRA/EMAR(FR) 145 approval issued by DSAÉ
- EMAR 145 approval issued to MOs located outside FR by the relevant NMAA recognised by DSAÉ, e.g.
- PERAM 145 issued by ES DGAM - MRP 145 issued by UK MAA Benefit of recognition of other NMAAs as per EMAD R
- EASA Part 145 approval issued by the relevant NCAA on behalf of EASA - Examples of NCAAs : FR DGAC, UK CAA, DE LBA, ES AESA, IT ENAC… Feasibility ?
- When the EASA Part 145 approval is not applicable, the applicant draft a supplement to the Part 145 MOE to address specific FRA or EMAR 145 requirements
- Audit by DSAÉ on the supplement only Cooperation protocol with FR CAA to share findings
Oct 2015 FR DSAÉ considerations for the
approval of industrial MOs 24
EASA Part 145 approvals
- EASA issued a letter on 20 Mar 2013 : Rulemaking interpretation on “Maintenance release of aircraft not covered by the Basic Regulation” carried out by Part 145 approved MOs
- 3 practices (1/3): - Practice 1 :
- release statement referring to 145.A.50, - signing under EASA approval number not legally valid
- But then EASA clarified that the 3 practices are applicable to aircraft not to
components and in the NPA 2013-12, EASA proposes to add in GM 145.A.50: - For engines, propellers and other components it is not possible, in most
cases, to know in which aircraft they will be eventually installed and whether such aircraft are covered by the Basic Regulation or not. As a consequence, an EASA Part-145 (145.A.50) release (on an EASA Form 1) is generally possible. NOTE: there could be certain exceptions, such as the case of a component which can only be installed on aircraft for which civil versions do not exist.
Oct 2015 FR DSAÉ considerations for the
approval of industrial MOs 25
EASA Part 145 approvals
- 3 practices (2/3):
- Practice 2 : - the EASA Part 145 MO has also a national Part 145 approval - Release statement referring to national Part 145.A.50
- e.g. FRA, EMAR(FR), PERAM, MRP… - signing under the national approval number No objection from EASA
- Usual practice in FR
- This possibility is defined in the FRA and EMAR 145.A.70 (d) - The applicant may draft a supplement to the Part 145 MOE to address specific
FRA or EMAR 145 requirements
In order to save scarce human resources, DSAÉ chose to limit the audit to the military supplement to the Part 145 MOE
Oct 2015 FR DSAÉ considerations for the
approval of industrial MOs 26
EASA Part 145 approvals
- 3 practices (3/3):
- Practice 3 : - The national law (= national military airworthiness regulation) clearly states that
the release can be performed by an EASA Part 145 approved MO referring to the EASA Part 145 approval number
- FR military airworthiness regulation has a clear statement (Art 8 of Order Continuing Airworthiness)
- The State Aviation Safety Authority may recognize EASA approvals
- For the maintenance of A400M components, EASA proposed that a Release statement referring to national law, not to EASA Part 145.A.50
- Block 14a “Other regulation specified in Block 12 “ - Block 13 Remarks (based on EASA/EPI discussions for TP400 maintenance)
- “Certifies that the work specified was carried out in accordance with Part 145 standards as accepted by the respective NMAAs of BE, FR, DE, ES, MY, TR and UK whose national regulations have provisions for the recognition of the EASA Part-145 standards and the EASA Part-145 organisation’s approval and in respect to that work the items are considered ready for release to service”
No objection from EASA … but
Oct 2015 FR DSAÉ considerations for the
approval of industrial MOs 27
EASA Part 145 approvals
- 3 practices (3/3):
- … objection from FR CAA - Oversight limited to the capability of the applicant to maintain components
listed in its capability list, - the capability list may include military P/N recognized by EASA
- No oversight of: - the procedures applicable to military P/N - the data approved by the NMAA (e.g. ICAs) - the ADs issued by the NMAA - the recordings
- Further discussion is necessary between the various stakeholders :
- Civil : EASA and NCAAs - Mil : NMAAs
- with the support of EDA - and in the short term with OCCAR for the A400M
- Industry - to clarify what is feasible depending on the compatibility of the maintenance put
in place with the EASA PART standards
Oct 2015 FR DSAÉ considerations for the
approval of industrial MOs 28
French MO approval process : synthesis
Approved MO or applicant
Subcontractor: Approved MO or applicant
Certification of maintenance:
FRA/EMAR/EASA Form 1 or CRS for the airframe maintenance
(incl. maintenance of aircraft component by the same MO on the same facility)
Non approved subcontractor under the quality control of the approved MO
Maintenance of aircraft components within the MO capability list ?
Stores and equipment excluded from
continuing airworthiness order?
no yes yes
no
Maintenance i.a.w. maintenance manual
FRA/EMAR/Part 145 : airframe, engine/engine module
+ FRA 145 : propeller, APU, ejection seat
FRA/EMAR/EASA Form 1 signed by the MO or
« CLA » issued by the subcontractor and countersigned by the MO
CoC with traceability of the maintenance carried out
Other aircraft components
Outsourced maintenance no
yes
yes
no
Oct 2015 FR DSAÉ considerations for the
approval of industrial MOs 29
Audits of MOs
MO approvals can be optimized by:
• Outsourcing part of the audits
• Cooperation with the national CAA (for Practice 2 implementation)
• Win-win strategy through exchange of information
• Recognition of relevant NMAAs for MOs located abroad
• Win-win strategy :
• Single EMAR 145 approval
• Travel expenses limited to the recognition of the NMAA
• No more issues with the language barrier
• Use of EASA Part 145 approvals under NMAA responsibility when feasible (Practice 3)
• Limited additional workload for NCAAs
• Conditions for implementation to be further clarified with EASA in relation with NCAAs and NMAAs.
Oct 2015 FR DSAÉ considerations for the
approval of industrial MOs 30
Overview
1. STRATEGIC APPROACH
• Reminder about DSAÉ presentations during previous MAWA Forum : • Sep 2011 _ EMARs and the A400M
• Sep 2012 _ DSAÉ strategic vision on EMARs implementation for E.U products
• Sep 2013 _ Preserving our capacity to operate defence RPAS MALE / HALE
• Sep 2014 _ The need to achieve effective military airworthiness
• LINK between these previous presentations and the current subject : • Military harmonized Regulation as a necessity in the context of SES
• Airworthiness = cornerstone of an European military regulation harmonization
• EMARs as standards for airworthiness
• Example of A400M Industrial in service support
How to maintain a reliable controlled airworthiness environment ?
2. PRAGMATIC CONSIDERATIONS
• Reminder about FR airworthiness regulation
• Regulation applicable to Maintenance Organisations
• Approval of industrial Maintenance Organisations • Contractual structure
• Types of approvals
3. Conclusion
Oct 2015 FR DSAÉ considerations for the
approval of industrial MOs 31
Conclusion
Efforts for the near future
• At NMAAs level
• Speed up EMAR implementation by pMS in their national regulation
• Share the approval workload through recognition between NMAAs
• Priority on issuing EMAR 145 approvals where required in cooperation programmes
• At MAWA Forum level
• Obtain from EASA and the NCAAs the formalisation of practice 3
• Use of Part 145 approvals under NMAA responsibility without issuing additional EMAR 145 approvals where applicable
32
Thank you for your attention! Any questions? Oct 2015
FR DSAÉ considerations for the approval of industrial MOs