Post on 15-Dec-2015
Information for Delegation Holders
Peter GillAirworthiness Engineer
Topics to be covered:
Delegation Changes since 2009 Major Design Change Authorisation
Process Manufacturing Considerations STC’s AC’s Other Miscellaneous Topics
Delegation Changes since 2009
No approval of modification classified as “major design change” (schedule One) without CAA authorisation
CAA undertook to give authorisation for appropriate “one-off” modifications where not contrary to CAA policy
All delegations which included modifications were re-issued August 2010
Authorisation Process
Authorisation Requests
2010 10 Yes 0 No 2011 54 Yes 5 No Reasons for No: 1 – Unusual design features
1 – HEC (CAA Policy – STC)1 – 21.303 (later authorised)1 – Operational Concern1 – TCDS Change
2012 10 Yes 0 No
Manufacturing Considerations
Part 146 organisations approve data – do not authorise manufacture
CAA expect part 146 organisations to promote compliance with Rules where possible
CAA has publicised compliance with 21.303 to industry (Vector magasine article Nov/Dec 2010)
Factor in authorisation process
Manufacturing Considerations Contd
CAR 21.303 – be manufactured “by a person performing maintenance on the product…” No subcontracting (can supervise) NOTE: “Subcontracting” term here is used in the
manufacturing sense where the manufacturer takes responsibility for the subcontractors work.
Where the “subcontractor” has an organisation certificate of its own and can issue a release certificate, that is acceptable (they are then a “supplier” rather than a ‘subcontractor”.)
Manufacturing Considerations Contd
How to approved “existing” equipment (where origin unknown)? Should be a document (Form One or
Two) identifying part and origin Part 21Q has always required part
marking
STC’s
See later presentation from Beth Small number of “New” STC’s Large number started, stalled Time delays – CAA extra assessment Certification Basis – Determine iaw FAR
21.101 Changed Product Rule Requirement for any STC where FAA validation is likely
to be sought Should always specify why you can’t/don’t use the latest
requirements
Advisory Circulars
Advisory Circulars to be revised or written by ACU (we welcome comments or suggestions): AC 146-1 - Clarify CAA position on “one-
man-bands”; Clarify Delegation Issue Process; General Update
AC 148-1 – General Update; Remove Extraneous material; Clarify CAA position on Subcontractors, senior person qualifications, Critical Parts, Design Data.
Advisory Circulars Contd
AC 43-9 (Mods, Repairs, 337) – Complete re-write and update
AC 91-5 (PEDS) – General update
New AC on aircraft Electrical Load Analysis
- Probably an AC 91-X – detailing how the owner should maintain an ELA for his aircraft
Miscellaneous Topics
Where making a minor change to a “major design change” – is this major? Original approver? Effect of change?
Continuation of Class A/B delegation classifications? Not yet determined
Miscellaneous Topics Contd
Delegation of Part 146 activities: Testing Data (eg Weight & Balance data)
Electrical/Mechanical demarcation 1309 training – Seen by CAA as
essential
Miscellaneous Topics Contd
Surveillance – effect of new policy Increased preparation More targeted audit No change to delegate monitoring
Questions?