Task MDM.056 (Instructions for Continued Airworthiness)

Transcription

1 (Instructions for Continued Airworthiness) Juan Anton Continuing Airworthiness Manager Rulemaking Directorate EASA 1

2 Main issues addressed by task MDM.056: What information/documents/manuals are considered ICAs and how they are approved by the aviation authorities. What happens with the information/documents/manuals which are not considered ICAs. What is the level of approval/acceptance and who is responsible for their content. How does the MRB process fits in the approval/acceptance of ICAs. To whom (e.g. operators, maintenance organisation) and when this information (ICAs and non-icas) should be made available. How this information (ICAs and non ICAs) is used by operators/maintenance organisations and who can introduce changes. 2 2

3 Initial MDM.056 task: Task started with a meeting at the end of 2009 (1 day meeting) Workshop in January 2010 to better define the issues to be addressed. 3 meetings (3 days each) during participants in the Working Group: Authorities: EASA (6), FAA (2), TCCA (1), EU NAAs (1). Aircraft Manufacturers (6) Engine Manufacturers (1) Airlines / Maintenance Organisations (7) 3 3

4 Change of approach: The CMT (Certification Management Team) meeting (Dec. 2010) showed parallel activities on ICAs within EASA/FAA/TCCA. It was decided to hold a meeting between EASA/FAA/TCCA in order to have a consistent approach and to increase efficiency. The objective was to produce harmonised material. This meeting took place in April 2011, with the following conclusions: The scope of task MDM.056 was too large. It was agreed to split the task in sub-tasks: Sub-tasks related to issues of common interest would be subject to an harmonised approach between EASA/FAA/TCCA. Issues of no common interest would be dealt with separately by each authority. The group MDM.056 was put on hold (notified by letter in May 2011). 4 4

5 The following roadmap was accepted by EASA/FAA/TCCA management: Phase 1: EASA/FAA/TCCA to analyse the areas of common interest, priorities and, if necessary, the sequence of resulting sub-tasks. Phase 2: The detailed activities will be carried out according to the first phase. 5 5

6 Phase 1: Task MDM meetings (3 days each) took place between EASA/FAA/TCCA between September 2011 and January For each issue/question: The current regulations, guidance and procedures of each authority were analysed and existing differences were identified. The following was identified: the subject category whether the issue was of common interest the possible need for harmonization the importance of the issue, and the priority of work. For the issues of common interest, there was a further analysis and discussion on possible solutions (amendments to rules, guidance, policy, etc), with the intention to harmonise as much as possible. 6 6

7 Issues of common interest identified in Phase 1: Definition and identification of ICA (to be provided during the certification process). A definition has been agreed and some proposals have been made as to where such definition should be included. On-going work is taking place in order to identify the type of information which should be part of ICA and examples of typical manuals/documents. It was agreed that as soon as a document is referred within the ICAs, this document becomes an ICA and it is under the responsibility of the DAH. Proposals have been made as to where the list of approved/accepted ICAs will be included and made known to operators. 7 7

8 Issues of common interest identified in Phase 1 (continuation): Availability of ICA (to owners, operators, maintenance organizations, etc). FAA has released on 29/03/2012 a Policy PS-AIR on TDAH inappropriate restrictions on the use and availability of ICAs. Discussions need to take place on whether the availability policy applies also to TSO, PMAs, etc (not only to TC and STC). For repairs and alterations, this harmonization may not be needed since they are accepted though bilateral agreements. Completeness of ICA (at the point of aircraft certification or entry into service). 8 8

9 Issues of common interest identified in Phase 1 (continuation): Level of involvement of the competent authority (during the certification process). Each authority should clarify the meaning of the terms accepted/approved. Any guidance produced related to the level of involvement should maintain some flexibility for the authority depending on the complexity of the project. Scheduling Information (MRB process). The MRB process is already harmonised between EASA/FAA/TCCA. The objective is to reflect this in a harmonised guidance material. The FAA has AC C in the final stage of development (on how to develop and MRB process) 9 9

10 Issues of common interest identified in Phase 1 (continuation): Validation process (for ICA approved/accepted by another competent authority). The issue is whether there is a method to accept/validate imported product ICAs. Currently, the TIP seems to link ICA validation with a joint MRB process (instead of the validation of certification findings). Nevertheless, credits for the work done by other authorities for ICAs will depend on the harmonisation achieved in all the other ICA subjects. Review/acceptance of ICA by other than the authority. The system is different for each authority. EASA has received the Industry request to have the privilege to introduce minor changes (editorial) to ALS

11 Issues of NOT common interest identified in Phase 1: Mainly those linked to: What happens with the information/documents/manuals which are not considered ICAs. What is the level of approval/acceptance and who is responsible for their content. How ICAs and non ICAs are used by operators/maintenance organisations and who can introduce changes. Maintenance programme/maintenance data used during maintenance

12 Way forward (Phase 2): Sub-tasks will be created for the issues of common interest. The issues to be treated under each sub-task will depend on their similarity and on the category of stakeholders to be involved (for example, issues affecting DAHs but not affecting operators will be on a sub-task, but issues affecting also operators will be on a different sub-task). Since EASA/FAA/TCCA have already approached their positions on most of the issues of common interest (in order to achieve harmonisation), the discussions to be held with stakeholders during the sub-tasks should not significantly deviate from those pre-agreed margins (unless absolutely necessary) since it could jeopardise an eventual harmonisation

13 Way forward (Phase 2) (continuation): In order to increase efficiency, the more detailed existing regulatory/guidance material could be used as a basis during the drafting process of the future sub-tasks. For example, if on a particular subject the FAA has already more detailed guidance than EASA/TCCA, this material could be used during the drafting process (with appropriate changes, if necessary). The Terms of Reference for each sub-task will make clear all the aspects mentioned above

14 Possible sub-tasks (for issues of common interest): Sub-task 1 (mostly affects EASA/FAA/TCCA and DAHs): Definition and identification of ICA (to be provided during the certification process). Completeness of ICA (at the point of aircraft certification or entry into service). Level of involvement of the competent authority (during the certification process). Sub-task 2 (affects not only DAHs but also operators, maintenance organisations, CAMOs) Availability of ICA (to owners, operators, maintenance organizations, etc)

15 Possible sub-tasks (for issues of common interest) (continuation): Sub-task 3 (EASA/FAA/TCCA) Scheduling Information (guidance on the MRB process). Sub-task 4 (affects EASA/FAA/TCCA and DOAs/ODAs) Acceptance/approval of ICAs by other than the authority. Sub-task 5 (is a consequence of all the above): Validation process (for ICA approved/accepted by another competent authority). May need a modification of the TIP once harmonisation has been achieved on most other issues