South Asia Regional Initiatives (SARI) Overview on OSD aspects of cer2fica2on. 6 th SARI 21 Working Group mee7ng DOATL: Javier CASTILLO 5th to 7th December, 2016 Male (Maldives) Contents OSD fundamentals Changes to the Type Certificate encompassing OSD aspects Impact to the DOAs 5-7 December, 2016 6th SARI 21 Working Group mee7ng 2 1
OSD fundamentals 5-7 December, 2016 6th SARI 21 Working Group mee7ng 3 OSD fundamentals With EU Part-21 amendment 69/2014, the concept of OSD was included within the type cer7fica7on of aircraV products. The objec7ve of OSD is to ensure that certain data, necessary for the safe opera7on of aircraV by an EU operator, is made available to and used by the operators, training organisa7ons, and manufacturers of flight simulator training devices. This data is considered specific to an aircra6 type and should, therefore, be produced by the designer of that aircraV type. It could consist of: a minimum syllabus for pilot type ra7ng training; aircraV reference data to support the qualifica7on of simulators; minimum syllabus for type ra7ng training of maintenance cer7fying staff MCS; type-specific data for cabin crew training; and master minimum equipment list (MMEL). 5-7 December, 2016 6th SARI 21 Working Group mee7ng 4 2
OSD: Bridging cer7fica7on and OPS Type Specific Data OSD Part-FCL Part 21 CS-23, -25, … Part-ARO, -NCC, CS-FCD -ORO, - CAT, -SPA The OSD contributes to bridging the gap between airworthiness (AW) and air opera:ons (OPS) and, therefore, to improving safety. Furthermore, the OSD provides the basis to enable greater standardisa:on in the EU for type training and MEL. 5-7 December, 2016 6th SARI 21 Working Group mee7ng 5 OSD fundamentals Once approved, the core of the OSD must be used by operators and training organiza7ons when establishing their customized training courses and minimum equipment lists (MELs). The Type Cer:ficate (21.A.41) is therefore the customary Type Design (21.A.31) and addi7onal OSD elements Cer2fica2on basis of the A/C is the typical CS-25, CS-29, (…) and the CS- [OSD] applicable to the product. When conduc7ng of changes to the TC, it has to be assessed as well for impact on OSD. 5-7 December, 2016 6th SARI 21 Working Group mee7ng 6 3
OSD Cer7fica7on Specifica7ons CS-MCSD s:ll in progress: (RMT.0106, NPA 1st quarter 2018 – interim period to be covered through CM-MCSD-001) 5-7 December, 2016 6th SARI 21 Working Group mee7ng 7 Changes to the Type Certificate encompassing OSD aspects 5-7 December, 2016 6th SARI 21 Working Group mee7ng 8 4
Changes to Type Cer7ficate incl. OSD: Rule Subparts D and E of Part-21 made consistent: ‘change to design’ replaced by ‘change to TC’ Changes to OSD have to be approved as any other change When design change affects OSD, the OSD must be changed. [OSD]-Supplements would have to be issued by DOA. Similar to TC: possibility to postpone OSD un7l Entry into Service 5-7 December, 2016 6th SARI 21 Working Group mee7ng 9 Changes to Type Cer7ficate incl. OSD: Principles OSD is included in TC When showing compliance to applicable cer7fica7on basis, it has to be noted the applicable CS-25, CS-29, (…) and the applicable CS-[OSD] to the product. Changes to OSD need approval Main ques7ons: When does a design change require changing OSD How to classify OSD changes in minor/major How to combine design change + OSD change approval 5-7 December, 2016 6th SARI 21 Working Group mee7ng 10 5
Changes to Type Cer7ficate incl. OSD: Principles Two kinds of OSD changes Linked to a design change Stand-alone change Special case: MMEL Allevia7ve document Design change does not necessarily require MMEL change 5-7 December, 2016 6th SARI 21 Working Group mee7ng 11 OSD - FAQ When is my design change affec7ng OSD? • Determine applicability by reviewing TCDS. Note specific cer7fica7on basis • Minor changes can only affect MMEL (GM No 1 to 21.A.93(c)) • Review of OSD cons7tuent for content that might be affected • ( on STCs / major design changes ) discuss with Agency through CP 5-7 December, 2016 6th SARI 21 Working Group mee7ng 12 6
Classifica7on minor/major Classifica7on can be done separately from design change classifica7on However: in the end the whole change to the TC (design + OSD) has only one final classifica7on Criteria provided in new AMC&GM to 21.A.91 and to 21.A.93 (for MMEL) 5-7 December, 2016 6th SARI 21 Working Group mee7ng 13 Approval of changes: use of DOA If both design change and OSD change are minor: use DOA privilege to approve If design change major: 5-7 December, 2016 6th SARI 21 Working Group mee7ng 14 7
Approval of changes: use of DOA What is required when OSD is affected? • Crea7on of supplementary informa7on • Changes to OSD are provided through supplementary informa7on (similarly to e.g. AMM or AFM) • Supplements can replace certain parts of the original OSD or provide addi7onal informa7on • Demonstra7on of compliance against cer7fica7on basis • Approval • Provision of supplementary data to end user 5-7 December, 2016 6th SARI 21 Working Group mee7ng 15 Impact to the DOAs 5-7 December, 2016 6th SARI 21 Working Group mee7ng 16 8
Impact of OSD introduc7on on DOA No change to DOA principles Addi7on of ‚new‘ elements to cer7fica7on process: MMEL CCD MCSD SIMD FCD Equivalent to introduc7on of new technical areas 5-7 December, 2016 6th SARI 21 Working Group mee7ng 17 OSD - FAQ DOA has to demonstrate it has established appropriate Procedures Resources What changes to the DOA procedures are necessary? Applica7on for major change / STC approval, incl. OSD approval Determina7on of applicable requirements; Cer7fica7on program; Cer7fica7on basis; Classifica7on; Design; Demonstra7on of compliance; Approval; Declara7on of compliance; Issue of design data and informa7on and instruc7ons; 5-7 December, 2016 6th SARI 21 Working Group mee7ng 18 9
Required procedures Iden7fica7on of applicable OSD requirements To be addressed in cer7fica7on programme The change classifica7on procedure shall be revised to include OSD Specific procedures if required for demonstra7on of compliance with OSD CS (e.g. FCD) 5-7 December, 2016 6th SARI 21 Working Group mee7ng 19 Required resources Competent DEs and CVEs per OSD element (for changes) access to TC holder‘s OSD 5-7 December, 2016 6th SARI 21 Working Group mee7ng 20 10
Competence No specific qualifica7on requirements in Part 21 DO has to demonstrate that its qualifica7on requirements are appropriate e.g. previous experience from OEB ac7vity specific technical competence appropriate to the OSD element 5-7 December, 2016 6th SARI 21 Working Group mee7ng 21 Thank You for your attention! Your Safety is our Mission 11
Back-up slides Back-up 5-7 December, 2016 6th SARI 21 Working Group mee7ng 23 History and Background JOEB JOEB > EOEB OSD Evolu7on of the OPS/FCL evalua7on into the OSD 5-7 December, 2016 6th SARI 21 Working Group mee7ng 24 12
History and Background JOEB u Voluntary for the OEMs u Non-binding to the end user JOEB/EOEB u Limited to Flight Crew, Cabin Crew and MMEL u Legal status unclear 5-7 December, 2016 6th SARI 21 Working Group mee7ng 25 History and Background u Based on Basic Regula7on and Part 21 u Required for the OEMs OSD u Mandatory for the end user u Scope expanded to Maintenance Cer7fying Staff and Simulator Data 5-7 December, 2016 6th SARI 21 Working Group mee7ng 26 13
Opera7onal Suitability Data (OSD) “Data that is considered necessary for the safe opera8on of an aircra9!” 5-7 December, 2016 6th SARI 21 Working Group mee7ng OSD Regulatory Framework u Regula7on (EC) 216/2008 – " Basic Regula2on " – was extended to include the elements of opera7onal suitability evalua7on (Art. 5 – Airworthiness) u Regula7on (EU) 748/2012 – Annex I [" Part 21 "] – has been amended to approve opera7onal suitability data as part of the cer7fica7on process (Regula7on (EU) 69/2014) 5-7 December, 2016 6th SARI 21 Working Group mee7ng 14
OSD Regulatory Framework Part-ARO, -ORO, Aircrew Part-21 Regula2ons Part-CAT, -SPA Commission Regula7on 1178/2011 Commission “Part-FCL” (amended Regula7on 965/2012 by Commission Regula7on (EU) Regula7on 290/2012) 748/2012 as amended by Commission Regula7on (EU) 69/2014 AMC & GM to Part-FCL AMC & GM to Part- and to Part-ORA ORO 5-7 December, 2016 6th SARI 21 Working Group mee7ng 29 The “4 boxes” concept ”OSD contain mandatory and recommended elements” (Example based on CS-FCD) Type ra2ng license Footprint – Ini2al type endorsement ra2ng course Required from (dura2on, devices, etc.) Training Areas of Special Manufacturer Emphasis (for ini2al type ra2ng course) Footprint – Differences ODR / MDR Tables course / reduced type Training Areas of Special Voluntary by ra2ng course. Training for Emphasis (e.g. for Manufacturer op2onal equipment, differences training special procedures, etc. course) 5-7 December, 2016 6th SARI 21 Working Group mee7ng 15
OSD implementa7on 7meline Deadline for OSD approval OSD 18 Jun (and extension 19 Dec Implementa7on 2014 of DOA scope) 2016 OEMs to Deadline for STC 17 Feb 18 Dec propose M vs and changes 2014 2015 or EIS NM elements for grandfathering 5-7 December, 2016 6th SARI 21 Working Group mee7ng 31 Interac7on of changes to the type design and changes to OSD 5-7 December, 2016 6th SARI 21 Working Group mee7ng 32 16
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