Overview on OSD aspects of cer2fica2on. 6 th SARI 21 Working Group - - PDF document

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Overview on OSD aspects of cer2fica2on. 6 th SARI 21 Working Group - - PDF document

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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

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1 South Asia Regional Initiatives (SARI)

Overview on OSD aspects of cer2fica2on.

6th 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

6th SARI 21 Working Group mee7ng 2 5-7 December, 2016

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2

OSD fundamentals

6th SARI 21 Working Group mee7ng 3 5-7 December, 2016

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

  • pera7on of aircraV by an EU operator, is made available to and used by the
  • perators, 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). 6th SARI 21 Working Group mee7ng 4 5-7 December, 2016

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3

OSD: Bridging cer7fica7on and OPS

Part-FCL Part-ARO, -NCC,

  • ORO, -

CAT, -SPA Part 21 CS-23, -25, … CS-FCD OSD Type Specific Data 6th SARI 21 Working Group mee7ng 5

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

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.

6th SARI 21 Working Group mee7ng 6

OSD fundamentals

5-7 December, 2016

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4

OSD Cer7fica7on Specifica7ons

5-7 December, 2016 6th SARI 21 Working Group mee7ng 7

CS-MCSD s:ll in progress: (RMT.0106, NPA 1st quarter 2018 – interim period to be covered through CM-MCSD-001)

Changes to the Type Certificate encompassing

OSD aspects

6th SARI 21 Working Group mee7ng 8 5-7 December, 2016

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5

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

  • ther 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

6th SARI 21 Working Group mee7ng 9 5-7 December, 2016

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

6th SARI 21 Working Group mee7ng 10 5-7 December, 2016

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6

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

6th SARI 21 Working Group mee7ng 11 5-7 December, 2016

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

6th SARI 21 Working Group mee7ng 12 5-7 December, 2016

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7

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)

6th SARI 21 Working Group mee7ng 13 5-7 December, 2016

Approval of changes: use of DOA

If both design change and OSD change are

minor: use DOA privilege to approve

If design change

major:

6th SARI 21 Working Group mee7ng 14 5-7 December, 2016

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8

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

Approval of changes: use of DOA

6th SARI 21 Working Group mee7ng 15 5-7 December, 2016

Impact to the DOAs

6th SARI 21 Working Group mee7ng 16 5-7 December, 2016

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9

6th SARI 21 Working Group mee7ng 17

Impact of OSD introduc7on on DOA

No change to DOA principles Addi7on of ‚new‘ elements to cer7fica7on process:

FCD SIMD MCSD CCD MMEL

Equivalent to introduc7on of new technical areas

5-7 December, 2016

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; 6th SARI 21 Working Group mee7ng 18 5-7 December, 2016

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10

6th SARI 21 Working Group mee7ng 19

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

  • f compliance with OSD CS (e.g. FCD)

5-7 December, 2016 6th SARI 21 Working Group mee7ng 20

Required resources

Competent DEs and CVEs per OSD element (for changes) access to TC holder‘s OSD

5-7 December, 2016

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11

6th SARI 21 Working Group mee7ng 21

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

Your Safety is our Mission Thank You for your attention!

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12

Back-up slides

Back-up

6th SARI 21 Working Group mee7ng 23 5-7 December, 2016

History and Background

JOEB JOEB > EOEB OSD

Evolu7on of the OPS/FCL evalua7on into the OSD

24 6th SARI 21 Working Group mee7ng 5-7 December, 2016

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13

History and Background

JOEB JOEB/EOEB

u Voluntary for the

OEMs

u Non-binding to the

end user

u Limited to Flight Crew,

Cabin Crew and MMEL

u Legal status unclear

25 6th SARI 21 Working Group mee7ng 5-7 December, 2016

History and Background

u Based on Basic Regula7on

and Part 21

u Required for the OEMs u Mandatory for the end

user

u Scope expanded to

Maintenance Cer7fying Staff and Simulator Data

OSD

6th SARI 21 Working Group mee7ng 5-7 December, 2016 26

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“Data that is considered necessary for the safe

  • pera8on of an aircra9!”

Opera7onal Suitability Data (OSD)

5-7 December, 2016 6th SARI 21 Working Group mee7ng

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)

OSD Regulatory Framework

5-7 December, 2016 6th SARI 21 Working Group mee7ng

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15

Part-21

Regula7on (EU) 748/2012 as amended by Commission Regula7on (EU) 69/2014

Aircrew Regula2ons

Commission Regula7on 1178/2011 “Part-FCL” (amended by Commission Regula7on 290/2012) AMC & GM to Part-FCL and to Part-ORA

Part-ARO, -ORO, Part-CAT, -SPA

Commission Regula7on 965/2012 AMC & GM to Part- ORO

OSD Regulatory Framework

29 6th SARI 21 Working Group mee7ng 5-7 December, 2016

Type ra2ng license endorsement Training Areas of Special Emphasis (for ini2al type ra2ng course) Footprint – Ini2al type ra2ng course (dura2on, devices, etc.) ODR / MDR Tables Training Areas of Special Emphasis (e.g. for differences training course) Footprint – Differences course / reduced type ra2ng course. Training for

  • p2onal equipment,

special procedures, etc. Required from Manufacturer Voluntary by Manufacturer

The “4 boxes” concept

”OSD contain mandatory and recommended elements” (Example based on CS-FCD)

5-7 December, 2016 6th SARI 21 Working Group mee7ng

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OSD implementa7on 7meline

OSD Implementa7on OEMs to propose M vs NM elements for grandfathering Deadline for OSD approval (and extension

  • f DOA scope)

Deadline for STC and changes 17 Feb 2014 18 Jun 2014 18 Dec 2015 or EIS 19 Dec 2016

31 6th SARI 21 Working Group mee7ng 5-7 December, 2016

Interac7on of changes to the type design and changes to OSD

6th SARI 21 Working Group mee7ng 32 5-7 December, 2016

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17

Interac7on of changes to the type design and changes to MMEL

6th SARI 21 Working Group mee7ng 33 5-7 December, 2016

Design changes requiring MMEL change

When does a design change trigger the need to

change MMEL

Due to allevia7ve nature of MMEL: not required to

add MMEL relief for new equipment

Design change can have affect on exis7ng MMEL

item: see graph

6th SARI 21 Working Group mee7ng 34 5-7 December, 2016

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18

6th SARI 21 Working Group mee7ng 35

Competence FCD

Delivery:

Pilot Type Ra7ng Training syllabus

MC 6:

Flight Tes7ng

Human factors Handling characteris7cs TASE

DE:

TRI cer7ficate?

CVE:

TRE cer7ficate?

5-7 December, 2016 6th SARI 21 Working Group mee7ng 36

Competence MMEL

Delivery: Master Minimum Equipment List

MC 3:

Safety assessment

DE/CVE: equipment / system knowledge

  • pera7onal requirements knowledge

5-7 December, 2016

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6th SARI 21 Working Group mee7ng 37

Competence CCD

Delivery: AircraV descrip7on

MC 1:

Design review

DE/CVE: Cabin Safety

  • pera7onal requirements knowledge

5-7 December, 2016

The OSD Team