defence aviation safety regulation · dasr 21 practitioner course y one background introduction to...
TRANSCRIPT
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Defence Aviation Safety Regulation DASR 21 PRACTITIONER COURSE Aircraft Design, Production and Certification
1
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Course Administration
Welcome:
• Emergency Brief – Fire Exits / First Aid
• Amenities – Toilet / Coffee / Food etc
• Mobile Phones
• Course:
– Style (guided discussion)
– Questions
– Feedback (formal/informal) [email protected]
– Sign in (PMKeys reported)
2
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DASR 21 Practitioner Course
Da
y O
ne
Background
Introduction to DASR 21
Subpart B – MTC & MRTC
Subpart D & E – changes to MTC & MSTC
Subpart M – Repairs
Da
y t
wo
Subpart H – MCoA & MRCoA
Subpart P – MPTF
Subpart K – Parts & Appliances
Subpart O – AUSMTSO
Subpart J – MDOA
Safety Management System (SMS)
Subpart F & G – Production
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Learning Outcomes
To provide working level understanding of DASR 21 regulation and its application.
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DASR 21 Practitioner Course
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Outline
– Nimrod accident
– Genesis of DASR
• Former Defence Airworthiness Regulations
– DASR progress
– Defence Aviation Safety Program (DASP)
– Defence Aviation Safety Regulation (DASR)
• Structure
• Definitions
• Organisational responsibilities
Outline: DASR Background
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Sir Charles Haddon-Cave address to DGTA-ADF
6
Nimrod XV230
DASR Background – Nimrod accident
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‘7 Pillars of Nimrod’:
– Responsibility
– Risk to Life/Operators input
– Challenge Orthodox practices
– Have moral Courage
– Leadership
– Just Culture
– Duty Holders (accountability)
DASR Background – Nimrod accident
Nimrod Accident (Haddon-Cave)
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Nimrod Accident (Haddon-Cave)
Outcomes:
– ‘Clear line of Accountability and Responsibility’
– Issues with outsourcing
– Assignment of Risk
– Status of Continued/ing Airworthiness
8
DASR Background – Nimrod accident
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Former Defence Airworthiness Regulations
9
DI(G) OPS 2-2
Defence Aviation Safety
Program
AAP7001.053
Technical Airworthiness Management Manual
TAREG
AAP7001.048
Defence Aviation Safety Program Manual
MILAVREG
AAP8000.010
Defence Operational Airworthiness Manual
OAREG
DASR Background – Genesis of DASR
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DASR Background – Genesis of DASR
•Civil Australian
•Military Australian
•Civil International
•Military International
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DASR Background – Genesis of DASR
Harmonisation: EMAR/DASR Evolution
Military Regulation
Complex & non-complex aircraft
Aviation Safety Frame work
Complex & non-complex aircraft
Aviation Safety Frame work
Military Airworthiness Requirements
Civilian International
Militarised
(Airworthiness only)
EASA Regulations
European Military Airworthiness Requirements (EMAR)
Implemented EMAR in military aviation safety framework
For Example: Defence Aviation Safety Regulation (DASR)
Alignment between Civil and Military
International Civil Aviation Organisation (ICAO)
Complex & non-complex aircraft
Modelled on EASA
Aviation Safety Frame work
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Defence Aviation Safety Framework
12
Defence Aviation Authority (Chief of Air Force)
Defence Aviation Safety Authority
ACPA DDAAFS
Command / Executive Authority Responsible for Aviation Safety
Operational
Organisations
Continuing
Airworthiness
Organisations
Continued
Airworthiness
Organisations
Assure aviation safety.
Ensure aviation safety.
Assure aviation safety.
Ensure aviation safety.
Sa
fety
In
ve
stig
atio
n
Program Level
System Level
Co
mp
lian
ce
an
d R
evie
w
DAVCOMP, DAVENG, DAVCERT, DAVREG,
DBSI
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DASR Background – DASP
13
DASA Command Arrangements and Organisation
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DASR Background
14
Operational Airworthiness nomenclature in DASR Previous regulatory framework (MILAVREG)
Technical
airworthiness
Operational airworthiness
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DASR Background
15
Operational Airworthiness nomenclature in DASR
DASA manual
Guidance Material
Operational elements
Technical elements
DASR framework
Technical
airworthiness
Operational airworthiness
I n i t
i a l a
i r w
o r t
h i n
e s s
Flight operations
AwBs
I n i t
i a l a
i r w
o r t
h i n
e s s
C o
n t i
n u
i n g
a i r
w o
r t h
i n e
s s
A i r
s e r
v i c e
s
A e
r o d
r o m
e s
m s
A v
i a t i
o n
S a
f e t y
M a
n a
g e
m e
n t
S y
s t e
Previous regulatory framework (MILAVREG)
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DASR Background
16
Operational Airworthiness nomenclature in DASR
DASA manual
Guidance Material
Operational elements
Technical elements
DASR framework
Technical
airworthiness
Operational airworthiness
I n i t
i a l a
i r w
o r t
h i n
e s s
Flight operations
AwBs
I n i t
i a l a
i r w
o r t
h i n
e s s
C o
n t i
n u
i n g
a i r
w o
r t h
i n e
s s
A i r
s e r
v i c e
s
A e
r o d
r o m
e s
m s
A v
i a t i
o n
S a
f e t y
M a
n a
g e
m e
n t
S y
s t e
Operational Airworthiness
Previous regulatory framework (MILAVREG)
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DASR Background
DefenceAA/DASA/DASP/DASR amplify WHS legislation
WHS Act
Command must ensure that hazards/risk reduced SFARP
Explosives
Aviation
Radiation
Falling objects Confined spaces
Noise
Lifting Demolition
Diving
Electrical
Chemicals
Lead
Asbestos
Fire
Contaminated air
Heights
Maintenance of plant
Excavating
Poor training
Poor labels
Poor health monitoring
Poor reporting
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DASR Background
DefenceAA/DASA/DASP/DASR amplify WHS legislation
DefenceAA
DASA - DAVREG - DAVCERT - DAVCOMP - DAVENG - DDAAFS - DACPA
DASP - Policy / regulation - Promotion/education - Initial Safety Case - Ongoing Assurance
DASR
DefenceAA assures Defence aviation safety
No WHS obligations : specialist amplification of WHS provisions for Defence Aviation hazards
Ris
k d
ecis
ion
s r
egar
din
g ca
pab
ility
/ s
afet
y
Ris
k a
dvi
ce r
egar
din
g d
efen
sib
le s
tan
dar
ds
Explosives
Aviation
Radiation
Falling objects Confined spaces
Noise
Lifting Demolition
Diving
Electrical
Chemicals
Lead
Asbestos
Fire
Contaminated air
Heights
Maintenance of plant
Excavating
Poor training
Poor labels
Poor health monitoring
Poor reporting
WHS Act
Command must ensure that hazards/risk reduced SFARP
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DASR Background
Clear safety accountabilities under Legislation / Common Law
CO/CENGR CO SQN
OC Wing
DefenceAA assures Defence aviation safety
DefenceAA
DASA
DASR
CAF
ACAUST
FEGCDR
CASG
HASD
OC SPO
Command must ensure that hazards/risk reduced SFARP
No WHS obligations : specialist amplification of WHS provisions for Defence Aviation hazard
DASP
Ris
k d
ecis
ion
s r
egar
din
g ca
pab
ility
/ s
afet
y
Ris
k a
dvi
ce r
egar
din
g d
efen
sib
le s
tan
dar
ds
DG
WHS Act
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DASR Background
CO/CENGR CO SQN
OC Wing
DefenceAA assures Defence aviation safety
DefenceAA
DASA
DASR
CAF
ACAUST
FEGCDR
CASG
HASD
OC SPO
Command must ensure that hazards/risk reduced SFARP
No WHS obligations : specialist amplification of WHS provisions for Defence Aviation hazard
DASP
Ris
k d
ecis
ion
s r
egar
din
g ca
pab
ility
/ s
afet
y
Ris
k a
dvi
ce r
egar
din
g d
efen
sib
le s
tan
dar
ds
DG
Appointment of OAA confuses legal obligations/accountabilities
OAA
WHS Act
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DASR Background
Former regulatory approvals and appointments
ACAUST OAA
SPO SQN
AEO AMO
OP
TECH
OP
TECH
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DASR Background
DASR targeted at lowest practicable level (MAO/CAM)
SPO SQN
DASR-21 DASR-145
ACAUST/COMD FORCOMD/COMAUSFLT: •Exercise command authority •Make capability/safety decisions •Govern (multiple) air operators •Establish common systems and interoperability QMS QMS QMS
DASR-SMS DASR-SMS DASR-SMS
Military Air Operator: • Flying Management System • Orders, Instructions, Pubs • Training and Qualifications • Quality Management • Safety / Risk Management • Continuing Airworthiness
MAO / CAM
FEGCDR
ACAUST CAA
IAW
Co
mm
an
d D
ire
cti
on
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Hierarchy of Defence Aviation Safety Policy
CAF Charter Letter Appoints Defence AA and articulates accountabilities
Basic Regulation Implementing Regulation
AMC & GM
Glossary
Joint Directive 24/2016 Mandates compliance with aviation safety policy manuals
Defence Aviation Safety Assurance Manual Establishes aviation safety framework and gives effect to subordinate manuals
Defence Aviation Safety Regulations
MDOA & MPOA Instructions & Publications
DOE & POE
TCAE QM & SMS
Flight Manual / ICA
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CPP
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DASR Structure
24 Airworthiness Operations
DASR Background – DASR
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Initial vs Continuing Airworthiness
• Initial & Continued Airworthiness: – Type Design – Certification – Production – Design changes post initial type certification – Repair designs
• Continuing Airworthiness: – All of the processes ensuring that the aircraft:
• complies with airworthiness requirements • is in condition for safe operation • Supported within a ‘Controlled Environment’
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DASR 21
Type
DASR M
Tails
DASR Background – DASR
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DASR Language
Key to effective application of the DASRs is to understand the meaning of the ‘Language’ used:
• Use of uncommon terms • Translation issues (inconsistent use of terms)
• Civil aviation language/alignment
• ‘Plain’ Language application
*Refer DASR Glossary
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DASR Background – DASR
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Airworthiness Definition
• DASR definition of airworthiness – The ability of an aircraft, or other airborne equipment or system, to
operate in flight and on ground without significant hazard to aircrew, ground-crew, passengers (where relevant) or to other third parties.
• Derived from UK MOD JSP 553 Military Airworthiness Requirements
• Consistent with EASA use of this term and ICAO definition of “Airworthy” – The status of an aircraft, engine, propeller or part when it conforms to its
approved design and is in a condition for safe operation
“Focus on the Air Vehicle”
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DASR Background – DASR
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DASR Definitions (1/2) Certification. Recognition that a product, part or appliance, organisation or person complies with the applicable airworthiness requirements followed by the declaration of compliance.
Continued (design) airworthiness. All tasks to be carried out to verify that the conditions under which a Type Certificate (TC) or Supplemental Type Certificate (STC) has been granted continue to be fulfilled at any time during its period of validity.
Military Type Certificate (MTC). Recognition that a product complies with the applicable airworthiness requirements.
Type Certificate Holder. The organisation responsible for the relevant type design and applying for, and then holding, the TC and accepting the rights and obligations for the product.
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DASR Background – DASR
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Type Certification Basis. An agreed set of airworthiness requirements a product must be compliant with in order to obtain a TC. For more details see EMAR 21.
Type Design. The minimum set of approved design information necessary to define the product type, as detailed in EMAR 21.A.31.
Derogation. “An alternative to.”
Airworthiness vs. Technical DASR. Elements of a ‘Technical’ nature are embedded across most of the DASR. ‘Airworthiness’ relates to Initial and Continuing.
DASR Definitions (2/2)
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DASR Background – DASR
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Old DASR DASR explanation
Appointments
Defence AA Defence AA Defence Aviation Authority (DAA)
ACPA, DGTA-ADF, DDAAFS
DASA Defence Aviation Safety Authority (DASA) & NMAA
DASP DASP Defence Aviation Safety Program (DASP)
MILAVREG, OAREG, TAREG
DASR Defence Aviation Safety Regulations (DASR)
Definitions New definitions using global language
Aviation Safety Aviation Safety Aviation Safety
Operational Airworthiness Operational Airworthiness
Retained for ADF use (ADF unique usage)
Technical Airworthiness Airworthiness Airworthiness (tenet of aviation safety)
OAA Nil No regulatory appointment
OAR Nil No regulatory appointment
TAA/TAR Nil No regulatory appointment
OAAR (Acq) / OAAR Nil No regulatory appointment
DASR Background – DASR Terminology
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Old DASR DASR explanation
Appointments (continued)
FEG CDR (non regulatory) MAO AM Accountable Manager for Military Air Operator (Flying Command only) and AM for CAMO
FTAA DoSA (FT) Refer explanation
Authority Delegation for flight test related Authority functions
Nil CAM Continuing Airworthiness Manager (CAM) (DASR M)
DAR Nil Replaced in part by DoSA delegations
SDE HoD Head of Design (DASR 21)
SMM RM Responsible Manager (of DASR 145 maint org)
Organisations
FEG MAO Military Air Operator (MAO)
AEO (Design elements) DASR 21J MDOA Military Design Org Approval (DASR 21J)
AEO (Continuing Airworthiness elements)
DASR M CAMO
Provider of CAMO services to FEG / CAMO
AMO (Maintenance elements)
DASR 145 AMO Approved Maintenance Organisation (DASR 145)
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DASR Background – DASR Terminology
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Old DASR DASR explanation
Instruments
AMTC MTC / MRTC Military Type Certificate (MTC) / Military Restricted Type Certificate (MRTC)
SFP MPTF Military Permit to Fly (MPTF (type))
STC MSTC Military Supplemental Type Certificate (MSTC)
FTP, SFP, AD (authorising flights), UASOP
Military Permit to Fly
Military Permit to Fly (MPTF)
Service Release MAOC Military Air Operator Certificate (MAOC)
AD AD (Global Definition)
Airworthiness Directive (Global definition)
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DASR Background – DASR Terminology
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An Air Operator
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DASR Background
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DASR Background
Australian Airline Construct
Quality (Including SMS)
Continuing Airworthiness Management Organisation
CASR Part 42
Operations - Aircrew - Training - Ground Ops
Accountable Manager
Airworthiness instruments:
* Type Certificate
* Certificate of Airworthiness
Airline must have a Relationship
with:
* Maintenance Org - CASR Pt145
* Design and Production Org –
CASR Pt21 J/G
CASR Part 119
CASA - Civil Aviation Safety Authority Issues an Air Operator’s Certificate (AOC)
145 AMO (Organic/
Contractor)*
* 145 AMO Can exist within the Air Operator
or as an external contractor
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DASR Background
Military Air Operator
MTC Holder
Quality &
Safety
CAMO
Operations
Accountable Manager (FEG CDR)
MDOA (Contractor)
145 AMO (Contractor)
145 AMO
MDOA Defence
DASR – Defence Aviation Safety Authority
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• Defence Aviation Safety Framework is setup through Joint Directive
24/2016
• DASR replaces the old MILAVREG/OAREG/TAREG
• Defence Aviation Safety Regulations are based on European Military
Airworthiness Requirements for Initial and Continuing Airworthiness
content
• Better practice regulations are hazard and outcome based & defensible
• Command must ensure that hazards / risks are reduced So Far As
Reasonably Practical (SFARP)
• Defence Aviation Authority assures Defence Aviation Safety
• DASR comprises of a basic regulation and implementing regulations
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DASR Background – Summary
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Questions/Discussion?
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Break
DASR Background
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DASR 21 Practitioner Course
Introduction to DASR 21
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Introduction to DASR 21
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Scope of DASR 21
• DASR 21 – Certification of Military Aircraft and Related Products, Parts and Appliances, and Design and Production Organisations
– Certification vs qualification
– Relevant products, parts and appliances
– Relevant organisations
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Introduction to DASR 21
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Overview: DASR 21A Subparts
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http://www.defence.gov.au/DASP/DASR-Regulations/Default.asp
Introduction to DASR 21
A General Provisions J Military Design Organisation Approval
B Military Type-Certificates & Military
Restricted Type-Certificates K Parts & Appliances
C N/A L N/A
D Changes to Military Type-Certificates &
Military Restricted Type-Certificates M Repairs
E Military Supplemental Type-Certificates N N/A
F Production without Military Production
Organisation Approval O
Australian Military Technical Standard
Order Authorisations
G Military Production Organisation
Approval P Military Permit to Fly
H
Military Certificates of Airworthiness &
Military Restricted Certificates of
Airworthiness
Q Identification of Products, Parts &
Appliances
I Noise Certificates (to be added later if
required)
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Initial & Continued Airworthiness Instruments
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http://drnet/dasa/Pages/Instruments-Platforms.aspx
Introduction to DASR 21
• Certification instruments
Military Type Certificate
Military Supplemental Type Certificate
Design Change Approval
• Repair design approval instruments
Major Repair Design Approval
Minor Repair Design Approval
• Safe to fly instruments
Military Certificate of Airworthiness
Military Permit to Fly
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Declaration of safety
Holder obligations
(continued airworthiness)
Initial & Continued Airworthiness Instrument Process
42
Develop
Application requirements
DASA assurance
Approve / issue to a holder
Introduction to DASR 21
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Introduction to DASR 21
Develop
Declare
Assure
Hold
Approve / issue
Apply
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Type Design Data
21.A.31
1. Drawings and specifications
2. Materials and processes, methods of manufacture and assembly.
3. Approved airworthiness limitations of the Instructions for continuing airworthiness (ICA).
4. Any other data necessary.
Type Design
1 2
3 4
Introduction to DASR 21
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Design Change
What constitutes to a change to Type Design?
Not all engineering work is a change to type design:
1. Changes to maintenance intervals within the limits defined by the OEM
2. Threat and EW libraries
3. Aeronautical data (Nav data etc.)
4. Software not affecting airworthiness
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Introduction to DASR 21
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DASR 21 Practitioner Course
Subpart B
Military Type Certificates and Military Restricted Type
Certificates
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Subpart B MTC & MRTC
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Outline
– Military Type Certificate (MTC)
– Type Certification Basis (TCB)
– Certification Program
– Issue of MTCs & MRTCs
– Holder obligations
– ADF context
47
Subpart B MTC & MRTC
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Military Type Certificate
• Recognition that the Type Design of a product complies with the appropriate airworthiness standards (TCB)
• Can include equivalent level of safety findings
• No feature or characteristic that makes the product unsafe for its intended use
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Subpart B MTC & MRTC
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Type certification basis
21.A.17A
– Airworthiness codes specified by the Authority (AAP 7001.054)
– Special conditions prescribed by the Authority – Tailoring of the European Airworthiness Certification Criteria
(EMACC) for military specific applications
• Engage with the Authority (DAVCERT) to establish TCB
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Subpart B MTC & MRTC
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21.A.20 - Certification Program – Applicant proposes a TCB including a Means of Compliance (MoC)
– Accepted by the Authority
– Fulfils other planning requirements
• Mechanism by which the Authority agrees to the certification basis (including special conditions) for the aircraft, and that the means of compliance are appropriate
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Subpart B MTC & MRTC
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In Groups describe the CPP for the design of an aircraft to fulfil a transport and Air-to-Air refuelling role
• Key contents
• Where does this document fit in the scheme of the overall project? Timing/importance?
• Where does this document fit in the organisation?
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Exercise
Subpart B MTC & MRTC
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Subpart B MTC & MRTC – Certification Program
• CP is the overarching planning document which communicates across the organisation and to the authority; – How compliance will be
shown – Against What
Airworthiness Code – When it will be
demonstrated, and – by Whom
Covered by CP
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21.A.20 – Compliance with the TCB • The applicant (Design Organisation) is the one
responsible for demonstrating compliance with the TCB
• The applicant must provide to the authority the data supporting the showings of compliance
• The applicant must also declare that compliance (or equivalent safety) has been shown
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Subpart B MTC & MRTC
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• Issue of a Military Type Certificate
• DASA must be satisfied that:
– The evidence presented shows compliance with the TCB
– An organisation has been identified to fulfil the MTC holder continued airworthiness obligations (21.A.44)
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Subpart B MTC & MRTC
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• Restricted Type Certificates (MRTCs) only apply to aircraft (as opposed to other products)
• Are issued when:
– Elements of certification outstanding
– Restrictions to operation of a/c to ensure safety
– Airworthiness Issue papers (AwIP) raised
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Subpart B MTC & MRTC
Restricted Type Certificates (MRTCs)
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Military Type Certificate Holder
• Single accountability for continued airworthiness of the product
• Obligations are at DASR 21.A.44
• AC 006/2017 MTC Holder Arrangements
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Subpart B MTC & MRTC
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MTC Holder – Obligations (1/2)
• Collect, investigate and analyse 21.A.3A(a)
– failures, malfunctions and defects
• Report any occurrence has / may result in 21.A.3A(b)
– an unsafe condition
• Report the results of any investigations 21.A.3A(c)
• Submit relevant data 21.A.3B(c)
– support an Airworthiness Directive
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Subpart B MTC & MRTC
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MTC Holder – Obligations (2/2) • Coordinate production and design organisations 21.A.4
– support continued Airworthiness
• Continue to demonstrate capability 21.A.14
• Record keeping 21.A.55
• Manuals 21.A.57
• Instructions for continuing airworthiness 21.A.61
• Specify product, part and appliance marking Subpart Q
• Aircraft Structural and Propulsion System Integrity assessments
– Periodic, unless specified by the NMAA 21.A.44(c)
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Subpart B MTC & MRTC
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MTC Holder –ADF context
59
Subpart B MTC & MRTC
• DASA issues MTCs for ADF aircraft type
• MTC holder: Australian government organisation – Manages and oversees holder obligations
– CASG
• Holder obligations AMC 21.A.44 – Detailed in Type Continued Airworthiness Exposition (TCAE)
– Holder may outsource holder obligations 21.A.2
• AC 006/2017 - MTC Holder Arrangements
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DASR 21 Practitioner Course
Subparts D and E
Changes to Military Type Certificates and Military
Supplemental Type Certificates
Subpart D & E – changes to MTC & MSTC
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Changes to Type Certificates
• Subpart D – Changes to MTCs and MRTCs
• Subpart E – Military Supplemental Type-Certificates (MSTCs)
• Subpart M – Repairs
• All reliant on the applicant
• All subject to Design Organisation’s Design Assurance System
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Subpart D & E – changes to MTC & MSTC
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21.A.91 – Classification of changes • Changes in type design are classified as minor or major.
– A ‘minor change’ is one that has no appreciable effect on the mass, balance, structural strength, reliability, operational characteristics, or other characteristics affecting the airworthiness of the product
• MDOA holders may be privileged to classify designs as minor or major
• When in doubt – consult with the authority for classification
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Subpart D – changes to MTC
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– Appendix A to GM 21.A.91 - Examples of Major Changes per
discipline
• Structural changes especially those impacting static strength or fatigue
• Cabin safety inc egress and crashworthiness
• Performance and handling inc flight envelope changes
• Catastrophic/hazardous Consequence software changes
• Most changes to engines and propellers
• Changes to rotor/drive systems on helicopters and systems that might
induce a hazardous/catastrophic failure consequence (lubrication and
cooling systems)
• New operational capabilities
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Subpart D – changes to MTC
Examples:
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Changes to Type Design
• Only the MTC Holder can apply for an approval of a major change to the type design
• Any organisation may apply for a minor change to type design
• Under DASR:
• Only the MTCH will be issued with a major change approval
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Subpart D – changes to MTC
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Subpart D – changes to MTC
• 21.A.95 – Minor Changes • Minor changes in a type design shall be classified and
approved either: – By the Authority; or – By an appropriately approved design organisation under a
procedure agreed with the Authority.
• 21.A.97 – Major Changes – Approved by DASA
– DASA will have direct involvement in the approval process – Applicant signs declaration of compliance – Applicant still liable for the design – Holder responsible for continued airworthiness
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• 21.A.101 - Designation of applicable Airworthiness codes (Changed Product Rule): – Comply with the current Airworthiness code; – Comply with an earlier amendment of the airworthiness
code applicable to the change (must be at least as recent as the code in effect when the aircraft was type certified); or
– Where the authority deems the airworthiness codes in effect are not sufficient they may specify special conditions
• Guidance material is very extensive
66
Subpart D – changes to MTC
UNCLASSIFIED
UNCLASSIFIED
• A Military Supplemental Type-Certificate (MSTC) certifies the approval of a major change to Type Design
• Under TAREGs, issuance of a MSTC went through the full AwB process including SR
• With the change to DASRs, DASA will issue MSTCs
67
Subpart E – MSTC
UNCLASSIFIED
UNCLASSIFIED
21.A.117 – Changes to MSTCs
• Minor changes as per any other minor change
• Major changes
– Either new and separate MSTC, or
– Up-issue of the original MSTC
• Ostensibly this is the same treatment as for changes to a MTC
68
Subpart E – MSTC
UNCLASSIFIED
UNCLASSIFIED
Changes to Type Certificates
B AMTC
D Changes to AMTC
E STCs
• Airworthiness Codes • Certification
Program Plan • Investigations • Flight Test • Declaration
• Application • Classification of
Design • Certification Basis
for changed design • Minor Design
Changes process • Minor design holder
obligations
• Demonstration of Capability
69
Subpart E – MSTC
UNCLASSIFIED
UNCLASSIFIED
Major Change - Scenarios
70
Subpart D & E – changes to MTC & MSTC
• Scenario 1: A user organisation seeking development of a MSTC or major
change by a DASR design organisation.
• Scenario 2: A user organisation seeking the development of a MSTC or
major change by a DASR approved design organisation with design
development supported by an existing design certified by another National or
Military Airworthiness Authority whose certification is recognised by
DASA.
UNCLASSIFIED
UNCLASSIFIED
Scenarios 1 – DASR MDOA
71
Subpart D & E – changes to MTC & MSTC
Holder Organisation
Design Organisation*
CAMO / Project Office / TLS
Organisation
Authority
NEED FOR PRODUCT
Contract for
product
Consume Product
DEVELOP DESIGN
CPP
DELIVER DESIGN
PERFORM HOLDER
OBLIGATION
Contract for Holder obligations
Approve Design
Issue TC
CPP Approval
TCB Approval
Means of Compliance Approval
1
4
5
Declaration of Compliance
Manage holder obligations
* The design organisation must be compliant with DASR 21.A.14.(a) or (b)
APPLY FOR APPROVAL Establish Contract
Countersign application
2 3
UNCLASSIFIED
UNCLASSIFIED
Scenarios 2 – DASR MDOA and foreign design
72
Subpart D & E – changes to MTC & MSTC
Holder Organisation
Design Organisation*
CAMO / Project Office /
TLS Organisation
Authority
NEED FOR PRODUCT Contract for
product
Consume Product
DEVELOP DESIGN
CPP
DELIVER DESIGN
PERFORM HOLDER
OBLIGATION
Contract for Holder
obligations
Approve Design
Amend / Issue TC
CPP Approval
TCB Approval
Means of Compliance Approval
4
5
Declaration of Compliance
Manage holder obligations
* The design organisation must be compliant with DASR 21.A.14.(a) or (b) (i.e hold a Military/Alternate Design Organisation Approval)
APPLY FOR APPROVAL Countersign Application
Establish Holder Contract
3
N/MAA
Certified Design
Design Organisation
Declaration of Compliance
1
21.A.239.(c)
Non-Certified Design
Design Organisation
Non-Certified Design
2
UNCLASSIFIED
UNCLASSIFIED
Subpart M
Repairs
73
DASR 21 Practitioner Course
Subpart M Repairs
UNCLASSIFIED
UNCLASSIFIED
Subpart M - Repairs
• Repairs (i.e. those not already approved in a SRM) are similar to design changes
– Return aircraft to an airworthy state
– Must comply with applicable airworthiness codes in the certification basis
• Repair designs are classified according to the same criteria as designs changes
• Repair design approval:
– Repair designs may be approved by a privileged MDOA Holder or DASA
74
Subpart M Repairs
UNCLASSIFIED
UNCLASSIFIED
Subpart M - Repairs
• Applicant for repair design approval must show compliance with the TCB
• Applicant must declare compliance
• Repairs are approved by either DASA or an organisation with MDOA
• Holder of a repair design approval to carry out continued airworthiness obligations (21.A.451)
75
Subpart M Repairs
UNCLASSIFIED
UNCLASSIFIED
Subpart M - Repairs
• Repair parts can be manufactured:
– Under Subpart F (production without MPOA)
– By an organisation approved under Subpart G
– By an appropriately approved maintenance organisation
• Embodiment can only be carried out by:
– An approved maintenance organisation
– An approved production organisation (MPOA) under privilege
76
Subpart M Repairs
UNCLASSIFIED
UNCLASSIFIED
Subpart M - Repairs
21.A.445 Unrepaired damage
• Assessment of damage for airworthiness consequences
• Is made by appropriate MDOA or Authority
– Usually the TC or STC Holder (If not, justification on basis of information is required)
• Necessary limitations transmitted to operator in accordance with approved repair procedures
77
Subpart M Repairs
UNCLASSIFIED
UNCLASSIFIED
Subpart H
Military Certificates of Airworthiness and Military Restricted Certificates
of Airworthiness
78
DASR 21 Practitioner Course
Subpart H MCoA & MRCoA
UNCLASSIFIED
UNCLASSIFIED
• A MCoA/MRCoA is a document certifying that a particular aircraft (tail no.) conforms to its type design at the date of issue
79
Subpart H MCoA & MRCoA
UNCLASSIFIED
UNCLASSIFIED
• Any organisation (operator) is eligible to apply
• Application must include data that substantiates conformance with the Type Design
• Issued by DASA
80
Subpart H MCoA & MRCoA
UNCLASSIFIED
UNCLASSIFIED
– MCoA/MRCoA remain valid as long as the aircraft
• complies with its type design, applicable ADs and ICA
• complies with applicable modifications and repairs
• MTC remains valid and aircraft remains on the Defence register
81
Subpart H MCoA & MRCoA
MCoA validity
UNCLASSIFIED
UNCLASSIFIED
Subpart P
Military Permits to Fly
82
DASR 21 Practitioner Course
Subpart P – MPTF
UNCLASSIFIED
UNCLASSIFIED
Subpart P – Military Permits to Fly
• Required when the MCoA is invalid
• Aircraft is still capable of safe flight under prescribed conditions
• Applicant must declare that aircraft is safe to fly under prescribed conditions
• Flight conditions approved by either:
– DASA, or
– MDOA holder under privilege
83
Subpart P – MPTF
UNCLASSIFIED
UNCLASSIFIED
• Following approval of flight conditions, MPTF issued by:
– DASA
– MDOA Holder under privilege
– MPOA Holder under privilege
• Holder of MPTF to fulfil obligations of the holder (21.A.727)
84
Subpart P – MPTF
UNCLASSIFIED
UNCLASSIFIED 85
Aut
hori
tyM
ilita
ry A
ir O
pera
tor
(MA
O /
CA
MO
)D
esig
n O
rgan
isat
ion
Seek Technical Input
Need Identified?
Technical Substantiation
Operational Substantiation
and Endorsement
Raise Form 18a Sign Declaration
of Safety
CO A
RD
UO
IC A
MA
FTU
SO
1 A
AT&
E
Flight Test related
Operational Substantiation
and Endorsement
Approve Flight Conditions
DoS
A/A
uth
Raise Form 21 (MPTF)
Raise Form 21 (MPTF)
Issue MPTF
DoS
A-F
T
Hold MPTFRaise Form 18a Sign Declaration
of Safety
Approve Flight Conditions
Issue MPTF
N
Y
CAT 1 &
2
CAT 3 &
4
Subpart P – MPTF
UNCLASSIFIED
UNCLASSIFIED 86
Aut
hori
tyM
ilita
ry A
ir O
pera
tor
(MA
O /
CA
MO
)D
esig
n O
rgan
isat
ion
Seek Technical Input
Need Identified?
Technical Substantiation
Operational Substantiation
and Endorsement
Raise Form 18a Sign Declaration
of Safety
CO A
RD
UO
IC A
MA
FTU
SO
1 A
AT&
E
Flight Test related
Operational Substantiation
and Endorsement
Approve Flight Conditions
DoS
A/A
uth
Raise Form 21 (MPTF)
Raise Form 21 (MPTF)
Issue MPTF
DoS
A-F
T
Hold MPTFRaise Form 18a Sign Declaration
of Safety
Approve Flight Conditions
Issue MPTF
N
Y
CAT 1 &
2
CAT 3 &
4
Subpart P – MPTF
UNCLASSIFIED
UNCLASSIFIED 87
Aut
hori
tyM
ilita
ry A
ir O
pera
tor
(MA
O /
CA
MO
)D
esig
n O
rgan
isat
ion
Seek Technical Input
Need Identified?
Technical Substantiation
Operational Substantiation
and Endorsement
Raise Form 18a Sign Declaration
of Safety
CO A
RD
UO
IC A
MA
FTU
SO
1 A
AT&
E
Flight Test related
Operational Substantiation
and Endorsement
Approve Flight Conditions
DoS
A/A
uth
Raise Form 21 (MPTF)
Raise Form 21 (MPTF)
Issue MPTF
DoS
A-F
T
Hold MPTFRaise Form 18a Sign Declaration
of Safety
Approve Flight Conditions
Issue MPTF
N
Y
CAT 1 &
2
CAT 3 &
4
Subpart P – MPTF
UNCLASSIFIED
UNCLASSIFIED
Subpart K
Parts and Appliances
88
DASR 21 Practitioner Course
Subpart K – Parts & Appliances
UNCLASSIFIED
UNCLASSIFIED
• Establishes the means for approval of parts and appliances
• What is a Part or Appliance?
– Lower level component fitted to a product
• What is the difference between Part & Appliance?
– An appliance is a part that requires power
89
Subpart K – Parts & Appliances
UNCLASSIFIED
UNCLASSIFIED
• Four means to have any given part or appliance be included in approved design data:
– In conjunction with the certification process under Subparts B, D or E
– Under the AUSMTSO Authorisation process in Subpart O
– Use of standard parts
– For equipment not subject to airworthiness standards, by demonstration that integration does not adversely affect airworthiness
90
Subpart K – Parts & Appliances
UNCLASSIFIED
UNCLASSIFIED
• Installation
– No part or appliance may be installed on a product unless accompanied by a Form 1, except:
• Standard parts, or • equipment not subject to airworthiness standards, but
demonstrated that the integration does not adversely affect airworthiness
• Approval of Parts/Appliances is not explicit under Subpart
K, but rather inherent in the activities conducted under Subparts B, D, E & O.
91
Subpart K – Parts & Appliances
UNCLASSIFIED
UNCLASSIFIED
Subpart O
Australian Military
Technical Standard Order Authorisations
DASR 21 Practitioner Course
Subpart O – AUSMTSO
92
UNCLASSIFIED
UNCLASSIFIED
AUSMTSO Authorisations
• Establishes the procedure relating to the issue of Australian Military Technical Standard (AUSMTSO) Authorisation as well as the obligations and privileges of the holder. (21.A.601)
• What is a TSO? (AUSMTSO)
– Detailed airworthiness specification issued by a NAA/NMAA e.g. FAA, EASA
– Minimum performance standard for specified articles
93
Subpart O – AUSMTSO
UNCLASSIFIED
UNCLASSIFIED 94
Subpart O – AUSMTSO
• Full list of ETSOs available on EASA website (CS-ETSO) https://www.easa.europa.eu/system/files/dfu/CS-ETSO.pdf
• Similarly a full list of FAA - TSOs and CASA - ATSOs available on the FAA and CASA websites respectively. (Search for TSO and ATSO respectively)
- Requirements
- Applicable Appliance
ETSO No. -
UNCLASSIFIED
UNCLASSIFIED
• An AUSMTSO Authorisation recognises that: – The design of the article has been approved
– The holder of the authorisation is able to produce the article
• For the design of the article: – Applicant must show compliance with the TSO
– Applicant must declare compliance via the declaration of design and performance
– DASA will issue the AUSMTSO Authorisation
– Holder of the AUSMTSO Authorisation must carry out the continued airworthiness obligations (21.A.609)
• For production of the article: – Applicant must hold MPOA under Subpart G or a letter of
agreement under Subpart F
95
Subpart O – AUSMTSO
UNCLASSIFIED
UNCLASSIFIED
AUSMTSO Authorisations
96
Subpart O – AUSMTSO
UNCLASSIFIED
UNCLASSIFIED
AUSMTSO Authorisations
97
These aircraft lights meet TSO C96a
design specifications and EXCEED
the requirements of TSO C96a, SAE
AS 8037 and AS8017A, plus DO-160.
Subpart O – AUSMTSO
UNCLASSIFIED
UNCLASSIFIED
Requirements
– Data (21.A.605) submitted to the Authority
• Statement of Compliance to this subpart
• Expositions and/or manual of procedures
• Declaration of Design and Performance (DDP)
– DDP contains (21.A.608) – use DASR Form DDP
• Declaration by the holder that the article conforms to the AUSMTSO and its rated performance
• ‘Type design’ data (Drawings, Specifications, Test reports, ICA, etc)
98
Subpart O – AUSMTSO
UNCLASSIFIED
UNCLASSIFIED
Requirements (continued)
– Design Changes (21.A.611)
• Can only be performed by the AUSMTSO holder
• Minor changes without further authorisation allowed, but data to be forwarded to the Authority
• Major changes require a new AUSMTSO Authorisation
99
Subpart O – AUSMTSO
UNCLASSIFIED
UNCLASSIFIED
Obligations of the holder
– Comply with 21.A.3 (occurrence reporting), 21.A.3B (Airworthiness Directives) & 21.A.4 (Design / Production coordination)
– Ensure each article conforms to its design data and is safe for installation
– Prepare and maintain a current file of complete technical data and records
– Prepare, maintain, update and supply to The Authority and users all manuals incl. maintenance, overhaul & repair manuals
100
Subpart O – AUSMTSO
UNCLASSIFIED
UNCLASSIFIED
Subpart J
Military Design
Organisation Approval
(MDOA)
DASR 21 Practitioner Course
101
Subpart J MDOA
UNCLASSIFIED
UNCLASSIFIED
What is a design organisation?
• Consider
– Does your organisation design aeronautical products, parts and/or appliances?
– What are the current arrangement for design within your organisations?
102
Subpart J MDOA
UNCLASSIFIED
UNCLASSIFIED
Design organisation
• Design activities
– design, and design changes, of products, parts and appliances
• Australia and ADF context
– granted MDOA: SPOs (e.g. ATACSPO, SRSPO), AWC, DAVENG (SI & NDT), QinetiQ, Boeing Defence Australia, etc
103
Subpart J MDOA
UNCLASSIFIED
UNCLASSIFIED
Examples
104
Subpart J MDOA
Repair and modification design - QinetiQ Aircraft design - Boeing Defence Australia
Minor change design - ATACSPO Minor changes in support of flight test - AWC
UNCLASSIFIED
UNCLASSIFIED
Outline
• Eligibility
• Application
• Terms of approval
• Design Assurance System (DAS)
• Design Organisation Exposition (DOE)
• Issue of Military Design Organisation Approval (MDOA)
• Privileges
• Obligations
105
Subpart J MDOA
UNCLASSIFIED
UNCLASSIFIED
Eligibility
• To demonstrate capability to apply for and hold a
− Military Type Certificate (MTC)
− Military Supplemental Type Certificate (MSTC)
− Major Repair Design Approval
− AUSMTSO Authorisation for APUs
• Or to obtain privileges to approve
− Minor changes
− Minor repair designs
106
Subpart J MDOA
UNCLASSIFIED
UNCLASSIFIED
Application
• DASR Form 80 – MDOA application form
• Management staff: DASR Form 4 holder applications
• Design Organisation Exposition (DOE)
• Procedures / plans / instructions referenced in the DOE
• Proposed Terms of Approval
107
Subpart J MDOA
108
DASR Form 80
http://www.defence.gov.au/DASP/DASR-Regulations/DASR-Forms.asp
109
DASR Form 4
UNCLASSIFIED
UNCLASSIFIED
Terms of Approval
• Scope of approval
• Categories of products (platforms)
• List of products
• Privileges
• Limitations
The Terms of Approval are stated on the certificate issued by DASA.
110
Subpart J MDOA
UNCLASSIFIED
UNCLASSIFIED
Design Assurance System
111
Subpart J MDOA
• Basis of Military Design Organisation Approval (MDOA)
• Described in the Design Organisation Exposition (DOE)
• Provide planned and systematic actions to
– design products, or parts
– demonstrate and verify compliance
– declare compliance
• Defined in terms of
– Organisational structure, Responsibilities, Procedures and Resources
UNCLASSIFIED
UNCLASSIFIED
Design Assurance System (DAS) & Safety Management System (SMS)
• DAS minimum elements
– ensure the design of products, parts and appliances, design changes and repair designs comply with the applicable type-certification basis (TCB)
– independent checking of showings of compliance
– independent monitoring and improvement of the Design Assurance System
112
Subpart J MDOA
– account for design input provided by other organisations
– Safety Management System (SMS)
UNCLASSIFIED
UNCLASSIFIED
Organisational structure and Responsibilities
• Chief Executive
• DASR Form 4 holders
– Head of Design Organisation
– Chief of the Office of Airworthiness
– Chief of Independent System Monitoring
• Authorised signatories
– Compliance Verification Engineers (CVEs)
– Other authorised signatories
113
Subpart J MDOA
UNCLASSIFIED
UNCLASSIFIED
Management staff: Head of Design Organisation
114
Subpart J MDOA
• Responsibilities
– responsible for Design Organisation output
– signs the declaration of compliance (or authorised representative)
– can be the same person as the Chief Executive
• QTE requirements
– tertiary qualified Bachelor of Engineering
– Chartered Professional Engineer (CPEng)
– ten years aviation experience
– two of ten years at DGTA-ADF/DASA or an organisation holding a Design Organisation Approval under DASRs, CASA, EASA or EMARs
UNCLASSIFIED
UNCLASSIFIED
Management staff: Chief of Office of Airworthiness (1/2)
115
Subpart J MDOA
• Responsibilities
– liaison with Authority during Type Investigation
– prepare and update DOE
– interpretation of airworthiness requirements
– classification of design changes and repair designs
– independent checking of showings of compliance
– collection of design failure and defect information
– assisting in preparation of Airworthiness Directives
– approval of minor changes and repair designs
UNCLASSIFIED
UNCLASSIFIED 116
Subpart J MDOA
• QTE requirements
– tertiary qualified Bachelor of Engineering
– Chartered Professional Engineer (CPEng)
– ten years aviation experience
– two of ten years at DGTA-ADF/DASA or an organisation holding a Design Organisation Approval under DASRs, CASA, EASA or EMARs
Management staff: Chief of Office of Airworthiness (2/2)
UNCLASSIFIED
UNCLASSIFIED
Management staff: Chief of Independent System Monitoring
117
Subpart J MDOA
• Responsibilities
– continual evaluation of the Design Assurance System to
ensure it remains effective
– function can be achieved through corporate quality assurance system
– must cover design suppliers
• QTE requirements
– lead Auditor course
– eight years aviation experience
– two of eight years at DGTA-ADF or an organisation holding a Design Organisation Approval under DASRs, CASA, EASA or EMARs
– three years experience in aviation quality management
UNCLASSIFIED
UNCLASSIFIED
Authorised Signatories: Compliance Verification Engineers
118
Subpart J MDOA
• Conduct the independent checking function of all compliance data
• Approve the technical content of:
– Flight Manual
– Airworthiness limitations section of ICA
– Certification Maintenance Requirements (CMR)
• Must be independent to those compiling the compliance data
• CVE function can be outsourced
UNCLASSIFIED
UNCLASSIFIED
Other Authorised Signatories
– Declaration of compliance
– Change classification
– Release of documents (implementing instructions etc.)
– Design change approval / repair design approval
– Changes to Flight Manual or ICA
– Approval of flight conditions
– Issue Military Permit to Fly (if applicable)
119
Subpart J MDOA
UNCLASSIFIED
UNCLASSIFIED
Procedures
– Design procedures
– Independent checking procedures (CVE function)
– Independent monitoring procedures
– Selection, training, ongoing competence and identification of authorised signatories (includes CVEs)
120
Subpart J MDOA
UNCLASSIFIED
UNCLASSIFIED
• Satisfy certificate or other design/repair approval, i.e. DASA instrument holder obligations
– Military Type Certificate (MTC) (21.A.44)
– Military Supplemental Type Certificate (MSTC) (21.A.118A)
– Minor change approval (21.A.109)
– Major/minor repair design approval (21.A.451)
– Australian Military Technical Standard Order (AUSMTSO) Authorisation (21.A.609)
121
Subpart J – MDOA
Procedures
UNCLASSIFIED
UNCLASSIFIED
• Required for exercising MDOA privileges
– Change classification
– Approval of minor design changes or minor repair designs
– Issue of information or instructions
– Approval of documentary changes to flight manual or ICA
– Approval of major repairs designs to products for which it holds the MTC or MSTC
– Approval of flight conditions for a Military Permit to Fly
– Issue Military Permit to Fly (if applicable)
122
Subpart J – MDOA
Procedures
UNCLASSIFIED
UNCLASSIFIED
Resources
– Human resources
– Equipment
– Tools
– Facilities
– Design data etc.
123
Subpart J MDOA
UNCLASSIFIED
UNCLASSIFIED
Subpart J - Organisational Approval Design Assurance System Elements
124
Organisation
– Design organisation
– Independent system monitoring
– Office of airworthiness
Procedures
– Design procedures
– Independent checking procedures
– Authorised signatory (including CVE) selection
– Independent system monitoring
– Change classification procedure
– Design Approval procedure
– Control of subcontractor product
Resources
– Design Engineers
– Design tools and data
– Compliance Verification Engineers
– Independent system monitoring personnel
Responsibilities
– Head of Design Organisation
– Chief of Independent System Monitoring
– Chief of Office of Airworthiness
– Compliance Verification Engineers
– Authorised signatories
Subpart J MDOA
Design Assurance System elements
125
- Design of PPA
- Design Changes
- Repair Designs
Show compliance
with Certification
Basis
Independent
check of all
compliance
data
Independently
monitor and
improve
system
Classification
Privileges
CISM COAw
CHANGE
CLASSIFICATION
PROCEDURE
ISM
PROCEDURES
DESIGN
PROCs
IC PROCs ISM
PPL
ENGRs
DESIGN
TOOLS / DATA
SELECTION
PROCEDURE
CONTROL SUB-
CONTRACTORS
PROCEDURE
Approval by
Authority
HDO
DESIGN
APPROVAL
PROCEDURE
Auth
Sign.
CVE Declaration of
compliance
major
Approval by
MDOA holder
minor
UNCLASSIFIED
UNCLASSIFIED
Example Organisational Structure 1
126
HDO
Design Office
of Aw
ISM
Subpart J – MDOA
UNCLASSIFIED
UNCLASSIFIED
Example Organisational Structure 2
127
HDO
Design Quality
Office
of Aw
ISM
Subpart J – MDOA
UNCLASSIFIED
UNCLASSIFIED
Example Organisational Structure 3
128
Technical
Management
Quality
Management
HDO
Office of Aw
Testing Design Other
ISM
Subpart J – MDOA
UNCLASSIFIED
UNCLASSIFIED
Example Organisational Structure 4
129
CEO
Dir. of Eng Dir. of Maint Dir. of Prod
Design Testing Cert Mgr
Quality
ISM
Subpart J – MDOA
UNCLASSIFIED
UNCLASSIFIED
Design Organisation Exposition (DOE) • Describes the organisation, the relevant procedures and the
products, or changes to products to be designed
• Describes the Design Assurance System (DAS)
• May be completely or partially integrated into the company organisation manual
130
Subpart J MDOA
DAS elements Examples
Organisation Scope of work, DO / PO coordination
Responsibilities Organisation chart, management staff
Procedures Design, independent checking, design approval
Resources Facilities, equipment, human resources
UNCLASSIFIED
UNCLASSIFIED 131
DASA MDOE example: AWC MDOE
Organisation
Procedures
Resources
Responsibilities
UNCLASSIFIED
UNCLASSIFIED
• Design Organisation Exposition exercise
• DOE for MDOA holder with:
– scope for major and minor design changes and the design of major and minor repairs
– all privileges except those relating to the issue of major repairs and MPTFs
132
Subpart J MDOA
Design Organisation Exposition
133
Design Organisation Approval
134
135
Military Design Organisation Approval
136
Military Design Organisation Approval
UNCLASSIFIED
UNCLASSIFIED
Privileges
• Design activities
• Change classification
• Approval of minor design changes or minor repair designs
• Issue of information or instructions
• Approval of minor documentary changes to flight manual or ICA
• Approval of major repairs designs to products / APU
– holds the MTC or MSTC or AUSMTSO authorisation
• Approval of flight conditions for a Military Permit to Fly
• Issue of a Military Permit to Fly
137
Subpart J MDOA
UNCLASSIFIED
UNCLASSIFIED
Obligations
138
Subpart J MDOA
• Maintain DOE in conformity with the design assurance system
• Ensure the DOE is the basic working document
• Determine the design comply with applicable airworthiness requirements
• Provide compliance statements and documentation to the Authority
• Provide information related to Airworthiness Directives to the Authority
• Determine flight conditions for a Military Permit to Fly (if applicable)
• Issue of a Military Permit to Fly (if applicable)
UNCLASSIFIED
UNCLASSIFIED
Safety Management System (SMS)
DASR 21 Practitioner Course
139
SMS
UNCLASSIFIED
UNCLASSIFIED
MPOA Process
140
21.A.231 Scope
21.A.233 Eligibility
21.A.234 Application
21.A.235 Issue of Military design organisation approval
21.A.239 Design assurance system and Safety Management System
21.A.243 Design Organisation Exposition
21.A.245 Approval requirements
21.A.247 Changes in design assurance system
21.A.249 Transferability
21.A.251 Terms of approval
21.A.253 Changes to the terms of approval
21.A.257 Investigations
21.A.258 Findings
21.A.259 Duration and continued validity
21.A.263 Privileges
21.A.263 Obligations of the holder
Subpart J MDOA
UNCLASSIFIED
UNCLASSIFIED
Safety Management System
141
SMS
UNCLASSIFIED
UNCLASSIFIED
The All-Seeing Regulator?
142
SMS
‘Regulators cannot foresee all the
possible scenarios of failure in
complex, tightly-coupled and
highly interactive systems, and so
cannot universally proscribe
particular types of human
response.’
- James Reason
SMS aims to address this shortfall.
UNCLASSIFIED
UNCLASSIFIED
Process Regulations are only so effective…
143
SMS
ONLY COMMON HAZARDS ARE MITIGATED
70%
UNCLASSIFIED
UNCLASSIFIED 144
UNCLASSIFIED
UNCLASSIFIED
Safety Management System
145
SMS
• Process regulation provides a minimum level of protection against hazards that threaten safety, with overall effectiveness limited by technical, organisational, environmental and human factors
• A safety management system provides a higher level of safety by supporting and extending the protection afforded through process regulation alone.
UNCLASSIFIED
UNCLASSIFIED
A mature SMS will complement the regulatory controls…
146
SMS
Top Event
Hazard
Regulated
Control
Regulated
Control
Regulated
Control
SMS
Identified
Controls
Regulated
Control
SMS
Identified
Controls
Regulated
Control
SMS
Identified
Controls
SMS
Identified
Controls
Regulated
Control
Regulated
Control
SMS
Identified
Controls
TH
RE
AT
S C
ON
SE
QU
EN
CE
S
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What is ‘DASR SMS’?
Definition:
‘A systematic approach to managing aviation safety, including the necessary organisational structures, accountabilities, policies and procedures’.
ICAO Annex 19
147
SMS
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Based on the ICAO Framework
148
SMS
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Safety Policy & Objectives Summary
149
SMS
Management Commitment
Safety Accountabilities
Key Safety Personnel
MNGT of 3rd Party Relationships
Emergency Response Plans
Documentation
ERP ____ ____
SMM ____ ____
TRAINING RECORDS, HAZARD REGISTER, RISK REGISTER, PROMOTION MATERIAL, SURVEYS, AUDITS, SRC MEETING MINUTES, SAG MEETING MINUTES, CHANGEMENT MANAGEMENT FORM, HAZARD ID FORM…………
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Safety Risk Management Summary
150
SMS
Hazard Identification Assessment & Mitigation
&
APPROPRIATE AVIATION RM AT ALL LEVELS & RECORDED EVIDENCE OF IT
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Safety Assurance
151
SMS
Performance Monitoring & Measurement
Change Management
Continuous Improvement
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Safety Promotion
152
SMS
Training & Education Safety Communication
• Toolbox talks, • Safety Days, • Posters, • Magazines, • Group emails, • Bulletin boards, • Investigation summaries, • Handover/takeovers, • Safety interactions, • Newsletters, • Group discussions, • Management walk-arounds.
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Benefits of an SMS
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SMS
• CLARITY: Operations, maintenance
and design safety that can be explained to others and analysed – with evidence.
• CONTROL: Knowledge of key risks,
mitigations and their performance provides control over safety outcomes.
• DEFENSIBILITY: When things turn
to custard, management can demonstrate that risks were being managed within reasonable expectations.
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SMS Oversight Considerations
154
SMS
{
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Pt. 21J
(HOD)
SPO* CAMO
Functions
QMS & SMS
(QM) (SM)
CAMO (CAM-DLC)
Accountable Manager
(FEG CDR)
Part 145*
Contractor
Part 21*
Contractor
Contractor CAMO
Functions
Force Element Group
Military Air Operator
SMS Scope (Military)
SQN Operations
(XO) SQN 145
(RM)
= No SMS Required
= SMS Required
Same Colour = Same SMS
= 3rd Party Relationship (Only CAMO 3rd Parties Shown)
MEOMS
Fuel, Eq., Fire…
TRAMM-L
CSG
Pt. 21J
(HOD)
SPO* CAMO
Functions
QMS & SMS
(QM) (SM)
CAMO (CAM-DLC)
Accountable Manager
(FEG CDR)
Part 145*
Contractor
Part 21*
Contractor
Contractor CAMO
Functions
DEFENCE ORGANISATION
MTC/MSTC Holder
Force Element Group
Military Air Operator
SQN Operations
(XO) SQN 145
(RM)
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Many ways to meet the requirements…
156
SMS
• Although the AMC is based on the ICAO Framework, organisation’s SMSs do not have to contain the exact same structure…
• The DASM and other modified management systems (e.g. AS/NZS 4801 modified) can be used to meet the requirements of the DASR SMS.
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The PSOE Method
157
SMS
Present (10%)
Suitable (20%)
Operating (40%)
Effective (30%)
• PSOE (Present, Suitable, Operating & Effective) is a graduated approach to determining if policies, procedures and systems are actually effective.
• ‘Suitable’ and ‘Effective’ – SUBJECTIVE
– ENCOURAGES CRITICAL THINKING.
– PREVENTS ‘PAPER SAFETY’.
Plan
Execute Maturity score is the average across all PSOE AMC scores.
P – Present
S – Suitable
O – Operating
E – Effective
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Assessment Outputs
SMS
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Subparts F & G
Military Production
159
Subpart F & G – Production
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What is a production organisation?
• Consider
– Does your organisation produce physical aeronautical products, parts and/or appliances?
– What are the current arrangement for production within your organisations?
160
Subpart F & G – Production
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Production • Perform production activities: products, parts or appliances
– same item on a large (DASR 21 G) and smaller scale (DASR 21 F) – quality assurance system (DASR 21 G) – production inspection system (DASR 21 F)
• Australia and ADF context
– unlikely to be many production organisations
– example: RUAG
• Not production activity
– brackets, cable, etc, for maintenance activities
• considered production under maintenance
• does not require a production approval
• and demonstrate their conformance to the applicable design data.
161
Subpart F & G – Production
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Production organisations
Subpart G Subpart F
Scope
• Military production organisation approval (MPOA) for
production of products, parts and appliances
• Privileges and obligations
Production without MPOA
Eligibility Any organisations
See details in later slides
Application See details in later slides
Requirements More comprehensive production assurance system Less comprehensive production inspection system
Authority
issues MPOA certificate (Form 55) Letter of agreement (Form 65)
Output
• Issue Form 1 for products, parts and appliances
• Issue Form 52 for a complete aircraft
• Issue Form 53 for a produced aircraft completed
maintenance
• Must seek Authority validation of output
• Needs Authority approval for Form 1 and Form 52
release
Production
duration Ongoing production < 1 year
Subpart F & G – Production
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G
Examples
F or G?
163
G
G
G / F
Subpart F & G – Production
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Eligibility (1/2)
• Has requirement / need for production
• Ability to show conformity of products, parts and
appliances with the applicable design data 21.A.133(a)
• An organisation either,
– holds or has applied for approval of the design data
– has an appropriate arrangement with the holder
of the design data for the coordination between
production and design
164
Subpart G MPOA
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• DO transfers design data correctly and timely
• PO receives, manages and uses the design data
• PO develops manufacturing data when applicable
• PO assists DO with continuing airworthiness matters
• PO assists DO with compliance demonstration prior to TC
• Deals with production deviations and non-conforming parts
• Configuration control of manufactured parts
• Responsible person / offices
• Acknowledgement of design data provided by holder of the approved design
AMC1 to 21.A.133(b) & 21.A.133.(c)
Eligibility – DO / PO Arrangement (2/2)
Subpart G MPOA
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Application
• Use DASR Form 50
• Provide a Production Organisation Exposition (POE)
– signed by the accountable manager
– duties and responsibilities of the manager(s)
– ORPR elements of the Quality System (Production Assurance System)
– DO / PO arrangement
– flight Test (FT) operations manual, if FTs are to be conducted
• Propose Terms of approval
166
Subpart G MPOA
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Requirements
• Quality System 21.A.139
– ensure conformity of the product, part or appliance
• applicable design data
• in condition for safe operation
168
– procedures to control operation that may affect conformity
– independent quality assurance function
• monitor compliance with and adequacy of the system
– Safety Management System (SMS)
Subpart G MPOA
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Subpart G - Production
170
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MPOA Privileges
• Privileges 21.A.163
– perform production activities under DASR
– issue Form 1 (Authorised Release Certificates) for products, parts and appliances
– issue Form 52 (Aircraft Statement of Conformity) for a complete aircraft to obtain a CoA
– maintain a new aircraft that the organisation has produced and issue Form 53 (Certificate of Release to Service)
– issue a military permit to fly and approve associated flight conditions for an aircraft it has produced
171
Subpart G MPOA
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Subpart G - Production
172
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• Obligations 21.A.165
– ensure POE is used as basic working document
– maintain conformity with the data and procedures approved for MPOA
– determine conformity of the products, parts or appliances
– record work details
– establish and maintain an occurrence reporting system
173
MPOA Obligations (1/3)
Subpart G MPOA
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• Obligations 21.A.165
– report to the MTC / design approval holder to investigate deviation of produced products, parts or appliances
– report to the Authority when an unsafe condition identified due to deviation of released products, parts or appliances from the applicable design data
– report adverse findings on deviation to other interested parties
174
MPOA Obligations (2/3)
Subpart G MPOA
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• Obligations 21.A.165
– assist MTC / design approval holder for continuing airworthiness matters
– establish a recording and archiving system
– for a complete aircraft, determine the conditions / suitability for the issuing of a certificate of release to service
– when applicable, determine the conditions for a MPTF
– when applicable, establish compliance before issuing a MPTF
175
MPOA Obligations (3/3)
Subpart G MPOA
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MPOA Process
176
21.A.131 Scope
21.A.133 Eligibility
21.A.134 Application
21.A.135 Issue of Production Organisation Approval
21.A.139 Quality System
21.A.143 Production Organisation Exposition
21.A.145 Approval requirements
21.A.147 Changes to the approved production organisation
21.A.148 Changes of location
21.A.149 Transferability
21.A.151 Terms of approval
21.A.153 Changes to the Terms of Approval
21.A.157 Investigations
21.A.158 Findings
21.A.159 Duration and continued validity
21.A.163 Privileges
21.A.165 Obligations of the holder
Subpart G MPOA
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Subpart F
Production without
Military Production
Organisation Approval
Subpart F Production without MPOA
177
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Eligibility & Application
178
• Any organisation can apply
• An organisation either,
– holds or has applied for approval of the design data
– has an appropriate arrangement with the holder
of the design data for the coordination between
production and design
• Use DASR Form 60
Subpart F Production without MPOA
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Assurance & Approve
• Once approved, the Authority issues a Letter of Agreement (LoA) Form 65
• A LoA formalises the arrangement between the Authority and the manufacturer 21.A.125A
− the Authority agrees to the showing of conformity of individual products, parts and appliances
• A LoA is valid for a maximum duration of 1 year
179
Subpart F Production without MPOA
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Requirements (1/2)
180
• A production inspection system has been
established
• A documented manual contains
– production inspection system
– means for making determinations within inspection system
– a description of tests for aircraft, engines & propeller
– names of authorised persons for Statement of Conformity
• A system to provide assistance to relevant DO related to an occurrence or continuing airworthiness issues
Subpart F Production without MPOA
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Requirements (2/2)
• Production Inspection System 21.A.126
– control incoming material / parts
– ensure processes / manufacturing techniques in accordance with specifications
– design changes approved
– parts in process inspection
– materials storage and protection
– design drawings readily available
– system of identifying and quarantining non-conforming items
• rejected / withheld materials and parts
– recording and archiving
181
Subpart F Production without MPOA
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Manufacturer Obligations
• Obligations 21.A.129
− each manufactured item available for inspection by the
Authority
182
− maintain all relevant design data at the place of manufacture
− maintain the production inspection system
− assist relevant parties on continuing airworthiness matters
− establish and maintain an occurrence reporting system
− report adverse findings to all interested parties (Authority, MTC holders, MPOA Holders etc)
Subpart F Production without MPOA
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Entitlement
• Manufacturer shall raise a Statement of Conformity
– Form 52 (Aircraft Statement of Conformity) for a
complete aircraft
– Form 1 (Authorised Release Certificates) for products, parts and appliances
• Statement of Conformity shall be
– issued for all items the organisation manufactures
– signed by an authorised person
– presented to the authority for validation
– counter-signed by the authority after inspection to validate conformity
183
Subpart F Production without MPOA
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MPOA Process
184
21.A.121 Scope
21.A.122 Eligibility
21.A.124 Application
21.A.125A Issue of a letter of agreement
21.A.125B Findings
21.A.125C Duration and continued validity
21.A.126 Production inspection system
21.A.127 Tests: Aircraft
21.A.128 Tests: Engines and propellers
21.A.129 Obligations of the manufacturer
21.A.130 Statement of Conformity
Subpart F Production without MPOA
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Subparts F and G - Production
185
Subpart F & G – Production
Subpart G Subpart F
Scope
• Military production organisation approval (MPOA) for
production of products, parts and appliances
• Privileges and obligations
Production without MPOA
Requirements More comprehensive production assurance system Less comprehensive production inspection system
Authority
issues MPOA certificate (Form 55) Letter of Agreement (Form 65)
Output
• Issue Form 1 for products, parts and appliances
• Issue Form 52 for a complete aircraft
• Issue Form 53 for a produced aircraft completed
maintenance
• Needs Authority approval for Form 1 and Form 52
release
• Must seek Authority validation of output
Production
duration Ongoing (> 1 year) < 1 year
Note:
• An organisation applying for Subpart F should demonstrate to the Authority why MPOA under Subpart G is not appropriate
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Subpart F & G - Production
• Discussions
– Revisit your previous activity on production
– Discuss the expected type of approval required under DASR to encompass the type of production currently undertaken
186
Subpart F & G – Production
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Regulation Interrelationship
187
Design Organisations Production Organisations
MPOA
Subpart G
Non-MPOA
Subpart F
MDOA
Subpart J
MTC
Holder
Subparts
B & D
MSTC
Holder
Subpart E
AUSMTSO
Holder
(APUs)
Subpart O
Minor
Changes
Subpart D
Military
CoA
Subpart H
General Provisions Subpart A
Parts and Appliances Subpart K
Repairs Subpart M
Military Permit to Fly Subpart P
Identification of Products, Parts and Appliances Subpart Q
AUSMTSO Holder
Subpart O
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Discussion: ACs / TAACs
03/2016 – Design Acceptance in DASRs
01/2017 – Transition Arrangements
03/2017 – Military Permits to Fly
06/2017 – Military Type Certificate Holder Arrangements
188
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Carpark Resolution
189