dsaÉ (fr maa) considerations for the approval of ... · the type certificate holder (tch) is eg.:...

DSAÉ (FR MAA) considerations

for the approval of industrial

Maintenance Organisations

MAWA Conference

2015

EINDHOVEN

Brigadier General Guy-Daniel MARY French Airworthiness Directorate

ICETA (Lt-Col) Richard DURIEZ Initial Airworthiness Adviser to the Directorate

Oct 2015 FR DSAÉ considerations for the

approval of industrial MOs 2

Overview

1. STRATEGIC APPROACH

• Reminder about DSAÉ presentations during previous MAWA Forum : • Sep 2011 _ EMARs and the A400M

• Sep 2012 _ DSAÉ strategic vision on EMARs implementation for E.U products

• Sep 2013 _ Preserving our capacity to operate defence RPAS MALE / HALE

• Sep 2014 _ The need to achieve effective military airworthiness

• LINK between these previous presentations and the current subject : • Military harmonized Regulation as a necessity in the context of SES

• Airworthiness = cornerstone of an European military regulation harmonization

• EMARs as standards for airworthiness

• Example of A400M Industrial in service support

How to maintain a reliable controlled airworthiness environment ?

2. PRAGMATIC CONSIDERATIONS

• Reminder about FR airworthiness regulation

• Regulation applicable to Maintenance Organisations

• Approval of industrial Maintenance Organisations • Contractual structure

• Types of approvals

3. Conclusion



Overview
















3. Conclusion

French DSAÉ presentation to the MAWA Executive Level Forum September 21st, 2011

ITEMS • EMARs and the A400M

• Prioritise EMAR 145 implementation

• Mutual challenges for industry and pMS

CONCLUSION

• Successful implementation of EMAR 145 is paramount for the A400M in service support

• EDA / MAWA Forum credibility is at stake

• Industry is clearly willing to adopt an internationally recognised standard

• Let the A400M programme be the pathfinder for the continuing airworthiness of all current and future cooperation programmes

Oct 2015 FR DSAÉ considerations for the approval of industrial MOs 4

SUBJECT French DSAÉ strategic vision on EMARs implementation

for European programmes

CONCLUSION


French DSAÉ presentation to the MAWA Executive Level Forum September 21st, 2012

Defence Ministers' Political Declaration (EDA Document No. 2009/36) : political support for NMAAs to develop and implement the EMARs under the auspices of EDA MAWA Forum

Failure to implement EMAR 145 for the A400M would:

Be a failure for A400M pMS in achieving the Ministers’ objective

Result in economical losses (cost of the A400M’s support)

Result in reduced interoperability and thus decreased operational capabilities

Jeopardise EDA’s credibility and efforts to harmonise airworthiness standards

To perform the mission, we need to use the A400M programme as the pathfinder

of the implementation of EMARs, mainly EMAR 145 and associated AMC.

French DSAÉ presentation to the MAWA Executive Level Forum September 24th, 2013

SUBJECT

CONCLUSION

• In order to anticipate future operations, RPAS must be integrated into international exercises, using the European airspace.

• Airworthiness is not the only domain necessary for the RPAS insertion into the airspace, but is probably the main one.

• It is crucial for the European States to produce a common regulation, anticipating the implementation of the Single European Sky, and taking into account their own operational constraints but within entire secure conditions.


PRESERVING OUR CAPACITY TO OPERATE DEFENCE RPAS MALE / HALE

French DSAÉ presentation to the MAWA Conference September 23-24th, 2014

SUBJECT

CONCLUSION • AIRWORTHINESS is fully part of AVIATION SAFETY and Civil & Military AVIATION

SAFETY is more than ever a European point of interest with the Single European Sky Initiative.

• The implementation of European Military Airworthiness Requirements in national regulations will undoubtedly represents a success in the context of SES

BUT

• there is now a need, more than ever, to speed up the implementation of EMARs in each national regulation if we want to show to the EASA world that the European Military Airworthiness is effective, as one of the main pillars of a wider European Military Safety !!!


The need to achieve effective military airworthiness in the context of ensuring wider aviation safety



Overview






• LINK between these previous presentations and the current subject : • Military harmonized Regulations as a necessity in the context of SES

• Airworthiness = cornerstone of a European military regulation harmonization

• EMARs as standards for military airworthiness








3. Conclusion

SES Goal = Economic Competitiveness of EU ATM



2014

10

ATM/ASM

AIRPORTS

CNS

MISSIONS:

•REGULATION

•OVERSIGHT

AIRCREW

TRAINING

&

OPERATIONS

MISSIONS:

• REGULATION

WATCH &

HARMONIZATION

INITIAL

CERTIFICATION

CONTINUED

AIRWORTHINESS

CONTINUING

AIRWORTHINESS

MISSIONS:

•REGULATION

•OVERSIGHT


approval of industrial MOs

MAA pillars to ensure wider aviation safety

A military total aviation system approach like EASA

AIRWORTHINESS

AIR ACCIDENT

INVESTIGATION

MISSIONS:

•INVESTIGATION •RECOMMENDATIONS



The Type Certificate Holder (TCH) is eg.:

- FR : DO - DE : MoD BAAINBw - UK : MoD DE&S (TAA)

DESIGN

A Certificate of Airworthiness (CoA) and a Certificate of Registration (CoR) are issued for each

individual aircraft

AIRWORTHINESS MANAGEMENT

The military operator has a Continuing Airworthiness Management

Organisation (CAMO) holding a EMAR-M approval

MAINTENANCE

TRAINING

The aircraft is maintained in a EMAR-145 approved maintenance organisation (MO),

manned by technicians holding a EMAR-66 licence

(mandatory for certifying staff)

Technicians are trained in EMAR-147 approved Maintenance Training Organisation (MTO)

The Design Organisation (DO) has a EMAR-21 J approval

A Type Certificate (TC) is issued:

- Aircraft TC - Engine TC - Propeller TC - STC

PRODUCTION

The Production Organisation (PO) has a EMAR-21 G approval

11

The Airworthiness Controlled Environment in the EU military world



Overview
















3. Conclusion



A400M ISS mapping

13

2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

EMAR 145 EMAR M EMAR 66 EMAR 147 EMAR 21

EMAR(FR) 145

EMAR(FR) 147

EMAR(FR) M EMAR(FR) 66

A400M first deliveries :

ISS contracts : FRISS

TRISS

OCCAR long term objective (2020) : Global ISS contracts

EMAR approval by MAWA Forum

EMAR implementation in the FR regulation

Multinational ISS ?

Which nations ? When will they join ?

FR/UK SSE

DEISS

AMSL and EPI are not MOs

AD&S: PERAM 145 approval 10 Feb 2014 ITP: applying to Part 145 extension for TP400 Other MOs: pending AMSL declaration

Maintenance organisations:

AIA CF : EMAR(FR) 145 approval 11 Feb 2015 AIA BX : Part 145 approval Snecma: applying to Part 145 extension for TP400 Other MOs: pending AMSL declaration

MTU: applying to Part 145 extension for TP400 Other MOs: pending AMSL declaration

RR: applying to Part 145 extension for TP400 Other MOs: pending AMSL declaration

ITP: applying to Part 145 extension for TP400

other nations : ?

Other MOs: pending AMSL declaration



Overview
















3. Conclusion



French airworthiness regulation structure

Decree 2013-367 (superseding the decree 2006-1551)

Order

« Duties »

Order

« Conditions »

Order

« Registration »

Order

« Continuing airworthiness »

Order

« RPAS »

Interdepartmental level

Authorities level

Instruction

« Initial airworthiness »

Instruction

« Continuing airworthiness »

- Essential airworthiness requirements

- Regulations considered as acceptable

means of compliance

- FRA 21

- FRA Forms

- FRA M - EMAR(FR) M (provision)

- FRA 145 - EMAR(FR) 145

- FRA 147 - EMAR(FR) 147

- FRA 66 - EMAR(FR) 66 (provision)

- FRA Forms - EMAR Forms

AMC & GM for all FRA

Mementos and procedures

Internal documents

documents : - applicable to State organisations and personnel

- applicable to industry through contracts

DGA Technical Authority DSAÉ State Aviation Safety Authority

Instruction

« Report of

technical occurrences »

Instruction

« Civil ADs and TCH

technical directives »

Instruction

« Stores and equipment

excluded from continuing

airworthiness »



FR regulation

Order continuing airworthiness

• Art 8 - Organisation approval

• The State Aviation Safety Authority or Technical Authority , in their respective remit, issues an approval to organisations involved in the airworthiness environment, as soon as they apply for and comply with the terms and conditions of the present order.

• DO and PO approvals

• CAMO, MO & MTO approvals

• Where the organisations are involved in the frame of a State contract or a framework agreement (= industrial MOs) , the approval is issued as per the terms and conditions of the contract or the framework agreement.

• The Technical Authority or the State Aviation Safety Authority may recognize the approvals and their associated privileges, issued by the French, the European or the foreign Civil Aviation Authorities or by foreign Military Authorities.



FR regulation

Order continuing airworthiness

• Art 8 - Organisation approval (cont’d)

• The approved organisation may subcontract all or part of its activities.

• The State Aviation Safety Authority or Technical Authority may issue an approval to a subcontracted applicant, if it complies with the eligibility conditions defined in the contract between the organisation and the State.

• In particular, the subcontractor, which produces or maintains aircraft, engines, including auxiliary power units, and propellers may be eligible to apply.

• Until the approval is issued, the competent authority may, in the conditions specified in the contractual documents, authorize an organisation bound with the State by a contract to issue documents recognized as equivalent to acceptance documents, on the scope of the application.



Release to service documents for aircraft components

• AMC of FRA 145

• FRA Form 1

• EMAR(FR) Form 1

• An equivalent document from another authority, e.g.

• EASA Form 1

• FAA Form 8130-3

• EMAR Form 1 from a recognized NMAA

• CLA “Certificat libératoire acceptable” = Acceptable Release to

Service Certificate

• Used for non-approved MOs

• Transitional provision until 31 Dec 2017 or until the end of the

ongoing contract

• Used for non-approved subcontractors and countersigned by the

contractor

18



Challenge of approving industrial MOs

• The regulation is applicable to industry through contracts

• Organisation approvals cannot be a prerequisite

• Organisations to apply for approval once the contract is signed

• If no approval from a former contract, the applicant is granted a

deadline to get the approval

If change of MO further to a tender between several MOs,

specific provisions to meet the requirements for a controlled

environment

• Notion of provisional approval introduced in the regulation

19



Challenge of approving industrial MOs

• About identified 80 MOs to approve before 31 Dec 2017 (end of

transitional provisions), probably more due to the A400M ISS

• Contract award forecast schedule offers limited visibility on long

term workload

• The workload relating to the approval of MOs anticipated at the

creation of DSAÉ did not take into account complex international

contractual structure

• Poor visibility on subcontractors to be approved

• About 15 equivalent full time auditors for EMAR/FRA 145 audits

• FR auditors acting on MOs located in France only

• Travel expenses budget limitations

• Language barrier

Is FR DSAÉ workforce adapted ?

20

The contractor is not an MO (e.g. AMSL, NHI, EPI)



Contractual structure

Project management (incl. Procurement) :

Contractor:

DGA, SIMMAD, OCCAR, NAHEMA…

approved MO or applicant

Maintenance is subcontracted to one or several approved MOs or

applicants

Industrial organisation is sometimes more complex than expected, particularly for programmes in cooperation

• DGA for initial MRO together with aircraft procurement • SIMMAD (Joint Structure for the MRO of Aeronautical Products) for the next MRO

contracts • OCCAR : Tiger and A400M • NAHEMA : NH90

Eventually 2nd level subcontractors Eventually 1st level subcontractors

No direct contractual links with Procurement



Types of industrial MOs • EMAR M.A.201 Responsibilities:

• (g) Maintenance of military aircraft, and components thereof shall be carried out by a EMAR 145 approved Maintenance Organisation (MO)

Several cases for subcontracting :

• For the maintenance of any aircraft component outside its capability list, the approved MO may outsource to another MO which is approved or able to apply with the said component in its capability list

• For the maintenance of any aircraft component within the capability list of the approved MO

• EMAR145.A.75 (b) An approved MO shall be entitled to arrange for maintenance of any aircraft or component for which it is approved at another organisation that is working under the quality system of the organisation. This refers to work being carried out by an organisation not itself appropriately approved to carry out such maintenance under this EMAR and is limited to the work scope permitted under EMAR 145.A.65(b) procedures.

• This work scope shall not include a base maintenance check of an aircraft or a complete workshop maintenance check or overhaul of an engine or engine module

Different types of subcontractors :

• approved MOs or

• not approved organisations under the quality control of an approved MO

22



Types of FR MO approvals

- FRA/EMAR(FR) 145 approval issued by DSAÉ

- EMAR 145 approval issued to MOs located outside FR by the relevant NMAA recognised by DSAÉ, e.g.

- PERAM 145 issued by ES DGAM - MRP 145 issued by UK MAA Benefit of recognition of other NMAAs as per EMAD R

- EASA Part 145 approval issued by the relevant NCAA on behalf of EASA - Examples of NCAAs : FR DGAC, UK CAA, DE LBA, ES AESA, IT ENAC… Feasibility ?

- When the EASA Part 145 approval is not applicable, the applicant draft a supplement to the Part 145 MOE to address specific FRA or EMAR 145 requirements

- Audit by DSAÉ on the supplement only Cooperation protocol with FR CAA to share findings



EASA Part 145 approvals

- EASA issued a letter on 20 Mar 2013 : Rulemaking interpretation on “Maintenance release of aircraft not covered by the Basic Regulation” carried out by Part 145 approved MOs

- 3 practices (1/3): - Practice 1 :

- release statement referring to 145.A.50, - signing under EASA approval number not legally valid

- But then EASA clarified that the 3 practices are applicable to aircraft not to

components and in the NPA 2013-12, EASA proposes to add in GM 145.A.50: - For engines, propellers and other components it is not possible, in most

cases, to know in which aircraft they will be eventually installed and whether such aircraft are covered by the Basic Regulation or not. As a consequence, an EASA Part-145 (145.A.50) release (on an EASA Form 1) is generally possible. NOTE: there could be certain exceptions, such as the case of a component which can only be installed on aircraft for which civil versions do not exist.




- 3 practices (2/3):

- Practice 2 : - the EASA Part 145 MO has also a national Part 145 approval - Release statement referring to national Part 145.A.50

- e.g. FRA, EMAR(FR), PERAM, MRP… - signing under the national approval number No objection from EASA

- Usual practice in FR

- This possibility is defined in the FRA and EMAR 145.A.70 (d) - The applicant may draft a supplement to the Part 145 MOE to address specific

FRA or EMAR 145 requirements

In order to save scarce human resources, DSAÉ chose to limit the audit to the military supplement to the Part 145 MOE





- Practice 3 : - The national law (= national military airworthiness regulation) clearly states that

the release can be performed by an EASA Part 145 approved MO referring to the EASA Part 145 approval number

- FR military airworthiness regulation has a clear statement (Art 8 of Order Continuing Airworthiness)

- The State Aviation Safety Authority may recognize EASA approvals

- For the maintenance of A400M components, EASA proposed that a Release statement referring to national law, not to EASA Part 145.A.50

- Block 14a “Other regulation specified in Block 12 “ - Block 13 Remarks (based on EASA/EPI discussions for TP400 maintenance)

- “Certifies that the work specified was carried out in accordance with Part 145 standards as accepted by the respective NMAAs of BE, FR, DE, ES, MY, TR and UK whose national regulations have provisions for the recognition of the EASA Part-145 standards and the EASA Part-145 organisation’s approval and in respect to that work the items are considered ready for release to service”

No objection from EASA … but





- … objection from FR CAA - Oversight limited to the capability of the applicant to maintain components

listed in its capability list, - the capability list may include military P/N recognized by EASA

- No oversight of: - the procedures applicable to military P/N - the data approved by the NMAA (e.g. ICAs) - the ADs issued by the NMAA - the recordings

- Further discussion is necessary between the various stakeholders :

- Civil : EASA and NCAAs - Mil : NMAAs

- with the support of EDA - and in the short term with OCCAR for the A400M

- Industry - to clarify what is feasible depending on the compatibility of the maintenance put

in place with the EASA PART standards



French MO approval process : synthesis

Approved MO or applicant

Subcontractor: Approved MO or applicant

Certification of maintenance:

FRA/EMAR/EASA Form 1 or CRS for the airframe maintenance

(incl. maintenance of aircraft component by the same MO on the same facility)

Non approved subcontractor under the quality control of the approved MO

Maintenance of aircraft components within the MO capability list ?

Stores and equipment excluded from

continuing airworthiness order?

no yes yes

no

Maintenance i.a.w. maintenance manual

FRA/EMAR/Part 145 : airframe, engine/engine module

+ FRA 145 : propeller, APU, ejection seat

FRA/EMAR/EASA Form 1 signed by the MO or

« CLA » issued by the subcontractor and countersigned by the MO

CoC with traceability of the maintenance carried out

Other aircraft components

Outsourced maintenance no

yes

yes

no



Audits of MOs

MO approvals can be optimized by:

• Outsourcing part of the audits

• Cooperation with the national CAA (for Practice 2 implementation)

• Win-win strategy through exchange of information

• Recognition of relevant NMAAs for MOs located abroad

• Win-win strategy :

• Single EMAR 145 approval

• Travel expenses limited to the recognition of the NMAA

• No more issues with the language barrier

• Use of EASA Part 145 approvals under NMAA responsibility when feasible (Practice 3)

• Limited additional workload for NCAAs

• Conditions for implementation to be further clarified with EASA in relation with NCAAs and NMAAs.



Overview
















3. Conclusion



Conclusion

Efforts for the near future

• At NMAAs level

• Speed up EMAR implementation by pMS in their national regulation

• Share the approval workload through recognition between NMAAs

• Priority on issuing EMAR 145 approvals where required in cooperation programmes

• At MAWA Forum level

• Obtain from EASA and the NCAAs the formalisation of practice 3

• Use of Part 145 approvals under NMAA responsibility without issuing additional EMAR 145 approvals where applicable

32

Thank you for your attention! Any questions? Oct 2015

FR DSAÉ considerations for the approval of industrial MOs

dsaÉ (fr maa) considerations for the approval of ... · the type certificate holder (tch) is eg.:...

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