june 13, 2017 chicago, il - federal aviation administration · 10:30 – 10:45 designee management...

June 13, 2017 Chicago, IL

Delegation and Organization Procedures Branch AIR-160

General Session Presentation Printout Section 508 Compliant

Section 508 requires that when federal agencies develop, procure, maintain, or use electronic and information technology (EIT), individuals with disabilities have access to and use of information and data that is comparable to the access and use by individuals without disabilities. For more information visit: Section508.gov.

Use of the information provided in this document is for general reference only. This document can be superseded at any time by the next revision or expiration of the referenced information.

Renewal Requirements

FAA22000002 DER Recurrent General Session

FAA Order 8100.8D paragraph 803.g. states: "DERs must attend a recurrent seminar every 2 calendar years to maintain their knowledge of the regulations and policies and as a condition for renewal. DERs may satisfy the 2 year requirement by attending a DER seminar in the calendar year it is due.

Contact EDR Training

If you have any questions or comments concerning the content of this document, send an email to the Engineering Designee Recurrent Training Branch.

For Program Information visit our website: Engineering Designee Recurrent Training Information

http://www.section508.gov/

mailto:[email protected]

http://www.faa.gov/other_visit/aviation_industry/designees_delegations/training/der_recurrent/

2017 Engineering Designee Recurrent Seminar General Session

Chicago, Illinois

June 13, 2017

8:00 – 8:15 Intro/Logistics/Announcements Tony Jopling (AIR-160) 8:15 – 8:30 Welcome TBD / Kevin Kendall (AIR-160) 8:30 – 9:15 Engineering Designee Training Program

Changes Tony Jopling (AIR-160)

9:15 – 9:45 Stump the Regulator All AIR-160 9:45 – 10:00 Break 10:00 – 10:30 New Policy Jon Mowery (AIR-160) 10:30 – 10:45 Designee Management System (DMS) Jon Mowery (AIR-160) 10:45 – 11:15 DER: Roles and Responsibilities Jon Mowery (AIR-160) 11:15 – 12:00 The Future of Aircraft Certification Kevin Kendall (AIR-160) 12:00 – 12:15 General Questions / Learning Assessment 12:15 – 1:30 Lunch 1:30 – 2:15 International Update (optional) Robert Sprayberry (AIR-400) 2:15 – 3:00 Policy Updates: Order 8110.4C Chg 6,

STC Compatibility, Flammability by Trace, and Destroyed Aircraft

Sue McCormick (AIR-110)

3:00 – 4:30 Bonus Session (optional)

Repairs and Alterations Repair Specification Management DERs

All AIR-160

4:30 – 5:00 General Questions

AIR-160 Engineering Designee Recurrent Seminar List of Acronyms

Acronym/Symbol Definition § Section 14 CFR Title 14 of the Code of Federal Regulations AC Advisory Circular ACE Small Airplane Directorate (SAD) ACO Aircraft Certification Office AD Airworthiness Directive ADO Approved Design Organization AEG Aircraft Evaluation Group AIA Aerospace Industries Association AIR Aircraft Certification Service AIR-1 Director, Aircraft Certification Service AIR-100 Design, Manufacturing & Airworthiness Division AIR-110 Certification Procedures Branch AIR-120 Technical & Administrative Support Staff Branch AIR-130 Systems & Equipment Standards Branch AIR-140 Operational Oversight Policy Branch AIR-150 System Performance and Development Branch AIR-160 Delegation and Organization Procedures Branch ASTC Amended Supplemental Type Certificate ASW Rotorcraft Directorate ATC Amended Type Certificate ASTM American Society for Testing and Materials AVS Aviation Safety C of A Certificate of Airworthiness CA Certificating Authority (a.k.a. exporting authority) CBT Computer Based Training CDO Certified Design Organization CDPO Certified Design Production Organization CFR Code of Federal Regulations CLOA Certificate Letter of Authorization CMACO Certificate Management ACO COA Certificate of Authority COS Continued Operational Safety CP Certification Plan CPN Certification Project Notification DAH Design Approval Holder DAR Designated Airworthiness Representative DBR Delegation by Regulation DER Designated Engineering Representative DIN Designee Information Network DMS Designee Management System DOT Department of Transportation DRS Designee Registration System

Page 1 of 3 Last updated: March 21, 2016


E&PD Engine and Propeller Directorate ECO Engine Certification Office EDR Engineering Designee Recurrent EMI Electro-Magnetic Interference F Fahrenheit F&R Function and Reliability F/A Flight Attendant FAA Federal Aviation Administration FAATC Federal Aviation Administration Technical Center FADEC Full Authority Digital Engine Control FANS Future Aeronautical Navigation System FAQ Frequently Asked Questions FAR Federal Aviation Regulation FCAA Foreign Certification Airworthiness Authority FSDO Flight Standards District Office GA General Aviation GAMA General Aviation Manufacturers Association GAO General Accounting Office HQ Headquarters ICA Instructions for Continued Airworthiness

LOPI Level of Project Involvement

MARPA Modification and Replacement Parts Association MOC Method of Compliance MOU Memorandum of Understanding NACIP National Automated Conformity Inspection Process NAS National Airspace System NPRM Notice of Proposed Rulemaking NTSB National Transportation Safety Board ODA Organization Designation Authorization ODAR Organizational Designated Airworthiness Representative OIG Office of the Inspector General OMT Organization Management Team PACO Project Aircraft Certification Office PMA Parts Manufacturer Approval PNL Program Notification Letter POA Production Organization Approval POC Point of Contact PSCP Project Specific Certification Plan PSP Partnership for Safety Plan



PTRS Program Tracking and Reporting Subsystem R&A Repairs and Alterations RBDM Risk Based Decision Making RBRT Risk Based Resource Targeting RFC Request for Conformity RGL Regulatory and Guidance Library SAD Small Airplane Directorate SAIB Special Airworthiness Information Bulletin SAR Selection, Appointment, and Renewal SFAR Special Federal Aviation Regulation SME Subject Matter Experts SMS Safety Management System SOP Standard Operating Procedure SRM Safety Risk Management STC Supplemental Type Certificate TAD Transport Airplane Directorate TBD To Be Determined TC Type Certificate TCDS Type Certificate Data sheet TSO Technical Standard Order TSOA Technical Standard Order Authorization UM Unit Member


1 Federal Aviation Administration

Federal Aviation Administration

Presented to: 2017 DER Recurrent Seminar General Session

Engineering Designee Training Overview


Seminar Program Overview • Designee Training Program Website • Course Fees • Policy Memo • New Training System • Recurrent General Session • Seminar Locations • Course Certificate • Feedback • Contact Us


Designee Training Program Website

• http://www.faa.gov/other_visit/aviation_industry/designees_delegations/training/DER_Recurrent/

• Good place for information on: – Recurrent General Session Schedule – ODA Training Information – Technical Session Updates – Deviation Memos – etc.

http://www.faa.gov/other_visit/aviation_industry/designees_delegations/training/DER_Recurrent/

http://www.faa.gov/other_visit/aviation_industry/designees_delegations/training/DER_Recurrent/


Course Fees • Course fees are being updated based upon actual Engineering

Designee training budget • The FAA has been subsidizing Engineering Designee training,

this will no longer be the case • This means all courses will see some sort of increase in tuition • New fees will make the Engineering Designee program solvent • All monies collected from training course fees will be used for

engineering designee program • Technical training will have a flat fee


Policy Memorandum AIR100-17-160-PM02

• Revises the recurrent training requirements contained in FAA Order 8100.8D paragraphs 803g and 201b

• Changes the technical training requirement to an annual requirement for DERs, ODA UMs, DER advisors and OMT members

• General Session training requirements will remain unchanged for DERs

• General Session training requirements for DER Advisors being changed to every 2 years to align with the DER requirement


New Training Program • Engineering Designees will be able to access and complete

required training at any time during the calendar year • No longer dependent upon FAA development schedule • Technical courses will be release individually as they are

available • Technical training course curriculum will include required

courses and electives – Required courses will be any courses selected by the FAA to be completed by all

designees within a particular discipline – Elective courses will be within the designees discipline – Designees will select a minimum number of elective courses


New Training Program (cont.) • Access to the technical training will be based on a flat annual

fee – Once paid designees will have access to the entire training library for the duration

of the calendar year – Designees will then be able to register for and complete their required training by

the end of the calendar year as required

• The FAA will be issuing a required “Introductory” course which will include: – Details on the changes to the technical training program – Instructions on how to access and navigate DRS and Blackboard – Details on required versus elective courses – Instructions for the selection and completion of elective courses


• Recurrent General Session will now have a mandatory morning session and an optional afternoon session

• Beginning in 2017 there will be an online option for the Recurrent General Session

• The fee will be the same between the face to face and online versions

• Online version will include the required morning session but will not include the material covered in the optional afternoon session (although the presentations from the afternoon will be made available)

• General Sessions will be offered in same locations but less frequently (next slide)

Recurrent Seminar General Session


Seminar Locations


Course Certificate

• Course Certificate: Issued after up to 4 hours after successful completion. – If you do not receive a course certificate:

• Grade not recorded: System error, browser, etc. • User did not meet the course requirements:

– For example, user completed 4 of 6 topics. Requirements are provided at registration (DRS), in the course and course printout.

– Do not wait until Jan after the course expires to figure this out

– You may retrieve your current and past certificates from DRS (see FAQ webpage)


We Need Your Help!

• Feedback: – Engineering Designee Seminar Program is YOUR

program – Most topics come from field suggestions

(Designees, ACOs, Directorates, etc.) – Future changes/improvements will include input from

our designees – There are many ways YOU can provide input

• End of course Survey • Website: Contact us Email: [email protected] • Each course provides a Contact Us button


Contact Us Please allow time to look into your problem and respond. The program is growing and we are doing our best to respond to all inquiries in a timely manner. 1. For content specific questions each course will now have contact information for the Subject Matter Expert (SME) for that course. Please contact the SME for content related questions. 2. Preferred Method: Email: 9-AMC-EDR [email protected]. Each course has a Contact Us Menu Item. Provide as much information as possible, but at a minimum be sure to include: • Your full name as it appears in DRS – not a nickname • Course Number and title for example: (27200106) Electrical: Electronic Flight Bag • Page Number: Page 5 of 25 • Explain the error found • Provide a screen shot if possible 3. If you decide to call and leave a Message: • a. Clearly Provide your full name as it appears in DRS – not a nickname • b. Course #, Lesson and problem: We can troubleshoot and perhaps correct the issue if we have the

details before we contact you by email or returning your call. FUP


Questions

Presented to: 2017 Engineering Recurrent Seminar


Stump the Regulator


Stump the Regulator

• Open Q&A session with everyone from FAA Headquarters on stage

• We reserve the right to tap into local FAA knowledge

• Any question relating to delegation of any kind is fair game

• Prize to those who manage to stump us Note: not liking our answer is not stumping us


Sample questions

• Question: – As a DER I last took the general session training in

Sept of 2015. My renewal is in Aug of 2017. Can I be renewed or do I have to take the training before?

• Answer: – Yes, you can. The training requirement is once

every 2 calendar years, which means you have until Dec 31st of 2017 to take the training in this scenario.


Sample questions

• Question: – Can a Repair Specification be created for minor

repairs? • Answer:

– No, Repair Specification approvals are for major repairs ONLY. Minor repairs only require acceptable data not approved data and therefore no 8110-3 or 8100-9 is required.

Ref 8110.37E and 14CFR 43


Sample questions

• Question: – I see there is something called a “vintage DER” Do I

have to have that before I can work on Vintage Airplanes?

• Answer: – No, a vintage DER is a DER who did not meet all the

qualifications of a DER but who has demonstrated expertise in a certain type of vintage aircraft.

Ref 8110.37E


Questions before we begin?


Ok, then let’s see if you can STUMP THE REGULATORS



New Policy


New Regulations/Policy of Note

• 8110.37F • 14 CFR 23 • AMOC Order 8110.103B • PMA for minor modification articles • Lithium Battery policy memo • New DER “landing page” website


Recent Policies

• Where can Policy information be found? • http://rgl.faa.gov/Regulatory_and_Guidance

_Library/rgPolicy.nsf/ • This site contains Policy that has yet to be

incorporated in FAA guidance

http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgPolicy.nsf/

http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgPolicy.nsf/


What’s planned for in Rev F of Order 8110.37

• 8110.37F is not out yet, but is projected to be out for comment in spring of 2017

• Here are some of the changes planned – Remember nothing is final or required until the order

is published


What’s planned for in 8110.37F • No more DER Candidates

– anyone who fit the previous description will now be a DER with authority limited to Recommend Approval only

• A note will be added to address the removal of Administrative and Management DERs – Management function will now be a special authority

similar to Repair Specification • Added a section on rescinding an 8110-3

after it’s been issued


What’s planned for in 8110.37F

• Adding a section on repair of TSO products – Cannot just repair a part that was produced under a

TSOA to the TSO – Must address the certification basis of the product

upon which the repaired part will be installed on


Questions?


14 CFR Part 23 rewrite

• The entire part 23 has been rewritten • Final rule was out in December 2016 • It becomes effective on August 30th 2017 • The philosophy is to have the WHAT we

want to happen in the rule (e.g. keep occupants from severe injury during a crash) and put the HOW into Method Of Compliance (MOC) documents


14 CFR Part 23 rewrite • The rule and the MOC documents will be

used together to show compliance • Initially the new form (Rule and MOC

documents) will look very similar to the current 14 CFR Part 23 at amendment 62 because that was the starting point for the ASTM documents

• As time goes by changes to the ASTM MOC’s and other accepted MOC documents will result in a more streamlined process for applicants



• How does this affect DERs? – Actually very little impact – If you currently have a delegation for part 23 you

may, when delegated, find compliance to the new part 23

– The compliance finding will be to the new performance based regulation (all new numbering system!)

– IF your delegation is limited by regulation number then you’ll need to coordinate with your advisor to reword the limitation to remove the number



– The DER will list the new regulation in block 9 applicable requirements.

– The DER will also be required to list the MOC in block 7 the list of data block

– A memo from AIR 160 will be forthcoming with instructions on how to document new part 23 findings on the 8110-3/8100-9 form



• If you will be finding compliance to the new part 23, you’ll most likely need to subscribe to ASTM to get access to the MOC’s. $75/year.


Questions?


AMOC Order 8110.103B

• The AMOC order has been rewritten. • It allows for the FAA to delegate AMOC

authority in certain cases • Still limited to company DERs and ODA’s

and only certain AD’s. • It can be found at • http://rgl.faa.gov/Regulatory_and_Guidance

_Library/rgOrders.nsf/0/9EB2E3C417522B5E86258030005AD1FC?OpenDocument

http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgOrders.nsf/0/9EB2E3C417522B5E86258030005AD1FC?OpenDocument




PMA for minor modification articles PS-AIR-21-1601 • This policy statement allows for the FAA to

issue a PMA for parts that modify a product where the modification does not rise to the level requiring a STC

• http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgPolicy.nsf/0/553F0BD99E1C3A3D8625804A004BA665?OpenDocument

http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgPolicy.nsf/0/553F0BD99E1C3A3D8625804A004BA665?OpenDocument




Lithium Battery policy memo AIR100-15-140-GM50 • This policy details a change made to the Flight

Standards Service (AFS) Major Repair and Alteration Data Approval Job Aid

• The change affects when Lithium Battery alterations or repairs require an STC

• This only affects installations on Part 25 Transport Category Aircraft

• http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgPolicy.nsf/0/BCFC7C16684BC47E86257F640071F14E?OpenDocument

http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgPolicy.nsf/0/BCFC7C16684BC47E86257F640071F14E?OpenDocument




Questions?


The New DER Landing Page


The New DER Landing Page

• Serves as a place for DERs to start looking for FAA information – Goal is for any information useful to a DER is only

one or two clicks away – It will have newsfeed for updated topics – It will have a library of useful information such as

links to forms etc. – Please put on your comment form any information

you think would be useful to have on the site


Questions?



Designee Management System (DMS)


What is DMS?

• DMS is a web based tool for the FAA to use in managing its designees

• Created in Response to a Government Accountability Office (GAO) audit of the FAA

• Replaces the individual systems that each line of business was using


What will DMS do? • It will roll up

– Appointment – Renewal – Terminate as well as provide for the management of the delegation


Current Deployment Schedule

• DMS is up and running for Manufacturing Designees, and Aeromedical

• AFS is next • DERs are last • We will be working on the requirements

document through this fiscal year (Oct) • DERs should not expect to have to do

anything until mid 2018 at the earliest.


DMS

• When we do transfer your data over from our existing system we will need you to verify that the data we have is correct

• We may do that before or after the transfer depending on what is easiest


Questions?



DER: Roles and Responsibilities


Roles and Responsibilities

• This is a refresher of some information presented in the initial DER training

• We’ll remind you of: – Use of DER Numbers – Proper Use of Form 8110-3 – DERs and Conformity – Certification Plans


Use of DER Numbers • There are limited instances where it is appropriate for

DERs to use their DER identification number. • DERs have used their DER numbers inappropriately. • We DO NOT permit DERs to use their DER

identification number when signing: – Company or personal reports – Drawings – Service documents – Letters

• DER’s signature on these types of documents does not constitute FAA approval.


Use of DER Numbers

• DERs may use their DER identification numbers in five places: – FAA Form 8110-3

• DERs find compliance to airworthiness standards.

– FAA Form 8100-1 • DERs may be authorized to disposition items found to be unsatisfactory during the

conformity inspection process.

– FAA Form 8120-10 • DERs may be authorized to initiate a request for conformity.

– Repair Specifications • DERs with a special delegation are authorized to approve repair specifications

– Certification Plans • DERs are encouraged to review the applicant’s certification plan prior to review and

acceptance by the FAA.


Questions?


Proper Use of Form 8110-3

• Even though it is referred to as a data approval, except for major repairs or alterations, the Form 8110-3 signifies only that the data complies with the airworthiness standard

• In general, Form 8110-3 is not an FAA approval to produce parts or otherwise use the data

• Form 8110-3 signifies that the DER has verified compliance on behalf of the FAA, or has reviewed the data and recommends that the FAA concur with this recommendation



• A DER authorized to approve technical data may decline to approve any or all portions of the data. – DER submits Form 8110-3 to FAA as “Recommend Approval”

for FAA to review and approve. – The DER must specify reasons for not approving the data.

• For major repairs or major alterations • Approval of the engineering design data is required before the

repair or alteration may be accomplished. • Form 8110-3 serves as:

Finding of compliance Approval to accomplish the repair or alteration



• Form 8110-3 is used to document a finding of compliance with airworthiness standards.

• Form 8110-3 is NOT used to document a DER’s participation in or review of any other part of a certification project, such as: – Certification plans – Compliance checklists – Conformity plans – Project schedules – Proposed certification basis


Questions?


DERs and Conformity

• “Conformity” is verification that aircraft and parts were manufactured according to the approved engineering drawings.

• Form 8100-1, Conformity Inspection Record, is used to document conformity inspections during type, production, and airworthiness certification programs. – Lists all discrepancies and nonconformities identified during a

conformity inspection of a part, installation, or entire product. – Records corrective actions taken to resolve discrepancies and

nonconformities.


DERs and Conformity

• Items identified on the Conformity Inspection Record as unsatisfactory are referred to as UNSATs, and must be cleared before the part, installation, or product can be issued an approval or certificate

• A DER may be authorized to participate in the conformity process when corrective action to resolve any UNSATs involves the engineering design

• All inspections conducted by an ASI or designee to determine conformity to an approved type design before an airworthiness certificate is issued must be recorded on FAA Form 8100-1


DERs and Conformity

• DERs authorized to disposition UNSATs on a Form 8100-1 must be identified by the ACO requesting the inspection

• DERs are specified by name and DER identification number on the Request for Conformity, Form 8120-10


DERs and Conformity

• An authorized DER can determine, from an engineering standpoint, if the nonconformance is acceptable, if the part must be reworked, or if it must be scrapped. – If the discrepancy allows the part, installation, or product to

comply with the airworthiness standard, the DER may approve a drawing revision to clear the UNSAT

– Form 8110-3 only approves the drawing revision, and does not reference Form 8100-1

– DER’s entry on Form 8100-1 to clear the UNSAT should reference the new Form 8110-3


DERs and Conformity

• DERs authorized to clear unsatisfactory conditions/nonconformities will enter the nonconformity in block 9, and describe the corrective action in block 13

• When corrective action is completed, the DER will: – Line through and initial the UNSAT in block 12 – Sign the corrective action in block 13 with his/her DER

identification number


Request for Conformity

• The Project ACO may designate a Management DER to initiate this request on their behalf

• The DER completes a Form 8120-10, Request for Conformity (RFC)

• The completed RFC is sent to the MIDO to request the inspection, whether by a MIDO inspector or by one of their designees, a DMIR or DAR-F


Request for Conformity

• Instructions for completing the RFC are found as a separate instruction sheet attached to the printed version of the form, or as the first two pages of the electronic version of the form

• DERs initiating the RFC on behalf of the ACO should record their name and DER identification number on the line identified for the FAA project manager

• The completed RFC must be reviewed and signed by the FAA project engineer


Questions?


Certification Plans

• We encourage DERs to review and coordinate on certification documents submitted to the FAA, such as certification plans

• DERs may use their DER number and title on the certification plan cover sheet to indicate that they reviewed the documents

• A DER’s signature on a certification plan does not constitute FAA approval


Questions?


Federal Aviation Administration Aircraft

Certification Transformation


Introduction

• Aircraft Certification Service (AIR) Transformation

• Discuss evolution of FAA/Industry roles and responsibilities

• Discuss the implementation of Applicant Showing policy


AIR Transformation is our holistic approach to becoming more efficient and effective


Refresh Certification Strategy


Improve Our Organization


Next Steps for Implementation

“Realignment” will be the first visible step of a phased implementation of the functional organization

AIR plans on realigning the organization in 2017 to begin to institutionalize the process improvements that are currently in progress.

Realignment changes management structure of AIR’s existing local offices (ACOs, MIDOs, etc.) to align with AIR’s functional divisions.

During realignment AIR’s existing industry POCs will be retained to ensure seamless relationship management and to facilitate contact with the appropriate AIR employee.

AIR will continue to brief industry on implementation status and to solicit feedback.

As an outcome of realignment, AIR’s directorate structure will cease to exist.


Evolution of FAA/Industry roles and responsibilities • Goals:

– Provide ability to better manage workload and be more responsive

– Define involvement based on compliance risk – Maximize applicant’s capability to show compliance – Develop an applicant base fully capable and

competent in showing compliance so that the FAA can focus its resources on risk based oversight

– Expand FAA recognition of applicant showing only (ASO) for compliance


• Strategic Objectives: – Support an empowered FAA workforce who embrace

risk based oversight for applicants that demonstrate a compliance culture.

– Utilize ASO policy memo on targeted certification activities

– Build/Enhance a systems approach to certification within the company

Evolution of FAA/Industry roles and responsibilities


Applicant Showing Only (ASO) without an FAA finding of compliance • Recognition of Applicant Showing without FAA involvement is

available, and is specifically promoted through Streamlined PMA and through “Low Risk” policy memo

• Benefits to applicant – Resources/logistics/schedule – Most logical examples: Part conformity, Test witness

• Benefits to DER/UM – Experienced as compliance show-ers

• Benefits to FAA – Not as clear or quantifiable, but – Focus designee resources/oversight on higher risk – Possibly less designee oversight – Recognized confidence in applicant capability for future

• Potential costs – Applicant - Correction of noncompliance – FAA - Oversight of showings


Recognition and Use of Applicant Showings

• Streamlined PMA Order 8110.119 (11/30/12) – Approve eligible non-safety significant articles in

about 30 days with minimal use of ACO resources – Applicant guidance is in the Modification and

Replacement Parts Association (MARPA) Document 1100

http://pmaparts.org


Recognition and Use of Applicant Showings

• Policy memo AIR100-15-150-PM16, issued 9/30/15,

Guidance for Recognition and Use of Applicant Showings on Standard Certification Projects – Allows ACO to determine LOPI based on defined risk criteria

using a risk based decision making (RBDM) tool – For low risk areas of standard projects the project team can

rely on applicant showing – Decision made case by case, project by project and is subject

to additional criteria


Recognition and Use of Applicant Showings • ASO additional criteria

– Successful past projects including projects of comparable complexity, and

– Same compliance methodology as used before, and – Either the same person(s) is making the applicant

showing, or an auditable documented company process is used to develop the specific substantiating data and,

– The applicant provides a signed written statement of compliance for each regulation that applicant showing was authorized


Summary • FAA Transformation is responsive to:

– Congressional Direction (FAA Modernization and Reform Act of 2012) – Industry requests for more efficient certification processes

• Implementation of FAA initiatives that support the transformation have already begun: – ODA Scorecard – Risk Based Level of Project Involvement Tools (RBRTa/RBRTo) – Certification Process Improvement (CPI) Guide Revision

• Next step is to continue to implement ASO for low-risk activities


Questions?

Presented to: 2017 Engineering Designee Recurrent Seminar


Engineering Designee Recurrent Seminar

International Update


Overview • FAA’s Global Leadership • International Policy Division ( AIR-400) • Bilateral Agreement Overview

– Implementation Procedures – Current Agreements

• FAA and EASA (TIP) • DERs and International Policy • DER Do’s and Don’ts • Helpful Links • Questions???


• Certification Management Team (CMT) – Represents the key authorities for global aviation

• FAA, EASA, TCCA, and ANAC • Leadership for FAA is AIR-1 (Dorenda Baker)

• CMT Collaboration Strategy (May 2016): – Partnership leveraging – Continued confidence building – Global leadership – Certification policy alignment

FAA’s Global Leadership


FAA’s Global Leadership, Cont’d

• CMT Goals for 2017 – Develop bilateral validation improvement roadmaps

with each CMT partner • FAA and EASA signed a Validation Improvement Roadmap

(VIR) in August 2016 • FAA is working with TCCA and ANAC on specific roadmaps

– Integrate key areas into FAA policy and our bilateral agreements

• EASA: TIP Rev 6 on target for FY17 • TCCA: IPA Rev 2 was signed in Nov 2016, Rev 3 is

underway • ANAC: IPA Rev 2 on target for FY17


International Policy Division (AIR-400) • Advocate in worldwide Aircraft Certification

activities – Promote strategic and effective international

partnerships – Lead international conferences and meetings – Promote U.S. priorities at International Civil Aviation

Organization (ICAO) and other international forums • Representative on ICAO Airworthiness Panel

• Policy holder for FAA Order 8110.52, Type Validation Procedures (TVP) – Currently at Revision A – Rev. B due out no later than COB FY17


International Policy Division (AIR-400) • Bilateral Agreement Development and

Management – Assessment, negotiation, development, and

management of bilateral agreements – Address issues faced by AIR offices and U.S.

industry in foreign certification activities • Special Arrangements and Management

plans – Supplemental IPA language; provides additional

authority and provisions – Detailed “how to” information describing a technical

situation (design, production, or airworthiness)


Bilateral Agreement Overview


Bilateral Agreement Overview, Cont’d



• Implementation Procedures – Implementation Procedures for Airworthiness (IPA)

• Represents the majority of IPs between the FAA and our FCAA partners

• TCCA, ANAC, JCAB, India’s DGAC, etc…

– Technical Implementation Procedures (TIP) • ONLY between the FAA and EASA • Unique in its specifics and breadth

– Schedule of Implementation Procedures (SIP) • Older version no longer utilized moving forward • CAAC, Indonesia’s DGAC, Mexico, etc…


FAA and EASA (TIP) • EASA Represents –

* These countries chose to adopt EC legislation for aviation safety


FAA and EASA (TIP), Cont’d • Overview of the agreement

– Currently at Revision 5, signed on 9-15-2015 • Rev. 5.1 due imminently • Rev. 6 due out later this year

– Emphasis on more efficient validation processes – Acceptance of U.S. STCs on third-country State of

Design products – TSO/ETSO reciprocal acceptance – Basic STC reciprocal acceptance – Reciprocal acceptance of most major and minor

repair data


DERs and International Policy • A DER can be used in international

work... – To make findings on behalf of the FAA for

• U.S. State-of-Design (SoD) products • U.S. State-of-Registry (SoR) aircraft • Other activities as authorized by the appointing ACO

and per FAA policy – e.g. technical assistance (witness a test for another civil

aviation authority)

• A DER can NOT be used: – To make compliance determinations directly for a

FCAA – In FAA Shadow Programs of FCAAs (typically)


DERs and International Policy, Cont’d

• ICAO places responsibility for an aircraft’s airworthiness with the State of Registry – N-registered aircraft are FAA’s responsibility – Non-N registered aircraft are the responsibility of their SoR

even if they are U.S. SoD products – DERs act only on behalf of the FAA and can only provide FAA

approvals as authorized by the FAA

• Following countries require notification prior to designee activity: – Israel, Malaysia, New Zealand, Russia, & Taiwan – All non-bilateral agreement countries


DERs and International Policy, Cont’d • Supporting a U.S. company in FV requests

– Your experience as a DER is a benefit even when not officially acting as a DER

• Project Familiarization Meetings – Know the differences between the foreign

requirements and the U.S. requirements • U.S. regulations are not always the more stringent

standard • Be proactive in identifying differences and means for

showing compliance

– A few FCAA’s set certification basis on date of application to FCAA (thus not to the FAA)


DERs and International Policy, Cont’d • Project Planning & Management

– Help your company develop a good relationship with the FCAA by:

• Submitting your application as early as possible – Many CAAs have even more limited resources than the

FAA – Do not expect success if unrealistic schedules are asked of

CAA • Discussing problems and issues openly and immediately

with your ACO project manager

– Avoid supplying unnecessary data • Some data is not allowed to be shared • Ref. the applicable IP and/or Order 8110.52


DERs and International Policy, Cont’d • Project Planning & Management

– Stated again, keep your ACO involved in the process

– Report to ACO when meetings with the FCAA seem to become training sessions

– Raise issues with the ACO to avoid problems on follow-on projects

• e.g., type validation principles not being followed • Note guidance within the applicable IP

– These efforts support our internal requirements for our Bilateral Relationship Management (BRM) process


DER Do’s and Don’ts • When Working on Foreign Activities

– DO • Read the bilateral agreement – specifically the IPA (e.g., scopes

of IPA vary greatly) • Recognize that bilateral agreements are government-to-

government agreements, not applicant to authority • Be well prepared at meetings with the CAA • Work through your ACO; keep advisor involved • Submit 8110-3’s and data to FAA • Contact your ACO if you feel pressured by a CAA • Keep your advisor aware of all international activities

– DON’T • Work directly with FCAA unless instructed by ACO • Provide 8110-3’s or data directly to FCAA for validation projects • Put your DER number on FCAA forms


Helpful Links https://www.faa.gov/aircraft/air_cert/international/

AIR-400 Mailbox Address:

[email protected]

https://www.faa.gov/aircraft/air_cert/international/



Contact Info. Robert Sprayberry Aerospace Engineer / TVP Policy FAA Aviation Safety Aircraft Certification Service International Policy Branch, AIR-410 T: 202.267.1655 E: [email protected]


Federal Aviation Administration Policy Updates:

Order 8110.4C Chg 6, STC Compatibility, Flammability by Trace, and Destroyed Aircraft

Presented to: DER Recurrent Seminars

By: Ian Lucas AIR-111 Date: June 2017


Order 8110.4C Change 6

• Effective Date 3/6/2017 • General Objectives

– To incorporate approved deviations to the order – To incorporate directive feedbacks from public and

field offices • Both corrections and suggestions for improvement

– Editorial revisions throughout the whole document. – Removal of outdated material

• This includes removal of material when other current policy and procedures documents covering the same material exist. Directing the readers to those documents.

2 Order 8110.4C, Change 6


STC Compatibility

• Addressing the Issue – FAA released AC 20-188, Compatibility of Changes

to Type Design Installed on Aircraft, dated12/9/16

– Compatibility is ensuring that changes to type design approved separately do not create a safety issue if installed together

– STC Compatibility not a new issue • Can also be referred to as “Layering STCs”

3 STC Compatibility


Other Documents

• Transport Canada Airworthiness Notices - B045, Edition 1 - 15 May 1998, Compatibility of Multiple Modifications

• Three NTSB Safety Recommendations – Issued by the Board on May 24, 2012

4 STC Compatibility


Other Documents

• Anchorage ACO flyer, How Do I Determine Supplemental Type Certificate (STC) Compatibility?

• Aircraft Owners and Pilots Association (AOPA) article “Layering STCs: Understanding and Managing the Risks. November 21, 2013

• FAA Safety Briefing - May/June 2014 article Beware the Frankenplane! The Hidden Dangers of Layering STCs

5 STC Compatibility


The STC Itself

8110.4, 4-19(f)(2): For multiple STCs, include the following note:

“The installer must determine whether this design change is compatible with previously approved modifications.”

6 STC Compatibility


FAA Form 337

NOTICE Weight and balance or operating limitation changes shall be entered in the appropriate aircraft record. An alteration must be compatible with all previous alterations to assure continued conformity with the applicable airworthiness requirements.

7 STC Compatibility


AC 20-188

• Promotes awareness • Provides “examples” of potentially

incompatible STCs to help installers • Promotes owners to review aircraft history • Provides recommendations for sources of

information – This includes the design approval holders and

designees • Focuses on STC; could apply to alterations

8 STC Compatibility


What Can You Do?

• AC meant to be a starting point to create awareness – Expected to evolve over time – Add cases/information as available

• Submit feedback form in AC if you have a recommendation

• Help installers with technical aspects • Provide approval for data

9 STC Compatibility


Questions?

• STC Compatibility Program Manager: – Edward Garino, AIR-111, 404-474-5532 – [email protected]

10 STC Compatibility


Minor Mods and PMA • Policy Statement PS-AIR-21-1601

– Signed on Oct. 6th, 2016 – Rev. D of the Order clarified the definition of a

Modification Article as new to the product via a major or minor change

• Historic precedence has allowed PMAs for mod articles outside the use of a STC (this is NOT new)

– Onus of utilizing this guidance is on the applicant • NOT to be used to subvert a STC project • Will not be reliant on any comparative analysis but rather a

general analysis only • Will NOT be applicable for most modification articles • Supplemental ICAs will almost always be required

11 Policy Statement PS-AIR-21-1601


Changed Product Rule (CPR) • New AC 21.101-1B, Establishing the Certification

Basis of Changed Aeronautical Products – International CPR CIT fourth charter established in September

2013 to update the AC – Published on March 11, 2016 – Harmonized with EASA, FAA, TCCA and ANAC – No fundamental change to policy, only clarification

• Guidance on many situations encountered since last revision – Appendix has more pre-determined examples by aeronautical

products • Substantial, Significant, Not Significant

– Flow chart for CPR procedures – Optional CPR Decision Record 12 Changed Product Rule (CPR)


Changed Product Rule (CPR) • Upcoming Order 8110.48A, How to Establish the

Certification Basis for Changed Aeronautical Products – Order based on the harmonized AC 21.101-1B – Planned to be published later this year – Delegation language deleted to align with AC

• Delegation details to be moved to FAA Order 8100.15, Organization Designation Authorization Procedures

• Projects that do not require a program notification letter (PNL) are pre-determined as not significant when properly authorized and managed in accordance with the ODA procedures manual.

• CPR Training Course will be offered through the FAA Academy next year

13 Changed Product Rule (CPR)


Questions?

• CPR Program Manager: – Michael Jewell, AIR-111, 202-267-9623 – [email protected]

14 Changed Product Rule (CPR)


15

Flammability by Trace • Reduction of certification costs through the use of

trace compliance based on previous FAA approvals • Applies to §§ 23.853, 23.855, 25.853, 25.855, 27.853,

27.855, 29.853, and 29.855 • Addresses

– § 21.20, Compliance with applicable requirements – § 21.21, Issue of type certificate – § Section 21.31, Type design – § Section 21.117, Issue of supplemental type certificates

Flammability by Trace


FAA Order 8110.4C • Section 2-6(k) Data Submitted for Approval

– (2) FAA personnel may use the applicant’s or certificate holder’s data for reference or evaluation of any subsequent applicant’s submitted data if the information is used solely for that purpose.

– (3) Provides procedural guidance on the use of a previous applicant’s data as a means of compliance for a subsequent applicant (assumes applicant has the data)

• Must show evidence it was approved by the FAA • Must show previous approved data is applicable • Provides sufficient substantiation and descriptive data of its own

modification • Has sufficient engineering data for COS support or multiple STC

Situation

16 Flammability by Trace


What Is Compliance By Trace • A means for an applicant to satisfy the § 21.21(b)

requirement to submit type design, test reports and computations by showing traceability to previously FAA approved data

• An applicant initiated action – Applicant provides sufficient data/analysis to establish traceability

• Show that the approved design holder’s parts complied with the appropriate flammability requirements for the product on which they were installed

• Applicable aspects of the material, design, use, orientation, and certification basis align between the holder’s and applicant’s articles



How Does It Work • Applicant submits for STC or ASTC design approval • Applicant & FAA develop compliance checklist • Applicant provides line item evidence of previously

submitted and FAA approved (TC holder) flammability compliance data

– List of items showing applicability (found in PS)

• Applicant submits other required compliance data • FAA finds compliance based on submitted and trace

data



Importance of Evidence • Compliance by Trace is not a waiver of any

airworthiness requirement • Applicant must provide evidence of FAA

approval to support request for compliance by trace

• Evidence must be specific enough to minimize or eliminate the need for FAA to access previous compliance data for verification of finding

• Policy details list of required items



§ 21.20 Compliance Statement

If an applicant shows sufficient evidence of traceability to previously FAA approved data,

the responsibility for submission of the necessary data has been satisfied, and

“Traceability to previously FAA approved data” would be the documented line item means of

compliance as required by § 21.20(a)



Questions?

• PMA and Compliance by Trace Program Manager: – Ian Lucas, AIR-111, 202-267-1693 – Email: [email protected]




Destroyed Aircraft • Aircraft owners, aircraft registration certificate holders and

repairers have been building aircraft from spare parts and attaching an ID plate of a different aircraft, classified as destroyed by the NTSB or the FAA, to them

• The spare parts used in building these aircraft could be from military surplus or salvaged from other destroyed aircraft. Rebuilding of destroyed aircraft poses two issues that the FAA is very concerned of: violation of the regulations and safety of the aircraft

• Currently, there is no guidance for FAA employees and the public in how to define an aircraft as destroyed, who can make the determination and how to resolve the dispute of the determination

22 Destroyed Aircraft


Applicable regulations §47.41 Duration and return of Certificate • (a) Each Certificate of Aircraft Registration, AC Form 8050-3, issued by

the FAA under this subpart is effective, unless registration has ended by reason of having been revoked, canceled, expired, or the ownership is transferred, until the date upon which one of the following events occurs:

(1) . . . . . . (2) The aircraft is totally destroyed or scrapped §45.13 Identification data . . . . . • (2)(e) No person may install an identification plate removed in accordance

with paragraph (d)(2) of this section on any aircraft, aircraft engine, propeller, propeller blade, or propeller hub other than the one from which it was removed



Challenge and Solution Challenge: • § 47.41 does not define the term “Totally Destroyed” nor who has the authority

to determine that an aircraft is destroyed Solution - an FAA-wide policy via order / advisory circular: • Any body having monetary or safety interest in the aircraft can declare an

aircraft destroyed, but anyone else can dispute it • Interested party can submit a repair scheme to ACO to show the aircraft is

repairable • If ACO approves the repair, the aircraft is not destroyed • To repair an aircraft, at least one of its primary structures must be repairable.

Replacing all of an aircraft structure is not a repair but a replacement of the aircraft - § 45.13 prohibits this action

• DER will help Applicant and ACO in developing and approving the repair scheme

• In summary: the condition of the aircraft itself determines whether it is repairable or destroyed



Current status

• A draft order and an advisory circular is completed and in circulation for FAA internal review



Questions?

• Destroyed Aircraft Program Manager: – Ky Ngo (AIR-111)

• Email: [email protected] • Telephone: 202-267-1637



Presented to: 2017 DER Recurrent Seminar


Topics for Bonus Session


Bonus Session

• Repairs and Alterations • Repair Specification • Management DERs


Repairs and Alterations

• Some Issues: – DERs being asked to approve data for minor repairs – Confusion over where the “original” 8110-3 is

supposed to go – Insufficient data being used to approve the major

repair (e.g. the thumb approach) – Use of prescribed 8110-3 notes (still seeing the “…

is not an installation approval”


Repair Specification

• Repair Specifications provide an alternative to the major repair technical data as well as the methods, techniques and/or practices contained in the current manufacturer’s manuals, service bulletins, or ICA

• Approval as an RS is required for multiple-use major repairs that do not come from the DAH

• They are used only for major repairs


RS DER Role

• Manage as a project (cert plan, compliance plan)

• Account for all disciplines • Account for maintenance requirements

(ICA) when affected or “no impact” statement

• Meet the 8110.37 policy requirements for an RS


RS DER Role

• Not used for part production unless part consumed in repair

• Not used for “process spec” approval except for as used in the course of the major repair


Repair Specification

• Some of the issues we’ve seen: – Not being used for major repairs – Not containing sufficient data

• Doesn’t define the starting state with enough detail • Doesn’t contain sufficient instructions to accomplish repair

– Approving the RS with a 8110-3 – FAA not realizing that a DER with RS approval can

approve (unless specifically limited) RS utilizing data from other DERs


Management DERs

• Do manage a project for the ACO • May issue conformity requests when

delegated • Act as a liaison between applicant and ACO • Don’t approve certification plans with a

8110-3


Management DER (during a project) • Use a cert plan & keep it updated, • Coordinate necessary changes with ACO • Resolve issues (changes in MoC, designees,

suppliers, test details) • Refer to the compliance listing part of it as the

method that compliance was shown (ref 21.20(a)/21.97)

• Ensure applicant understands requirement to make a certifying statement and that it’s not based on DER findings


Management DER (outside of a project) • Make sure you are representing the FAA

position when project planning with applicant

• Don’t oversell your authority or capability • When you present yourself as a

management DER – are you doing what the FAA would otherwise do?