the path to certificationaea.net/events/incubator/pdf/2018_08/aea_thepathto...philosophy +...
TRANSCRIPT
The Path to Certification
Ric Peri
Aircraft Electronics Association
The New World Order:
FAA Allows Anything
The New World Order:
FAA Allows Anything
Headlines:
Non-certified parts in certified airplanes!
Headlines:
Non-certified parts in certified airplanes!
EXCITING TIMES!!!!
…. But It Is NOT The Wild West!!
Today’s Agenda
• How did we get here?
• Where is “here”?
• And what does it mean?
It All Stated Here!
Applying Safety Continuum
Zero Risk
No
Operations
No
InnovationSociety’s
Accepted Risk
&
Desire for Low
Cost
•Part 25 Transport Category Passenger Aircraft
•Amateur Built
•Large Part 25 Business Jets
•Part 23 Commuter Aircraft
•Part 23 Business Jets
•Part 23 Light Jets, Twins
•Part 23 Single Engine
•Light Sport Aircraft
Philosophy + Motivation
Angle of Attack Indicator
Applying Safety Continuum
Generation 1: February 5, 2014
Applying Safety Continuum
Generation 2:
Applying Safety Continuum
Generation 3: NORSEE
What is NORSEE?
• NO R S E E:
– Non Required Safety Enhancing Equipment
• Non required Safety Enhancing Equipment
addresses equipment that is not required by any
Federal regulation with the intent to measurably
increase aircraft safety.
• https://www.faa.gov/aircraft/air_cert/design_approvals/norsee/
Applying Safety Continuum
Generation 4:
Electronic Replacement for Vacuum Indicators
• Primary attitude indicator,
• Primary rate-of-turn
indicator, w / backup AI
• Directional Gyro
Applying Safety Continuum
Generation 5: Autopilots
Parts Regulations (14 CFR)
• § 21.8 Approval of articles.
• § 21.9 Replacement and modification articles.
§21.9 Replacement and Modification
Articles
• (a) If a person knows, or should know, that a
replacement or modification article is reasonably
likely to be installed on a type-certificated
product, the person may not produce that article
unless it is—
§21.9 Replacement and Modification
Articles
• (a) …. the person may not produce that article
unless it is—
– (1) Produced under a type certificate;
– (2) Produced under an FAA production approval;
§21.9 Replacement and Modification
Articles
• (a) …. the person may not produce that article
unless it is—
– (3) A standard part (such as a nut or bolt)
manufactured in compliance with a government or
established industry specification;
– (4) A commercial part as defined in §21.1 of this part;
§21.9 Replacement and Modification
Articles
• (a) …. the person may not produce that article
unless it is—
– (5) Produced by an owner or operator for maintaining
or altering that owner or operator's product; or
– (6) Fabricated by an appropriately rated certificate
holder with a quality system, and consumed in the
repair or alteration of a product or article in
accordance with part 43 of this chapter.
§21.9 Replacement and modification
articles
• (a) …. the person may not produce that article
unless it is—
– (7) Produced in any other manner approved by the
FAA. (new)
§21.8 Approval of articles.
• If an article is required to be approved under this
chapter, it may be approved—
– (a) Under a PMA;
– (b) Under a TSO;
– (c) In conjunction with type certification procedures for
a product; or
– (d) In any other manner approved by the FAA.
FAA Approvals
• Generation 1, and 3
– AOA & NORSEE
Approved under:
– §21.8 Approval of articles.
FAA Approvals
• Generation 2, 4 & 5
– EAA/Dynon (Commercial Part);
– Garmin G-5 (PMA);
– Autopilots (PMA)
• Approved under:
– §21.9 Replacement and modification articles.
Applying Safety Continuum
The New Generation of Products
are designed and produced for a
specific market
•Part 25 Transport Category Passenger Aircraft
•Amateur Built
•Large Part 25 Business Jets
•Part 23 Commuter Aircraft
•Part 23 Business Jets
•Part 23 Light Jets, Twins
•Part 23 Single Engine
•Light Sport Aircraft
Most
TSO/MOPS
written for
Transport
Category
applications
What’s the difference?
TSO (Technical Standard Order)
vs
PMA (Parts Manufacturing Authority
Technical Standard Orders (TSO)
• A TSO is a minimum performance standard for
specified materials, parts, and appliances used
on civil aircraft.
• When authorized to manufacture a material,
part, or appliances to a TSO standard, this is
referred to as TSO authorization.
• Receiving a TSO authorization is both design
and production approval.
Technical Standard Orders (TSO)
• Receiving a TSO Authorization is not an
approval to install and use the article in the
aircraft.
• It means that the article meets the specific TSO
and the applicant is authorized to manufacture it.
Parts Manufacturer Approval (PMA)
• Is a combined design and production approval
for modification and replacement articles.
• It allows a manufacturer to produce and sell
these articles for installation on type certificated
products.
Parts Manufacturer Approval (PMA)
• The design approval phase of PMA certifies that
a replacement or modification article complies
with the airworthiness standards of eligible
products (aircraft, engine, or propeller).
• The applicant shows this compliance through
tests and computations unless the article is
identical to the article design on a type-
certificated product.
What’s the difference?
TSO is BROAD-BASED
What’s the difference?
There is No Free Lunch!
• These new generation products all have
Limitations:
– Installation
• Aircraft
• Applications
– Maintenance
• OEM involvement
– Import/export
• No (limited) NORSEE/Commercial Part export.
Limitations -- Example
• In the attitude application, the Garmin G5
indicator can replace an existing vacuum
attitude indicator or rate – of - turn indicator.
The G5 can also replace existing vacuum driven
DGs or existing HSI’s , either standalone or in
combination with a G5 attitude display.
Limitations -- Example
• … This Approval includes a FAA Approved
Commercial Parts List, EAA Document Number
JAE-CPL-)1, Rev 1, dated March 25, 2016 or
later FAA approved revision.
Limitations – Cert Basis
Limitations – Cert Basis
Sec. 23.1311
Electronic display instrument systems
Amendment 23-49
03/11/1996
There is No Free Lunch!
• Know your products
• Know your customers
• Know the limitations
Questions?