U.S./Europe International Aviation Safety Conference By: Martin Thieringer – TCCA, Roger Simon – EASA, Scott Geddie – FAA Date: June 4, 2008 “Global Safety

U.S./Europe International Aviation Safety Conference

By: Martin Thieringer – TCCA, Roger Simon – EASA, Scott Geddie – FAA

Date: June 4, 2008

“Global Safety Management: Revolution or Evolution”

Reconciling Organizational Privileges

and Aviation Authority Responsibilities

Practical Challenges in Global SMS Implementation

Reconciling Organizational Privileges and Aviation Authority Responsibilities 2June 4, 2008

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Topics• Formation of the Joint Cooperation Team on

Approved Design Organizations

• Authority Updates on Approved Design Organization Programs:– EASA Design Organization Approval (DOA) – TCCA Accredited Design Organization (ADO)– FAA Certified Design Organization (CDO)– Similarities and Differences

• Sample Joint Cooperation Team Issues:– SMS and Design Organizations– Accountability Framework– Authority Involvement– Suppliers and Specialty Service Suppliers


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Joint Cooperation Team on Approved Design Organizations

• Chartered by the FAA/EASA/TCCA Certification Management Team (CMT) in November 2007

• Purpose: To create a forum for sharing ideas and plans regarding development and expansion of each authorities approved design organization programs.


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Scope• Knowledge Sharing

– Understanding of each authority’s approach in developing and recognizing approved design organizations

– Identify similarities and differences– Lessons learned

• Areas of Collaboration– Areas where programs can be harmonized – Areas where common terminology, guidance and

regulatory language can be used


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Scope (cont.)• Global implications

– Impact of each authority’s approach on partner authorities

– Areas that will require international acceptance by partner authorities

• Share timelines and schedules


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Authority Updates on Design Organization Programs


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EASA Design Organization Approval (DOA) Program


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The EASA DOA

• " qualified framework " for:– Aviation design– Compliance demonstration with applicable

requirements– Discharge of responsibilities

• set the basis for:– EASA acceptance of statements– Approvals, for certain cases


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In other terms:

• Means to recognise the capability of a design organisation

AND• Foundation for the exercise of privileges

The EASA DOA


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Organisation, • with the necessary management• allocation of responsibilities• procedures • and resources

necessary for the accomplishment of the activities defined in the scope of DOA

Qualified framework

The EASA DOA


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AND...• A system that monitors the performance of

the organisation and ensures that the need for effective corrective action is identified and carried out.

Qualified framework

The EASA DOA


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Resp

on

sib

ilities

(21A

.265)

A Design Assurance System (21A.239)

A Handbook

(21A.243)

Terms of Approval

(21A.251 + 21A.263)

The RIGHT PEOPLE,in the RIGHT PLACES,

with the RIGHT MEANS(21A.243 + 21A.245)

The EASA DOA


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J DOA

PART PARTPART

PRODUCT

Type

Certificate STC

Others...

The EASA DOA


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• EASA investigation to verify:– Compliance with all applicable Part 21 requirements– Adherence to approved system

Audits PracticeComplianceChecklist

Part 21/AMC/GM

Handbook/Procedures

The EASA DOA


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• Implementation started before EASA (first DOA issued in 1996)

• Currently ~235 organisations approved, including:

– All TC Holders (exceptions for balloons, airships and sailplanes)

– STC Holders

– Companies with scope limited to minor changes or repairs

• Discussions for further development on-going

The EASA DOA


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TCCA Accredited Design Organization (ADO) Program


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TCCA Accredited Design Organization (ADO)

• Holders of Transport Canada issued operation certificates are required to implement a safety management system (SMS).

• SMS will be applicable to design organizations (year 2010+).

• However, existing TCCA delegation system does not provide for:– integration of SMS into design activities;– the accreditation of design organization; and– clear aircraft certification accountability framework.


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TCCA ADO “operating certificate” for design organizations

• A distinct vehicle is needed to recognize design organizations knowledge and technical capabilities.

• Best approach is to build on existing expertise gained by 20+ years of delegation principles while clarifying the roles and responsibilities of all stakeholders.

• “Accreditation” is believed to be the best tool to enable the introduction of a “operating certificate” for design organizations.


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TCCA ADO – What it means…

• TCCA is building a system that will recognize the knowledge and technical capabilities of design organizations – Accredited Design Organization (ADO).

• Fundamentally, any person may apply for a design approval provided the applicant meets knowledge and technical capability requirements which are function of design approval sought, category of aeronautical product and “criticality” or “risk severity”.


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TCCA ADO – the ABC’s …• A: ADO will…

– make determinations of compliance for every applicable airworthiness requirements; and

– issue a single declaration of compliance for the design approval sought.

• B: TCCA will…– make a single finding of compliance;– conduct Project Surveillance through its Level of

Involvement (LOI);– conduct System Oversight through SMS

implementation.

• C: A design approval will be issued.


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TCCA ADO – some features…

• ADO may use subcontractor(s) AND is 100% responsible for all compliance determinations for the design approval sought.

• ADO must have a design assurance system.

• ADO will be scalable to fit an individual to small, medium, large design organizations.

• Intent is aligned with EASA’s DOA and FAA’s CDO.


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TCCA ADO (the benefits…)

• TCCA’s level of confidence in design organizations holding an ADO certificate would provide for their declarations of compliance to be accepted by the Minister without further verification subject to appropriate TCCA surveillance*.

* Project surveillance (LOI) and System Oversight (SMS)


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FAA Certified Design Organization (CDO) Program


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CDO Authorizing Statute

• U.S. Congress created the program in 2003 -- Vision 100-Century of Aviation Reauthorization Act

• Allows FAA Administrator to rely on certifications of compliance by a CDO when making a “finding” to issue a type certificate

• FAA has proposed changes to extend implementation date from 2010 to 2013, and to encompass production


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CDO Aviation Rulemaking Committee (ARC)

• Chartered in May 2005 for two year period– Membership

• 15 from industry and industry associations• 5 from FAA• 1 from TCCA

– ARC was free to make any recommendations including those that might require additional statutory changes

• ARC report submitted to FAA last week– Recommends CDO for TC, STC, PMA and TSOA

holders– Includes a proposed NPRM


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Principles and Attributes

• Not a delegation – certificate-based privileges

• Must be a design approval holder

• US must be State of Design

• CDO makes all ‘determinations of compliance’


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Principles and Attributes (cont.)

• A CDO can extend its system into its suppliers allowing them to make ‘compliance determinations’

• CDO intended to encompass continued airworthiness of legacy products

• FAA relies on CDO ‘statement of compliance’ when issuing a certificate or design approval


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Principles and Attributes (cont.)• Compliance by process rather than by the

action of a few individuals at the end of a program

• CDO requires – – Compliance Assurance System– Quality Management System– Safety Management System– Culture of Compliance

• FAA approved procedures manual required

CAS QMS

SMS


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FAA Level of Involvement

• Establish cert basis, approve alternate means of compliance, issue exemptions

• After that, FAA involvement in any program will consist of oversight and audit of the CDO operation

• FAA may, at any time, and for any reason conduct any certificate oversight it deems appropriate

• Delegation retained to issue certificates


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SMS/QMS (Company)

SMS (FAA)

Air Agency

Repair

CDO Concept Model

TCSTC

AW

FA

A A

dm

inis

tra

tor

Approved Data

Approved Parts Production “Finding”

Design “Finding”

PC

Production

CDO

Design


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Benefits• Recognizes a design organization’s system,

processes, and capabilities• Safety Management System (SMS) in place• A catalyst to promote further maturity of the

‘safety cultures’ within FAA and industry• Allows FAA to re-focus its resources on:

– areas of highest safety risk– developing clear policy and guidance for industry– enhanced role as compliance educator, coach


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Benefits (cont.)• The creation of “eligible” data• Reinforces industry’s responsibility for

compliance• Industry has greater control over its project

costs and schedules• Suppliers can be integrated into the process• CDO procedures manual replaces FAA Type

Certification Order


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Similarities and Differences Between DOA, ADO and CDO


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Similarities

Applicant’s System

Product Compliance

• Greater focus on process management and system oversight

• Design Organizations responsible for all compliance determinations

• Authority performs project and system oversight

• Routine projects require little authority involvement

• Suppliers can be incorporated with proper oversight

Moving to…

Agency


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Differences

Item EASA

DOA

TCCA

ADO

FAA

CDO

Acts as agent for other applicants Yes Yes No

Contains provisions to include production

No No Yes

Applicant must be an organization Yes No Yes

Declarations of compliance must be accepted by the authority

No Yes No

Must be located in country/union No Yes Yes


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Sample Issues Being Addressed by the Joint Cooperation Team


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SMS and Design Organizations• TCCA

– SMS is overarching (mandated by regulation)– Design Assurance elements will complement the SMS

requirements

• FAA– SMS is overarching– Single seamless system likely, but SMS, QMS and Design

Assurance requirements are separate

• EASA– New requirement for Management Systems will be the new

basis for organisation approvals to which DOA requirements will be added

– Introduces risk based approach to DOA activities and manner in which agency conducts oversight


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SMS and Design Organizations

• Things to consider going forward– ICAO requirements– The relationship between Safety Management,

Quality Management, and Design Assurance– Scalability– SMS regulations and oversight– Interface points between the authority and the SMS

of an approved design organization – Alignment of design organization SMS requirements

with other SMS facets of the company


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Accountability FrameworkApplicants have a regulatory obligation to:

Use means of compliance acceptable to the Authority Show that their designs are compliant

Design Approval Holders have an obligation to: Maintain compliant designs with no unsafe features

Authorities promote Aviation Safety by… Issuing regulations Specifying the certification basis Providing guidance regarding acceptable means of compliance Overseeing compliance Taking enforcement actions as necessary Issuing certificates and approvals; and Mandating corrective action as necessary


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Accountability Framework• TCCA

– Framework originated with TCCA– Provides the foundation of stakeholder responsibilities– Serves as the basis for any program undertaken

• FAA– Slight deviation from TCCA version– CDO ARC included it in proposed NPRM

• EASA– Will evaluate TCCA version, taking into account

responsibilities allocated by community laws


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Accountability Framework

• Things to consider going forward– Working toward a common definition– Impact of individual country laws, regulations, or

agency polices, in defining our views of the Accountability Framework

– Significant implications, if any, resulting from our differences


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Post CertComplianceConcept

• Ongoing system oversight based on risk management indicators

Pro

ject

Sys

tem

• COS

• Issue Certificate

• Trend monitoring

• Post-project reviews

• Determine cert basis

• Special conditions

• Exemptions

• Project shadowing/oversight

Authority Involvement


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Authority Involvement• Topic:

– To what extend the Authority is involved in product certification?

• Two main domains: – Obligations (e.g., development of cert basis, means of

compliance, issue certificates…)– Involvement in compliance determination (witnessing

of tests, verification activities…)

• Discussion on impact of CDO/ADO/DOA on involvement in compliance determination


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Authority Involvement

• Things to consider going forward– Impact of individual country laws, regulations, or

agency polices, on our view of LOI– Significant implications, if any, resulting from our

differences


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Suppliers• EASA

– Integration of suppliers in DOA already defined– Chartered working group to investigate granting sub-

tier DOA to suppliers• Limited scope of privileges• Concept exists under production system for POA• Prime has ultimate responsibility for continued

airworthiness

• TCCA/FAA– ADO/CDO can extend its system into suppliers

allowing them to make ‘compliance determinations’– No plan to introduce sub-ADO/CDO for suppliers


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Specialty Service Suppliers

• Consideration of authority recognition of suppliers of specialized services to the aviation industry– Have unique expertise and testing capability– Supply to multiple applicants

• Examples – Flammability labs– Materials labs– Environmental and HIRF/Lightning test facilities


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Specialty Service Suppliers• EASA

– Open to possibility of recognizing suppliers of specialty services

– Sub-tier DOA would be applicable, if specialty service supplier has the capability to make compliance determinations

• TCCA/FAA– Open to possibility of recognizing suppliers of

specialty services (e.g. test laboratories)– No plan to introduce sub-ADO/CDO for any

suppliers


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Suppliers• Things to consider going forward:

– International implications– Competition driving need to ensure a ‘level playing field’– Impact on safety– Alignment with Accountability Framework– Establishing a basis in regulation– Authorities/Industry role in Oversight– Responsibility for compliance– What is the resulting product – ‘compliance

determination’, ‘recognized data’ or something else? – Establishing standards and requirements


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Questions?

Documents

U.S./Europe International Aviation Safety Conference By: Martin Thieringer – TCCA, Roger Simon – EASA, Scott Geddie – FAA Date: June 4, 2008 “Global Safety