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Preliminary Analysis of Industry Questionnaire: Addressing Challenges in the DOA System

This preliminary analysis examines the responses to an industry questionnaire on the challenges and future needs of the Design Organization Approval (DOA) system. It highlights industry ideas for improvement, including recognition of sub-contractors, novel concepts of certification, and industry self-certification.

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Preliminary Analysis of Industry Questionnaire: Addressing Challenges in the DOA System

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  1. PRELIMINARY ANALYSIS OF RESPONSES TO INDUSTRY QUESTIONNAIRE David Haddon Initial Airworthiness EASA Rulemaking Directorate

  2. Background WHY A QUESTIONNAIRE? • Acknowledgement that moving from JAR 21 to Part 21 (EC 1702/2003) have created some difficulties in some areas • Recognition that industry practices are changing • To seek out stakeholders views and to build on previous discussions to generate specific ideas • To listen to our stakeholders and to help ensure that regulations are developed that are appropriate and proportional to the safety risks

  3. Industry Response • 3 Associations • Aerospace & Defence Association of Europe (ASD) • European Council of General Aviation Support (ECOGAS) • European Glider Manufacturers Association (EGM) • 23 DOA holders • 16 Non-DOA holders Total 42 responses

  4. The Good News (Advantages of the current DOA system) • Clear lines of responsibility • The level of safety remains very high • DOA privileges to classify and approve compliance with EASA standards • DOA has contributed to an increased level of trust between holders and EASA • International recognition

  5. Stakeholder Satisfaction Only 26% of those who responded said they were satisfied with the current DOA concept. Reasons given for dissatisfaction included: • Part 21 is seen as being inferior to JAR-21/ National system • Loss of “JB” approval • Framework does not cater for a consortium of major companies • DOA system is not suitable for GA and recreational aircraft manufacturers.

  6. Meeting Future Needs 83% of respondents (92% of those who expressed an opinion) felt that the existing DOA will be ineffective/uneconomic in meeting the future needs of Industry. Areas for improvement include: • Recognition and distribution of responsibilities to suppliers and “centres of excellence” • Workshare between the EASA and DOA holders • De-regulation for GA and recreational aircraft • Etc, etc.

  7. Meeting Future Needs:Some Industry Ideas • Allow TC/STC holders to distribute responsibilities and privileges. • Harmonisation of design assurance rules. • Recognition of industry standards (e.g. EN 9100) • A single design and production approval. • Enhanced EASA oversight of NAAs. • New and/or extensions to DOA privileges • Simpler rules for GA and recreational aircraft

  8. Meeting Future Needs: Recognising Sub-Contractors 67% were in favour of recognising design expertise at sub-contractor/supplier level. • Against were manufactures of non-complex aircraft and equipment, who retained expertise in-house. • A TC/STC applicant will generally not have expertise for the complete design. • Already today, the TC applicant relies on sub-contractors/suppliers to support compliance declarations.

  9. Recognising Sub-Contractors PROS (for) • Serves the needs of industry. • Specialist firms can retain their expertise and know-how. • Post TC work would be more efficient if done by the OEM. • Aid acceptance of European parts in a global context. • Aid standardisation of implementing rules. CONS (against) • Privileges could only be granted if associated with a dedicated CS. • Must not lead to uncertain or ambiguous interfaces and responsibilities. • Determination of the effect a system change has on an aircraft could not be made without the TC holder, even for the approval of minor mods.

  10. Meeting Future Needs:Novel Concepts of Certification A modular approach to certification • 31% generally in favour - 40% against • Those against were generally the large aircraft/engine TC holders and existing DOA holders, who felt that this would blur responsibilities and create system integration issues. • Extension to ETSO? • Small aircraft manufacturers would like to keep both options open.

  11. PROS (for) Clearer allocation of responsibilities/liabilities. TC applicant could accept certification documents and data without further verification. PMA type approval could help European industry to compete. For GA applications, “plug and play” equipment could have a unique approval. Any generic system with potential multiple applications could be considered. CONS (against) Responsibility should be retained in a single org. Experience shows that interfaces are problematic. An aircraft is not a sum of its parts. Developing cert. specs. would be a huge effort. Integration of parts could result in dual certification. Each approval would add additional costs. Most systems are adapted for each specific aircraft. Recognition outside Europe. A modular approach to certification

  12. Meeting Future Needs:Novel Concepts of Certification Industry self-certification • 31% generally in favour - 43% against • GA and DOA holders (modification/repair), generally in favour, Large aircraft/engine TC holders and suppliers, against. • Could be linked to experience or Agency confidence. • A distinction should be made based on the criticality of the item. • Adopt a system of “Designees” similar to the FAA ODA system.

  13. Industry Self-certification PROS (for) • Product developer is fully responsible/accountable. • Existing DOAs could focus on integration issues. • Could formally adopt AS EN 9100. • Would reduce admin., provide flexibility and lead to cost/time savings. • Clearer planning of resources and activities would be possible. CONS (against) • Recognition by foreign authorities? • Decrease in the level of safety? • Loss of Agency expertise. • Experience with other self regulating bodies is poor. • Loss of uniformity. • Insurance? • Introduction of new technology/processes requires independent technical oversight.

  14. Meeting Future Needs:Novel Concepts of Certification 3rd Party Certification • Could be on a voluntary basis. • 3rd party organisation would need to be cheap, independent and constant. • Use existing NAAs in this role, subject to control.

  15. 3rd Party Certification PROS (for) • Could increase safety and reduce costs by enabling a greater focus on safety rather than continually preparing for different audits. • Would harmonise with FAA ODA. CONS (against) • Will add another tier of bureaucracy. • Issues of finance may cloud cert. requirements. • A single independent body should be retained. • International recognition? • Impact of insolvency and loss of traceability of 3rd party organisation. • Aviation safety is a state function to be controlled by the people, for the people.

  16. Questions Please feel free to ask any question

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