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TGL No. 36 Approval of Electronic Flight Bags (EFBs)

TGL No. 36 Approval of Electronic Flight Bags (EFBs). Georges Rebender – JAA Operations Director. Presentation Overview. Background Consultation Comment Response Summary Recommendation. Background.

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TGL No. 36 Approval of Electronic Flight Bags (EFBs)

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  1. TGL No. 36Approval of Electronic Flight Bags (EFBs) Georges Rebender – JAA Operations Director OST 04-2, Helsinki

  2. Presentation Overview • Background • Consultation • Comment Response • Summary • Recommendation OST 04-2, Helsinki

  3. Background • Preparation of a Temporary Guidance Leaflet for Approval of Electronic Flight Bags has been in work for a year • Coordinated by members of the Airbus JOEB team • Incorporates experience gained on: • Airbus Step 1, A340-600 and A380 platform approvals • Validation of Boeing 777 EFB • National approvals OST 04-2, Helsinki

  4. Background • Contains airworthiness and operations guidance material • Based closely on FAA AC 120-76A, but with differences reflecting the scope of JAA Ops and airworthiness processes • Also reflects lessons learnt and new applications not considered when the FAA AC published OST 04-2, Helsinki

  5. Background • Airworthiness content of TGL now subject of EASA approval (responsibility taken from CST) • EASA does not have an equivalent section for TGL material so title reference may change, probably AMC-20 series • Will have to await EASA formal process but should not prevent advance publication in JAA Admin & Guidance Material (JAR-OPS) OST 04-2, Helsinki

  6. Consultation • Progress reports made to OST (October 2003) and CST (December 2003) • Mature draft presented to both Sectorial Teams end of February 2004 • Also circulated widely to industry and certification teams closely involved with EFB approvals e.g., JAA Avionics CSP, FAA, Boeing, JAA A380 and Dassault certification teams OST 04-2, Helsinki

  7. Comments • Comments received from: • CAA NL, LBA, DGAC-F, Airbus, JAA A380 certification team members • IFALPA, GAMA, CAA Denmark OST 04-2, Helsinki

  8. Comment Response (1) • Confusion over the difference between Type C software applications and a “normally” certified system • Type C definition removed • In fact the airworthiness approval process was the same and confusion came from trying to work out the differences between the two i.e., none • Questionable whether Type C was ever really an EFB application • Consulted with FAA and they agree, but not changing AC 120-76A at this time OST 04-2, Helsinki

  9. Comment Response (2) • Involvement of airworthiness authorities in Type classification and assessment of some Type B software applications • Stems from concerns that some Type B software applications are close to normal aircraft functions and should in fact be fully certified • Confusion between the two • Section 6.2 and Appendix B revised OST 04-2, Helsinki

  10. Comment Response (3) • Treatment of FCOM and MEL • Distinction between without contextual access (Type A) and with contextual access (Type B) • Class 2 device mounting requirements • Reflecting actual experience where control yoke installation resulted in pilot unable to attain full and free movement • Consistent with TCA policy OST 04-2, Helsinki

  11. Comment Response (4) • Suggestion to exclude non-commercial operations as per FAA Part 91 • TGL only guidance information • References only include JAR-OPS 1 and 3 paragraphs, but could include Part 23 aircraft, so implicitly non-commercial operations excluded • Classification of moving map/chart displays for in-flight and on-ground applications • Clarification provided in Appendix B • Consistency with FAA policy OST 04-2, Helsinki

  12. Comment Response (5) • Application of 25.1309 • Restricted to software applications requiring airworthiness assessment • Clarification now provided regarding what requires airworthiness assessment and what does not • Typically on Class 3 systems • Airworthiness authorities will have to apply judgement in terms of “safety effect” and suitability for hosting on COTS platform e.g., limitations of use, operational mitigations OST 04-2, Helsinki

  13. Comment Response (6) • Potential confusion in the use of term Administrator • Changed to EFB Administrator and added to Definitions • Suggestion to move performance calculations from Type B to Type A • Rejected • Based on JOEB experience concerns over accuracy of these software applications and consistency with AFM data OST 04-2, Helsinki

  14. Comment Response (7) • JAA Leaflet more restrictive, why not just reference AC 120-76A • Rejected • Whilst much of what included in the leaflet goes beyond the AC, JAA processes are different and inclusion of airworthiness authorities involvement and administrator responsibilities considered consistent with the level of safety and configuration management/quality control the JAA would expect to see OST 04-2, Helsinki

  15. Comment Response (8) • FAA/JAA harmonisation - suggested inclusion of a difference report • Rejected • JAA provided underlined text in JAR-25 to show differences from FARs but in general has not issued difference reports for Operations Rules, Advisory or Leaflet material • FAA do not provide a reciprocal service • FAA fully consulted during drafting and have raised no objections OST 04-2, Helsinki

  16. Comment Response (9) • Expectations for CRM and workload assessment • Section 7.7 revised, LOFT session added • Further elaboration may be required following JOEB/JAA experience but would not expect advisory material to be prescriptive • There needs to be a “common sense” approach depending on EFB system and software applications and intended use OST 04-2, Helsinki

  17. Comment Response (10) • Own ship position • Policy consistent with FAA, see Appendix B • Controlled PED, Lithium Batteries, importance of correct classification of software application • Considered an improvement over current guidance and largely in response to questions from industry and certification teams OST 04-2, Helsinki

  18. Comment Response (11) • Requirements for an Operational Evaluation Test • Section 7.7 re-written to distinguish between when initial retention of paper required, versus commencement of operations without paper back up • Suggest an airworthiness evaluation of flight critical data • Airworthiness involvement clarified in Section 6.2 and Appendix B • Requirements for duplicate EFB system • Addressed by operational risk analysis Section 7.1 OST 04-2, Helsinki

  19. Summary • Defining the EFB approval process is not easy • Extent of airworthiness approval activity is linked to EFB hardware Classes and to EFB application Type • The TGL has attempted to define the boundary between airworthiness and flight operations approval taking into account existing JAA roles and responsibilities OST 04-2, Helsinki

  20. Summary • It is clear that EFB approval process has led to a change in working practices • Requires a much more integrated approach between airworthiness and flight operations specialists working within the JOEB OST 04-2, Helsinki

  21. Recommendation • The JAA Operations Sectorial Team are: • Invited to note the changes to Final Draft of TGL No. 36 • Invited to note the Comment Response prepared through this presentation • Agree to the publication of TGL No. 36 in Section 4/Part 3 (JAR-OPS) of JAA Administrative & Guidance Material OST 04-2, Helsinki

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