Professional Documents
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FAR 23 Part 23
FAR 23 Part 23
A Report from the
14 CFR Part 23 Reorganization Aviation
Rulemaking Committee
to the
Federal Aviation Administration
Recommendations for increasing the safety of small general aviation
airplanes certificated to 14 CFR part 23
June 5, 2013
Prepared for
Manager
Small Airplane Directorate
Federal Aviation Administration
Kansas City, MO
TABLE OF CONTENTS
Letter from the ARC Co‐Chairs
Executive Summary
1.0 Introduction
2.0 Background
2.1 ARC Structure and Scope
3.0 Working Groups
3.1 Regulatory Structure
3.2 Type Certification / Production Certification
3.3 Alterations / Modifications
4.0 Regulatory Structures Working Group – Recommendations
4.1 14 CFR part 23 Revision and Reorganization
4.2 Part 23 Airworthiness Design Standards
5.0 Type Certification / Production Certification Working Group – Recommendation
5.1 FAA Conformity
5.2 Airplane Manufacturer Minor Change Approval Process
5.3 Applicant Showing Only Process
5.4 Use of Video Recording in Testing
5.5 Production Manual
5.6 Design Organization/Production Organization Handbook
6.0 Alterations / Modifications Working Group – Recommendations
6.1 Facilitation of Systems & Equipment
6.2 Critical Information for Alterations & Maintenance
6.3 14 CFR Part 43 Preventative Maintenance
6.4 Primary Non‐Commercial Category
7.0 Certification Cost/Benefit Overview
7.1 Regulation and Standard Changes
7.2 Cost Estimates
7.3 Certification Plan Acceptance
7.4 FAA Sequence List
7.5 Foreign Validation Costs
7.6 Summary of Costs
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8.0 Summary
TABLE OF APPENDICES
Appendix A – Team Members
Appendix B – Acronyms
Appendix C – ARC Charter
Appendix D – CPS Report Executive Summary
Appendix E – 14 CFR Part 23 Recommended Revision Language
Appendix F – Type Certification / Production Certification Working Group Papers and
Proposals
Appendix G – Alterations / Modifications Working Group Papers and Proposals
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LETTER FROM THE ARC CO-CHAIRS
June 5, 2013
The Part 23 Reorganization Aviation Rulemaking Committee (ARC) has completed its analysis of part 23,
Title 14 of the Code of Federal Regulations (CFR) including the 2009 Part 23 Certification Process Study
recommendations to restructure the regulations based upon airplane performance and complexity and
to write regulations in a broad, general, progressive manner. Currently, part 23 is prescriptive in nature,
written to address out-of-date technologies and structured based upon broad assumptions, including
airplane weight and propulsion type, which are becoming less accurate and more constraining as time
progresses. The ARC also strived to assure recommendations would be acceptable to international
regulators and the global industry to reduce the complexity and costs related to foreign validation.
The Part 23 Reorganization ARC presents its recommendations in this final report. The ARC members
deliberated, collaborated and used their extensive first-hand experience with the aircraft certification
process to produce recommendations that reorganize part 23 to maintain performance based safety
requirements in part 23 complemented by acceptable consensus standards which provide more detailed
means of compliance. The recommendations in this report meet the objectives of the ARC and include
comprehensive reorganization of the design requirements. Additionally, it recommends changes to
production, alterations and continued airworthiness regulations, orders, and policies to support our goal
of twice the safety at half the cost.
On behalf of the Part 23 Reorganization ARC, it has been an honor to be selected to undertake this
important initiative. We are confident the ARC recommendations, upon implementation as a complete
package, will result in safer new airplanes, improvements in the safety of the existing fleet, and
significant reduction of certification costs. We have written this recommendation in a manner so the
new part 23 regulations can stand the test of time beyond the next 20-years. Furthermore,
implementation of the ARC's recommendations will serve to revitalize the health and safety of general
aviation on a global scale.
Sincerely,
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EXECUTIVE SUMMARY
The FAA Small Airplane Directorate has been tasked with improving the safety of general aviation
airplanes to be consistent with public expectations for the range of vehicles and operations covered by
Title 14 of the Code of Federal Regulations, part 23. Over the past four decades, the health and vitality
of the general aviation industry have faded significantly. The health and safety of general aviation are
inseparably linked. A healthy industry drives a cycle of pilot proficiency, improved training, increased
investment in new technology and enhanced safety. Unfortunately, public interest in general aviation is
shrinking due to a lack of new products, high costs and lack of perceived value. These realities are
highlighted by the 40‐year old average age of the general aviation fleet and the steady loss of 10,000
private pilots each year over the last decade.
In order to improve general aviation safety and make it vibrant again, the FAA Administrator chartered
the Part 23 Reorganization Aviation Rule Making Committee (ARC) in August 2011. Section 312 of the
Federal Aviation Administration (FAA) Modernization and Reform Act of 2012 (Public Law 112–95)
requires the FAA Administrator, in consultation with the aviation industry, to conduct an assessment of
the aircraft certification and approval process. The
Act specifically addressed updating airworthiness
requirements, including implementing
recommendations in the Administration’s report
entitled “Part 23‐‐Small Airplane Certification
Process Study.”
This ARC was a follow‐on to the Part 23‐‐Small
Airplane Certification Process Study (CPS), but the
committee’s tasks were not limited to
implementing the recommendations from the
FAA’s Part 23 CPS report.
The Part 23 Reorganization ARC recommendations
are comprehensive and unlike recommendations from many other ARCs, are not stand alone. The
following recommendations are considered a package. Although partial implementation of these
recommendations may offer modest improvement in some areas, any one recommendation alone or
combination of recommendations short of the full package will not provide the transformational
improvements in safety or reductions in cost that are desperately needed and driving this effort.
METHODOLOGY
The ARC established a committee of members from the global aviation community and the international
aviation airworthiness authorities. FAA participation and support included all affected lines‐of‐business
from design and production certification to continued airworthiness and alterations. Where necessary,
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the committee set up specialized work groups that included at least one committee member and invited
subject matter experts from industry and government to participate.
The ARC formed three working groups and some of these working groups had subgroups including:
Regulatory Structure Working Group
o Flight Test Subgroup
o Propulsions Subgroup
o Structures Subgroup
o Systems Subgroup
Type Certification & Production Working Group
Alterations & Maintenance Working Group
o Non‐Commercial Use Subgroup
The above subgroups developed recommendations that were briefed to the ARC as a whole. Following
these briefings, the ARC as a whole discussed the recommendations and once the discussion was
completed, the ARC conducted a hand vote to accept or reject recommendations. All recommendations
included in this report had overwhelming majority agreement.
The ARC recommendations are in the area of the design safety regulations for new and existing
airplanes (part 23 and policies), in the area which dictates certification process (part 21 and policies) and
in the area of continued airworthiness rules and policy (part 43 and policies).
Small Airplane Certification Regulations Summary
Initially the ARC planned to follow the CPS recommendation for tiering part 23 in the CFR’s. This
approach was rejected by the ARC, which included the foreign authorities. The reason for its rejection
was the realization that tiering the requirements using current ideas for performance and complexity
would eventually lead us to many of the same challenges we face today with weight and propulsion
divisions ‐‐ tiers would become less accurate and more constraining as time and technology progress.
The ARC looked at how outdated design requirements and certification regulations affect both initial
certification and alteration processes. The prescriptive and outdated rules are the major barriers to
installing safety‐enhancing modifications in the existing fleet and to fielding newer, safer airplanes
because they inhibit innovation. The ARC also looked at harmonization of requirements between
authorities that could improve safety and reduce costs. Adopting top level, safety based CFRs that
facilitate international harmonization, coupled with internationally accepted airworthiness design
standards, could play a significant role in cost savings and enabling safety enhancing equipment
installations. These standards will be reviewed and voluntarily accepted by the authorities in
accordance with a process established by them. Some authorities may reject all or part of a standard,
but the intent is to have full civil authority participation in the creation of airworthiness standards.
The ARC recommendations address the reorganization of part 23 to maintain performance based safety
requirements while moving prescriptive methods and technology dependent aspects from the CFRs into
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Airworthiness Design Standards or other guidance. These new regulations make the retrofit of new
technology more straightforward without the need for special conditions, equivalent methods of
compliance or exemptions, and they also remove barriers to bringing new, safer airplane designs to
market with similar benefits. The time and expense to the FAA and the industry of working in an overly
prescriptive and outdated regulatory environment must be removed to improve the safety and health of
GA in a meaningful way.
The recommended changes to part 23 assure the rules maintain the proper, performance based safety
requirements while detailed, technology specific methods are moved to Airworthiness Design Standards
or other guidance that has the agility to keep up with technological innovation. The ARC recommends
these prescriptive methods to achieve the safety intent of part 23 be contained in consensus standards
which the FAA will accept as methods to achieve the requirement of part 23. The international aviation
industry, including representatives from the world’s leading aviation authorities agree with this
approach and that clear paths to compliance for a multitude of technologies are available through the
consensus standards approach.
Recommendations for Changes to Small Airplane Certification Regulations)
1. Retain the enforceable, performance based safety objectives in part 23 while moving the
prescriptive and technology dependent provisions or methods of compliance out of regulatory
text and into FAA accepted consensus standards.
2. Ensure the enforceable safety objectives of part 23 are written broad enough to address the full
range of part 23 products and will remain applicable to foreseeable and unforeseeable
technologies over the next 20 years.
3. Utilize FAA accepted consensus standards as methods of compliance to the safety objectives
contained in the new part 23 and maintain a process for applicants to propose methods which
are not contained in consensus standards.
4. Assure that accepted consensus standards include methods of compliance appropriate to the
broad spectrum of airplanes and technologies governed by part 23.
5. Work with the international regulatory community on the part 23 reorganization
recommendations to assure there is a globally acceptable approach to certifying part 23
airplanes.
6. Prioritize this rulemaking to assure that the health and safety improvements of general aviation
can be realized as soon as possible.
7. Develop a means to track information on certification basis for both new and legacy airplanes to
facilitate alterations and maintenance throughout the airplane’s service life.
8. Apply the principles of double the safety at half the cost also be applied to the existing fleet of
general aviation aircraft as well as new production aircraft. Cost effectively expediting
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alterations involving non‐required safety enhancing equipment (such as the incorporation of
angle of attack indicators) is critical.
9. Ensure that guidance, policy, and agency culture align so as to support the new regulations and
fleet‐wide safety improvements.
Note: The purpose, scope, and suggested wording for the new rules have been included in
Appendix E.
Certification Process Summary
In addition to reviewing the part 23 regulations and their
effect on the certification costs and safety of the general
aviation fleet, the ARC created the Type Design and
Production Certification Working Group to review the
certification processes related to 14 CFR 21.The Type Design
and Production Certification Working Group focused on the
certification processes that have significant impact on
certification costs. These processes are largely driven by
part 21 and the associated part 21 FAA Orders and policies.
For the part 21 requirements evaluated, the group
determined the current part 21 requirements were not
significant cost drivers, but the Orders written by the FAA
and for the FAA that have been applied to industry are
significant cost drivers that have not kept pace with technology and do not allow industry to utilize more
efficient processes. The changes described in this section, section 3 and recommended in section 5 do
not require any changes to part 21 and could be accomplished quickly through:
Issuance of policy papers,
Relatively minor changes to existing Orders to allow alternative processes,
Issuance of new Advisory Circulars, or
Acceptance of aviation design standards addressing the issue.
Recommendations for Changes to Certification Process
1. Align the processes for demonstrating compliance and producing small airplanes with the
complexity of the product being produced. This can be accomplished in the short term by the
FAA developing or recognizing a design & production organization handbook that specifies the
minimum content for an entry‐level product producer. As currently envisioned, the handbook
could be structured so it could expand as a company grows. In addition, the Design
Organization/Production Organization Handbook for a mature company producing multiple
products could satisfy all of the requirements for an Organization Designation Authorization
(ODA) manual under 14 CFR 183, Subpart D.
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2. Standardize configuration management process as an alternative to the traditional conformity
processes. This recommendation should be coordinated with the FAA’s Safety Management
System (SMS)/Part 21 ARC currently underway.
3. Standardize the minor change process through the issuance of guidance material or policy. This
recommendation should be coordinated with the FAA’s SMS/Part 21 ARC currently underway.
4. Make better use of applicant showing of compliance in areas of low risk and the FAA develop
guidance material and policy to standardize this activity. This recommendation should be
coordinated with the FAA’s SMS/Part 21 ARC currently underway.
5. Increase the use of remote video for test witnessing by issuing policy and guidance in this area.
This recommendation should be coordinated with the FAA’s SMS/Part 21 ARC currently
underway.
Part 43 Summary (Continued Operational Safety Certification)
While the design, certification and production of an airplane are important to safety, the continued
airworthiness of an airplane can only be assured by proper maintenance. As the current fleet of part 23
airplanes averages 40‐years old, the ability to conduct proper and cost effective maintenance is of
critical importance. The part 23 ARC Airworthiness and Maintenance Working Group reviewed current
maintenance inconsistencies, especially in the area of preventative maintenance, which should be
addressed by the FAA.
Recommendations for Changes to Continued Operational Safety Certification
1. Review 14 CFR part 43 preventative maintenance items to both clarify the current capabilities
and to create a system whereby the FAA can expand these capabilities without the need for
rulemaking.
New Aircraft Certification Category
At the FAA’s ARC kick‐off meeting, the FAA challenged the ARC members to be bold, creative, and non‐
traditional. A proposal for a new aircraft category similar to the Canadian Owner Maintenance
Category, but with some significant safety enhancements reflects that challenge.
Recommendation for New Category
1. The ARC recommends the FAA adopt a new category of airworthiness certificate that would
align maintenance and alteration requirements of older aircraft, not operated for hire, to a level
more appropriate for a privately owned vehicle.
Summary
Upon implementation, the ARC recommendations will result in safer new airplanes and improvements in
the safety of the existing fleet through the ability to more easily and rapidly incorporate new
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technology that can reduce pilot workload, provide better situational awareness, and afford other safety
enhancements. It also has the potential for a significant reduction of certification costs through reduced
need for Special Conditions, Equivalent Level of Safety (ELOS) findings, or other activities.
The implementation projections of twice the safety and half the cost are based on these
recommendations being implemented as a complete package. Safety, harmonization, and innovation
all rely on a revision to part 23 as well as the development of accompanying airworthiness design
standards. The cost savings and safety improvements necessary for new airplane certification, as well as
the improved safety of the existing fleet, also depend on the implementation of the parts 21 and 43
recommendations in this report.
With the new part 23 and airworthiness design standards in place, it will be easier for FAA staff to
determine the critical elements of a project and focus their time and resources to things that need more
oversight. It will help the FAA reduce their workload and focus their attention on safety and more value
added functions.
These recommended changes to part 23 are designed to make part 23 more stable, require less
maintenance, reduce cost for the FAA, and stand the test of time for at least the next 20 years.
Furthermore, because of the international nature of this ARC, the implementation of the ARC’s
recommendations will serve to revitalize the health and safety of general aviation on a global scale.
Finally, in addition to the technical solutions proposed in this report, the cultural issues involved must be
addressed with both the FAA and the applicant. Many of the recommendations in this report require
changes to long standing ways of doing business that must change if the recommendations in this
proposal are to succeed. This will require training and a willingness to accept cultural change from both
the authorities and industry so that new processes are accepted. Without a willingness on both sides to
make changes, the chances of success are greatly diminished.
NEXT STEPS
Following are recommended next steps:
1. Stand up an FAA Small Airplane Directorate group to develop new part 23 language based on
the suggested language and the intent expressed in this report.
2. Provide the white papers presented in this report to the appropriate FAA organizations and the
part 21 ARC to determine the feasibility of implementing the proposals.
3. Work with industry in prototyping and implementing some of the proposals.
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1.0 INTRODUCTION
This report will present the results of the 14 CFR Part 23 Reorganization Aviation Rulemaking Committee
(ARC). The ARC’s main objective was to propose changes to part 23 that would improve safety and
reduce certification costs for new airplanes. Over the course of the first few meetings, the ARC
determined that including improvements to the existing fleet was an absolute necessity to get the
desired safety increase in a reasonable timeframe.
The approached taken by the ARC serves the goal of improving general aviation safety by:
1. Streamlining of part 23 to make new technology integration easier and more cost effective, and
2. Adding flexibility to the certification process by utilizing consensus based Airworthiness Design
Standards as acceptable means of compliance, giving it a level of nimble adaptability never
before seen.
To reduce costs the ARC looked at both initial certification costs and costs for making modifications to
field aircraft. These costs are the barriers to both new airplanes and installing safety‐enhancing
modifications in the existing fleet. The ARC also looked at how harmonization between authorities
could improve both safety and reduce costs.
The ARC team members were all people with significant experience in both the certification and
maintenance areas and thoroughly evaluated the proposals brought forth in this report. The proposals
represent a significant change in the organization of the certification requirements and the
accompanying processes aimed at achieving improved safety and reduced costs to certify and maintain
general aviation (GA) aircraft.
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2.0 BACKGROUND
Historically, the FAA has hosted regulatory reviews for part 23
about every 10 years. The two most recent part 23 reviews were
performed in 1974 and 1984. In 2008, the FAA initiated the
current, on‐going review process by starting with the Part 23
Certification Process Study (CPS).
The CPS team reviewed part 23 and Civil Air Regulations, part 3
(CAR 3) airplanes (looking at the whole lifecycle) and made
recommendations based on current and anticipated products.
Specifically, the team’s challenge was to determine the future of
part 23, given today’s current products, and anticipated products
twenty years from now. This forward thinking led to one of the
major recommendations from the study: reorganize part 23
using “performance and complexity” criteria instead of today’s
“aircraft weight and propulsion type” criteria. When the Civil
Aeronautics Administration adopted CAR 3 standards, airplane
construction methods and operations were narrowly focused;
likewise, their performance parameters were narrow. As aviation technology progressed, construction
methods, performance, and complexity evolved. The normal, utility, acrobatic, and commuter
categories have seen remarkable advances in capability in the last few years that were unanticipated by
the current regulations.
The CPS team’s objective was to assess the adequacy of the various operations and airworthiness
processes currently in place throughout the airplane’s service life and, if appropriate, to identify
opportunities for process improvements. The team has:
Made recommendations for long‐term improvements; and
Encouraged implementation of near‐term, easy to address improvements.
Accident data historically shows that human performance that includes operators and maintenance
personnel contribute to 70 to 80 percent of GA accidents. Given that the GA fleet comprises over
200,000 airplanes, the majority of the CPS recommendations focused on keeping the existing fleet safe.
This includes upgrading and maintaining airplanes with better systems, newer avionics (for NextGen,
navigation, information, or redundancy), and the latest safety equipment (e.g., ballistic parachutes and
inflatable restraints). Requirements that make it easier to install safety‐enhancing equipment in older
airplanes will be interconnected to part 23 revisions. This interconnection concept was carried over into
the public meetings that took place in 2010, the year following the release of the CPS.
The objective of these meetings was to share the findings/recommendations from the certification
process study and ask the public for feedback. The purpose of this feedback was to confirm and/or
challenge the findings/recommendations and add issues that might have been overlooked during the
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study. Overall, the feedback was supportive of the CPS recommendations and in some cases augmented
the findings. One significant difference between the CPS
findings and the public feedback was that the public
focused on the need to address the light/simple airplanes
in part 23. Over the past two decades, part 23 has been
shifting in complexity towards complex, high
performance airplanes, which has placed increasingly
unnecessary burden on simple airplane certification.
Therefore, the public focus was on reducing simple
airplane certification costs and time burden through
resetting requirements to an appropriate level based on
safety risk. The safety risk for most simple, proven
airplane designs is typically low. There was very little feedback regarding the high performance end of
part 23.
Section 312 of the Federal Aviation Administration Modernization and Reform Act of 2012 (Public Law
112–95) requires the FAA Administrator, in consultation with the aviation industry, to conduct an
assessment of the aircraft certification and approval process. The Act specifically addressed updating
airworthiness requirements, including implementing recommendations in the Administration’s report
entitled “Part 23‐‐Small Airplane Certification Process Study.”
In Aug, 2011, the Administrator chartered the 14 CFR Part 23 Reorganization Aviation Rulemaking
Committee. The committee’s tasks included, but were not limited to implementing the
recommendations from the FAA’s CPS report for reorganizing part 23. This final report responds to the
Administrator’s charter and addresses the requirements of the FAA’s Modernization and Reform Act of
2012.
2.1 ARC STRUCTURE AND SCOPE
The committee consisted of members from the Federal Aviation Administration including members from
the Small Airplane Directorate (ACE‐100), Aircraft Certification (AIR‐100 and AIR‐200), and Flight
Standards Service (AFS‐200, AFS‐300, and AFS‐800). It also consisted of about 50 members,
representing manufacturers of part 23 airplanes, part 23 equipment, light sport airplanes, aviation
associations, and foreign aviation authorities. Federal officials and foreign authorities served as
observers. However in practice, the views, contributions, and opinions of all participants were
considered in the development of the recommendations.
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Each member or participant on the committee represented an identified aviation community segment
with the authority to speak for that segment. To promote discussions and different perspectives,
membership on the committee was open to a broad range of parties. Active participation and
commitment by members was essential for achieving the committee objectives. The committee invited
additional participants as subject matter experts to support specialized work groups. For additional
information see the ARC Charter in Appendix C.
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3.0 WORKING GROUPS
The 14 CFR Part 23 Reorganization ARC consisted of three primary working groups:
The Regulatory Structure Working Group performed the primary review of the part 23 code and made
recommendations for the future structure and organization of this code as well as how these regulations
can utilize international consensus standards in the future. The Regulatory Structures Working Group
also had four subgroups that addressed propulsions, flight test, structures, and systems areas.
The Type Certification and Production Certification (TC/PC) Working group looked into the process of
performing certification and production oversight (part 21) where part 23 aircraft have unique
characteristics that could provide for more efficient and streamlined application of these methods.
The Alterations and Maintenance (A&M)Working Group (AMWG) addressed how existing and future
aircraft can be better maintained and altered under the future structure of a proposed part 23.
The recommendations from these working groups are considered a package. The ARC objective of twice
the safety and half the cost rely on these recommendations being implemented together. The chances
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of success are greatly diminished or eliminated altogether if these recommendations are implemented
in a piecemeal approach.
3.1 REGULATORY STRUCTURE
3.1.1 Background
Part 23 today has grown out of the initial set of design standards which began back in the 1930’s. As
time progressed, the relatively simple regulations in CAR 3 evolved into increasingly comprehensive
rules to address safety issues that emerged with the growing number of aircraft in service, as well as the
increasing complexity due to incorporation of new technologies into aircraft. These new rules were only
applicable to new aircraft entering the market or significant changes to existing aircraft that required
accepting the latest rule. Any issues with existing aircraft in the field were dealt with through ADs or
changes to operational rules.
Part 23 needs to be able to
capture both simple aircraft as
Majority of current well as future developments
GA aircraft are without rewriting the code
Requirements / complexity
certified to CAR3
Explicit requirements, This gap needs to be recaptured
specified in regulatory code to assure that basic Part 23
aircraft have the appropriate
means of compliance.
Figure 1: Evolution of Part 23 Regulations
The regulations moved away from the simple basis of CAR 3, effectively leaving a gap in the bottom part
of the certification spectrum (Figure 1). However, the reality is that most aircraft flying today are based
on CAR 3 certification and would not be able to be certified under the current part 23 rules without
significant additional costs. Yet these aircraft have proven an acceptable level of safety to fly over the
last 50 to 60 years.
The structure and complexity of the current regulations also inhibits rapid introduction of new
technologies that can enhance safety not only in new but also in existing aircraft. By incorporating very
specific technical requirements into part 23, it has become difficult to introduce new technologies, as
this requires rulemaking, which is a long tedious process.
The consequence of today’s situation is that the certification costs are so high, entry level part 23
airplanes have little or no, chance of recovering the development/certification costs. This has two other
side effects: first, the users will tend to retain or purchase older airplanes that are less expensive and
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second, as it is hard to introduce new safety enhancing technologies into the current production aircraft
and the existing fleet, the safety level of general aviation aircraft does not improve. Newer aircraft with
advanced technology (that are possibly safer) are not introduced and older aircraft cannot be easily
upgraded. This has already had a negative impact on general aviation aircraft and will continue to hurt
general aviation significantly without substantive changes to the certification process.
In order to improve the GA fleet safety and the health of the industry, the certification cost needs to
come down to allow more profitability and quicker introduction of safety enhancing features. Within
industry and the FAA there is a strong desire to recapture the simple and low cost certification process
previously used based on commonplace, proven engineering practices, requiring minimal FAA oversight.
3.1.2 Present State of Part 23
Part 23 is a large body of regulatory material that is complimented by a system of overlapping Advisory
Circulars (AC) and, to a lesser extent, industry standards from SAE, RTCA, etc. to lay out the means by
which an applicant complies with the safety requirements of part 23. A significant portion of the part 23
safety regulations prescribes design solutions which preclude manufacturers from finding more
economical paths to provide acceptable safety. AC’s provide interpretations of the regulations as well
as one acceptable means of compliance (MOC). In practice, it has been found that the MOC presented
in ACs have been treated as the only acceptable MOC, which again precludes manufacturers from
proposing a simplified MOC intended to show equivalent safety more economically. Both the safety
regulations within part 23 as well as the ACs are authored by the FAA and are historically revised
infrequently, much slower than the pace of advances in technology.
Figure 2 depicts the current structure and interdependence of the regulations and other FAA documents
and industry standards.
Figure 2: Current structure of regulations and standards
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Section 23.1309, System Safety, was recognized as an example of the evolution of part 23 away from the
original intent regarding simple, lower performance aircraft. Amendment No. 23‐14 added § 23.1309
and provided general guidance related to installed systems and the hazardous effects of failures. A
“minimization” approach was possible allowing manufacturers design freedom to find the most suitable
and feasible solutions to design. Later amendments were added in reaction to increasing complexity of
installed systems and increasing performance levels of part 23 aircraft. As a result, prescriptive analysis
methods evolved that have limited the manufacturers’ ability to implement new safety enhancing and
cost reducing technologies due to the difficulty defining an acceptable means of compliance within the
existing rules and guidance.
3.1.3 Analysis of Part 23 Requirements
The Regulatory Structure working group was tasked to review the current part 23 regulations and
determine how to implement part of the CPS recommendations regarding performance based standards
as well as dealing with the issues brought up during the public meetings on CPS in 2010. As discussed
above, it was clearly recognized that part 23 had become too prescriptive and broad in scope, thereby
making it difficult for new aircraft to enter the market or to modify aircraft to enhance their use or
safety.
During the first two ARC meetings, the Regulatory Structure Work Group focused on the activities in the
14 CFR Part 23 Reorganization ARC resulting from the findings in the first major area of study within the
CPS which recommended:
Reorganizing part 23 based on airplane performance and complexity versus the existing aircraft
weight and propulsion type divisions.
Rewriting certification requirements for part 23 airplanes as a top‐level safety regulation with
more detailed implementation methods defined by reference to the airworthiness design
standards and supported by other industry and government consensus standards.
The initial position of the ARC was to develop a new tiered structure that would address the need for
reduced certification cost for entry level airplanes, as well as provide a means to increase safety
significantly. As ideas were generated how to accomplish this, it became clear that the way the
regulations are structured needs to be reviewed and that just defining new tiers using broad aircraft
level differentiators would not address the underlying issues.
A high‐level analysis of part 23 reveals the following:
There are 4 categories of aircraft covering 0 to 19000 lbs., Maximum Take‐Off Weight (MTOW),
and 1 to 19 passengers
Part 23 has variations to a requirement based on certain factors such as weight, engine type or
number of engines.
Changes to part 23 through amendment 62 have addressed advancements in technology
(available features), lessons learned from accidents and other sources, occupant safety
improvements and the addition of the Commuter Category
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Part 23 consists of 1293 individual sub‐paragraphs (including the appendices)
While a few categories can be tied to airplane simplicity and/or performance levels, it is apparent that
most are applicable to general configuration of aircraft or features on aircraft as is shown in Table 3.1.
Table 3.1 – Part 23 Sub‐paragraph Applicability Table
Applicability of Part 23 sub‐paragraphs
# of paragraphs specific to:
811 All Aircraft Types
29 < 6,000 lbs.
29 Piston engines
6 Single Engine
28 Propellers
24 Multi‐engine
78 Commuter
13 > 6,000 lbs. & turbine
40 Turbine / Turboprop
10 Aerobatic
40 Seaplanes
17 Pressurized aircraft
168 Some other specific system or
feature
3.1.4 Part 23 Future State
The Regulatory Structure Working Group proposed a future state for the regulations slightly different
from that proposed by the CPS. Whereas the CPS proposed that the regulations be reorganized based
on performance and complexity, the Regulatory Structure Working Group proposed the performance
and complexity be addressed in the airworthiness design standards. The body of regulatory material and
airworthiness design standards will thus be characterized by the following:
1. Define regulations for safety, not design solutions that are assumed to achieve an acceptable
level of safety.
2. Define safety regulations in a way that is independent of aircraft performance level, complexity,
or configuration (i.e. they define what is expected and enforceable, but not “how”.)
3. The new regulations should be written such that new technology can be easily integrated into
aircraft while maintaining or improving safety for current or past technology with reduced, or at
least no increase, in certification costs.
4. The new regulations must not contain any prescribed technical requirements but rather suitable
safety requirements that will not require changing for the foreseeable future.
5. The new regulations must be general enough to apply across the full spectrum of part 23
airplanes.
~ 9 ~
6. Add scope and purpose in the rules to serve as guidance for showing new technologies
(standards) meet the objective. The regulatory text is often too high level to fully understand the
intent.
7. Make use of international airworthiness design standards for acceptable Means of Compliance to
the new part 23 as well as guidance material to assist in the use of the standards. These
standards would contain the requirements that would be based on performance level, aircraft
complexity, configuration, and operational use, i.e. tiering of the requirements.
The idea behind the proposed change of part 23 is to separate the safety‐oriented intent of the rule
from any acceptable technical implementation details and means of compliance. The intent of the rule
will remain in the regulatory text and the technical implementation requirements and means of
compliance will be captured in ADS guidance documents.
It is important to note that direct showing of compliance to the rules by applicants is still supported.
ADS and other identified acceptable means of compliance cannot, by law, add to or change rules.
Nevertheless, the availability of these supporting materials provide “one means, but not the only
means” of compliance will, as today, offer preferred compliance approaches.
The future structure and relationship between the new part 23 and ADS holding MOCs are shown Figure
3.
Future
Instructions
to FAA
ADS Guidance
Orders (MOC to the New Part 23) (MOC to Industry Standard)
Future Part 23
Industry Industry
Requirements Standards
Industry Industry
Standards
Recognizes Appropriate
Industry Standards Standards
Industry Industry
Standards
Future Part 23 Industry
Standards Industry
Standards
Federal
Register Standards Standards
Figure 3: Future state of regulations and guidance
This will allow the rule to remain stable into the future, yet have a mechanism that provides a way to
implement new, safety enhancing technology quickly without having to go through a lengthy rule‐
changing process.
The resulting body of safety regulations would require updating less frequently since updates driven by
technology changes can be reflected in the ADS. Those standards are maintained by industry experts
and regulatory participants and will be updated frequently as technology changes require, providing a
level of adaptability to technical change not present in today’s scheme. The referenced ADSs will also
establish definitions of airplane simplicity/complexity tier boundaries, relevant to their particular
technical areas and compliance approaches. Through collaboration on the ADS, the regulatory agencies
will become a party to the establishment of acceptable ADS.
~ 10 ~
As such, through the work of the Regulatory Structure Working Group it became clear that a complete
new approach needed to be taken to the definition of the regulations and the showing of compliance.
Figure 5 provides the high‐level concept of how the transition from the current part 23 to the new part
23 and the international standards will occur.
Figure 4: Transition to New Rule Structure
3.1.5 Regulatory Structure Working Group Output
The Regulatory Structure working group has reviewed the current set of regulations to determine the
safety intent of each. This involved review of the Notice of Proposed Rulemaking (NPRM) and Final Rule
Notices for prior amendments. From this understanding, the working group had discussions on how to
revise the language to capture the safety intent of the rule while addressing the underlying 14 CFR Part
23 Reorganization ARC charter.
Part of the exercise involved the grouping of the current regulations into areas where there was a
common set of safety intents. This was captured in a spreadsheet that can be sorted by new or old
regulations. The intent of the spreadsheet was to also provide the basis for the initial ADS. It provides a
cross reference table detailing which old paragraphs supplied the intent of the new requirements. This
spreadsheet can be maintained for as long as needed and will be available through either the FAA or a
standards organization.
~ 11 ~
As this was accomplished, new part 23 requirements were drafted and refined. The criteria for the new
part 23 language were as follows:
There was no effort to establish a specific number of CFR rules reduction in establishing the new
proposed rules, but to create the best balance of organization, clear requirements, broad
reaching for future applications, and ability to enforce the current level of safety in part 23.
Must be able to “stand on their own”
o The Type Certificate will be based on showing compliance to the rules (not the standard), so
the rules should contain enough content to be able to make a finding of compliance (i.e.
pass/fail) that will show the safety intent is met. However, as in today’s environment this is
not done independent of acceptable means of compliance.
o The Type Certificate Data Sheet (TCDS) will reference the rules only
Must drive the safety objective
o Safety objectives are captured in the rules
o Design requirements to achieve those are captured in the ADS
Should not prescribe a specific design solution or testing method to show compliance
o Keep the path open for future technologies without having to rewrite the rules
Shall use consistent philosophy, terminology and definitions across all paragraphs
o Airplane/aircraft, engine/propulsion, etc.
Should only contain “technical” requirements where specifically needed to drive the safety
objective
Should allow for all foreseeable future technologies
The result of this work was the creation of the draft regulations for the new part 23 and is
shown in Appendix E
3.1.6 International Standards Methodology
The second part of the process, after the new part 23 is published, is to create a new General Aviation
aircraft certification environment. It is important to note that the Regulatory Structure working group
saw the importance of having both the new safety intent regulations along with an accepted
airworthiness design standard to meet the goals identified by the FAA and the ARC charter. Each could
not exist without the other.
The chosen methodology for the development of the initial set of International Standards is to begin
with the current part 23 regulations and then modify them to reflect the requirements in the new part
23 regulations. These standards will also take into account input from the other Civil Aviation
Authorities (CAAs) involved to facilitate recognition by any regulatory authority as an acceptable means
of compliance. The new airworthiness design standard language should be drafted using the existing
part 23 language while removing redundant requirements and requirements that do not provide any
safety benefit. The language also should be revised such that the new regulations are not repeated in
the standard. A cross‐reference table, similar to the one mentioned above, will assist in determining
which part of a regulation is a standard, or part of a standard, and proved an addition link between the
regulations and standards.
~ 12 ~
It should also be noted that although the standards may be developed by a consensus body made up of
both industry and international authority representatives with the intent of harmonization, it remains
the responsibility of each authority to determine if a standard approved by the consensus body is
acceptable, either whole or in part to show compliance to their regulations. Each authority will
determine their means of acceptance to the standards upon approval by the consensus body.
It is intended that there is no restriction on the number of standards that can be accepted to provide an
acceptable means of compliance to a specific regulation. Any group or individual can propose a
standard and have an authority accept it as an acceptable means of compliance provided it meets
established guidelines for the creation and approval of a standard. These guidelines may follow
requirements of the Issue Paper process or other designated process agreed to by the authorities.
Use of the accepted standards would not be mandatory, but would be encouraged to avoid the effort
required to create and obtain approval of new standards. However, in the event that there is a desire to
protect proprietary information, or other reasons, it may be desirable in some cases to propose a new
standard.
Also, there needs to remain a distinction between the standard and guidance material. It is not
intended that current ACs and other guidance (current SAE, RTCA or ASTM documents) become part of
the ADS. In essence, the new standards should capture the “what”, “why”, “when” and “where”, to the
extent possible, but should not restrict technical solutions; the guidance captures the “how”. However,
in some cases a standard may be created that would incorporate the information in an FAA AC and
other Civil Aviation Authority guidance such that the standard could replace multiple guidance
documents from different authorities and significantly simplify the means of compliance. This may not
occur immediately but over time.
As the ADSs are written, it should be determined if there is a need for any tiering to account for simple
designs, well understood technologies, and/or simple (robust) analysis methods. Determine where
there is need for different levels of requirements in the standard based on the aircraft performance,
complexity, or operational risk. The ADS
should provide an acceptable means of
compliance with regard to the feature being
considered and aircraft performance,
complexity, and/or operational risk. This
tiering structure would be developed for
each functional area of the aircraft and not
necessarily apply to the whole aircraft.
Therefore tiering will be very different from
one area to the next.
While the standard is being written, a
review of the current guidance will be
undertaken to determine if there is a need
~ 13 ~
for revised, new or additional guidance. A list of current guidance will be generated for each paragraph
written, including current ACs that include material that can be considered as standard material (such as
in ACs 23. 1419 or 23. 1309).
Once an ADS is completed and accepted, the standard should be continually reviewed and updated to
keep it relevant to the changing technology. New ADS will not increase the compliance burden on an
applicant unless there are new technology requirements.
3.1.7 Notes on Tiering
The tiering begins by assessing the simplest individual airplane elements that is envisioned to determine
how it could most easily comply with the rule that it services in part 23. These methods should be
captured so they can be included in a specification that would be a means of compliance for that kind of
airplane. Additionally, the features and characteristics that defined that simplest product should be
noted.
Next, a less simple airplane should be evaluated (the next level of airplane for which the method of
compliance just documented isn’t fully appropriate) and determine what additional methods of
compliance are necessary and what features define that kind of airplane. This exercise should be
continued through the envisioned spectrum of airplanes.
Safety impact and risk should be evaluated, i.e. what are the risks and outcomes of a failure. Figure 5
provides a diagram that can be used to help determine tiers and specific compliance rigour.
~ 14 ~
Cutting Edge
new developments
with little or no in‐
Technology Application
Level of Technology
service experience
Mainstream
and/or
current state‐of‐the‐
art , based on recent
experience (10 yrs?)
Commonplace
based on standard Increasing operational
design practices with complexity could drive
extensive in‐service more rigor
experience
Certification & Compliance Rigor
Figure 5 Tiering and Risk Evaluation
Tier definitions are likely to be different for the various areas of the standard. Structures tiers may have
natural transitions to more certification rigor that do not coincide with tiers in propulsion or systems.
The envisioned result may be more like a matrix addressing the different means of compliance for the
elements or systems of the airplane taking different operational characteristics in consideration.
This means that an aircraft that has basic characteristics will be simple to certify, except for one specific
system or type of operation that may require different substantiation. This is conceptually shown in
Figure 6 and Figure 7.
~ 15 ~
This could be the Aircraft Type and
Basic Airplane
definition type of operation
Group 1
Group 2
Group 3
Compliance
shown by AC
Code
Subsystems
(non‐tiered Compliance
TLRs) ACs /MOC / by Standard
Standards/Comp
any specific
NO technical compliance docs
solutions prescribed (Tiered)
This is where the
simple aircraft
lives System added to
basic airplane,
requiring additional
MoC
Acceptable technical solutions
Figure 6 Tiered means of compliance by subsystem
Each point requires
Night a specific MOC with
3
2.5
increasing rigor
Structural
2 IFR / FIKI
Complexity
1.5
1 Level 1
0.5 Level 2
0
Number of Max Oper. Level 3
Passengers Altitude Selected
Max Oper.
Stall speed
Speed
Figure 7: Different MOC levels across one aircraft
3.1.8 Conclusion
Based on the numerous discussions and work prepared by the Regulatory working group a feasible path
forward for the new Part 23 was developed. This involved the breakdown of Part 23 at Amendment 62
into appropriate safety intent regulations using the guidelines identified above. The resulting language
is shown in Appendix E. These draft rules have been reviewed and vetted by all participants in this ARC
~ 16 ~
working group, including many different aviation authorities, and recommended as a starting point for
the FAA and other authorities to draft a final set of regulations to be proposed by each authority.
With the draft language developed for the new part 23, the Regulatory Structure working group then
developed a set of guidelines and instructions to pass to the ADS group. This ensured the concepts and
ideas from the Regulatory Structure working group are crafted so that the new part 23 and accepted
airworthiness design standards complement each other. This will provide industry with a set of
requirements that is: useable; effective; changes as quickly as technology; allows the new rules to be
used with older designs; reduces cost; increases safety; and reduces the workload of all regulatory
agencies across the world.
3.2 TYPE CERTIFICATION / PRODUCTION CERTIFICATION
3.2.1 Background
In response to the 14 CFR Part 23 Reorganization ARC Charter to reduce simple airplane certification
cost and time burden, the TC/PC working group set out to identify improvements in both the type
design certification process and the production certification process. These improvements would cut
the cost of certifying new part 23 airplanes, modifying airplanes, and also cut the costs of production
through changes to the certification process. Furthermore, opportunities to improve safety were also
considered. These safety improvement opportunities were expected to be realized by incentivizing the
installation of new safety enhancing technology thru lower certification costs.
The initial activity of the working group was to identify cost drivers in the certification process (Appendix
F.2). For each cost driver, comments were identified along with suggested changes or solutions. In
addition, suggested solutions included noting when a decrease in costs for industry would apply to the
FAA as well. Safety improvements were also identified.
After considerable discussion about this list of cost drivers and possible solutions, the working group
decided to focus their efforts on several key areas and develop supporting white papers. These white
papers would explain the issue and then provide a suggested solution for FAA consideration. White
papers were developed for the following:
FAA Conformity
Minor Change Approval
Applicant Showing Only
Use of Video Recordings in Testing
Design Organization/Production Organization Handbook including Simplified Production
Certification
~ 17 ~
For each of the above items cost savings estimates were made in the white papers and those estimates
are included in section 7 of this report.
The following sections will summarize the proposals at a high level and section 5 includes the
recommendations for each. Appendix F.1 contains the TC/PC Work Group Report Out that contains
more detail on each of the proposals and the white papers on each of the proposals.
3.2.2 FAA Conformity Process Summary
There was unanimous agreement by the working group that the FAA conformity process was the
number one cost driver in certification. The FAA conformity process is essentially a double check of the
applicant process, as the applicant is required to do 100% company conformity. It is interesting to note
that the FAA conformity process is unique to the FAA. For example, two of the other major certification
authorities, European Aviation Safety Agency (EASA) and Transport Canada Civil Aviation (TCCA), do not
require this second check of configuration.
In addition, as currently required, individual test article conformities often require a test article to be
completely opened up and inspected in order to satisfy a Request for Conformity. Whereas with
configuration management, the exact configuration of the test article is known at all times from the
~ 18 ~
beginning of a program and the configuration can be quickly checked against the test requirements.
This opening up of the test article can sometimes delay starting a test by several hours or days. On a
program with several different test articles, or large test articles such as an airplane, this can result in
significant program costs due to the added man‐hours and delays in testing.
Travel costs involved with sending FAA designees to do a second conformity can add several thousands
of dollars in direct travel costs plus additional delay costs when designees aren’t immediately available
or have to conduct several inspections at different locations during a trip. Eliminating or reducing the
number of articles that a designee must personally inspect would significantly reduce direct and indirect
costs to the program. Also, with an electronic configuration management system, some FAA conformity
verifications could be conducted from the designee’s or FAA inspector’s home base without the need for
travel.
The working group outlined the following objectives for a new process:
Replace individual component‐based conformity with a systematic approach to test article
configuration management that satisfies FAA conformity and safety requirements in accordance
with 14 CFR 21.33 and 21.53.
Streamline the test article inspection and conformity process to eliminate unnecessary and
redundant activities.
Maintain or improve safety for flight test pilots.
Consolidate and integrate records for as‐designed, as‐built, and as‐tested configurations to
improve assurance that the as‐tested configuration is representative of the approved type
design, or serves the intended purpose of the test.
Consolidate and integrate records showing a company’s progression towards production
approval readiness for a new airplane model as well as facilitate expedient issuance of
applicable airworthiness certificates.
Utilize Configuration Management as an integral part of the production process.
The proposed solution was for the FAA to allow adoption of modern configuration management
practices. Configuration Management (CM) can be used to track the design throughout the life of the
test article and provides the same information as conformity about the as‐designed, as‐built, and as‐
tested configurations, including any deviations and their disposition, at any time during the project. This
approach ensures the article is properly controlled through a CM system versus the current conformity
process that is only capable of managing configuration at the individual component level. This is
because a CM system manages the complete lifecycle of the article through an integrated system
whereas the FAA conformity process manages build configuration in discrete packages that require
manual reconciliation of configuration, which is often overly burdensome to manage. Further, under
FAA conformity, the business systems for managing as‐designed, as‐built and as‐tested configurations
are often separate systems (e.g., design and test configuration changes are often tracked separately
following the as‐built conformity inspection), which makes reporting difficult during the reconciliation
process.
~ 19 ~
Benefits of this process for the applicant would be reductions in:
1. Direct expenses caused by FAA conformity,
2. Indirect expenses caused by program delay, and
3. Operating expenses for designees or FAA inspectors to travel to witness FAA conformity
inspections.
The white paper details direct type certification conformity expense savings on the order of 2 to 8 full
time personnel depending on the complexity of the project as well as travel savings of $40,000 per year
during routine times to $200,000 per month during peak type certification efforts.
While the FAA also benefits from reduced cost of oversight and travel, some of the more intangible
benefits the FAA may see include:
1. Advisory Circular guidance that will standardize the CM procedure across applicants that is
created by industry participants to assure grounding in current practice (note there is significant
disparity between applicants implementing the FAA conformity process today).
2. More accurate revision control of test article configuration for applicants and Aircraft
Certification Offices (ACO) that allow use of “…or later FAA approved revision” statements on
Request For Conformity (RFC). The CM process would allow the applicant or FAA to query
article configuration and compare to the required configuration at any time during the test
program rather than leaving an open‐ended conformity request. In order to avoid having to
continually revise RFCs when a configuration changes during a certification testing program, it
has been accepted practice for the RFC to specify a particular configuration, or a later
configuration if it has been approved by the appropriate Designated Engineering Representative
(DER), AR, or other authorized engineer. Under a CM process, when a configuration changes,
the appropriate engineer(s) will review the configuration and determine if it meets the
requirements for the applicable tests and will approve the configuration in the configuration
management database as being acceptable for the applicable tests. If it is not acceptable for
certain tests, that will also be identified and noted in the CM database by the engineer.
Therefore, the database records the appropriate engineer(s) conscious decision to accept the
revised configuration for the applicable tests. This process actually provides a better, more
robust process for ensuring the correct configuration is used for testing than the current
conformity request process.
3. Configuration management systems that enable documentation of the evaluation of mid or late
program design changes on previously accomplished testing. With the configuration
management process, the exact configuration tested for any test is recorded in the database.
Thus, it is easy to review configuration changes made after a test has been successfully
completed and determine if a new configuration is acceptable without re‐testing. This new
configuration may be the result of changes during the open project or actually may be changes
~ 20 ~
made as a result of a later project. This evaluation will be recorded in the configuration
management database and can be retained in the database and exported directly to a
compliance report. It is also possible to use this information to evaluate more easily whether
testing may be required on subsequent projects involving the same test article.
Three sections of 14 CFR part 21 apply to the conformity process: §§ 21.33, 21.35(a) and 21.53. The
white paper provides a brief discussion of each and the impact of this proposal. In summary, the
proposal to use configuration management meets the requirements of part 21 without further rule
change. FAA conformity is not discussed anywhere in the regulation, but instead has been used as one
method to meet the intent of § 21.33(a). This proposal would enable an alternative method to the
current conformity process to meet the inspection and configuration management requirements of part
21.
The white paper proposes new guidance should be developed to provide a configuration management
and inspection standard that can be referenced by applicants and FAA personnel and provide the
minimum requirements by which to approve and audit the applicant’s program. An AC should be
developed to provide a complete description of the CM process as follows:
1. Draft AC 21‐xx Configuration Management System for Control of Certification Test Articles,
Production, and other appropriate article configuration relevant areas (this will be drafted by
industry through the ASTM process and proposed to the FAA)
2. This AC should consider:
a. The controlled data listed in FAA Order 8110.4C, Para 5‐3.d,
b. The controlled data listed in FAA Order 8110.49, Para 4‐3 and 4‐4,
c. Description of Compliance Verification Engineer qualifications, functions, and limitations
and,
d. Improving guidance for completing Request for Conformity Special Instructions that
addresses the issue of generic Special Instructions that are insufficient to determine the
specific issue of concern to the requesting FAA ACO Engineer or designee.
To avoid burden for applicants already using FAA approved inspection procedures for type certification,
the guidance should allow for inclusion of inspection procedures in the Quality Assurance Manual
(QAM), Organizational Designation Authorization (ODA) manual or other FAA approved manual held by
the applicant.
3.2.3 Minor Change Approval Summary
The working group compared the minor change approval process that each ARC member company used
and noted a lot of variation, with some companies having a very onerous process and others a more
streamlined process. The working group compared each manufacturer’s processes and then selected
~ 21 ~
best practices from each to develop a proposed method for approval of minor changes to type design by
an airplane manufacturer. It should be noted the Alterations and Maintenance Working Group also
addressed this issue, but from an alteration perspective. The two groups worked together to develop
common definitions to the extent possible.
Applicable Rules:
1. Sec. 21.93 ‐ Classification of changes in type design.
(a) In addition to changes in type design specified in paragraph (b) of this section, changes in
type design are classified as minor and major. A "minor change" is one that has no
appreciable effect on the weight, balance, structural strength, reliability, operational
characteristics, or other characteristics affecting the airworthiness of the product. All other
changes are "major changes" (except as provided in paragraph (b) of this section).
2. Sec. 21.95 ‐ Approval of minor changes in type design.
Minor changes in a type design may be approved under a method acceptable to the [FAA]
before submitting to the [FAA] any substantiating or descriptive data.
Section 21.95 states that minor changes in a type design may be approved under a method acceptable
to the FAA before submitting to the FAA any substantiating or descriptive data. Further, § 21.93 defines
a minor change as one that has no appreciable effect on the weight, balance, structural strength,
reliability, operational characteristics, or other characteristics affecting the airworthiness of the product.
A significant area of concern to both working groups was the definition of “appreciable” in § 21.93. The
white paper proposes what “appreciable” means for each of the six characteristics identified in the rule
(weight, balance, etc.). The paper also offers guidance as to the types of changes that affect different
engineering disciplines. Lastly, the paper proposes a process for approval of a minor change to type
design.
The proposed process relies on qualified personnel to determine if a change to type design is major or
minor based on § 21.93 and the guidelines in the white paper which supplement § 21.93 (i.e. the
definition of appreciable). The decision of major or minor for the change is determined for each
affected discipline, including consideration for the cumulative effect of minor changes. For the change
to be minor, it must be determined to be minor for all affected disciplines. The change evaluation
rationale is documented and retained.
The company completes any engineering activities associated with the minor change, including that:
1. Any analysis is complete and company approved,
2. Any company testing required to confirm no appreciable effect at the airplane level is complete,
documented, and company approved, and
3. The changes to the type design drawing(s) are company approved.
~ 22 ~
After completing these activities, the minor change is considered approved through this process. The
company retains evidence of completion of this process for every minor change. This evidence may be
reviewed during FAA audit activities.
One company with a more onerous minor change approval process than other companies stated they
review approximately 2000 minor changes per year. This company believes they could save over
$100,000 per year by implementing this proposed process.
It is the working group’s expectation that the FAA will find the process described here as acceptable and
issue a policy memo or other statement supporting it as a “method acceptable to the FAA.” Each
company then has the option to either stay with their currently approved process or adopt this new one.
3.2.4 Applicant Showing Only Summary
The goals of the 14 CFR Part 23 Reorganization ARC were to improve safety for the part 23 aircraft and
to reduce the cost of certification. This paper, described in Appendix F.5, proposes a method to do both
through:
1. Use of Safety Management tools the FAA is implementing, and
2. Less direct involvement of the FAA in determining compliance to the regulations as allowed by
part 21.
A number of the FAA Safety Management Processes and Orders were considered when developing the
risk‐based process proposed in this paper, which determine when an applicant can simply show
compliance without the FAA, a DER, or ODA unit member finding of compliance.
A recent change to part 21 is the addition of the Statement of Compliance requirement of §§ 21.20(b)
and 21.97(a)(3) that increases the accountability of the applicant’s management to ensure that
compliance is properly shown as described in AC 21‐51. Consequently, in addition to there being
economic incentive, there is further legal incentive for applicant management to ensure compliance is
properly accomplished without having to rely on the FAA, a DER, or ODA unit member to find
compliance.
There are varieties of applicants for type certification projects. At one end is the applicant who is very
competent, has successfully completed multiple certification programs, and holds an Organization
Designation Authorization (ODA). At the other end is a company lacking proven processes and
organizational competency relevant to the certification process and everything in between. All
applicants, no matter what level of experience or competency, have a responsibility when executing a
part 21 type certification project to:
1. Conduct all inspections and tests to show the compliance of the design and product (§ 21.33(b)),
2. Make all flight tests that the Administrator finds necessary (§ 21.35(b)),
3. Submit all data showing compliance (§ 21.21(b)), and
~ 23 ~
4. Provide a statement certifying compliance (§ 21.20(b)).
As the applicant completes the showings of compliance detailed in steps 1 through 4 above, the FAA or
its designees:
1. Find upon examination of the type design that applicable requirements have been met
(§ 21.21(b)1)
2. Make any inspections and tests necessary to determine compliance of applicant’s design and
product (§ 21.33(a))
This paper proposes a structure for when applicant showing only is sufficient as a function of the type of
applicant, the risk of improper test conduct/data analysis, and their resulting potential impact on safety.
This proposal evaluates applicants based on three criteria:
1. Staff Competency – What is the skill level of the individual staff members of the company
working the certification activities? Are there sufficient DER’s or ODA Unit Member’s (UM’s) on
staff to support a complete aircraft design and certification project? Does the company have
ready access to specialists at suppliers or consultants as necessary to complement staff?
2. Company Competency – What internal organization and resources does the company have in
place to facilitate certification programs? Does the company management fully support the
staff training and access to resources necessary to keep the staff current with FAA policies,
regulations, and guidance related to certification activity?
3. Procedural Effectiveness – Does the company have adequate internal processes to ensure that
work product is thorough, consistent, well‐documented, etc.? Are the processes in place
proven, industry best practices? Do the internal processes include a continuous improvement
process to evaluate the procedures on a regular basis and take corrective action as needed?
For each of three criteria, the paper details the characteristics for being rated low, medium, or high. An
applicant would work with the FAA to determine their rating for each of the three criteria. This rating
could be re‐evaluated on a regular basis as the company improves or concerns are raised. Either the
FAA or the applicant may request a re‐evaluation of the company’s rating. Based on the ratings for the
three criteria, an overall classification is established for the company based on the following:
1. Tier 1 would rank low in two or more of the criteria.
2. Tier 2 would rank medium in at least two of the criteria and high in the other.
3. Tier 3 would rank high in all three criteria.
For each of these company classifications, analysis and testing methods have been reviewed to assess
the risk of improper test conduct and the resulting potentially inaccurate data or potential errors in
analysis. The various analysis and tests were selected based on:
~ 24 ~
1. Analyses where:
a. The analysis method is well defined and understood – the method has been validated and is
proven; and
b. The likelihood that the analysis method will not adequately show compliance to the
requirements is very low.
2. Tests where:
a. Testing methods are well defined by either an Airworthiness Design Standard, Advisory
Circular, or other accepted standard including company test procedures that are proven;
b. Testing methods are well understood and have little subjectivity;
c. Testing methods are repeatable – all variables that could affect the test are known and are
controllable and repeatable;
d. There are clear pass/fail criteria; and
e. The likelihood that the test method will not adequately show compliance to the
requirements is very low.
~ 25 ~
Table 3.2 provides the proposed work split between the applicant and the FAA.
Table 3.2 – Work Split Definition
Category of Applicant
Type Tier 1 Tier 2 Tier 3
Data Analysis Data Analysis Data Analysis
Performed by Applicant Performed by Applicant Performed by Applicant
Analysis
Analysis Approval Analysis Approval Analysis Approval
Approved by FAA (or DER) Approved by Applicant Approved by Applicant
Test Procedure Test Procedure Test Procedure
Approved by FAA Approved by Applicant Approved by Applicant
Conformity Conformity Conformity
Conformed by applicant, Conformed by Applicant Conformed by Applicant
may have FAA oversight (or
DAR)
Testing
Test Conduct
Conducted by Applicant Test Conduct Test Conduct
Conducted by Applicant Conducted by Applicant
Test Witness
Witnessed by FAA (or DER) Test Witness Test Witness
Witnessed by Applicant Witnessed by Applicant
Test Data Approval Test Data Approval Test Data Approval
Approved by FAA (or DER) Approved by FAA (or DER) Approved by Applicant
Note 1: Table 2 of the white paper identifies 24 types of analysis covered by this proposal.
Note 2: Table 3 of the white paper identifies 87 types of testing covered by this proposal.
3.2.5 Use of Video Recording in Testing Summary
Objectives:
1. Acknowledge validity of utilizing video recording techniques for capturing key testing
information.
2. Improve quality and/or integrity of captured test data.
3. Improve utilization of FAA resources and designees by enabling remote witnessing.
4. Define parameters necessary for the successful utilization of video recordings for data capture.
Background Information:
The current primary method of data capture during certification testing is via real‐time witnessing by
appropriately delegated individuals. While this method of witnessing is sometimes augmented with
video recordings, the use of video is typically viewed as a “back‐up” to the physical presence and real‐
time witnessing of a human being. (Note that there are precedent instances where video has been
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utilized as the sole means of witnessing, but these have been rare and have required “special
dispensation.”)
FAA designees perform the vast majority of test witnessing, which places a burden on the applicant to
either hire consulting Designated Engineer Representative (DER)/UMs or obtain delegation of company
DER/UMs. Regardless of the nature of the designee, minimizing the time required of that person will
have a direct corollary effect on the financial impact experienced by the applicant.
For testing that takes place at or near the applicant’s place of business, direct travel expenses for the
applicant already will be minimal. However, if the applicant is utilizing consulting DER/UMs it is likely
that such individuals will need to travel in order to witness the test. In addition to the “base fee” for the
consultant’s time, the applicant will also incur travel, lodging, and meal expenses. Also, many
consultants will charge for their on‐location time based on full‐day increments, even if the actual
witnessing efforts consume only a few hours. Even if company DER/UMs are utilized, some testing
requires travel to lab locations for witnessing; thus, the associated travel costs remain.
These effects can also significantly consume FAA resources when the option is exercised to witness tests
with FAA personnel. Exercising this option normally involves traveling some distance to the test site,
incurring similar expenses to those discussed above due to either the distance traveled or the length of
the testing in question. This eventuality is more likely in the case of startup companies when confidence
in the company personnel, processes, and procedures is still being assessed.
FAA test witnessing is conducted for one primary reason: To provide confidence in the validity of the
test setup, the test execution, and the ensuing results. It is possible to accomplish all of these
requirements through an alternate means to personal, real‐time witnessing through utilization of video
witnessing or recording.
The white paper described in Appendix F.6:
1. Details many potential uses of video recording and the advantages.
2. Details the benefits to both the applicant and the FAA.
3. Identifies three primary areas that must be considered to make the use of video witnessing a
viable proposition. These are:
a. Adequate coverage,
b. Video fidelity, and
c. Data integrity.
4. Discusses various requirements to consider when the FAA establishes the guidelines for video
witnessing.
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5. Concludes based on a part 21 review, that the use of video as described in the white paper
would not violate any part 21 requirements; therefore, no modifications to the Federal Aviation
Regulations (FARs) are necessary to allow the use of video witnessing.
A brief search of the available guidance material was conducted to see if any language was currently
being used that would preclude the use of video as described in the document; none was found.
However, two lines of reasoning were discovered that lend credence to the idea that video witnessing is
in line with the current philosophy underlying witnessing.
a. In FAA Order 8110.37E, paragraph 2‐6.b, it states:
“…DERs may be authorized to witness tests outside their area of authority provided that the
DER (1) is authorized to do so by the ACO, and (2) does not make the final compliance
finding.”
The implication here is that physically observing the test‐taking place is not necessary to find the
data valid. The importance is in monitoring the activity to ensure that the test plan was
followed, no critical errors were introduced, the data was appropriately collected, etc.
Employing video witnessing as described in the white paper can accomplish these same goals,
enabling properly authorized individuals to make final compliance findings although they were
not physically present for the test.
b. Additionally, FAA Order 8110.37E, paragraph 4‐4.a states:
“…Before witnessing the test, the DER must verify that the necessary FAA conformity
inspections have been accomplished, that the test article is in conformity, or that all
unsatisfactory conditions have been dispositioned. A DER is not required to witness an entire
test to approve the test data. However, the DER must coordinate with the ACO to determine
which conditions are critical and must be witnessed in order to ensure that all the data are
valid. When DERs approve test data, they indicate that they witnessed those portions of the
test dealing with critical conditions, the test was conducted in accordance with the FAA
approved test plan, and the data are official test results that satisfy the test criteria for
compliance.”
The proper use of video witnessing would provide the ability to not only “witness those portions of the
test dealing with critical conditions”, but also the ability to review these critical events in detail. In
addition, non‐critical portions that may otherwise go un‐witnessed would be available for review at the
DER’s discretion. The utilization of video witnessing would not only meet the intent of the existing
guidance, but could be leveraged to actually enhance the witnessing coverage.
The white paper concludes with the recommendation that new guidance should be developed to
provide a video witnessing standard that can be referenced by applicants and FAA personnel, and to
provide the minimum requirements by which video witnessing can be successfully utilized. An Advisory
Circular should be developed to provide a complete description of the video witnessing process to
include:
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1. Update policy to endorse the use of video technology in test witnessing,
2. Endorse an ADS on Video Witnessing of Certification Tests,
3. This standard should consider:
a. The types of testing that could most benefit from the use of video witnessing; and
b. The minimum parameters discussed above regarding coverage, fidelity, and integrity.
3.2.6 Production Manual Summary
Many new startup companies struggle with creating basic guidance for their workers that will help them
ensure that they are accomplishing the major requirements necessary to produce an aircraft.
The intent of the Production Manual found in Appendix F.7 is to satisfy the minimum requirements for a
Quality Assurance Manual of a new startup company but in such a way that it will integrate with the
more comprehensive requirements of a Design Organization (DO)/Production Organization (PO)
Handbook without major changes, should one be desired in the future. The basis of this Production
Manual is the requirements in 14 CFR 21.137.
Several airplane manufacturers of this working group provided a copy of their Quality Manual to show
how the 14 elements of § 21.137 are satisfied to establish and maintain a production certificate. These
manuals were compared to identify best practices with emphasis on simplicity. The result is a draft
quality manual that provides new aviation business entrants with a detailed starting point in developing
and obtaining their own production certificate. This draft manual could then be integrated as part of
the DO/PO handbook described in the next section.
The Production Manual is organized so a new company with only a few employees could start with it
and easily modify it to be integrated with a more comprehensive DO/PO Handbook to accommodate
company growth as needed.
The Production Manual provides only the basic general information and each company must determine
how much to add to or modify to satisfy their needs.
3.2.7 Design Organization/Production Organization Handbook Summary
Today’s typical aviation manufacturing company is segmented into different activities (e.g., engineering,
production, quality, etc.). Each of these segmented activities normally use separate handbooks to meet
their specific requirements. Most companies maintain separate Design Organization Type Certificate
and Production Organization Production Certification handbooks or manuals, and when operating in
different countries, sometimes slightly varying versions of these handbooks.
The FAA currently asks for handbooks covering each operational segment such as certification or
production. Significant effort is spent to establish and maintain separate handbooks resulting in high
administrative burdens, especially for small companies that maintain both TC and PC handbooks for one
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product, for one company, and under one roof. This gets more complicated when the same company
acts as a component supplier under AS/EN 9100 approval with a third set of requirements and a third
handbook. The situation leads directly to potentially conflicting information in the different handbooks
because of process disconnects. This increases the opportunity for process errors in daily work.
By comparing the requirements basis for existing accepted handbook samples, including the ODA
manual, a harmonized approach is identified that allows small companies to set up one single,
integrated quality management process satisfying all typical requirements, as an alternative to today’s
interpretation indicated by the FAA Orders such as FAAO 8110.4, 8100.15, and 8130.2.
The harmonized approach is manifested in a standard handbook template that can be utilized and
adopted to the individual company conditions.
The harmonized standard handbook approach implements several recommendations from the list of 17
cost drivers the TC/PC Working Group identified that are listed in Appendix F.2. Topics identified as
having significant potential for optimizing processes in terms of time, effort, cost, and safety are
included in these recommendations. By including these results within a standard handbook, a level
playing field is established with limited room for local FAA interpretation that might have negative
impact for an individual company.
Throughout the process of generating the standard handbook approach, the ability for this handbook to
comply with the regulations of different major agencies, such as the FAA and EASA was verified. This
levels the playing field even beyond the limits of FAA jurisdiction.
3.3 ALTERATIONS AND MAINTENANCE
3.3.1 Background
The stated objective of the 14 CFR Part 23 Reorganization ARC is to
improve safety within the fleet by reducing the average cost of certifying,
maintaining and operating part 23 airplanes and facilitating safety‐related
upgrades. The preferred approach is to:
1. Define the regulations at a higher level that maintains the original
intended safety requirement and eliminate prescriptive requirements
within the regulations according to as‐yet to be determined criteria, and
2. Modulate the part 23 requirements by tiering through standards
to create a more rational and economical relationship between the
certification requirements and the characteristics of each airplane.
Part 23, however, is not used in isolation; other regulations and standards are also applied. While part
23 provides structural, performance, and systems requirements (for example), these requirements are
applied under procedures governed by part 21 for both initial manufacture and for alterations approved
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by STC. Alterations and maintenance for these airplanes are performed under part 43. Airplanes
certified under "old" (amendment 62 or earlier) part 23 and the even older CAR 3 will continue to be
flown, altered, and maintained for many, many years.
The full benefits of changes to part 23 may not be realized if they are applied with a traditional view of
other CFR parts. Some level of coordinated change to these regulations (or to the policy, guidance, and
culture that govern their application to part 23 airplanes)
may be desirable.
The goal of the Alterations and Maintenance working
group was to identify issues related to post‐production
activities under the "new" (post amendment 62) part 23.
These issues may apply to airplanes certified under "new"
part 23, the "old" part 23 or CAR 3, and may involve part
21 and part 43 considerations. For each identified issue, the working group made recommendations
whereby the issue might be addressed. Solutions should be seamless for any previous certification
process.
The working group considered and wrote reports (each of which included specific recommendations) on
the following subjects:
Simplified certification of systems and equipment for use on in‐service airplanes
Procedural issues associated with STCs and alterations under the new Part 23
Preventive maintenance
In addition, the working group supported development of a proposal for the creation of a new Primary
Non‐Commercial category of airplanes.
Recommendations made by the working group are listed in Section 6. The reports written on each topic
can be found in Appendix G.
3.3.2 Certification of Systems and Equipment
Background
This section summarizes Alteration & Maintenance Working Group’s analysis and recommendations of
the Certification of Systems and Equipment.
Installed systems and equipment have the potential to contribute greatly to the safety of flight, both as
installed at the time of manufacture of the airplane and as installed throughout the airplane’s service
life. The cost of the articles and their installation; however, tend to inhibit their installation on airplanes
at all levels. If these cost barriers can be lowered without compromising safety, increased adoption
rates can result in safety improvements within the fleet.
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In many cases, the costs associated with design, manufacture, and installation of systems and
equipment are largely determined by the applicable certification requirements. Much of the cost of
airborne systems results from the requirements of §§ 23.1306, Electrical and electronic system lightning
protection, 23.1308, High‐intensity Radiated Fields (HIRF) Protection, and 23.1309, Equipment, systems,
and installations. If these certification requirements can be reduced without posing a direct threat to
safety, the resulting cost reduction may actually result in an overall safety improvement because of
increased adoption of newer equipment that can provide better situational awareness as well as other
safety features. The costs arise not only as a result of the rules themselves but also as a result of the
policy, guidance and culture that influence the application of the rules. Even in the absence of rule
changes, changes in the way the rules are applied can greatly influence the ease or difficulty and cost of
development and installation of these articles.
Comparative risk
The existing guidance describes safety‐related
certification requirements in relation to the risk
associated with deployment of a given system into
the fleet. That risk is estimated based on a functional
hazard assessment and mitigated based on the
results of a design and installation appraisal or
system safety assessment, depending on the level of
risk.
The existing guidance, however, fails to address the
risk associated with a failure to deploy. Specifically, safety related functions may have the potential to
reduce the accident rate associated with the specific flight hazards that they address. Any risk
associated with the deployment of systems that assist the pilot in avoiding specific hazards may be
offset by the avoided risk to operators and their passengers associated with those hazards in the
absence of the systems.
Thus, an appropriate way to judge the net safety impact of a given system would be by assessing the
comparative risk associated with its deployment and non‐deployment. Systems that have the potential
to address hazards that are especially significant in GA (such as loss of control) would merit
consideration at lesser‐estimated reliability (i.e., higher risk) than might be considered for less significant
hazards.
Exposure
The present guidance grants no credit for hazard exposure in the assignment of development assurance
levels.
Exposure describes the fraction of overall flight time during which a given failure would result in a
hazard. The failure of an attitude indicator, for example, is hazardous only in instrument meteorological
conditions (IMC) when the pilot cannot maintain attitude by reference to the actual horizon. Exposure
~ 32 ~
is used in the estimation of failure rates for comparison with the numerical reliability requirements (i.e.
using guidelines that are, some would argue, excessively conservative, such as the guideline that an
airplane certified for IFR use should be assumed to be in IMC at all times) but is not made a factor in
determining the appropriate DALs.
Alternate means of compliance (AMOC)
The FAA assists applicants by a number of means, including publishing Advisory Circulars that both
clarify the often abstract rules, providing specific compliance criteria, and offer means of compliance by
which the applicant can show that those criteria have been met. As noted previously, these acceptable
means of compliance are often supported by ADSs, such as RTCA DO‐160(), DO‐178() and DO‐254().
Indeed, some ACs serve no purpose other than to identify an industry standard as acceptable means by
which compliance with some rule, or some aspect of a rule, may be shown.
Notwithstanding the potential difficulty, an applicant proposes an AMOC ordinarily because it is more
appropriate to the situation than the usual means and this normally implies it will be more efficient
overall, whether within the course of the project in which it is first used or successive projects. For
efficiencies to be realized, the FAA must be a willing – or even enthusiastic – partner in the endeavor
and reason must prevail on both sides. Even though a given applicant’s AMOC is proprietary, the
experience gained in evaluating it and approving it has significant value to the FAA.
Use of service history for certification credit
Service history should not only be creditable for new systems but should also be creditable for
previously developed systems, primarily as a means of allowing systems shown to be reliable on less
complex airplanes to be used on more complex airplanes as well. Historically, the FAA has had very
limited ability to evaluate and accept service history arguments for DAL upgrades, thereby blocking this
path. For many systems, this has the effect of denying access to highly reliable and functional
equipment due to the economic barriers associated with DAL upgrades.
Use of functional standards for DAL credit
At Level D, both DO‐178B and DO‐254 essentially require only functional verification (with some
additional documentation, configuration management, and quality assurance requirements). It has
been observed that compliance with third party functional standards (e.g., TSO MOPS) could be
regarded as equivalent to compliance with Level D. Since the step function of cost from “no compliance
required” to Level D is very large, especially for companies not yet selling certified products, there are
correspondingly large advantages to be gained by formally recognizing such compliance as sufficient.
Cultural issues
In the end, the single most important factor in determining the success or failure of a regulatory
structure is the culture in which it is applied. If the regulations are thoroughly understood, if the
supporting guidance is clear, and if those in the culture embrace the regulations, abiding by the
requirements and using permissions granted to them to their advantage, great successes are possible.
~ 33 ~
If, however, the regulations are largely ignored, if the supporting guidance is unclear or unsubstantiated
in terms of the regulations, and if those in the culture operate on the basis of tradition and uninformed
intuition rather than on the basis of the true regulatory intent, the results are sure to be negative,
frustrating, and costly to all involved.
For any changes to regulations, policy, or guidance to succeed, it is imperative that they be fully and
clearly supported in guidance and policy. Moreover, they must be publicized and training must be
available to FAA personnel, designees, and applicants in order to ensure their proper use. In certain
cases (e.g., the use of service history, for example), it may prove desirable to identify specific pilot
projects in which the concepts can be tested for both efficacy and efficiency.
3.3.3 Supplemental Type Certificate (STC) and Alterations under the New Part 23
After manufacture, airplanes may be altered by means of Supplemental Type Certificates (STCs)
developed under part 21 and by means of major and minor alterations under part 43. With the
introduction of the new part 23, it is essential that these means be maintained for both new and legacy
airplanes in order to insure continuing access to safety improvements.
Background
Irrespective of the path by which an alteration is defined and approved, the airplane must continue to
comply with the applicable rules under which it was certified or, in some cases, newer or added rules
applicable to the specific alteration.
To improve the safety of the existing fleet it is imperative that operational airplanes be upgraded to
meet the needs of an evolving operational environment. The revised regulations, supporting guidance,
and resulting changes in behavior of all involved parties could result in the emergence of unanticipated
safety issues or (and, potentially, more likely) unacceptable impediments to the use of the new rules
and standards.
As the new part 23 and supporting guidance are developed, sensitivity to the needs of the aftermarket
must be shown to address owners’ ability to make safety related improvements to their airplanes after
delivery. These needs include:
Workable establishment of the boundary between compliance requirements (i.e. the
regulations) and means of compliance (i.e. ADSs and others),
Clear and appropriate establishment of the certification basis for the airplane as manufactured,
Provision of essential information facilitating alterations in the TCDS and aircraft service records,
and
Publication of guidance for applicants and FAA personnel on the proper interpretation and
application of it all.
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Certification Basis and TCDS for Newly Manufactured Airplanes
The certification basis of an airplane describes the airworthiness regulations and other provisions –
exemptions, (ELOS) findings, and special conditions – that apply based on the airplane’s configuration,
powerplant, equipment, intended use, and other characteristics (Order 8110.4C, paragraph 2‐3d(4)).
This process for establishing the certification basis and means of compliance should continue with no
significant change.
Because the certification basis is strictly regulatory and is not dependent on the means of compliance, it
follows that it must contain only rules, exemptions, ELOS findings, and special conditions. Thus, under
the new part 23, the certification basis cannot, and should not, identify either the ADS(s) employed or
particular provisions of the ADS(s) that are found to be applicable – any more than would be done for
Advisory Circulars or existing industry standards today.
The TCDS as defined by § 21.41 is a key input to determine the certification basis for subsequent
alterations. As the certification requirements contained in part 23 are simplified, and as aspects are
moved into ADSs, it is important that sufficient information remain in the TCDS to permit STC applicants
and the FAA to clearly and accurately identify the certification basis for the alteration.
The current TCDS essential characteristics requirements from FAA Order 8110.4 may not suffice and the
order may require revision to incorporate additional items that lead to certification basis determination
and compliance path choices within the ADSs, particularly when tiering within a standard is applicable.
Certification Basis and TCDS Information for Alterations
When airplanes are altered after initial delivery, whether under an STC or not, the same range of
airworthiness concerns may arise as in the original certification. Consequently, compliance with the
relevant provisions of the airworthiness regulations must be assured on the altered airplane.
Identification of airworthiness compliance issues can become complicated as an airplane ages. It’s rare
for an airplane of any substantial age to maintain its original configuration. As these alterations are
made, it is often the case that there is no single reliable data source regarding the airplane’s
configuration and aggregate certification basis.
One potential solution would be the creation of the altered configuration of the airplane, in a form that
is more conducive to maintenance and existing recordkeeping requirements. This reorganization of
existing information can be used as the sole detailed record in this regard, directly in support of
regulatory recordkeeping requirements, with references to its contents from the primary airplane logs
as needed for clarity.
New Regulations, Airworthiness Design Standards (ADSs) and Their Application to STCs and Alterations
As noted in the discussions of the activities of the Regulatory Structure subgroup, as the new part 23 is
developed, it is anticipated that portions of it will be restructured and that some of the more detailed
requirements will be moved into one or more industry‐maintained ADSs that effectively form the top‐
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level means of compliance with the regulations.
As these regulations, ADSs, and accompanying
guidance documents are developed, it is
important their structure and content continue to
support effectively the development of STCs and
the alteration of individual airplanes.
If multiple standards are recognized as means of
compliance with particular regulations, an
applicant must be permitted to choose from
among them without regard to the ADS chosen for other regulations. Use of one particular standard in
a project must not obligate the applicant to use that ADS in any other aspect of the project.
Approved Model List Supplemental Type Certificates
The use of Approved Model List (AML) STCs as described in AC 23‐22 is crucial to the efficiency of
alterations in the aftermarket. This is especially true for avionics systems, where support of many
airplane types by a single system is normal and the potential for safety improvement is high. Beyond
accommodations of the new part 23, modest changes to existing AML practices would add flexibility and
reduce cost.
Because the airplanes listed in an AML will inevitably have differing certification bases. The common
practice is to develop the STC to the latest regulation amendment level or, depending on the
classification of the change under § 21.101, to the latest amendment appearing in the certification bases
of the listed airplanes and to the most stringent requirements applicable to the listed airplanes. This
practice must still be applicable under the new part 23.
In particular, compliance with the new part 23, if elected by the applicant, irrespective of the chosen
means of compliance, must be regarded as sufficient with regard to airplanes originally certified under
any previous small airplane regulation at any amendment level.
In some cases, airplanes may have met more stringent certification basis than the latest amendment
level of part 23. In these cases, it is envisioned that future alterations of those aircraft could be
performed to the latest certification basis, which might no longer include a particular requirement
because of certain characteristics or simplicity of a particular design.
Field Approvals
At present, there are many cases where concerns about the categorization of proposed alterations
result in minor alterations being treated as major and major alterations are required to be made under
STCs. As the new part 23 is introduced, the conservatism currently found in the system could very well
increase, negating the hoped‐for increases in efficiency. If efficiency is to be improved, a combination of
updated guidance and targeted training for both FAA and industry personnel will be required. In
~ 36 ~
addition, close coordination between Flight Standards, the ACOs and SAD will be required to facilitate
minimum‐cost resolution paths for common introduction problems.
Alternate Means of Compliance
The industry‐developed ADSs are expected to constitute top‐level means of compliance with the new
part 23. As with any recognized means of compliance, the use of alternate means, including direct
compliance with the rules, has to be permitted. As is now the case, alternate means of compliance must
be permitted at lower levels as well.
In the current culture, the use of alternate means of compliance tends to be mostly impossible. Even
though it’s permitted in principle and supported, typically, by the ubiquitous “one means but not the
only means” clause in the Advisory Circulars, the FAA often has difficulty accepting concrete proposals.
As the transition toward greater and greater reliance on ADSs occurs, this situation will certainly persist.
Just as a genuine and effective openness to the efficient use of alternate means of compliance to
presently accepted means (e.g., RTCA DO‐160G, RTCA DO‐178B, RTCA DO‐254, SAE ARP 4754, various
ACs, etc.), is needed, so is alternate means for the new standards and future supporting documents will
be required.
Role of the Aircraft Manufacturer
Certain aspects of the development of the new part 23 are loosely modeled on the experience gained in
the development of the Light Sport Aircraft (LSA) approval process. In particular, the establishment and
maintenance of Airworthiness Design Standards has a direct analog in LSA. There are, however,
significant differences as well.
LSA are not type certificated under part 21. All airworthiness standards are maintained by industry and
recognized by the FAA. Many LSA manufacturers are relatively inexperienced and the majority are
foreign. Since there is no type certification, nor supplemental type certification process for LSA.
As a consequence of these and other factors, it is a requirement that all alterations to LSA be approved
by the aircraft manufacturer.
It might be tempting to impose this same requirement for airplanes certificated under the new part 23
based on the fact that a portion of the detailed airworthiness requirements are expected to move into
ADS. However, such a move is unnecessary because the essential airworthiness requirements will
continue to reside in part 23. Moreover, an extensive infrastructure of STC developers and shops is
already in place to support part 23 airplanes.
Imposition of a manufacturer approval process for alterations to part 23 airplanes would substantially
inhibit development and use of safety related improvements to airplanes in the fleet.
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3.3.4 Preventive Maintenance
The part 43 provisions on preventive maintenance are outdated, inflexible, and confusing, resulting in a
reduction of pilot performance of preventive maintenance below optimal levels.
Background
14 CFR 43.3(g) permits certificated pilots, with the exception of sport pilots, to perform specific
preventive maintenance (PM) operations on aircraft that they own or operate under part 91. These PM
operations are limited to those listed in part 43 Appendix A Section (c). Other sections of part 43 permit
the pilot to return the airplane to service following performance of PM and record keeping
requirements. In addition to the rules, there are also two Advisory Circulars with content on PM: AC 43‐
9C, Maintenance Records and AC 43‐12A, Preventive Maintenance.
Permitted Preventive Maintenance Operations
At present, part 43 does not include “other operations acceptable to the Administrator” in its definition
of preventive maintenance. This language is often included in the regulations in order to grant the FAA
flexibility in dealing with rapidly changing or extraordinary circumstances. It is difficult and time
consuming for the FAA to adapt to technological and other changes because “other means” is not
included in the regulations and the list of authorized preventive maintenance operations is contained
within the regulations.
With the introduction of sweeping new content in a revised part 23, the FAA will face such a change
situation. Moreover, the incorporation of new technology on airplanes has already led to difficulties in
this area. Additional advances in technology may be inhibited if the regulatory criteria governing
preventive maintenance are not modernized. The stated objective of the part 23 rewrite is to improve
the safety of small airplanes. A supporting objective is the reduction of the cost of airplane acquisition
and ownership, allowing owners to more readily afford the purchase of safety‐related components and
systems. Thus, changes to part 43 that increase the safe availability of pilot‐performed preventive
maintenance are supportive of the ARC’s goals.
Authorization of Additional Preventive Maintenance Operations
At present, the only means by which the list of authorized preventive maintenance operations can be
modified is through rulemaking. There is no allowance for additional authorizations in guidance or by
policy, nor is there any allowance for authorization of type‐ or installation‐specific preventive
maintenance. This poses a substantial impediment to the safe and effective conduct of an increased
variety of PM operations in the field.
Once appropriate language is added to part 43, additional PM items can be authorized for general use in
guidance or policy documents. Furthermore, type‐ or installation‐specific items can be accepted based
on manufacturer’s procedures, perhaps in an ICA. The AMWG sees numerous attractive opportunities
for safe and economical additions to existing PM authorizations by this route, including installation of
~ 38 ~
databases other than those authorized in part 43 itself and installation of software, where procedural
simplicity and aircraft configuration allow.
Preventive Maintenance Guidance
The FAA has issued two pilot‐directed guidance documents with content pertaining to preventive
maintenance (PM): AC 43‐12, Preventive Maintenance (last modified in 2007) and AC 43‐9,
Maintenance Records (last modified in 1998). While these documents are reasonably good at describing
the basic regulations that authorize the performance of PM operations by pilots and the approval for
return to service, along with the attendant documentation requirements, they do little to address the
lack of clarity in the regulations, and specifically the basic list of authorized PM operations in part 43
Appendix A. For example, as noted earlier, AC 43‐12A, Change 1, specifically avoids addressing the issue
of what constitutes “complex assembly operations”, stating, “Owners and pilots must use good
judgment when determining if a specific function should be classified as preventive maintenance.”
The Working Group believes that this lack of clarity and the delegation of responsibility to the pilot are
likely to intimidate and inhibit the performance of PM operations by pilots as intended. The AC, rather
than merely quoting the regulations and stating all of the conditions that apply to their use, which is
acknowledged to be an important contribution by itself, should strive to clarify both the basic
regulations and most importantly, the list of authorized PM operations.
As was noted earlier, the provision of clarifying these operations may serve to expand some readers’
understanding of the regulations and narrow the understanding of others. Both may prove problematic
in terms of acceptance in the field. Nevertheless, the AMWG feels the advantages that accrue from
increased numbers of pilots taking advantage of these regulations as a result of improved understanding
outweighs any potential disadvantage.
In addition, if other AMWG recommendations are followed, the AC would be an appropriate place to
introduce new universally authorized PM operations without the overhead of rulemaking, perhaps to be
introduced to the rule after a trial period, and to establish that aircraft and equipment manufacturers
may propose PM operations for FAA acceptance as part of their service documents.
3.3.5 Primary Non‐Commercial Category
Background
The 14 CFR Part 23 Reorganization ARC was tasked with doubling aircraft safety while reducing
certification costs by half. Currently, there are almost 200,000 General Aviation aircraft registered in the
United States; however, production of new aircraft averages less than 1 percent of this per year.
Consequently, it may be decades before this ARC’s improvements for new aircraft design will yield any
measurable safety improvements or cost reductions for the General Aviation Fleet as a whole.
One way to realize the safety and cost goals is by leveraging the concepts this ARC developed for use in
new aircraft certification in a manner that would have an immediately felt positive safety effect on the
existing General Aviation fleet.
~ 39 ~
This section will summarize the ARC’s recommendation to implement a Primary Non‐Commercial
Category (See Appendix G for complete paper) that is similar to the Canadian Owner Maintenance
Category, but with some significant safety enhancements to address some concerns with that program.
This recommendation is bold, but reflects the challenge posed to industry at the FAA’s ARC kick‐off
meeting. At that meeting, the FAA challenged the ARC members to be bold, creative, and non‐
traditional.
The Primary Non‐Commercial Category is intended for the private owner to operate their aircraft in a
substantially less burdensome and costly manner by reducing the level of FAA maintenance and
alteration requirements to a level appropriate for a privately owned vehicle.
This proposal has two precedents that support the concept. First, this class follows international
precedent by leveraging the concepts of the Canadian Owner Maintenance Category, which has a
proven safety record over the last decade. For more information on the Canadian system requirements
and safety results experience see the complete recommendation in Appendix G. Secondly, this concept
uses the maintenance training principles of the highly successful LSA program that has a proven safety
record. Incorporation of this new category will offer the FAA a rare opportunity for implementation of
sound safety continuum principles paired with international harmonization.
In addition, by allowing a practical and workable path to return Non‐Commercial aircraft to Standard
Category through dual airworthiness certificates, owners will have a large financial incentive to keep
their aircraft near type design to avoid devaluing their aircraft. This is a significant safety advantage
over the Canadian system where it is nearly impossible to return to Standard Category; therefore,
affording no incentive for owners to keep aircraft compliant to safety proven type design.
Finally, the principles set forth in the “Primary Non‐Commercial Category” proposal exclusively leverage
existing US regulations with proven safety records. The recommendation simply takes successful
existing regulatory practices and combines them into the new Primary Non Commercial Category. For
example, maintenance training and certification comes from LSA, airworthiness certification comes from
dual certificated Standard/Restricted Category aircraft and Non‐Commercial use from Experimental
Aircraft. There is nothing new or novel proposed, except for the potential for safety and cost
improvements that would be available for users of the Primary Non Commercial class.
3.3.5.1 Primary Non‐Commercial Category Recommendation
Applicability
The owner of a fixed wing, non‐ turbine powered part 23 aircraft or part 23 glider, 20 years or older,
may elect to redesignate their aircraft as a Primary Non‐Commercial.
Privileges
1. Aircraft in this category can be maintained by the owner with a repairperson’s certificate, similar
to currently established procedures for LSA aircraft repairpersons.
~ 40 ~
2. Replacement or alteration parts should be appropriate for aircraft use; however, such parts
need not be PMA/TSO authorized.
3. Owners can alter their own aircraft without the requirement for FAA approved data; however,
some alterations may require “phase 1” flight testing similar to Experimental Amateur Built
(EAB) requirements.
Limitations
1. Primary Non‐Commercial Category Aircraft are required to observe the FAA Approved Aircraft
Flight Manual Operational Limitations and/or required placard limitations established for the
Standard Category.
2. Aircraft cannot be used to carry persons for hire, this includes aircraft rental, but allows an
owner to receive flight instruction in their own aircraft.
3. Airworthiness Directives are only applicable as currently allowed for EAB.
4. Aircraft owners must maintain a list in the aircraft logbook of all applicable ADs and their
compliance status. This list will be used to highlight the owners’ awareness of the ADs existence
and document their choice of compliance. This list will also be used to facilitate the conversion
of the aircraft back to normal category.
5. Aircraft owners must maintain a list in the aircraft logbook of all alterations performed that are
not FAA approved and all non PMA/TSO parts installed. This list will be used to facilitate the
aircraft conversion back to normal category.
6. Incomplete or fraudulent maintenance logbook entries result in the revocation of the aircraft’s
standard airworthiness certificate.
Requirements
1. Before original conversion, the aircraft must have a current annual inspection – all applicable
ADs must be complied with at the current annual inspection.
2. Airplane owners must either add the prefix of “NC” to the aircraft registration number or affix a
“Non‐Commercial” placard readily visible to all passengers.
3. The aircraft must have a yearly condition inspection by an A&P mechanic certifying that the
aircraft is “in condition for safe operation.”
4. Upon transfer of aircraft ownership, the Non‐Commercial Airworthiness Certificate must be
reissued in the new owner’s name.
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Conversion Back to Normal Category
1. Aircraft operated in the Non‐Commercial type certification class would be dual certificated in
both the Normal and Non‐Commercial categories, as is commonplace for Restricted Category
aircraft.
2. Aircraft in the Non‐Commercial TC category can be operated in the Standard Category, provided
the aircraft meets it type design data including compliance with all ADs, removal of all Non‐
PMA/TSO parts and replacement with certified units and the removal of all non‐certified
alterations.
3. The conversion can be accomplished by an Inspection Authority (IA) mechanic with a complete
and thorough annual inspection and logbook audit. Upon successful completion, the aircraft
could be operated under its Standard Airworthiness Certificate. The procedure is very common
with Restricted Category aircraft and proven to be safe and successful.
Regulation and Order Changes
The following regulations would need to be revised to accommodate the Primary Non‐Commercial
Category.
1. New Regulation § 21.24 establishing the Primary Non‐Commercial Category
2. Revised Regulation § 21.184 issue of airworthiness certificates for primary category aircraft and
primary (non‐commercial) aircraft
3. New Regulation § 91.328 Operating Limitations for Primary Non‐Commercial Aircraft
4. Revised Regulation § 45.22 for markings on Primary Non‐Commercial Aircraft
5. New Regulation § 65.108 establishing Primary Non‐Commercial Repairmen Certificates
6. Revised FAA Order 8130.2 Airworthiness Inspector’s Handbook
7. New Order 800‐ANC‐ARC defining required training for Primary Non‐Commercial Repairman
Courses and Evaluation
3.3.5.2 Conclusion
The intent of the Primary Non‐Commercial Category is to reduce the level of FAA maintenance and
alteration requirements to a level more appropriate for a privately operated vehicle while
simultaneously improving safety and reducing owner costs.
This recommendation follows the international precedent of the Canadian Owner maintenance class.
Analysis of a decade of Transport Canada data indicates that this class has been fully successful in
maintaining (and in some cases enhancing) the safety of the Canadian GA fleet. It is reasonable to
conclude that similar US Primary Non‐Commercial Category would have safety results equivalent to the
~ 42 ~
Canadian success. Thus, incorporation of this new category will offer the FAA a rare opportunity for
international harmonization by the application of sound safety continuum principles.
It is important to note that there is absolutely nothing new or novel in this recommendation – the
“Primary Non Commercial Category” consists exclusively of regulations and procedures used to certify
and operate other categories of aircraft. These “borrowed” regulations are simply recombined in a way
that preserves the individual safety checks in a streamlined manner that is substantially less
burdensome for a private owner.
In order for general aviation to remain viable in the United States, it is essential that a way be found to
both lower costs and improve safety. The Primary Non‐Commercial Category offers the FAA a chance to
accomplish both goals, using existing regulatory language, while decreasing oversight requirements and
expenditures.
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4.0 REGULATORY STRUCTURES WORKING GROUP – RECOMMENDATIONS
4.1 PART 23 REVISION AND REORGANIZATION
The regulatory structures working group took the part 23 recommendations from the CPS and began the
process to implement them. During the bi‐monthly face‐to‐face meetings, the working group revised
the approach to the part 23 re‐organization from what was in the CPS. The working group determined
that the problem was more complicated than what CPS addressed.
As the working group members converged on a better approach to the part 23 re‐organization, the
leadership tasked four subgroups to work on specific part 23 revised language. The four subgroups
followed the disciplines in part 23: flight, structures, propulsion, and systems.
Each subgroup developed revised CFR language. In addition to the CFR language, the working group
learned from FAA legal that the option of using “scope” and “purpose” statements was available. The
subgroups were tasked with adding purpose statements. The idea behind the purpose statement is to
augment the safety rational in the actual requirement.
The recommendations from the working group are the revised part 23 text, which is extensive. For that
reason, the complete proposed CFR language, including the proposed scope and text is in Appendix E.
4.2 PART 23 AIRWORTHINESS DESIGN STANDARDS
The 14 CFR Part 23 Reorganization ARC recommended that initial Airworthiness Design Standards (ADS)
start with part 23, amendment no. 23‐62, as the basis for the detailed design specifications and means
of compliance. The ARC accepted that one set of consensus standards would be created and maintained
by ASTM International and would follow their processes for standards development that would satisfy
the FAA. Their consensus standards process ensures the standards are agreed to by a balanced group of
representatives from the regulators, industry, operators, and others. The ADS are not limited to ASTM
International standards and there is no limit on how many consensus standards could be accepted.
Other consensus standards developed by other organizations or individuals would follow the applicable
processes necessary to satisfy the FAA or other regulatory agency requirements for consensus
standards. Other consensus standards may be required to follow the FAA Issue Paper process that can
take a significant amount of time to develop and approve. This process might be used when a company
wishes to use a standard as a means of compliance but to retain it as proprietary information.
A primary goal is to make all consensus standards internationally accepted so that any civil aviation
authority could accept them as a means of compliance.
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5.0 TYPE CERTIFICATION / PRODUCTION CERTIFICATION WORKING GROUP –
RECOMMENDATIONS
This section contains the recommendations of the Type Certification/Production Certification
Working Group.
5.1 FAA CONFORMITY
The Type Design and Production Certification Working Group of the 14 CFR Part 23 Reorganization ARC
compared the current conformity process against a proposed configuration management system that
would allow the applicant and the FAA to ensure that the article being tested satisfied the requirements
in the applicable test plan(s). The current conformity process is very labor intensive and disjointed by
the fact that individual Requests For Conformity (RFC) are frequently required for different tests on the
same test article. Coordinating these RFCs requires significant manual effort, spreadsheets, or even
software for complex aircraft programs. This can be accomplished more quickly and efficiently using an
integrated data management system that links the test plan requirements directly to the test article
configuration and test schedule.
The following FAA Orders were evaluated for applicability to FAA conformity: FAAO 8110.4C, FAAO
8110.41A, FAAO 8110.49, FAAO 8110.105, and FAAO 4040.26A.
The analysis of the current conformity requirements and a description of the configuration management
process are found in the TC/PC ARC Report Out and Conformity White Paper found in Appendix F.3. The
ARC recommends that the appropriate policies, Orders, or other guidance be created or revised to allow
implementation of the configuration management process in lieu of the current conformity
requirements described in FAA Orders. No changes to part 21 would be required to allow for the use of
the configuration management process. In addition, this ARC recommends the following changes to
specific FAA Orders.
Recommendation: It is recommended FAAO 8110.4C, Section 5, be revised to allow use of a
configuration management system as an alternative to the current conformity.
The white paper originally proposed this CM process be described in an Advisory Circular.
However, the current thinking is that it should be a standard similar to the other standards
being proposed for showing compliance. The CM process should consider the following:
Conformity requirements of part 21
The controlled data listed in FAAO 8110.4C, paragraph 5‐3.d
The controlled data listed in FAAO 8110.49, paragraph 4‐3 and 4‐4
Description of Compliance Verification Engineer qualifications, functions, and limitations
Requirements called out on current FAA forms:
o Request for Conformity, FAA Form 8120‐10
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o Conformity Statement, FAA Form 8130‐9
o Conformity Record, FAA Form 8100‐1
o Type Inspection Authorization, FAA Form 8101‐1
o Type Inspection Report, FAA Form 8110‐5,
Recommendation: It is recommended FAAO 8110.49 be revised to remove the specific
conformity requirements found in section 4 and replace it with a reference to FAAO 8110.4 for
acceptable conformity management procedures. This, combined with the recommendation for
FAAO 8110.4, will allow either the existing FAA conformity process or the new FAA approved CM
system as methods for controlling test article configuration.
5.2 AIRPLANE MANUFACTURER MINOR CHANGE APPROVAL PROCESS
The Type Design and Production Certification Working Group minor change review is summarized in
section 3.2 and the complete review and recommendation is found in Appendix F.4. Because of the
significant differences in the procedures that have been accepted from different ACO’s, this would be an
area that the FAA could help industry and the FAA without significant effort. This could provide
significant relief for those companies whose approved processes are particularly onerous.
Recommendation: The FAA should evaluate the Minor Change Approval process defined in the
white paper and issue a policy memo or other statement supporting it as a “method acceptable
to the FAA.” Each company can then decide to either stay with their currently approved process
or adopt this new one.
5.3 APPLICANT SHOWING ONLY PROCESS
The testing and analysis activities that make up a typical certification project vary in difficulty and risk.
In 2007, the FAA proposed via Order IR 8110.102, Implementing Risk Based Resource Targeting (RBT),
that their level of involvement, or that of their designees, could be minimized based on the level of risk,
making use of a tool called RBRT (Risk Based Resource Targeting). The type of risk considered in this
paper is due to either improper test conduct or data analysis and the possibility of compromised data
~ 46 ~
fidelity. In low‐risk projects or low‐risk activities within a project, it may be acceptable from a risk
perspective to accept the applicant’s showing only with no further findings by either the FAA or their
designees.
The TC/PC Applicant Showing Only paper in Appendix F.5 proposes a structure for when applicant
showing only is sufficient considering both the applicant capabilities and the risk of improper test
conduct/data analysis and the resulting potential impact on safety.
Recommendation: The ARC recommends the FAA issue a policy memorandum, Advisory Circular,
or FAA Order to endorse the concept in the Applicant Showing Only white paper with any
adjustments as required.
5.4 USE OF VIDEO RECORDINGS IN TESTING
Just as part 23 has not adequately kept up with technology, neither have some of the certification
processes. When the test witness requirements were written many years ago, the capability to witness
tests real‐time at a location distant from the place of the actual test did not exist as they do today. In
addition, there are numerous examples where today, for safety reasons or inaccessibility, it is possible
to install video equipment to observe and record a test. These latter situations have all been deemed
acceptable. The use of Video Recordings in the Testing white paper Appendix F.6 simply proposes this
capability be extended to any testing unless there is a specific reason provided for not allowing it on
specific tests.
Recommendation: The ARC recommends that new guidance be developed to provide a video
witnessing standard that can be referenced by applicants and FAA personnel, and to provide the
minimum requirements by which video witnessing can be successfully utilized. The following
Advisory Circular should be developed to provide a complete description of the video witnessing
process:
Update policy to endorse the use of video technology in test witnessing
Endorse ADSs on Video Witnessing of Certification Tests
A video test witness standard should consider:
o The types of testing that could most benefit from the use of video witnessing; and
o The minimum parameters discussed in the white paper (Appendix F.5) regarding
coverage, fidelity, and integrity.
5.5 PRODUCTION MANUAL
Creation of the Production Manual (Appendix F.7) was an attempt to help new startup aircraft
companies gain an understanding of some of the basic requirements for such a company. It provides a
template that can be used as a starting point from which the company can expand the guidance as
necessary. It is designed to lead a company to having the necessary procedures in place to obtain a
Production Certificate meeting the requirements of § 21.137. The draft copy provided in Appendix F.7
~ 47 ~
has the basic requirements but could use further refinement to create a standard that could be used by
any new startup company.
Recommendation: The ARC recommends that the Production Manual in Appendix F.7 be turned
over to a group to finalize a standard that can be adopted as guidance for new startup
companies.
5.6 DESIGN ORGANIZATION/PRODUCTION ORGANIZATION HANDBOOK
Although DO/PO handbooks may not be recognized by many as having a direct cost impact on the
certification process, experience has shown that they do in fact have a significant impact. Experience
has shown that those organizations with clear and well organized handbooks can perform the same
certification activities faster and more efficiently than those companies where the handbooks are
incomplete or vague in their guidance. Unclear and/or poorly organized handbooks frequently result in
activities not being accomplished in a consistent manner with regular rework as a consequence.
Additionally, with unclear and/or poorly organized handbooks there are continual questions and
differences of opinions on how things should be accomplished that delay completion of activities. This
adds both time and direct cost to the programs. In addition, although the ODA Order 8100.15 provides
guidance on what should be in an ODA manual there is still a significant amount of local interpretation
that decides what is appropriate.
The Working Group made significant progress on this handbook but it still needs finished. The level of
completion of this task is such that the activity can be handed over to an Airworthiness Design
Standards body for completion.
Recommendation: The ARC recommends that work to date as shown in Appendix F.8 be
transferred to a standards body for completion.
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6.0 ALTERATIONS AND MAINTENANCE WORKING GROUP ‐ RECOMMENDATIONS
6.1 FACILITATION OF SYSTEMS & EQUIPMENT
Recommendations
Systems and Equipment component and installations
certification costs are major impediments to more
widespread installation of new equipment that can
provide significant safety improvements. Reducing this
burden could significantly increase the installation of
such equipment and help improve the safety of all
general aviation aircraft. Refer to Appendix G.2 for the
complete paper discussing Systems and Equipment
concerns.
The ARC recommends the following for Systems and Equipment:
1. Existing guidance should be revised or new guidance written to simplify certification requirements
for non‐required, replacement and emergency‐use‐only systems and equipment. The emphasis
should be on improvement in overall fleet safety from the prevailing level, not attainment of any
arbitrary level of reliability or system function.
2. Certification requirements as expressed in guidance should specifically consider the adverse effects
that accrue from failure to install to offset risk exposure from potential systems and equipment
failure.
3. Guidance should recognize “simple” software and provide
simplified compliance criteria not based on DO‐178().
4. Consideration should be given to amendment of AC
23.1309‐1() to generally relax the DO‐178() and DO‐254()
development assurance level requirements applicable to
part 23 airplanes.
5. Guidance should recognize an accepted relationship
between probability requirements and development
assurance levels and permit their use interchangeably in the system safety assessment process.
6. Realistic credit should be given for all factors related to hazard exposure in showing compliance with
probability and Design Assurance Level (DAL) requirements.
~ 49 ~
7. The existing lightning and HIRF requirements should be re‐evaluated in light of current historical
data and projected installation trends and re‐justified in terms of the environmental exposure of GA
airplanes.
8. Consideration should be given to the provision of standard protective circuits for lightning
protection as acceptable means of compliance.
9. Guidance should be introduced providing a framework for the use of both aviation and non‐aviation
service history for certification credit.
10. A suitable showing of compliance with an
established functional standard should be regarded
as equivalent to compliance with DO‐178() or DO‐
254 Level D.
11. Alternate means of compliance (AMOC) must be
allowed in practice, not just in theory. The FAA
must foster a culture and a process whereby an
AMOC can be encouraged and realistically
evaluated with regard to the basic regulations, not
just in comparison to existing acceptable means.
12. The FAA must ensure that regulations, guidance, training, and management combine to create a
culture that is focused on safety, not process, as the goal. Application of judgment must be
encouraged and supported at all levels. Owners, operators, maintainers, manufacturers, designees,
and FAA personnel must all be able to determine from clear guidance what is permitted with what
level of compliance effort.
6.2 CRITICAL INFORMATION FOR ALTERATIONS & MAINTENANCE
To improve the existing fleet’s safety, it is imperative that operational airplanes be upgraded to meet
the needs of an evolving operational environment. Regardless of the path by which an alteration is
defined and approved, the airplane must continue to comply with the applicable rules under which it
was certified or, in some cases, newer or added rules applicable to the specific alteration. With the
introduction of the new part 23, it is essential that these means be maintained for both new and legacy
airplanes in order to insure continuing access to safety improvements. Refer to Appendix G.2 for the
complete paper discussing this issue.
Recommendations:
1. Recognized industry‐maintained Airworthiness Design Standards (ADS) must be strictly regarded as
acceptable means of compliance. All compliance showings are made only with respect to the
regulations.
~ 50 ~
2. ADS and other means of compliance are not included in the certification basis and need not be listed
in the TCDS.
3. Airplane specifications, performance, operating limitations, etc., that lead to compliance decisions
within the ADS and supporting documents, including tiering, must be listed in the TCDS. Conversely,
ADS and other documents must wherever possible base alternative compliance paths on data that
are listed in the TCDS.
4. Comparable information with regard to alterations, particularly alterations made under STCs, should
be available as part of the airplane’s permanent records.
5. An STC or alteration must be shown to comply with the regulations by means of any acceptable
means of compliance. Use of the specific ADS and/or other documents of the unaltered airplane is
not required.
6. If an existing design approval (i.e. TC, STC) is amended, use of the ADS previously used to establish
compliance with the regulations may be preferred, to the extent that it is applicable to the change,
but is not required. Upgrade to the latest revision of an ADS may be required only under the
conditions that would require a cert basis upgrade under § 21.101.
7. ADS should be regarded as separable. If multiple standards are recognized in overlapping areas,
compliance with the regulations may be shown using them in any combination as long as all of the
compliance requirements applicable to any particular regulation within the chosen standard are
fully met.
8. ADS must be written in such a way as to make it clear what portions address which part 23
requirements. Portions of an ADS that address different part 23 requirements must be kept
separate as much as possible.
9. The approval of an aircraft's manufacturer must not be required in order that an STC or alteration
can be approved.
10. Guidance must clearly indicate that the new part 23 is acceptable for all changes to any airplane
certified under part 23 or any predecessor regulations. Section 21.101(a) indicates that the most
recent amendment can always be used if the applicant so elects. In particular, if a rule in the
certification basis of an airplane has been dropped from the new part 23; continued compliance
cannot be required, though compliance with its replacement or equivalent can. If there is a new
rule that supersedes the old rule, the applicant can use the old part 23 to new part 23 cross
reference table to determine what new part 23 regulation(s) is applicable in a situation like this. If
there is no superseding rule for a rule in the certification basis of a product, then there is no longer a
requirement to comply with the old rule on new projects on that product.
11. A process must be available by which an AMOC to a recognized standard can be proposed and
accepted.
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6.3 14 CFR PART 43 PREVENTATIVE MAINTENANCE
The part 43 provisions on preventive maintenance are outdated, inflexible and confusing, resulting in a
reduction of pilot performance of preventive maintenance below optimal levels. Section 43.3(g) permits
certificated pilots, with the exception of sport pilots, to perform specific preventive maintenance (PM)
operations on aircraft that they own or operate under part 91. These PM operations are limited to
those listed in part 43 Appendix A Section (c). Other sections of part 43 permit the pilot to return the
airplane to service following PM performance PM and record keeping requirements. In addition to the
rules, there are also two Advisory Circulars with content on PM: AC 439C, Maintenance Records and AC
43‐12A, Preventive Maintenance.
At present, part 43 does not include “other operations acceptable to the Administrator” in its definition
of preventive maintenance. This language is often included in the regulations in order to grant the FAA
flexibility in dealing with rapidly changing or extraordinary circumstances. Because “other means” is not
included in the regulations and because the list of authorized preventive maintenance operations is
contained within the regulations, it is difficult and time consuming for the FAA to adapt to technological
and other changes.
With the introduction of sweeping new content in a revised part 23, the FAA will face such a situation of
change. Moreover, the incorporation of new technology on airplanes has already led to difficulties in
this area. Additional advances in technology may be inhibited if the regulatory criteria governing
preventive maintenance are not modernized. Thus, changes to part 43 that increase the safe availability
of pilot‐performed preventive maintenance are supportive of the ARC’s goals. For the complete paper
on Preventive Maintenance, see Appendix G.1.
Recommendations
1. Part 43 should be changed to include “other operations acceptable to the Administrator” as
preventive maintenance under § 43.3(g).
2. The basic list of preventive maintenance operations contained in part 43 Appendix A should remain
in the regulations to guarantee availability of a well‐defined minimum set of authorized operations.
3. AC 43‐12() should be revised to:
a. emphasize the availability of preventive maintenance operations to pilots,
b. clarify the basic list of authorized PM operations,
c. establish conditions under which aircraft and equipment manufacturers may propose additional
PM operations and procedures for their safe performance for FAA acceptance, and
d. encourage manufacturers to propose such operations and procedures.
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6.4 PRIMARY NON‐COMMERCIAL CATEGORY
The Primary Non‐Commercial Category is intended for the private owner to operate their aircraft in a
substantially less burdensome and costly manner by reducing the level of FAA maintenance and
alteration requirements to a level appropriate for a privately owned vehicle.
Recommendation: The FAA create a Primary Non‐Commercial Category under 14 CFR part 21.
The Primary Non‐Commercial Category is intended for the private owner to operate their aircraft in
a substantially less burdensome and costly manner by reducing the level of FAA maintenance and
alteration requirements to a level appropriate for a privately owned vehicle.
~ 53 ~
7.0 CERTIFICATION COST / BENEFIT OVERVIEW
7.1 REGULATION AND STANDARD CHANGES
Today, each national authority adopts either the FAA’s part 23 or EASA’s CS‐23 or they develop their
own requirements that are largely equivalent. The different requirements translate into a cumbersome
comparison process when importing into or exporting from the US. Not only is this process time
consuming for applicants, but it also has to be validated by the authorities, which also takes time and
resources.
The ARC’s proposal for harmonization of part 23 with other CAA’s small airplane regulations such as
EASA CS 23, Canada’s AWM 523, National Civil Aviation Agency (ANAC) – Brazil’s RBAC 23, Civil Aviation
Agency of China’s (CAAC) part 23, New Zealand’s (NZ) part 23 and other CAA’s small airplane regulations
should reduce the costs associated with validation after the initial transition. The proposal should make
it easier for the US to harmonize top‐level language with foreign authorities. Furthermore, the
development of consensus standards that are accepted by the FAA and other regulatory authorities
could significantly reduce the validation burden on the applicant. They should no longer be required to
have authority‐by‐authority differences that are unpredictable and add cost and time to getting their
airplane to the market. The current lack of harmonization between authorities can add delays in
certification validation and add compliance and/or test costs to both the applicant and the regulatory
agencies involved. This added time can easily range from 1‐6 months.
Domestically, the long‐term benefit of harmonizing part 23 is the reduced numbers of special conditions
(SC), exemptions and equivalent ELOS findings that need to be processed internally by the FAA. A set of
special conditions can easily take the FAA up to one year to develop, and during that time, the applicant
is not able to bring their product to market. An ELOS finding or exemption can take the FAA between 4‐
12 months to develop and approve. The applicant will spend roughly the same amount of time as the
FAA in proposing what they need and responding to FAA questions and proposal a SC, exemption, or
ELOS. Clearly, there is a cost to industry due to this "loitering" time. For a complicated set of Special
Conditions, the FAA might commit, on average, half to three‐quarters of a man‐year to seeing the item
through completion. That time consists of the actual technical work as well as management and legal
review. Generally in these situations the applicant is forced to proceed at risk with the understanding
that when the final rule is issued, they may have to do additional analysis or tests. Ultimately, this may
result in a delay for the applicant of potentially 1‐4 months, or even more for complex special
conditions, and 2 to 6 weeks for ELOS or exemptions.
Table 7.1 highlights the past 7 years of special conditions, exemptions, and equivalent safety findings.
~ 54 ~
Table 7.1 – Special Conditions, Exemptions, Equivalent Safety Findings
2006‐ 2006‐
2006 2007 2008 2009 2010 2011 2012 2012 2012
Totals Average
Proposed
Special 7 5 5 3 3 2 1 26 4
Conditions
Final Special
22 21 15 9 8 4 2 81 12
Conditions
Total 36 47 46 39 48 26 17 259 37
Note 1: Using the average number of special conditions, exemptions, and ELOS from the above table, it
is seen that on average these items are costing the FAA approximately the following:
Note 2: Final Special Conditions – (12/year)(3 months/special condition) = 4 man‐years of work per year
for the FAA
Note 3: Exemptions – (5/year)(6 months est.)/(12 months/year) = 2.5 man‐years of work for the FAA
Note 4: ELOS – (17/year)(3 months avg./ELOS)/(12 months/year) = 4.25 man‐years of work for the FAA
Note 5: The FAA total man‐years effort is thus estimated to be approximately 10.74 man‐years of work
per year.
7.2 COST ESTIMATES
Following are some of the potential certification cost benefits that could be realized from the proposed
revision to part 23 and the other proposals. Table 7.2 summarized the savings for the proposals put
forth by the TC/PC Working Group. Table 7.3 in section 7.6 summarizes potential certification cost
Savings Estimates.
Typical development costs for a new airplane or a derivative can run from $1M to $3M per month while
typical development and certification costs for major changes can run from $250,000 to $500,000 per
month.
Revising the regulations to make them basic safety regulations to allow changes in technology without
the necessity to change the regulations can reduce costs and should result in:
1. Fewer, if any, special conditions, ELOSs, and exemptions, since the standards can be revised
quickly to provide an acceptable means of compliance for any new technology and that
standard becomes available for all to use.
2. Eliminating, or significantly reducing, applicant time to obtain a means of compliance
agreement with the authority.
~ 55 ~
3. Eliminating inconsistency in interpretation of the rules across any one authority, or between
authorities.
Table 7.2 – Summary of TC/PC Cost Savings Estimates
TC/PC Proposed Change Description of Cost Savings
FAA Conformity Direct type certification conformity expense savings for the applicant
is approximately 2.8 to 8 full time personnel depending on the
complexity of the project. Travel savings of $40,000 per year during
routine times to $200,000 per month during peak type certification
efforts. Savings for the FAA were estimated to be from 0.9 to 3
people if the FAA does not have to review RFC paperwork and can be
even more if the FAA makes full use of designees for inspections.
Since the Configuration Management process does not rely on issuing
a Request for Conformity (RFC) for each test, but links the
configuration directly to the test requirements, it provides a
continuous test article status and identifies what tests may be run at
any time. On configuration‐managed projects the FAA would simply
monitor the test condition requirements and the configuration rather
than reviewing RFCs against the test conditions and test article
configuration if they felt the need to do so. This would then eliminate
the need for the FAA to manage any RFCs on configuration‐managed
projects and only review the information as part of an audit and
potentially save the FAA time and money.
Minor Change Approval One company that has a more onerous minor change approval
process agreed to by their ACO stated they review approximately
2000 minor changes per year. They expect to save over $100,000 per
year through this proposed process. Another company has a process
that their ACO, which is different from the first company’s ACO, has
agreed to for which the proposed process would not provide any
significant savings.
Applicant Showing Only For a company with a single product line, this is estimated to be
approximately $50,000 per program. For a company with multiple
product lines, savings approximately $250,000 per year are
anticipated. Additional savings due to the ability to use critical
designee resources for higher‐level safety enhancing activities were
not quantified.
For the FAA, this could mean reviewing fewer compliance reports for
those things they have agreed the applicant has demonstrated the
ability to show compliance adequately.
Use of Video Recordings in Travel expenses for applicants easily could be reduced by $40,000 or
Testing more per project depending on the quantity of tests. This includes
designee travel and remote third party testing.
For the FAA this could mean watching testing from their office rather
than having to travel to the test site when they have indicated they
~ 56 ~
TC/PC Proposed Change Description of Cost Savings
wish to observe the test.
Design Organization / This handbook is essentially a template that guides the applicant on
Production Organization how to structure their procedures manual. It is designed to allow a
Handbook including Simplified company to start out with only minimum requirements and grow it as
Production Certification needed. A new entrant to the aviation field could save $200,000 in
their initial development of manuals and processes using this
handbook. Additional savings for routine maintenance were not
quantified.
Since the handbook provides the same basic requirements for all
applicants, it could mean the FAA spends less time reviewing each
applicant’s handbook and more consistency across all the applicants.
7.3 CERTIFICATION PLAN ACCEPTANCE
Another area that has not been discussed previously is certification plan acceptance. It is not unusual
for a certification plan to wait for FAA approval for 3‐5 months on relatively small planes to over a year
for new airplanes or major derivatives. Certification plan approval is frequently held up while waiting
for special conditions, exemptions, or ELOS issues to be resolved. But they are also frequently held up
because the FAA has continued to ask for more and more detailed compliance information on individual
sections of the airplane to be provided before they will grant approval on the certification plan. The
adoption of this ARC recommendations and their use by the applicants and the FAA should help reduce
this wait time.
7.4 FAA SEQUENCE LIST
The FAA sequencing list is another area that is very costly to the industry. The delays in getting approval
to work on a project with the FAA can take up to several months to over a year. This forces the
applicant to go into a holding mode or to proceed at risk and hope that the FAA will approve the project
in a reasonable time. As in the certification plan approval process, the ARC recommendations, if
enacted, could help relieve the FAA of some burden that is forcing projects to go onto the sequencing
list and perhaps allow more projects to be approved sooner; eliminating the need for them to go on the
sequence list at all.
7.5 FOREIGN VALIDATION COSTS
Harmonization of the part 23 regulations across all international CAAs along with the internationally
accepted standards has the potential to have a significant positive impact on both the time and cost
involved with foreign validation. For instance, a new clean sheet design can easily cost $0.5‐2M to
validate in the different countries, depending on the aircraft. Harmonization could potentially cut this
cost by 85‐90%.
~ 57 ~
The time it takes to obtain validation delays potential sales into that country adding more delay costs, or
loss of income, to the manufacturer. Harmonization and concurrent certification and validation could
potentially eliminate this additional cost.
Validation of subsequent changes to an airplane cost could also potentially be reduced by 65‐75%.
7.6 SUMMARY OF COSTS
The costs shown in Table 7.3 are estimated costs for one item or one applicant and in most cases are
probably conservative. When these numbers are multiplied by the total number of projects the FAA is
involved in each year, the FAA required manpower and costs become significant. For the applicant, the
costs must be multiplied by the numbers of each of the items affecting the applicant each year. For the
applicant this frequently translates into, not only direct operating costs, but delayed delivery of product
to market costs.
For simplicity, the estimated average cost per hour will be assumed to be $100.00 per hour for both the
FAA and industry. This will include direct pay plus benefits.
Table 7.3 Cost Summary
Directorate ACO Applicant Total
Item Range
Dollars/Each Dollars/Each Dollars Dollars/Each
~ 58 ~
~ 59 ~
8.0 SUMMARY
The 14 CFR Part 23 Reorganization ARC participants
have worked diligently for the past year and a half to
develop recommendations for revision to part 23 that
have the potential to significantly improve the safety of
the general aviation fleet while at the same time
reducing the time and cost involved in the certification
process. In addition to the recommended changes to
part 23, there are proposals to help reduce the
certification costs through more standardization of certification processes and reducing or eliminating
activities that provide no added value. Much of the latter can be accomplished without requiring
changes to the existing regulations, but rather through better guidance that allows more flexibility in
showing compliance to the requirements of parts 21, 23, and 43.
The recommended changes to part 23 are the cornerstone to achieving the underlying safety goals of
this ARC effort, but if the changes are done in isolation or piecemeal fashion, the safety improvement
and cost savings goals of the ARC will not be achieved. Cost savings encourage not only new airplanes
but the modernization of the existing fleet. Airworthiness design standard development will drive the
innovation needed for safety and international buy‐in to this approach. All of these efforts are needed,
as a package, to achieve the goals of this ARC.
The following list includes things that could be implemented quickly and relatively easily with no
changes to parts 21, 23, or 43, but simply with policy letters or changes to FAA Orders or ACs that could
potentially save the industry and the FAA considerable time and money.
1. Configuration Management in place of the current conformity requirements in FAA Order
8110.4 and other FAA Orders. See section 5.1.
2. Minor Change process using a consistent process across all ACOs as proposed in section 5.2.
3. Applicant Showing Only following recently approved changes to part 21 that have not been
understood or accepted by all FAA or industry participants. See section 5.3.
4. Video test witnessing as described in section 5.4.
5. Use of the Standard DO/PO Handbook as an acceptable means of meeting the requirements
for an ODA or other manuals required by the FAA for approved organizations. See section 5.5.
The future of general aviation depends on the FAA taking bold action to implement the
recommendations contained in this report. Without such action general aviation will continue to
decline. With it will go many jobs and an important means of transportation that benefits the entire
country. General aviation provides exports that significantly help the U.S. balance of trade.
~ 60 ~
~ 61 ~
Appendix A
APPENDIX A – TEAM MEMBERS
Name Organization
Allen Lyon Transport Canada
Andrew Barker TruTrak
Andy Supine Cessna
Anne Guisen EASA
Blake Cheney TCCA (AARTC)
Boudewijn Deuss EASA
Boyd Rodeman Cessna
Brian Hancock FAA
Brian Richardet Cessna
Bruce Mahone SAE
Bruno Rigaud Socata
Cesar Hess ANAC ‐ Brazil
Charlie Fellows FAA
Chris Durkin Honeywell
Chris Mitchell Cirrus
Christophe Robin Socata
Chuck Swanson Sensenich Propeller
Clay Barber Garmin
Cristiano Villa ANAC – Brazil
Cyrille Rosay ANAC
Damian Hischier Top‐View Aerospace
Dan Schultz ASTM
Dan Schwinn Avidyne
Dave Gill NZCAA
Dave Magruder FAA
David Armstrong Garmin
David Gribble Rockwell‐Collins
David Leedom Rockwell‐Collins
David Stevens Quest Aircraft
Dieter Koehler Flight Design
Don Wernert Hawker Beechcraft
Doug Edwards FAA
Edilson Manacero ANAC ‐ Brazil
Edmond Boullay Dassault Falcon
Eric Leaver Cub Crafters
Eric Tucker Rotax
Fausto Enokibara ANAC ‐ Brazil
Frank Keefer Hawker Beechcraft
~ 62 ~
Appendix A
Name Organization
Fred Barber Avidyne
Frederic Darcy Socata
George Braly GAMI
George Zografos EASA – Germany
Greg Bowles GAMA
Gu Baodong Chinese CAA
H.G. Frautschy EAA
Henk Pruis EASA
Jacqueline Jambor FAA – SAD
Jamie Slippy Quest Aircraft
Jean Rene Lepage Transport Canada
Jim Brady FAA
Joel Heck Cessna
John Wiseman Transport Canada
Joost List Diamond Aircraft
Keith Chatten Continental Motors
Kerri Hinton Kestrel
Kevin Bruce Diamond Aircraft
Kristine Hartzell AOPA
Ky Ngo FAA
Larry Van Dyke Consultant
Les Taylor FAA‐SAD
Lowell Foster FAA‐SAD
Luca Ciccolari‐Micaldi Hawker Beechcraft
Manfred Reichel EASA
Marcos Rama ANAC ‐ Brazil
Mark Giron FAA
Mark James FAA
Matthias Betsch Flight Design
Mike Reyer FAA‐SAD
Nick Bogner Bendix‐King Avionics
Nick Guida Tamarack Aero
Nick Roe EASA
Oliver Reinhardt Flight Design
Pat Mullen FAA‐SAD
Paul McLoughlin Hawker Beechcraft
Pedro Donato ANAC ‐ Brazil
Pete Rouse FAA‐SAD
Peter Buck Lockheed Martin
Peter Lyons Avionyx S.A.
~ 63 ~
Appendix A
Name Organization
Plinio Ribeiro ANAC ‐ Brazil
Randy Griffith Honda
Randy Shields Hawker Beechcraft
Ray Best Hawker Beechcraft
Ric Peri AEA
Ricardo Dupont ANAC ‐ Brazil
Robert Grove Garmin
Robert Hackman AOPA
Robert Murray Garmin
Romain Mbwang Sepoh SOCATA
Scott Fohrman NATCA (FAA)
Sean Elliott EAA
Sidney Bauguess Cessna
Stephane Jacques Socata
Steve Flanagan FAA: AIR‐110 (Cert Proc)
Steve Litke NATCA (FAA)
Steve Serfling Kestrel
Steven Rosenfeld NATCA (FAA)
T Jetheri Rockwell Collins
Tom Peghiny Flight Design
Wang Peng CAAC
Wes Ryan FAA‐SAD
Wulf‐Ingo Goesling EASA
Yves Borgeaud Socata
Zhu Xuefeng CAAC
~ 64 ~
Appendix B
APPENDIX B – ACRONYMS
A&M Alterations and Maintenance
AEO All Engines Operating
AOPA Aircraft Owners and Pilots Association
AC Advisory Circular
ACO Aircraft Certification Office
AD Airworthiness Directive
ADS Airworthiness Design Standards
AEA Aircraft Electronics Association
AFS Flight Standards Service
AML Approved Model List
AMOC Alternate Means of Compliance
AMWG Alterations and Maintenance Working Group
ARC Aviation Rulemaking Committee
ASTM American Society for Testing and Materials
CAA Civil Aviation Authority
CAM Civil Aeronautics Manual
CAR Civil Air Regulation
CFIT Controlled Flight Into Terrain
CFR Code of Federal Regulations
CG Center of Gravity
COSM Continued Operational Safety Monitoring
CPS Part 23 Certification Process Study
CVR Cockpit Voice Recorder
DAL Design Assurance Level
DER Designated Engineering Representative
DOT Department of Transportation
DO/PO Design Organization/ Production Organization
EAA Experimental Aircraft Association
EAB Experimental Amateur Built
ELOS Equivalent Level of Safety
ELT Emergency Locator Transmitter
EMI Electromagnetic Interference
FAA Federal Aviation Administration
FAR Federal Aviation Regulation
FDR Flight Data Recorder
GA General Aviation
GAMA General Aviation Manufacturers Association
GPS Global Positioning System
HF High Frequency
HIRF High Intensity Radio Frequency
IA Inspection Authority
ICA Instructions for Continued Airworthiness
ICAO International Civil Aviation Organization
LSA Light Sport Aircraft
MD Dive speed in Mach
MTOW Maximum Take‐off Weight
~ 65 ~
Appendix B
ODA Organization Designation Authorization
OEI One Engine Inoperative
OEM Original Equipment Manufacturers
QMS Quality Management System
PC Production Certification
PO Purchase Order
SC Special Condition
SMS Safety Management System
STC Supplemental Type Certificate
TC Type Certification
TCDS Type Certification Data Sheet
UM ODA Unit Member
U.S. United States
VA Maneuvering speed
VD Dive speed in knots
~ 66 ~
Appendix C
APPENDIX C – 14 CFR PART 23 REORGANIZATION ARC CHARTER
U.S. DEPARTMENT OF TRANSPORTATION
FEDERAL AVIATION ADMINISTRATION
ARC Charter
Effective Date:
AUG 1 6 2011
l. Purpose of this Charter. This charter creates the Title 14 Code of Federal Regulations (CfR) Part
23 Reorganization Aviation Rulemaking Committee according to the authority of the Administrator of
the Federal Aviation Administration (FAA) under Title 49 of the United States Code (49 U.S.C.)
§ I 06(p)(5). This charter also outlines the committee' s organization, responsibilities, and tasks.
2. Audience. This charter applies to industry and government organizations involved in the part 23
reorganization effort to include employees within the Office of the Associate Administrator for
Aviation Safety.
3. Where to Find tbjs Charter. You can find this charter on the FAA website at
http://www.faa.gov/about/committeeslrulemaking.
4. Background. Historically, the FAA has hosted regulatory reviews for part 23 about every I0 years.
The two most recent part 23 reviews were performed in 1974 and 1984. In 2008, the FAA initiated the
current, ongoing review process by starting with the Part 23 Certification Process Study (CPS).
The CPS team reviewed part 23 and Civil Air Regulations, Part 3 (CAR 3) airplanes, considering their
lifecycle, and made recommendations based on current and anticipated products. The challenge was to
determine the future of part 23, considering current and anticipated products, twenty years from then.
This led to one of the major recommendations from the study: reorganize part 23 using performance and
complexity criteria instead oftoday's weight and propulsion-based divisions. When the Civil
Aeronautics Administration adopted CAR 3 standards, airplane construction methods and operations
were narrowly focused; likewise, their performance parameters were narrow. As aviation technology
progressed, construction methods, performance, and complexity evolved yielding significant advances in
the normal, utility, acrobatic, and commuter categories.
The CPS team's objective was to assess the adequacy of the various operations and airworthiness
processes currently in place throughout the airplane·s service life and to identifY process improvements.
The team has made recommendations for long-term improvements; and encouraged implementation of
ncar-term, easy to address improvements.
The general aviation fleet is comprised of over 200,000 airplanes. Therefore, most recommendations
focused on keeping the existing fleet safe. This includes upgrading and maintaining airplanes with better
systems, newer avionics, and the latest safety equipment (e.g., ballistic parachutes and inflatable
restraints). In addition, Part 23 revisions should make it easier to install safety-enhancing equipment in
older airplanes. This concept carried into the public meetings that took place in 2010, the year following
the release of the Part 23 Certification Process Study.
~ 67 ~
Appendix C
In 2010, the FAA's Small Airplane Directorate hosted two public meetings. Embry-Riddle Aeronautical
University hosted a third meeting in addition to industry and trade-group focused meetings. The
objective of these meetings was to share the fmdings/recommendations from the certification process
study and ask the public for feedback. Overall, the feedback was supportive of our recommendations and
in some cases augmented the findings. One significant difference between the CPS findings and the
public feedback was that the public focused on the need to address the light/simple airplanes in part 23.
Over the past two decades, part 23 has been shifting in complexity towards complex, high performance
airplanes, which has placed increasing burden on simple airplane certification. Therefore, the public
focus was on reducing simple airplane certification costs and time burden through resetting requirements
to an appropriate level based on safety risk. The safety risk for most simple, proven airplane designs is
typically low. There was very little feedback regarding the high performance end of part 23.
The FAA has developed the following plan based on recommendations from the Part 23 Certification
Process Study and the public/industry feedback meetings. This plan focuses on the major regulatory
recommendation from the Part 23 Certification Process Study - reorganizing part 23.
5. Organization and Administration of the Part 23 Reorganization ARC. The FAA will establish a
committee of members from the aviation community and other aviation airworthiness authorities. FAA
participation and support will come from all affected lines-of-business. Where necessary, the committee
may set up specialized work groups that include at least one committee member and invited subject
matter experts from industry and government.
(I) Appoints members or organizations to the committee, at the manager's sole discretion;
(2) Receives all committee recommendations and reports;
(3) Selects industry and FAA co-chairpersons for the committee; and
(4) Provides administrative support for the committee through the Aircraft Certification Service.
(1) Determine (with other committee members) when a meeting is required (a quorum is desirable
at committee meetings, but not required);
(2) Arrange notification to all members of the time and place of each meeting;
(3) Draft an agenda for each meeting and conduct the meeting;
(4) Keep meeting minutes; and
(5) Provide quarterly status updates to the Manager, Small Airplane Directorate from the effective
date of this charter.
2
~ 68 ~
Appendix C
6. Committee Membership
a. The committee will consist of members from the Federal Aviation Administration including
members from the Small Airplane Directorate (ACE-I 00), Aircraft Certification (AIR-I 00 and AIR-
200), and Flight Standards Service (AFS-200, AFS-300, and AFS-800). It will also consist of about 20
members, representing manufacturers of part 23 airplanes, part 23 equipment, Jjght sport airplanes,
aviation associations, and foreign aviation authorities. Foreign authorities will serve as observers only.
b. Each member or participant on the committee should represent an identified aviation community
segment with the authority to speak for that segment. To promote discussions, membership on the
committee will be limited. Active participation and commitment by members is essential for achieving
the committee objectives and for continued membership on the committee. The committee may invite
additional participants as subject matter experts to support specialized work groups.
7. Public Participation. Persons or organizations outside the committee who wish to attend a meeting
must get approval in advance of the meeting from a committee co-chairperson.
a. The committee advises and provides written recommendations to the Manager, Small Airplane
Directorate, ACE-I 00.
b. Committee tasks include, but are not limited to, the following:
(I) Consider the Part 23 Certification Process Study recommendations 1.1.1 and 1.1.2.
a. The first tier should contain the requirements for low-complexity, low-performance
airplanes and it should act as a basic starting point for all other categories. These
basic requirements could be general with compliance methods maintained in industry
and government standards referenced by regulation or policy. The simple product
category would naturally fall in a lower oversight risk category allowing the FAA to
perform more oversight on products in more complex, higher performance tiers.
b. The next tier(s) should incorporate the requirements of the previous tier and add
unique requirements for medium-complexity, medium-performance airplanes. These
requirements could also be general with compliance methods maintained in industry
and government standards referenced by regulation or policy.
3
~ 69 ~
Appendix C
c. The highest tier should incorporate the requirements of the previous tiers and add
unique regulatory requirements for high-complexity, high-performance airplanes.
The highest product category would fall in an elevated oversight risk category that
would require an increased level of oversight as compared to the more simple
categories. Human factors standards related to maintenance and operation increase as
the tier risk increases.
(2) The committee may propose additional tasks to the Manager, Small Airplane Directorate.
(3) The ARC will submit a report detailing recommendations for tasks (l) and (2) no later than 18
months from the effective date of this charter. The Manager, Small Aitplane Directorate, may
extend this deadline up to 6 months if it is in the FAA's interest to do so.
9. Cost and Compensation. The estimated consetvative cost to the Federal Government is
approximately $50,000. Initial plans call for face-to-face meetings every other month. Bi-weekly
telecons and/or polycoms will supplement these face-to-face meetings. Most meetings will take place in
Washington, DC, to maximize participation from AIR-I 00, AIR-200, and AFS. All travel costs for
Government employees will be the responsibility of the employee's organization. Non-government
representatives setve without government compensation and bear all costs related to their participation.
10. Availability of Records. Consistent with the Freedom oflnformation Act, Title 5, U.S.C.,
section 522, records, reports, agendas, working papers, and other documents that are made available
to or prepared for or by the committee will be available for public inspection and copying at the
FAA Small Aitplane Directorate, 901 Locust, Kansas City, Missouri 64106. Fees will be charged for
information furnished to the public according to the fee schedule published in Title 49 of the Code
of Federal Regulations, part 7.
11. Committee Tenn. This committee becomes an entity on the effective date of this charter. The
committee will remain in existence for a term of24 months unless its term is ended sooner or extended
by the Manager, Small Airplane Directorate.
12. Distribution. This charter is distributed to director-level management in the Office of the Associate
Administrator for Aviation Safety, the Office of Aviation Policy and Plans, and the Office of
Rulemaking.
&
~1\.A _ _ ;>
/\ .~-~
strator
~ 70 ~
Appendix D
APPENDIX D – CPS REPORT EXECUTIVE SUMMARY
~ 71 ~
Appendix D
Executive Summary
Background
The primary objective of the part 23 Certification Process Study (CPS) was to assess the
adequacy of the current airworthiness standards throughout a small airplane's seiVice life while
anticipating future requirements_ Working groups comprised of various members of the aviation
industry were assigned to the five areas of this study to identify issues and develop
recommendations_The study was not limited to certification standards; study team members
reviewed other topics affecting general aviation including pilot training, operations, and
maintenance_
11Iis section of the report addresses perfonnance-based standards for part 23 airplanes _Part 23
currently differentiates airplane requirements based on engine type and airplane weight which
does not address the operational capabilities oftoday' s high-performance small airplane_
Historically, part 25 airplanes had technologies that for cost and weight reasons were not
practical for part 23 airplanes_ Smaller part 23 airplanes were typically simple and slow while
bigger airplanes were more complex and faster. Consequently, the existing approach to standards
based on weight and engine type was effective_ While the existing approach has produced safe
airplanes for decades, technological advances have changed the original assumptions of the part
23 divisions_The new small turbine engines, composite airframes, and lightweight digital
electronics offer part 23 airplanes the operational capability and performance of traditionally
larger part 25 airplanes. Part 23 standards have evolved beyond their original intent to address
the increasing perfonnance and complexity. Unfortunately, the slow, simple part 23 airplanes
have suffered as the s tandards have shifted towards more complex airplanes_ These findings led
to two major recommendations:
6
~ 72 ~
Appendix D
Design Certification
This section describes the challenges in meeting procedural requirements for the issue of type
certificates. It also addresses changes to those certificates and changes affecting the type design
of type-certified products and aviation articles like avionics.
The bulk of this section and the associated recommendations address the challenges of keeping
older airplanes operating safely. This includes upgrading airplanes \vith better systems (e.g.,
alternators), newer avionics (e.g., NextGen, navigation, infonnation, or redundancy), and safety
gear (e.g., ballistic parachutes and inflatable restraints). A parallel set of reconunendations
address maintenance of new equipment that the original manufacturer never envisioned being
installed on their airplane.
The recommendations from this section include but are not limited to the follov.ring:
This section addresses problems associated with airframes staying in service for half a century or
more. Considering lengthy service lives, what needs to be done for composites, life-limited parts,
and increasingly integrated electronic airplanes? A growing concem for O\vners of older
airplanes involves kno-v.ring the service history of parts and components that are sold as
airworthy. Few parts have life-limits and even fewer small airplane parts have in-service hours
tracked. Existing mles and guidance for the maintenance of part 23 airplanes do not accmmt for
the actual age of the airplanes and how the maintenance needs change as the airplan("S age.
~ 73 ~
Appendix D
• Issuing policy that would allow the use of accepted industry or government
standards (ASTM, DOT, etc.) in an alternation or modification of a product
that exceeds the original standards created under CAR 3. 1his policy would
also accept the declaration of the material manufacturer with regard to the
accepted standard.
Data l\lanagement
1his section focuses on existing data management tools and our involvement in their evolution.
The Data Management working group built on several existing data efforts . A major safety
concern is that the average fleet age for part 23 airplanes is already over 40 years old.
Furthermore, as newer airplanes age, they \vill include technologies we have no long term
experience maintaining. These technologies include composite airframes and integrated avionics
and engine controls that use large munbers of microprocessors. The SeiVice Difficulty Reporting
(SDR) program needs improvement. Currently, this program has linlited success. Unfortunately,
it was built when technology in aviation was limited. So today, many new critical areas need to
be added where problems should be reported.
Additionally, one of the important elements of the FAA Safety Management System (SMS)
effort is developing better tools to conduct Continued Operational Safety (COS) tasks. The
Monitor Safety Analyze Data (MSAD) team designed an application to address this need. The
MSAD tool relies upon various databases such as the SDR database for both maintenance and
operational in-service data to perform quantitative-based analysis to determine the level of risk
and appropriate mitigation actions. This requires a more progressive approach to data collection
and management. The recommendations in this section include greater involvement with these
and evolving programs.
~ 74 ~
Appendix D
Pilot lntt>rfact>
This st>ction addresses sharing information with pilots from both the airplane certification and
the training and operations disciplines. The Pilot Interface working group was composed of
representatives from the flight test, flight operations, and flight training segments of the industry
and FAA
As the findings show, this working group uncovered several disconnects benveen the
certification and operations world. The recommendations address how to share more pertinent
information from the flight test process with pilots. The intent is to increase pilot awareness of
the data provided through flight testing to ensure pilots understand the information and its
limitations. The recommendations from this section include but are not limited to the following:
a. Current FAA training focuses on maintaining pitch attitude and adding power.
b. Even in high-performance j ets, there may be some parts of the envelope where the
airplane will not recover from the stall with power only.
~ 75 ~
Appendix E
APPENDIX E – 14 CFR PART 23 RECOMMENDED REVISION LANGUAGE
Subpart A General
23.1 Applicability
Scope.
Purpose.
Application.
Requirement.
(a) This part prescribes the airworthiness requirements for the issuance of type certificates, and changes
to those certificates, for airplanes that are limited to seating configurations, excluding pilot seats, of 19
or less and a maximum certificated takeoff weight of 19,000 lbs. or less.
(b) For each aircraft the intended operations and flight envelope must be determined. Throughout the
entirety of this part, this aircraft definition shall be the basis for determining applicability. The aircraft
definition shall include sufficient information such that the applicable requirements of this part can be
determined.
(c) Each person who applies under part 21 for such a certificate or change must show compliance with
the applicable requirements of this part.
Embodies the safety intent of: §§ 23.1 and 23.2 (Amdt 62).
23.3 Special Retroactive Requirements.
Scope.
Purpose.
Application.
Requirement.
(a) Notwithstanding §§ 21.17 and 21.101 of this chapter and irrespective of the type certification basis,
each aircraft having a passenger seating configuration, excluding pilot seats, of nine or less,
manufactured after December 12, 1986, or any such foreign airplane for entry into the United States
must provide a safety belt and shoulder harness for each occupant which will protect the occupant from
serious head injury when subjected to emergency landing loads.
(b) For the purpose of this section, the date of manufacture is:
(1) The date the inspection acceptance records, or equivalent, reflect that the airplane is complete and
meets the FAA approved type design data; or
~ 76 ~
Appendix E
(2) In the case of a foreign manufactured airplane, the date the foreign civil airworthiness authority
certifies the airplane is complete and issues an original standard airworthiness certificate, or the
equivalent in that country.
Embodies the safety intent of 23.2 (Amdt 62).
23.5 Acceptable Standards.
Scope.
Purpose.
Application.
Requirement.
(a) Compliance to the requirements specified in this part can be accomplished through standards or
other means that are acceptable to the Administrator.
(b) The standards may include a tiered structure to allow requirements appropriate to the aircraft
design, construction and intended use.
(c) Acceptable standards may be developed by an industry organization or by an individual applicant.
Subpart B – Flight
23.21 Proof of compliance.
Scope. This section ties the operating characteristics defined “as required” by Subpart A to the
requirements of this Subpart.
Purpose. The purpose of this section is to ensure that all parameters that influence performance and
stability and control be considered in the showing of compliance within all of Subpart B. Beginning at
Amdt xx, a requirement is added in Subpart A to define all these relevant parameters. Certain values of
these parameters are defined as operating limitations and flight testing requirements.
Application. This section applies to all part 23 airplanes.
Requirement.
Each requirement of this Subpart must be met throughout the operating envelope of the airplane,
defined “as required” by Subpart A. This must be shown:
(a) By tests upon an airplane representative of the type for which certification is requested, or by
calculations based on, and equal in accuracy to, the results of testing; and,
(b) By systematic investigation of each probable combination of flight parameters within the operating
envelope to be approved, if compliance cannot be reasonably inferred from combinations investigated.
~ 77 ~
Appendix E
23.45 Performance.
Scope. This section establishes overall criteria for the showing of compliance with performance
requirements.
Purpose. The purpose of this section is to clarify the particular criteria for the determination of all
performance data required to be determined or achieved by this Subpart. Additionally, the intent is to
ensure that when using procedures established as required by Subpart A, a pilot with typical skills can
achieve the performance determined under the requirements of this Subpart and presented to the pilot
as required by Subpart G.
Application. This section applies to all part 23 airplanes.
Requirement.
(a) The performance requirements of this part must be met for the ambient atmospheric conditions
appropriate for the type of airplane for which certification is requested.
(b) In determining the performance data of this part, the conditions and procedures appropriate for the
type of airplane for which certification is requested must be followed.
(c) The performance data of this part must be determined in such a manner that their reproduction shall
not require exceptional pilot skill or strength, or exceptionally favorable conditions.
23.49 Stalling speed.
Scope. This section establishes a requirement to determine stall speeds to be used throughout this part.
Purpose. Stall speeds are used as the basis for many operating speeds and limiting speeds in the
development of various elements of airplane performance and also provide a basis for determining
energy in emergency landing conditions. Therefore, it is required to determine these speeds as a part of
showing compliance with the requirements of this Subpart.
Application. This section applies to all part 23 airplanes.
Requirement.
For the configurations appropriate for each stage of flight (e.g., take‐off, en route, approach, and
landing), the stalling speeds or the minimum steady flight speeds at which the airplane is controllable
must be determined.
23.53 Takeoff.
Scope. This section addresses to All Engines Operating (AEO) and One Engine Inoperative (OEI) takeoff
and takeoff flight path performance.
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Appendix E
Purpose. Takeoff distance and procedures information are necessary for safe operation of all airplanes.
Therefore, both distance and procedures data are required to be developed for use in takeoff planning.
The effects of airplane weight, field temperature and elevation, winds, runway gradient and runway
surface need to be included because of their affect on performance. Additionally, engine failures must
be considered for multi‐engine airplanes. Conservative takeoff distance and takeoff path data are
acceptable since they increase safety.
Application. This section applies to all part 23 airplanes.
Requirement.
The following must be determined:
(a) The distance required for safe takeoff operations;
(b) Takeoff speeds and procedures that allow safe takeoff operations considering margins to the stall
speeds and, in case of the sudden failure of the critical engine on a multi‐engine airplane, to the
minimum control speeds.
23.63 Climb.
Scope. This section addresses all the requirements for climb including all engines operating, engine
failures, enroute climb and descent, glide, and balked landing.
Purpose. Climb performance data is necessary for the safe operation of all airplanes. This section
requires certain climb performance data be provided to the pilot and that the airplane be capable of
certain climb capabilities. The effect of weight, as well as altitude, temperature and other atmospheric
conditions must be considered. Conservative data is acceptable since it results in greater safety. Metric
performance requirements can be a function of the operational risks encountered by the airplane in
service.
Application. This section applies to all part 23 airplanes.
Requirement.
(a) The airplane must meet the minimum climb performance requirements appropriate for the type of
airplane for which certification is requested.
(b) The takeoff flight path must be determined, if applicable to the characteristics of the airplane as
required to be defined by Subpart A.
23.75 Landing.
Scope. This section addresses landing distance performance.
Purpose. Landing distance information is necessary for safe operation of all airplanes. The resolution of
that data, however, may be variable based on conservatism demonstrated to exist in the data.
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Appendix E
Additionally, the effects of airplane weight, field temperature and elevation, winds, runway gradient and
runway surface need to be included in the performance date because of their affect on performance.
Clearly conservative landing distance data are acceptable since they lead to increased safety.
Application. This section applies to all part 23 airplanes.
Requirement.
The following must be determined:
(a) The horizontal distance necessary to land and come to a complete stop from the screen height above
the landing surface.
(b) Speeds and procedures that allow a safe landing considering margins to the stall speeds and, in case
of the sudden failure of the critical engine on a multi‐engine airplane, to the minimum control speeds.
23.143 Controllability and maneuverability.
Scope. This section addresses the safety related airplane flight characteristics which allow a pilot to
safely maneuver the airplane and control flight path.
Purpose. The intent of this section is to ensure that the maneuvering flight characteristics are safe and
appropriate throughout the flight envelope and the maneuverability results in repeatable and smooth
transitions between turns, climbs, descents and level flight. It is also intended that configuration
changes, such as flap extension and retraction, landing gear extension and retraction and spoiler
extension and retraction, along with asymmetric thrust due to engine failure, will result in safe
characteristics owing to the airplane’s controllability characteristics.
Application. This section applies to all part 23 airplanes.
Requirement.
(a) The airplane must be safely controllable and maneuverable during all flight phases.
(b) It must be possible to make a smooth transition from one flight condition to another.
(c) The requirements of paragraphs (a) and (b) of this section must be met, without requiring
exceptional piloting skills, alertness, or strength, throughout, but within, the operating envelope defined
as required by Subpart A (including configuration changes and, for multi‐engine airplanes, the sudden
failure of the critical engine).
23.161 Trim.
Scope. This section pertains to cockpit flight control forces during steady, unaccelerated flight.
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Appendix E
Purpose. The intent of this requirement is to provide for cockpit flight control force characteristics that
do not require excessive concentration by the pilot to maintain a desired speed and flight path to the
detriment of other tasks the pilot must perform for safe flight operations.
Application. This section applies to all part 23 airplanes.
Requirement.
When taking into account the stage of flight:
(a) The airplane must be able to maintain longitudinal, lateral, and directional trim without further force
upon, or movement of, the primary controls or its corresponding trim controls by the pilot, or
(b) If residual forces are exceeding those for prolonged application considered appropriate for airplanes
certificated under this part, those forces shall not be fatiguing or distracting to the pilot.
23.171 Stability.
Scope. This section addresses the airplane’s characteristics associated with airplane stability, or the
tendency to return to steady, unaccelerated flight after being perturbed.
Purpose. The intent of this section is to ensure the airplane has a tendency to remain in, or return to, a
flight condition after it is caused to deviate from that flight condition either by pilot actions or by
atmospheric conditions, unless these deviations are benign. This intent may be achieved by inherent
stability characteristics of the airplane or through augmentation by aircraft systems. It is also intended
that cockpit control stick and pedal forces provide intuitive feedback to the pilot when maneuvering
away from steady, unaccelerated flight.
Application. This section applies to all part 23 airplanes.
Requirement.
The airplane must meet the minimum required longitudinal, lateral and directional stability throughout
its operating envelope. In addition, the airplane must provide suitable stability control “feel” (static
stability) in any condition normally encountered in service, if necessary for safe operation.
23.201 Stall characteristics and stall warning.
Scope. This section addresses indications to the pilot of an impending stall and to post‐stall flight
characteristics.
Purpose. The purpose of this section is to require adequate stall warning and docile stall characteristics,
since some flight operations are conducted at a small margin above stall speed. These characteristics
should account for varying degrees of pilot skill, training and experience.
Application. This section applies to all part 23 airplanes.
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Appendix E
Requirement.
The airplane must demonstrate satisfactory stall characteristics in both straight and turning flight, and
with sufficient stall warning to the pilot.
23.221 Spin characteristics.
Scope. This section presents requirements for recovery characteristics following an unintentional or
intentional spin, or the resistance to depart controlled flight and enter a spin.
Purpose. The purpose of this section is to provide an airplane that can be recovered from an
inadvertent or intentional spin. However, since most spin accidents take place following spin entry
while in an airport traffic pattern and too close to the ground to recover, the purpose of this section is
also to provide airplanes that do not have a tendency to enter a spin during maneuvering that is typical
while preparing to land. This capability can be achieved through aerodynamic means or by using specific
systems that will help the pilot to avoid unintentional spins.
Application. This section applies to all part 23 airplanes.
Requirement.
(a) A single engine airplane must not have a tendency to inadvertently enter a spin.
(b) If a single engine airplane cannot comply with (a), or if intentional spins are approved, it must be
demonstrated that safe recovery can be made using defined recovery procedures.
23.231 Ground handling characteristics.
Scope. This section addresses ground handling characteristics for all taxi, takeoff and landing surfaces.
Purpose. The purpose of this section is to require that operating characteristics be safe and predictable
while operating on the surface, whether that surface is pavement, turf, water, snow or ice.
Application. This section applies to all part 23 airplanes.
Requirement.
The airplane must demonstrate satisfactory longitudinal and directional ground handling characteristics
during taxi, takeoff and landing operations.
23.253 High speed characteristics.
Scope. This section pertains to the requirements addressing high speed characteristics.
Purpose. This section is intended to address the flight characteristics of airplanes at and near their
maximum operating speed, particularly if those speeds reach Mach numbers where compressibility
effects become a factor. Experience shows that aerodynamics can breakdown more quickly in the
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Appendix E
transonic range resulting in sudden changes in flight characteristics. This requirement addresses various
aspects of safety when operating at or above this regime.
Application. This section applies to all part 23 airplanes.
Requirement.
(a) Vibration and buffeting.
(1) The airplane must demonstrate satisfactory vibration and buffeting characteristics.
(2) If compressibility effects are a factor, the boundary of perceptible buffet must be determined in the
cruise configuration. The airplane must demonstrate that probable inadvertent excursions beyond this
boundary do not result in unsafe conditions.
(b) Upsets. If a maximum operating speed VMO/MMO is established as an operating limitation, the
airplane must demonstrate satisfactory recovery characteristics following an inadvertent speed increase
at any likely cruise speed up to VMO/MMO.
(c) Out of trim characteristics. Airplanes with an MD greater than 0.6M and that incorporate a
trimmable horizontal stabilizer must demonstrate satisfactory maneuvering stability, controllability, and
recovery characteristics.
23.257 Flight in icing conditions.
Scope. This section provides flight characteristics requirements for airplanes whose definition as
required by Subpart A includes flight into known icing.
Purpose. The purpose of this section is to show safe flight characteristics for operations in various levels
of icing conditions. For conditions for which certification is not requested, it has been shown that a
means of exiting icing conditions has resulted in safe operations.
Application. This section is only applicable to airplanes whose definition as required by subpart A
includes flight into known icing.
Requirement.
If certification for flight in certain icing conditions is requested, the following apply:
(a) The airplane must be shown to operate safely, as appropriate for the icing conditions, and
(b) There must be a means to avoid, or to detect and safely exit, those icing conditions for which
certification is not requested.
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Appendix E
Subpart C Structures
23.301 Structures General
Scope. This section addresses the strength requirements that apply to all portions of the airframe the
failure of which would seriously endanger the safety of the airframe.
Purpose. This rule provides the top level airframe strength requirements. This rule encompasses the
intent of the current Subpart C General Section. Subpart C has historically been prescriptive and has
specific design solutions defined in the rule. These design solutions are moved to the ADS
(Airworthiness Design Standard) where future technology changes can be readily adopted into the
regulatory framework. The requirements listed in g) were previously defined in Subpart B 23.251.
Historically 23.251 has been shown compliance by both flight and structures DERs/Ums. Therefore a
structural rule has been added to the new Subpart C.
Application. CFR 14 part 23 Subpart C
Requirement.
a) Strength requirements are specified in terms of limit loads (the maximum loads to be expected
in service) and ultimate loads (limit loads multiplied by applicable factors of safety). Unless
otherwise provided, prescribed loads are limit loads. [301(a), 303]
b) The structure must be able to support limit loads without detrimental, permanent deformation
for each critical load condition. At any load up to limit loads, the deformation may not interfere
with safe operation. [305(a)]
c) If deflections under load would significantly change the distribution of external or internal loads,
this redistribution must be taken into account. [301(c)]
d) The structure must be able to support ultimate loads. Local failures or structural instabilities
between limit and ultimate load are acceptable only if the structure can sustain the required
ultimate load. [305(b)]
e) Compliance with the strength and deformation requirements of this section must be shown by
tests or analysis. Structural analysis may be used only if the structure conforms to those for
which experience has shown this method to be reliable. [302(a)(b),307(a)(b)]
f) Compliance with loads determined in this section must be shown in a rational or conservative
manner. [301(b)(d)]
g) The airplane must be designed to withstand any vibration and buffeting that might occur in any
likely operation condition. [251(a)]
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Appendix E
23.303 Mass and Mass Distribution
Scope. This section addresses mass and mass distribution for structural loads on the airframe.
Purpose. This rule incorporates the intent of the current §§ 23.301(b) and 23.23(b)(2). In current
industry practice, airframe mass distribution are in the details of the structural loads documents.
Structural loads are a result of load factor, distribution and weight. This rule provides a mechanism for
administrator approval of the mass and mass distribution used in the calculation of the airframe
structural loads.
Application. CFR 14 part 23 Subpart C
Requirement.
All loads requirements must be complied with when the mass is varied over the applicable weight and
C.G. envelope and is distributed in the most adverse manner, within the operating limitations.
[301(b);23(b2)]
23.321 Flight Loads
Scope. This section defines the flight loads to be used for the strength requirements of the airframe.
Purpose. This rule provides the non‐prescriptive flight loads used for structural substantiation of the
airframe. In combination with Design Airspeeds, these rules encompasses the intent of sections of the
current Subpart C Flight Loads, Horizontal Stabilizing and Balancing Surfaces, Vertical Surfaces, Ailerons
and Special Devices Sections. Flight loads requirements such as acceleration factors and gust velocities
of Subpart C has historically been prescriptive. These and other prescriptive requirements are moved to
the ADS (Airworthiness Design Standard) where future technology changes can be readily adopted into
the regulatory framework.
Application. CFR 14 part 23 Subpart C
Requirement.
a) Flight load requirements for symmetrical and asymmetrical loading must be determined and
shown:
(1) At each critical altitude within range in which the airplane is permitted to operate.
When significant the effects of compressibility must be taken into account;
(2) At each weight from the design minimum weight to the design maximum weight;
and
(3) For each required altitude and weight, for any practicable or conservative
distribution of disposable load within the operating limitations; and
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Appendix E
(4) For all combinations of airspeed and load factor on and within the boundaries of a
flight envelope that represents the envelope of the flight loading conditions
specified by the maneuver spectrum and gust environment. Variations in mission
profiles and loading configurations must be accounted for.
[301(b), 321(a)(b)(c), 331(a)(b)(c), 333(a)(b)(c)(d), 337(a)(b)(c), 341(a)(b)(c), 343(a)(b)(c), 347(a)(b),
349(a)(b), 351, 365(a)(b)(c)(d)(e), 367(a)(b), 369(a)(b), 373(a)(b), 421(a)(b), 423(a)(b), 425(a)(b)(c)(d),
427(a)(b)(c), 441(a)(b)(c), 443(a)(b)(c), 445(a)(b)(c)(d), 455(a)(b), 459]
b) And in combination with any other loads, such as flight control loads, cabin pressurization
loads or engine loads. [351, 361(a), 365(a), 371(a)(b)(c), 391, 395(a)(b)]
23.335 Design Airspeeds
Scope. This section defines the airspeeds used for determining the flight loads.
Purpose.
In combination with Flight Loads, these rules encompasses the intent of sections of the current
Subpart C Flight Loads, Horizontal Stabilizing and Balancing Surfaces, Vertical Surfaces, Ailerons and
Special Devices Sections. Airspeed requirements of Subpart C has historically been prescriptive. These
and other prescriptive requirements are moved to the ADS (Airworthiness Design Standard) where
future technology changes can be readily adopted into the regulatory framework.
Application. CFR 14 part 23 Subpart C
Requirement.
Design airspeeds shall be established for which the airplane structure is designed to withstand the
corresponding maneuvering and gust loads. To avoid inadvertent exceedances due to upsets or
atmospheric variations, the design airspeeds shall provide sufficient margin for the establishment of
practical operational limiting airspeeds. In addition, the design airspeeds shall be sufficiently greater
than the stalling speed of the airplane to safeguard against loss of control in turbulent air. Consideration
shall be given to a design maneuvering speed, a design cruising speed, a design dive speed, and any
other design airspeeds necessary for configurations with high lift or other special devices.
[335(a)(b)(c)(d)]
23.361 Engine Mount Loads
Scope. This section addresses the engine mount structural load requirements for the airframe which
have not been previously addressed by flight, ground and water loads.
Purpose. This rule provides the non‐prescriptive engine mount load requirements used for the structural
substantiation of the airframe. In combination with Flight Loads, these rules encompasses the intent of
sections of the current Subpart C Flight Loads Section. Engine mount loads of Subpart C has historically
been prescriptive. These and other prescriptive requirements are moved to the ADS (Airworthiness
~ 86 ~
Appendix E
Design Standard) where future technology changes can be readily adopted into the regulatory
framework.
Application. CFR 14 part 23 Subpart C
Requirement.
In addition to flight, ground and water loads, each engine mount and its supporting structure must be
designed for forces and moments generated by the operation of the engine in combination with
applicable flight loads. [361(a)(b)(c), 363(a)(b), 371(a)(b)(c)]
23.391 Flight Control Loads
Scope. This section addresses the flight control structural load requirements for the airframe.
Purpose. This rule provides the non‐prescriptive flight control load requirements used for the structural
substantiation of the airframe. This rules encompasses the intent of the current Subpart C Control
Surface and System Load Section. Flight control loads of Subpart C has historically been prescriptive.
These and other prescriptive requirements are moved to the ADS (Airworthiness Design Standard)
where future technology changes can be readily adopted into the regulatory framework
Application. CFR 14 part 23 Subpart C
Requirement.
Control surface, control system and supporting structure must be designed by loads assuming to occur
in addition to those prescribed in 23.321, except when limited by applicable pilot forces. [659(a)(b)(c),
391, 393(a)(b), 395(a)(b)(c), 397(a)(b), 399(a)(b), 405, 407, 409, 415(a)(b)(c)]
23.471 Ground and Water Loads
Scope. This section addresses the ground and water structural load requirements for the airframe.
Purpose. This rule provides the non‐prescriptive ground and water load requirements used for the
structural substantiation of the airframe. This rules encompasses the intent of the current Subpart C
Ground Loads and Water Loads Sections. Ground and water loads of Subpart C has historically been
prescriptive. These and other prescriptive requirements are moved to the ADS (Airworthiness Design
Standard) where future technology changes can be readily adopted into the regulatory framework.
Application. CFR 14 part 23 Subpart C
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Appendix E
Requirement.
Ground and water loads, including taxi, landing, take‐off and handling loads expected in service under
the anticipated operating conditions must be considered in the design of the airplane.
[471, 473(a)(b)(c)(d)(e)(f)(g), 477, 479(a)(b)(c)(d), 481(a)(b), 483, 485(a)(b)(c)(d), 493(a)(b)(c),
497(a)(b)(c), 499(a)(b)(c)(d)(e), 505, 507(a)(b)(c), 509(a)(b)(c)(d), 511(a)(b)(c), 523(a)(b), 525(a)(b)(c)(d),
527(a)(b)(c), 529(a)(b)(c), 531(a)(b), 533(a)(b)(c), 535(a)(b)(c)(d)(e)(f)(g), 537, 753]
23.551 Aeroelasticity
Scope. This section addresses the aeroelasticity requirements of the airplane.
Purpose. This regulation was originally located in Subpart D. Industry deemed it to be more applicable
to structural loads than design and construction and was therefore moved to Subpart C. This rule
provides the non‐prescriptive aeroelasticity requirements used for the structural substantiation of the
airplane. Aeroelasticity requirements of Subpart D has historically been prescriptive. These and other
prescriptive requirements are moved to the ADS (Airworthiness Design Standard) where future
technology changes can be readily adopted into the regulatory framework.
Application. CFR 14 part 23 Subpart C
Requirement.
(a) It must be shown that the airplane is free from flutter, control reversal, and divergence at all
speeds within the design envelope and sufficiently beyond the flight envelope for any condition
of operation, considering any critical failures.
[629(a)(b)(c)(d)(e)(f)(g)(h)(i), 677(c)]
(b) Tolerances must be established for quantities which affect flutter. [629(a)]
23.561 Emergency Conditions
Scope.
This section addresses the loading conditions on the airplane that must be taken into account during an
emergency landing.
Purpose.
This requirement covers the loads that the airplane structure must be able to sustain during an
emergency landing. These loads can be defined by static ultimate load factors, appropriate to the
emergency landing scenario. Damage to the airplane is acceptable, as long as every occupant has a
reasonable chance of escaping without serious injury. The occupants must be protected from items of
mass coming loose during a crash landing.
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Appendix E
Application. CFR 14 part 23 Subpart C
Requirements.
The airplane, although it may be damaged in emergency landing conditions, must be designed to
provide reasonable protection to the occupants. Specific emergency landing conditions that are likely to
occur shall be taken into consideration. [23.561(a)(b)(c)(d)(e), 23.785(c)(n), 23.787(a3)(b)]
23.571 Fatigue Evaluation
Scope.
This section requires that effects of fatigue loading must be considered where appropriate.
Purpose.
The purpose of this section is to ensure that the effects of repeated loading and damages on the aircraft
structure are taken into consideration over the operational life of the aircraft. Regular inspections can
be used as a means to prevent damages to grow to a point where they could lead to catastrophic
failures.
Application. CFR 14 part 23 Subpart C
Requirements.
a) The structure of the airplane must be designed to avoid catastrophic failure during the operational life
taking into account the expected repeated loads applied in service. [23.571(a)(b)(c)(d), 23.572(a)(b),
23.573(a)(b), 23.574(a)(b), 23.627]
b) The applicant must prepare inspections and procedures required by (23.571a) to preserve the
structural integrity of all primary structural elements for the operational life in the event/presence of:
(1) Fatigue Damage;
(2) Environmental Damage including likely corrosion or other degradation;
(3) Manufacturing, Accidental or In Service Damage;
(4) Maintenance Damage;
(5) Specified Maintenance; and
(6) Structural Repairs.
[23.575]
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Appendix E
Subpart D Design and Construction
23.601 General
Scope. This section addresses the general design and construction requirements that apply to all parts
and assemblies.
Purpose. The original intent of Subpart D as described in CAM 4a is primary structure and all
mechanisms essential to the safe operation of the airplane must not incorporate design features which
experience has shown to be unsatisfactory. Furthermore, the suitability of all design features must be
established, and certain design features which have been found to be essential to the airworthiness of
an airplane are specified and must be observed. Subpart D has historically been prescriptive and has
specific design solutions defined in the rule. These design solutions are moved to the ADS
(Airworthiness Design Standard) where future technology changes can be readily adopted into the
regulatory framework. Historically Subpart D has also created specific testing requirements for those
design solutions. These testing requirements have been imposed on design details which have been
deemed to have “an important bearing on safety”. Rather than requiring testing in the rule, the rule will
require that the suitability must be determined, and determination methods will be specified in the ADS.
Paragraph 601(b) establishes that design data must provide adequate definition. The interpretation of
§ 23.601 creates this requirement even though the verbiage does not exist in the current amendment
level.
Application.
a) Each part or assembly must be designed for the anticipated operating conditions. [601, 657(b),
675(c), 729(a), 731(a)(b), 733(a1)(a2), 737, 775(b)(d)(g)(h1), 787(a1)(a2),]
b) Design data must provide adequate definition of configuration, design features, and materials
and processes. [601]
c) The suitability of each design detail and part having an important bearing on safety in
operations, must be determined. [601, 641, 651(a)(b), 681(a)(b), 683(a)(b), 723(a)(b),
725(a)(b)(c)(d)(e)(f), 726(a)(b), 272(a)(b), 775(c), 843(a), 307(b)]
Requirement.
(a) Each part or assembly must be designed for the anticipated operating conditions.
(b) Design data must provide adequate definition of configuration, design features, and materials and
processes.
(c) The suitability of each design detail and part having an important bearing on safety in operations,
must be determined.
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Appendix E
23.603 Materials and Processes
Scope. This section addresses materials, processes and methods of fabrication.
Purpose. The original intent of “Materials, Workmanship, and Fabrication Methods” as described in
CAM4a is to insure the primary structure is constructed from materials that are “uniform in quality and
strength.” Furthermore, fabrication methods must “be such as to produce a uniformly sound structure.”
From the original inception of the regulatory requirements, design solutions such as adhesive gluing or
welding have been included in the regulations. These design solutions are removed and prescriptive
requirements related to those specific methods are found in the ADS (Airworthiness Design Standard).
In order to design structure that is “uniform in quality”, it also requires that the structure has consistent
strength and other properties assumed in the design. Insuring consistent strength requires the
generation of material strength properties and design values. The prescriptive nature of how material
strength properties and design values are generated are moved to the ADS and meets the original safety
intent of the rule.
Application.
a) The suitability and durability of materials and processes used for parts, the failure of which
could adversely affect safety, must—
(1) Be determined;
(2) Ensure consistent strength and other properties assumed in the design and;
(3) Take into account the effects of environmental conditions.
[603(a), 613(a)(b)(c)(d)(e)]
b) The methods of fabrication and assembly used must produce consistently sound structures.
[603(b), 605(a)]
c) Each new aircraft fabrication and assembly method must be substantiated by a test program.
[605(b)]
Requirement.
(a) The suitability and durability of materials and processes used for parts, the failure of which could
adversely affect safety, must‐‐
(1) Be determined;
(2) Ensure consistent strength and other properties assumed in the design and;
(3) Take into account the effects of environmental conditions.
(b) The methods of fabrication and assembly used must produce consistently sound structures.
(c) Each new aircraft fabrication and assembly method must be substantiated by a test program.
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Appendix E
23.609 Protection of Structure
Scope. This section addresses the protection of structure from deterioration and loss of strength.
Purpose. The original intent of “Protection” as described in CAM4a is to insure the primary structure is
suitably protected against deterioration or loss of strength in service. This could be caused by several
sources. CAM 4a specified corrosion, abrasion, vibration, or other causes. The actual causes of the
deterioration are prescriptive in nature, and are not necessary to define the original safety intent of the
rule. The prescriptive causes of deterioration are moved to the ADS (Airworthiness Design Standard).
Other rules in Subpart D that use the original intent of “Protection” are § 23.607 and § 23.611.
Protecting the structure also requires proper maintenance, inspection, and servicing. There must be an
appropriate means incorporated into the aircraft design to accomplish servicing. Section 23.607
addresses fasteners and design features of fasteners that must be incorporated to protect the structure
from loss of strength. Describing fasteners in the regulation is a design solution and prescriptive in
nature. These requirements are moved to the ADS and meet the safety intent of this rule.
Application.
a) Each part or assembly must be suitably protected against deterioration or loss of strength in
service; and [607(a)(b)(c), 609(a)]
b) Have adequate provisions for ventilation and drainage. [609(b)]
c) For each part that requires maintenance, inspection, or other servicing, appropriate means must
be incorporated into the aircraft design to allow such servicing to be accomplished. [611]
Requirement.
(a) Each part or assembly must be suitably protected against deterioration or loss of strength in service;
and
(b) Have adequate provisions for ventilation and drainage.
(c) For each part that requires maintenance, inspection, or other servicing, appropriate means must be
incorporated into the aircraft design to allow such servicing to be accomplished.
23.619 Special Factors
Scope. This section addresses the special factors of safety that must be established for certain aspects of
the structure.
Purpose. As described in CAM 4a, the original intent of requiring special factors of safety for certain
structural aspects was to “minimize the possibility of loosening of the joint in service, progressive failure
due to stress concentration, and damage caused by normal servicing and field operations”. For certain
prescriptive design solutions as described in the regulation, acceptable factors are provided. In
subsequent revisions to regulation, this was rewritten to include structure whose strength is uncertain,
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Appendix E
likely to deteriorate in service, or as a means to account for variability. These factors are provided in
several rules in Subpart D, and include castings, bearings, fittings, and control surface hinges. Since
these are prescriptive design solutions, they are moved to the ADS (Airworthiness Design Standard), and
meet the original safety intent of the rule.
Application.
a) Special factors of safety must be established; and
b) The factor of safety must be multiplied by the highest pertinent special factors of safety for each
part of the structure whose strength is –
(1) Uncertain;
(2) Likely to deteriorate in service before normal replacement; or
(3) Subject to appreciable variability because of uncertainties in manufacturing processes or
inspection methods.
[619(a)(b)(c), 621(a)(b)(c)(d)(e), 623(a)(b), 625(a)(b)(c)(d), 657(a)]
Requirement.
(a) Special factors of safety must be established; and
(b) The factor of safety must be multiplied by the highest pertinent special factors of safety for each part
of the structure whose strength is –
(1) Uncertain;
(2) Likely to deteriorate in service before normal replacement; or
(3) Subject to appreciable variability because of uncertainties in manufacturing processes or
inspection methods.
23.671 Cockpit Controls
Scope. This requirement accomplishes the objective as stated in the purpose.
Purpose. This rule embodies the requirements for layout, look, and feel of the controls in the cockpit,
other than those related to propulsion and fuel systems.
Application. This requirement applies to pilot compartment, automatic pilot systems, flight director
systems, circuit protective devices, master switch arrangement, switches, cockpit controls, and cockpit
control knob shape.
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Requirement.
The design of the flight crew compartment shall take into account the possibility of incorrect or
restricted operation of the controls by the crew, due to fatigue, confusion or interference.
23.773 Flight Crew Exterior Visibility
Scope. This requirement accomplishes the objective as stated in the purpose.
Purpose. This rule embodies the requirements for the arrangement of the pilot compartment to ensure
appropriate visibility for safe operation of the aircraft.
Application. This requirement applies to pilot compartment view, windshields, and windows.
Requirement.
The arrangement of the pilot compartment shall be such as to provide sufficient visibility to enable the
pilot to safely taxi, takeoff, approach, land, and perform any maneuvers within the operating limitations
of the airplane.
23.783 Doors
Scope. This requirement accomplishes the objective as stated in the purpose.
Purpose. This rule embodies the requirement that all doors including cargo doors, service/maintenance
doors, oil doors, or occupant access doors, need to be designed such that they will provide an
appropriate function and not cause a hazard to the aircraft. This rule is intended to capture the
requirements for safe door function and not emergency requirements.
Application. This requirement applies to all aircraft doors including cargo doors, service/maintenance
doors, oil doors, or occupant access doors.
Requirement.
Each door must be designed such that the function does not affect the ability of the aircraft to operate
safely and must be protected from opening inadvertently in flight.
23.785 Occupant Safety
Scope. This rule provides safety requirements during emergency situations for the airplane occupants,
including the crew and passengers.
Purpose. Occupants must be provided a safe environment during emergencies such as off‐airport
landings, fires and other emergencies. This environment may be provided by a number of different
approaches.
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Appendix E
Application.
Requirement.
Each airplane must be designed such that, each occupant is provided reasonable protection from injury
during an emergency event. This shall be accomplished through providing design elements in order:
(a) to provide protection from inertia forces acting on the occupant during an emergency landing.
(b) to allow for timely evacuation of the occupants.
(c) to protect the occupant from fire and smoke.
(d) to meet the emergency equipment requirements defined in operational rules.
(e) To provide occupant protection from a splintering windshield.
(f) To provide a means of communication from flight crew to the passengers.
23.865 Fire protection of structure
Scope. This section addresses fire protection of structure.
Purpose. The original intent of § 23.865 is to protect flight controls, engine mounts, and other flight
structure from the effects of fire. The current rule language provides both safety intent as well as design
related solutions and prescriptive information. The design solutions and prescriptive information are
removed from the rule and defined in the ADS (Airworthiness Design Standard).
Application.
Flight structure located in designated fire zones, or in adjacent areas that would be subjected to the
effects of fire in the designated fire zones, must be capable of withstanding the effects of a fire.
[23.865]
Requirement.
Flight structure located in designated fire zones, or in adjacent areas that would be subjected to the
effects of fire in the designated fire zones, must be capable of withstanding the effects of a fire.
23.867 Lightning protection
Scope. This section addresses lightning protection of the aircraft.
Purpose. This rule embodies the requirement to protect the aircraft against catastrophic effects from
the direct attachment of lightning to the structure and to aircraft components. The design solutions and
prescriptive information are removed from the rule and defined in the ADS (Airworthiness Design
Standard).
Application. This requirement applies to aircraft structure and components that are exposed to direct
attachment of lightning.
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Appendix E
Requirement.
The airplane must be protected against catastrophic effects from the direct attachment of lightning
considering the operational envelope required in Subpart A.
Subpart E ‐ Powerplants
23.901 Powerplant Installation Requirements
Scope. This section addresses the powerplant installation requirements. The term powerplant is used to
address both propulsion systems and APUs.
Purpose. The rule provides the basic framework necessary for the powerplant installation. The
definitions of what constitutes the powerplant system is included in order to take a systems level
approach to the installation, rather than a strictly isolated, component requirement approach. The
intent is to ensure that the powerplant system is suitable for installation into a part 23 airplane, and that
the installation complies with the installation requirements for the powerplant system components.
There are additional certification requirements for aircraft engines, propellers and powerplant emissions
that are contained within other subchapters.
Application. Rule applies to applicants who are proposing a new or change to the powerplant system
on an aircraft certified to part 23.
Requirement.
a) For the purpose of this part, the airplane powerplant installation includes each component that
is necessary for propulsion or for providing auxiliary power for the aircraft (APU); and affects the
safety of the major propulsive units.
b) Each engine and propeller must be approved. For specific classes of aircraft, the engine and
fuel/energy system shall meet the requirements as defined in part 34. The engine, propeller,
and APU installation must comply with installation instructions provided by the manufacturer
and the other applicable provisions of this subpart.
c) Each powerplant installation must ensure safe operation and be accessible for preflight
inspection & maintenance.
d) An automatic power reserve (APR) system that automatically advances the power or thrust on
the operating engine(s), when any engine fails during takeoff, must comply with the applicable
requirements of the subpart.
23.905 Propellers
Scope. This section addresses the propeller installation requirements.
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Appendix E
Purpose. The rule provides the basic framework necessary for the propeller installation. The intent is to
ensure that the propeller is suitable for installation into a part 23 airplane. In addition, if there are
propeller features, other than the basic function to provide propulsive thrust, those features are
installed in a manner that does not pose a hazard to the aircraft.
Application. Rule applies to applicants who are proposing a new or change to a propeller system
installed on an aircraft certified to part 23.
Requirement.
The applicant must evaluate the propeller throughout the operational envelope of the airplane and
show that:
a) The propeller shall not experience the harmful effects of flutter and failure due to fatigue will be
avoided throughout the operational life of the propeller as installed.
b) All areas of the airplane forward of the pusher propeller that are likely to accumulate and shed
ice into the propeller disc during any operating condition must be suitably protected to prevent
ice formation, or it must be shown that any ice shed into the propeller disc will not create a
hazardous condition.
c) The propeller speed and pitch are limited to values that will assure safe operation under normal
operating conditions.
d) Each featherable propeller shall have a means to un‐feather in flight. If the propeller feathering
system uses engine oil (or any other fluid) and that fluid supply can become depleted or can be
contaminated due to failure of any part of the system, there is a means incorporated to
accomplish feathering with reserved fluid.
e) Each propeller shall be marked so that the disc is conspicuous under normal daylight ground
conditions.
f) Installation considerations unique to the specific installation such as propeller clearance and
exhaust gas impingement shall be addressed to insure safe operation throughout the entire
operating envelop.
g) The propeller‐drag limiting systems installed on a turbopropeller‐powered are designed so that
no single failure or malfunction or likely combination of failures, or inadvertent operation of the
systems during normal or emergency operation will result in propeller drag in excess of that for
which the airplane was designed.
23.906 Powerplant Hazard Mitigation
Scope. This section addresses the powerplant installation hazards and mitigation.
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Appendix E
Purpose. The rule provides the basic framework necessary to minimize the hazards associated with the
powerplant installation. The intent is to ensure that the powerplant system is a fault tolerant and any
hazards from any powerplant system failure are minimized.
Application. Rule applies to applicants who are proposing a new or change to a powerplant system
installed on an aircraft certified to part 23.
Requirement.
a. The propulsion system shall minimize the resultant hazard from any powerplant system failure.
b. There must be a means to allow the appropriate flight crew members to rapidly shut off, in
flight, any source of fuel/energy to each engine individually.
c. The powerplants must be arranged and isolated from each other to allow operation, in at least
one configuration, so that the failure or malfunction of any powerplant system will not:
i. Prevent the continued safe operation of the remaining powerplant system; or
ii. Require immediate action by any crewmember for continued safe operation of the
remaining powerplant system.
d. All designated fire zones must be identified.
e. Each engine, auxiliary power unit, fuel burning heater, and other combustion equipment must
be isolated from the rest of the airplane by firewalls, shrouds, or equivalent means.
f. Each firewall or shroud must be constructed so that no hazardous quantity of liquid, gas, or
flame can pass from the compartment created by the firewall or shroud to other parts of the
airplane.
g. There must be means that ensure prompt detection of a fire in an APU or in an engine
compartment.
h. Fire extinguishing systems must be installed in all airplanes with engine(s) embedded in the aft
fuselage or in pylons on the aft fuselage, and for Auxiliary Power Unit if installed. The systems
must not cause a hazard to the rest of the aircraft.
i. In each area or component where flammable fluids or vapors might escape by leakage of a fluid
system, there must be means to minimize the probability of ignition of the fluids and vapors,
and the resultant hazard if ignition does occur and prevent the introduction of hazardous toxic
gases into the cabin.
23.933 Reversing Systems
Scope. This section addresses reversing systems (systems that provide thrust in the opposite direction of
flight) installation and hazard mitigation requirements.
Purpose. The rule provides the basic framework necessary to minimize the hazards associated with
systems that provide thrust in the opposite direction of flight. The intent is to ensure that the reversing
system is a fault tolerant and any hazards from any reversing system failure are minimized.
Application. Rule applies to applicants who are proposing a new or change to a reversing system
installed on an aircraft certified to part 23.
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Appendix E
Requirement.
(a) For turbojet and turbofan reversing systems and corresponding controls –
(1) Each system intended for ground operation only must be designed so that, during any
reversal in flight, the engine will produce no more than flight idle thrust and that no
inadvertent operation by flight crew of the system will result in unwanted reverse thrust
under any operating condition. In addition, it must be shown by analysis or test, or both,
that each operable reverser can be restored to the forward thrust position; or the
airplane is capable of continued safe flight and landing under any possible position of
the thrust reverser.
(2) Each system intended for in‐flight use must be designed so that no unsafe condition will
result during normal operation of the system, or from any failure, or likely combination
of failures, of the reversing system under any operating condition including ground
operation. Failure of structural elements need not be considered if the probability of
this kind of failure is extremely remote.
(3) Each system and each control system must have a means to prevent the engine from
producing more than idle thrust when the reversing system malfunctions; except that it
may produce any greater thrust that is shown to allow directional control to be
maintained, with aerodynamic means alone, under the most critical reversing condition
expected in operation, and for each control for reverse thrust below the flight regime to
prevent its inadvertent operation.
(4) Each system must meet the requirements of § 33.97 of this chapter or it must be
demonstrated by tests that engine operation and vibratory levels are not affected.
(b) Each propeller reversing or pitch setting system must be designed so that no single failure or
malfunction or likely combination of failures, or inadvertent operation of the systems during
normal or emergency operation, will result in unwanted reverse thrust under any operating
condition.
23.939 Powerplant Operational Characteristics
Scope. This section addresses the powerplant installation operating characteristics requirements.
Purpose. The rule provides the basic framework necessary for the powerplant operating
characteristics. The intent is to ensure that the powerplant system operates as intended when installed
in the aircraft, and that there are no adverse powerplant characteristics during normal and emergency
operations within the range of operating limitations of the aircraft.
Application. Rule applies to applicants who are proposing a new or change to a propulsion system
installed on an aircraft certified to part 23.
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Appendix E
Requirement.
(a) The powerplant operating characteristics must be investigated in flight to determine that no
adverse characteristics or vibration are present that would create a hazard during normal and
emergency operations within the range of operating limitations of the airplane and of the
engine.
(b) No hazardous malfunction of an engine, auxiliary power unit, or any component or system
associated with the powerplant or auxiliary power approved for use in flight may occur when
the airplane is operated at the negative accelerations within the prescribed flight envelope.
(c) The powerplant and auxiliary power unit provisions must maintain the temperature of each
component and fluid within the limits established for these items under the most adverse
ground, water, and flight operations throughout the operational envelope.
(d) It must be possible to stop and restart an engine in flight. Any techniques and associated
limitations for engine starting and stopping must be established and included in the Airplane
Flight Manual, approved manual material, or applicable operating placards. In addition:
1) An altitude and airspeed envelope must be established for the airplane for in‐flight
engine restarting. Each installed engine must have a restart capability within that
envelope.
2) The design of the installation must reduce the risk of fire or mechanical damage to the
engine or airplane as a result of starting the engine in any conditions in which starting is
to be permitted to a minimum.
3) It must be demonstrated in flight that when attempting to restart an engine following a
false start, all fuel or vapor is discharged in such a way that it does not constitute a fire
hazard
4) Following the in‐flight shutdown of all engines, if the minimum wind milling speed of the
engines is insufficient to provide the necessary electrical power for engine ignition, a
power source independent of the engine‐driven electrical power generating system
must be provided to permit in‐flight engine ignition for restarting.
5) If continued engine rotation would cause a hazard to the airplane, there must be means
provided for stopping combustion and rotation within any engine. Each component of
the engine stopping system located in any fire zone must be fire resistant including the
components of a hydraulic propeller feathering system.
23.951 Fuel / Energy System – General
Scope. This section addresses the powerplant energy storage and delivery system installation
requirements.
Purpose. The rule provides the basic framework necessary for the powerplant energy storage and
delivery system installation. The intent is to ensure that the system that provides energy used to
provide propulsive thrust is a suitable for installation into part 23 airplanes, is fault tolerant and any
hazards from any energy storage and delivery system failure are minimized.
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Appendix E
Application. Rule applies to applicants who are proposing a new or change to a fuel system installed on
an aircraft certified to part 23.
Requirement.
a) Each system must be designed, arranged, and installed to:
1) Ensure proper engine and auxiliary power unit functioning under each operating
condition and maneuver for which certification is requested.
2) Meet the applicable fuel / energy venting requirements of part 34 of this chapter based
on the class of aircraft being certified.
3) Prevent the ignition of fuel / energy vapor within the system caused by lightning.
4) Provide the applicable fuel / energy rates as required to achieve maximum power /
thrust with acceptable margin for all the other purposes for which the fuel is used.
5) Have at least one drain to allow safe drainage of the entire fuel / energy system with the
airplane in its normal ground attitude.
b) Each fuel / energy tank must be designed, arranged and installed in order to:
1) Withstand the loads and pressures it may be subjected to in operation, prevent hazards
to personnel, be isolated from fire zones, and be capable of retaining fuel / energy when
subject to inertia loads and when landing on a paved runway with landing gear retracted
or one landing gear collapsed.
2) Have provisions for expansion space and venting to function as a rapid pressure relief
system that prevents excessive loss of fuel during any maneuver.
3) Have a drainable sump and allow drainage of any hazardous quantity of water to the
sump with the airplane in the normal ground attitude.
4) Have fuel tight filler connections suitable for the type of fuel / energy used with
acceptable electrical bonding.
5) Provide provisions to prevent contamination of the fuel / energy supply.
6) Withstand acceptable pressures without failure or leakage throughout its operational
envelope. This must be shown by test.
7) Be able to establish the unusable fuel/energy supply considering effects due to any
supply system failure.
8) Prevent fuel overflow or structural damage when transferring fuel.
(c) If fuel pumps are required they must have independent power supplies, and not adversely affect
engine operation under any condition.
(d) If pressure refueling systems are used, they must have a means to prevent the escape of
hazardous quantities of fuel, include an automatic shutoff means, and have means to prevent
damage to the fuel system in the event of failure of the automatic shutoff means and include an
indication of the failure at the fueling station.
(e) If a fuel jettisoning system is installed, it must be free from hazards due to any probable single
malfunction, and control must be demonstrated throughout the operating envelope.
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Appendix E
23.1091 Powerplant Induction and Exhaust Systems
Scope. This section addresses the powerplant induction and exhaust system installation requirements.
These systems are typically associated with air breathing propulsion systems.
Purpose. The rule provides the basic framework necessary for the induction and exhaust system
installation. The intent is to ensure that the system that provides induction air and evacuates any
powerplant waste products is a suitable for installation into part 23 airplanes, is fault tolerant and any
hazards from any the induction and exhaust system failure are minimized.
Application. Rule applies to applicants who are proposing a new or change to an exhaust or induction
system installed on an aircraft certified to part 23.
Requirement.
(a) The air induction system for each engine and auxiliary power unit and their accessories must
supply the air required by that engine or auxiliary power unit and their accessories under the
operating and vibration conditions for which certification is requested and be appropriate for
withstanding the installation, operational, and environmental effects.
(b) Air intakes and exhaust systems must be properly segregated from fire sources, be made of an
appropriate material, and must not cause a hazard in the event of a backfire.
(c) Air intakes must minimize the ingestion of foreign matter.
(d) Each reciprocating engine installation must have an alternate air intake source.
(e) Each exhaust system, including exhaust heat exchangers, must be suitable for the specific
installation, be designed for continued operation at high temperatures, fireproof, resistant to
corrosion, and blockage due to internal system failures.
(f) The system that supplies air to the cabin must be suitably constructed or isolated to prevent
hazardous quantities of toxic gases from entering the cabin, and the exhaust system must
ensure safe disposal of exhaust gases.
23.1093 Powerplant Ice Protection
Scope. This section addresses the installation requirements necessary to protect the powerplant for the
hazards associated with icing.
Purpose. The rule provides the basic framework necessary for the icing protection requirements of the
powerplant system. The intent is to ensure that the powerplant system will continue to function when
exposed to icing conditions.
Application. Rule applies to applicants who are proposing a new or change to a powerplant system
installed on an aircraft certified to part 23.
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Appendix E
Requirement.
a) The powerplant system must be protected against the accumulation of ice as necessary to
enable satisfactory functioning without appreciable loss of thrust when operated in icing
conditions.
23.1101 Powerplant Bleed Air
Scope. This section addresses the air used for cabin ventilation and pressurization that is provided by the
powerplant system.
Purpose. The rule provides the basic framework necessary for the air used for cabin ventilation and
pressurization. The intent is to ensure that the powerplant system that provides the air used for cabin
ventilation and pressurization does not introduce harmful or hazardous gases or vapors during normal
and abnormal operation.
Application. Rule applies to applicants who are proposing a new or change to a bleed air system
installed on an aircraft certified to part 23.
Requirement.
The following applies to powerplant systems used for cabin pressurization:
(a) The supply air must be taken from a source where it cannot be contaminated by harmful or
hazardous gases or vapors during operation under all intended operating conditions.
(b) The cabin air system may not be subject to hazardous contamination following any probable
failure of the powerplant system used to provide cabin pressurization.
23.1141 Engine Controls
Scope. This section addresses the control the propulsive thrust of the powerplant system.
Purpose. The rule provides the basic framework necessary for the powerplant propulsive thrust control
system installation. The intent is to ensure that the control system is a suitable for installation into part
23 airplanes, is fault tolerant and any hazards from any control system failure are minimized.
Application. Rule applies to applicants who are proposing a new or change to a engine control system
installed on an aircraft certified to part 23.
Requirement.
(a) Each powerplant control necessary for and setting power/ thrust including fluid injection
systems, must give a positive and immediate responsive means of controlling its powerplant
function. The powerplant controls shall be installed, located, arranged, and provide adequate
independent control so that the pilot has full and unrestricted movement without interference.
Inadvertent operation shall not result in loss power or control.
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Appendix E
(b) When more than one primary control type is required, the control location and order from left
to right shall be power (thrust), propeller (rpm) and fuel /energy control. Identical controls for
multi‐engine installations shall be located to prevent confusion as to the engines that they
control.
(c) Each flexible control must be shown to be suitable for the particular application, without the
need for constant attention without the tendency to creep.
(d) For each engine control system installations ‐.
1) It must be established that no single failure or malfunction or probable combinations of
failures of control system components will have an effect on the system, as installed in
the airplane, that causes the LOTC/LOPC probability of the system to exceed those
allowed in part 33 certification.
2) For electronic engine controls it must be evaluated for environmental and atmospheric
conditions, including lightning. The EEC system lightning and HIRF effects that result in
LOTC/LOPC should be considered catastrophic.
3) The components of the installation must be constructed, arranged, and installed so as to
ensure their continued safe operation between normal inspections or overhauls.
(e) The portion of each power plant control located in the engine compartment that is required to
be operated in the event of fire must be at least fire resistant.
(f) Mechanical valve controls located in the cockpit used for propulsion or fuel management must
have positive stops or detents, in the open and closed position.
(g) For power‐assisted or electronic valves used for propulsion or fuel management, the indication
must be clearly marked and identify when the valve is in the fully open, fully closed position, or
is in transit.
(h) For APU’s a means must be provided to the flight crew for the starting, stopping, monitoring,
and emergency shutdown.
(i) Ignition switches must control and shut off each ignition circuit on each engine and must have a
means to prevent inadvertent operation.
23.1163 Powerplant Accessories & Components
Scope. This section addresses the powerplant accessories and components installation requirements.
Typically, these are pumps, generators, ducts, hoses, etc.
Purpose. The rule provides the basic framework necessary for the powerplant accessories and
components installation. The intent is to ensure that the accessories and components necessary for
powerplant operation, or powerplant driven and necessary for aircraft operation are suitable for
installation into part 23 airplanes. In addition, that those accessories and components do not pose a
hazard during normal and abnormal operation.
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Appendix E
Application. Rule applies to applicants who are proposing a new or change to a powerplant accessory
or component installed on an aircraft certified to part 23.
Requirement.
(a) For the purpose of this part, powerplant accessories and components include those items that
are not included with the type certificated engine or APU, but are:
(1) Necessary for engine or APU operation
(2) Necessary for the transfer of fuel or energy
(3) Powerplant driven and necessary for aircraft operation.
(b) Each powerplant accessory and component must be constructed and arranged to insure safe
operation under all intended operating conditions, including continuous operation for normal
operating conditions and limited operation for abnormal operating conditions, and be accessible
for necessary inspections and maintenance.
(c) Design precautions must be taken to minimize the hazards to the airplane in the event of a
powerplant accessory and component failure, incorrect installation, or inadvertent operation.
23.1225 Powerplant Instruments, and Indicators
Scope. This section addresses the information requirements necessary to operate the powerplant
system.
Purpose. The rule provides the basic framework necessary for the information requirements for the
operation of the powerplant system. The intent is to ensure that there is adequate procedural
information, as well as instrumentation, available to the aircrew in order to safely operate the
powerplant system normally and safely mitigate any powerplant system failure.
Application. Rule applies to applicants who are proposing a new or change to a powerplant instrument
or indicator installed on an aircraft certified to part 23.
Requirement.
(a) Required information, as defined per the appropriate installation manual and the type
certificate, from each aircraft powerplant and auxiliary power unit must be made available to
the operator for continued safe operation including the type certificated limits for engines,
APU’s, and propellers.
(b) Each indicator must be shown in sufficient detail to indicate readily and accurately indicate the
magnitude of the parameter under all operational conditions.
(c) Each powerplant fuel or energy control / valve —
(1) Must be marked to indicate the position corresponding to each source of fuel or energy
and to each existing feed position;
(2) Must be marked on or near the selector for those sources of fuel or energy where safe
operation requires the use of any source of fuel or energy in a specific sequence;
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Appendix E
(3) Must be marked on or near the selector with the full amount of usable energy and any
restricted usage conditions under which the energy can safely be used;
(4) Installed on any engine of a multiengine airplane must be marked to indicate the
position corresponding to each engine controlled.
Subpart F ‐ Equipment
23.1300 Aircraft Level Systems Requirements.
Scope.
This requirement accomplishes the objective as stated in the purpose.
Purpose.
The purpose of this requirement is to ensure:
a) airplane systems are appropriately designed to safely operate in the kinds of operations and
conditions for which the airplane is approved, and
b) airplane systems are designed to support continued safe flight and landing in the event of all but
the most unlikely of failures.
Application.
This requirement applies to aircraft equipment and systems other than propulsion and auxiliary power
systems, also excluded are propulsive and auxiliary power energy storage and distribution (aka fuel)
system
Requirement.
(a) The required equipment and other systems necessary for an airplane to operate safely in the kinds
of operations (VFR, IFR, Day, Night, Known Icing), must—
(1) Be installed.
(2) Perform their intended function throughout the operating and environmental limits specified as
required by Subpart A.
(3) be designed and installed to meet the minimum level of safety and reliability intended for the
type of airplane.
(b) The required and non‐required airplane systems considered separately and in relation to other
systems, must be designed and installed so their operation or failure does not cause a hazard to the
airplane or occupants.
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Appendix E
23.1301 Function and Installation
Scope.
This requirement accomplishes the objective as stated in the purpose.
Purpose.
The purpose of this requirement is to ensure:
a) Equipment used in the design airplane systems have performance appropriate to the application
b) Airplane systems are designed such that human interaction is unlikely to result in an unsafe
operating condition.
c) Crew members are provided with the information necessary to safely operate the airplane
d) Crew members are provided with the information necessary to respond appropriately to any
unsafe system condition.
Application.
This requirement applies to aircraft equipment and systems other than propulsion and auxiliary power
systems, also excluded are propulsive and auxiliary power energy storage and distribution (aka fuel)
system
Requirement.
(a) Each component of a system must—
(1) Be of a kind and design appropriate to its intended function.
(2) Be installed according to limitations specified for that component.
(b) Systems must be designed to minimize errors which could contribute to the creation of hazards.
(c) There must be means to provide, to the appropriate flight crew members, the systems operating
parameters required to safely operate the airplane
(d) Information concerning an unsafe system operating condition must be provided in a timely manner
to the crew to enable them to take appropriate corrective action. Presentation of this information
must be designed to minimize crew errors which could create additional hazards.
23.1302 Flight Information
Scope.
This requirement accomplishes the objective as stated in the purpose.
Purpose.
The purpose of this requirement is to ensure the crew is provided with the flight attitude, airspeed,
altitude and direction information necessary to safely operate the airplane.
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Appendix E
Application.
This requirement applies to all airplanes certified under this part.
Requirement.
There must be means to provide, to the appropriate flight crew members, the flight parameters
required to safely operate the airplane.
23.1304 Flight Controls
Scope.
This requirement accomplishes the objective as stated in the purpose.
Purpose.
The purpose of this requirement is to ensure flight controls, stability augmentation and automatic and
power‐operated systems, stops, trim systems, control system locks, spring devices, cable systems,
artificial stall barrier systems, control system joints, wing flap controls, wing flap position indicator, flap
interconnection, and takeoff warning systems are design to operate safely.
Application.
This requirement applies to all flight control systems required to satisfy subpart B of this part.
Requirement.
Required Control Systems:
(a) The design of the controls and control systems shall be such as to minimize the possibility of
jamming, inadvertent operation including prevention of mis‐assembly, and unintentional
engagement of control surface locking devices.
(b) Each control and control system shall operate with ease, smoothness and precision appropriate to
its functions.
23. 1308 Taxi, Take‐off and Landing equipment
Scope.
This requirement accomplishes the objective as stated in the purpose.
Purpose.
The purpose of this requirement is to ensure that airplanes have the equipment and systems necessary
to safely taxi on, take‐off from and land on surfaces for which the airplane is approved.
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Appendix E
Application.
This requirement applies to general landing gear equipment, landing gear extension/retraction system,
tires, brakes, nose/tail wheel steering, main float buoyancy, hulls, and auxiliary floats.
Requirement.
Equipment for safe taxi, take‐off and landing on the intended surface, must be provided.
23.1311 Integrated Indication Systems.
Scope.
This requirement accomplishes the objective as stated in the purpose.
Purpose.
The purpose of this requirement is to ensure integrated indication systems are designed to
a) simultaneously provide all the information needed to safely operate the airplane
b) be easily readable over the service live of the displays
c) be sufficiently reliable or contain sufficient backup to ensure safe flight and landing
d) easily provide required backup information in the event of a failure
Application.
This requirement applies to integrated indication systems
Requirement.
Indication systems which integrate the display of primary attitude, airspeed, and altitude, or powerplant
parameters needed by any pilot to set power within established limitations, must:
(a) Not inhibit the primary display of attitude, airspeed, altitude, or powerplant parameters needed by
any pilot to set power, in any normal mode of operation, nor inhibit the primary display of engine
parameters needed by any pilot to control starting, during the any starting mode of operation.
(b) Have criteria for replacement established, if the visibility of the display degrades with use or age.
(c) Have reliability or redundancy of determination and display of direction, altitude airspeed, and
attitude, appropriate to approved kinds of operation
(d) Be designed so that one display of information essential for continued safe flight and landing will be
available within one second to the crew by a single pilot action or by automatic means for continued
safe operation, after any single failure or probable combination of failures.
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Appendix E
23.1351 Power Generation, Storage and Distribution
Scope.
This requirement accomplishes the objective as stated in the purpose.
Purpose.
The purpose of this requirement is to ensure aircraft power generation and the related distribution
systems are designed for safe operation.
Application.
The requirement applies to all types of aircraft power generation, except propulsive power, and the
related distribution systems.
Requirement.
The power generation, storage and distribution for any system,
(a) shall enable it to supply the power required for proper operation of connected loads during all
intended operating conditions.
(b) shall be such that no single failure or malfunction will impair the ability of the system to supply
essential loads required for safe flight and landing.
(c) shall have enough capacity to power loads essential for safe flight and landing should the primary
power generation source(s) fail.
(d) shall be such that any storage of power will be safe during all intended operating conditions and in
the event of probable failures of the system.
(e) shall be such that the distribution of power will be safe during all intended operating conditions and
in the event of probable failures of the system.
23.1383 External Lighting
Scope.
This requirement accomplishes the objective as stated in the purpose.
Purpose.
The purpose of this requirement is to ensure that:
a) required external lighting will be effective at helping people, outside the subject airplane, to avoid
collision with the subject airplane.
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Appendix E
b) when used, any external lighting will not shine into the cockpit in such a way as to significantly
degrade flight crew performance.
c) sea/float planes, when parked on the water, are equipped with external lighting to help operators of
other water‐born craft avoid collision with the subject airplane.
Application.
This requirement applies to all airplanes, certified under this part, when equipped with external lighting
required by regulation, and to sea/floatplanes parked on the water at night.
Requirement.
(a) The lights required by operating rule shall have the intensities, colors, fields of coverage and other
characteristics such that they furnish the pilot, the pilot of another aircraft, or personnel on the
ground with adequate time for interpretation and for subsequent maneuver necessary to avoid a
collision. In the design of such lights, due account shall be taken of the conditions under which they
may reasonably be expected to perform these functions.
(b) Lights shall be installed in airplanes so as to minimize the possibility that they will adversely affect
the satisfactory performance of the flight crew’s duties.
(c) For seaplanes or floatplanes, riding lights are required when anchored at night.
23. 1400 Cockpit and Cabin Environment
Scope.
This requirement accomplishes the objective as stated in the purpose.
Purpose.
The purpose of this requirement is to ensure that airplanes are designed to have ventilation, pressurized
cabins, oxygen equipment and supply, minimum mass flow of supplemental oxygen, oxygen distribution
system, equipment standards for oxygen dispensing units, means for determining use of oxygen,
chemical oxygen generators, fire protection for oxygen equipment, and protection of oxygen equipment
from rupture, appropriate for safe operation.
Application.
This requirement applies to all airplanes certified under this part.
Requirement.
A safe, habitable environment for crew and passengers must be provided throughout the normal
operating envelope of the airplane and during emergency events.
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Appendix E
23.1419 Ice Protection Equipment.
Scope.
This requirement accomplishes the objective as stated in the purpose.
Purpose.
The purpose of this requirement is to ensure that airplanes are designed to be capable of operating in
icing conditions of durations consistent with the approved kinds of operations and limitations
established for the airplane
Application.
This requirement applies to all airplanes certified under this part.
Requirement.
(a) The airplane must be shown capable of operating in icing conditions of durations consistent with the
approved kinds of operations and limitations established for the airplane.
(1) For basic approval under this part, the aircraft must be capable of operating in accordance with
paragraph (b) of this section
(2) If approval for instrument flight rules is requested, the aircraft must be capable of operating in
accordance with paragraphs (b) and (c) of this section
(3) If approval for flight in icing conditions is requested, the aircraft must be capable of operating in
accordance with paragraphs (b)(c) and (d) of this section.
(b) The airplane propulsion system must be protected against icing and be shown capable of operating
through the applicable power ranges without accumulations of ice on the engine, induction system
components or airframe components that would adversely affect engine operation, result in
unacceptable engine damage, or provide insufficient power or thrust.
(c) Pitot and static pressure sources and any other critical external probes must be protected
sufficiently to perform the intended function
(d) The windshield and windows must be protected sufficiently to provide adequate view for taxi,
takeoff, approach, landing and approved maneuvers
Subpart G – Operating Limitations and Information
23.1501 Operating limitations.
Scope. This standard specifies performance standards for providing operating limitations to the pilot.
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Purpose. The purpose of this standard is to ensure the flight crew is supplied and has available a
complete, accurate and usable list of limitations used during airplane operation.
Application. This standard applies to all part 23 airplanes.
Requirement. The operating limitations within which compliance with this part is determined, together
with any other information necessary to the safe operation of the airplane, must be established and
made available to the flight crew by an acceptable means.
23.1529 Instructions for Continued Airworthiness.
Scope. This standard specifies performance standards for the continued airworthiness instructions.
Purpose. The purpose of this standard is to provide the airplane’s maintainers with the appropriate
instructions to repair and maintain the airplane in a safe manner relating to the airplanes conformity at
type certification and/or following an approved alteration or modification.
Application. This standard applies to all part 23 airplanes.
Requirement. The applicant must prepare Instructions for Continued Airworthiness in accordance with
Appendix G to this part that are acceptable to the Administrator. The instructions may be incomplete at
type certification if a program exists to ensure their completion prior to delivery of the first airplane or
issuance of a standard certificate of airworthiness, whichever occurs later.
23.1541 Instrument markings and placards.
Scope. This standard specifies performance standards for instrument markings and placards.
Purpose. The purpose of this standard is to provide the pilot with immediate information for critical
parameters such as loading limits and V‐speeds. It also provides the pilot with helpful references for
safety related parameters.
Application. This standard applies to all part 23 airplanes.
Requirement.
(a) Each airplane must contain:
(1) Placards and instrument markings appropriate for the category of airplane for which certification is
requested; and
(2) Any additional informational placards and instrument markings required for its safe operation if it
has unusual design, operating, or handling characteristics.
(b) Each placard and instrument marking prescribed in paragraph (a) of this section:
(1) Must be displayed in a conspicuous place; and
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(2) May not be easily erased, disfigured, or obscured.
(c) For airplanes which are to be certificated in more than one category:
(1) The applicant must select one category upon which the instrument markings and placards are to be
based; and
(2) The instrument marking and placard information appropriate for each category in which the airplane
is to be certificated and that is required for its safe operation must be furnished in the Airplane Flight
Manual.
23.1581 Airplane Flight Manual.
Scope. This standard specifies performance standards for pilot information requirements relating to
airplane limitations, operations, performance, and procedures.
Purpose. The purpose of this standard is to provide the pilot with all the information necessary for the
safe operation of the airplane as it applies to the relevant operating rules.
Application. This standard applies to all part 23 airplanes.
Requirement. An Airplane Flight Manual appropriate to the type of airplane for which certification is
requested must be furnished, stowage for it must be provided, and it must contain the following:
(a) Information that is necessary for safe operation because of design, operating, or handling
characteristics.
(b) Further information necessary to comply with the relevant operating rules.
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Appendix F
APPENDIX F – TYPE CERTIFICATION / PRODUCTION CERTIFICATION WORKING
GROUP PAPERS AND PROPOSALS
Appendix F.1 ‐ Type Certificate/Production Certificate Report Out
14 CFR Part 23 Reorganization ARC
Type Design and Production Certification (TC/PC) Working Group
Report Out
Purpose: In response to the 14 CFR Part 23 Reorganization ARC charter to reduce simple airplane
certification costs and time burden, the TC/PC working group set out to identify improvements in both
the type design certification process and the production certification process. These improvements
would cut the cost of certifying all part 23 airplanes or changes to them and also cut the costs of
production. Further, opportunities to improve safety were also considered.
Working Group Membership:
Name Company
Randy Shields ‐ chair Hawker Beechcraft
Oliver Reinhardt Flight Design
Brian Richardet Cessna
David Stevens Quest Aircraft
Rob Robino Honda
Larry Van Dyke ICX Consulting
Kerri Hinton Kestrel
Chris Mitchell Cirrus
Clay Barber Garmin
Anna Dietrich Terrafugia
Blake Cheney TCCA (AARTC)
Dave Magruder FAA: AIR‐220 (PC)
Steve Flanagan FAA: AIR‐110 (Cert Proc)
Approach: The initial activity of the working group was to identify cost drivers in the certification
process (Attachment 1). For each cost driver, comments were identified along with suggested changes
or solutions. In addition, it was indicated if the suggested solution would decrease costs for industry as
well as FAA. It was also identified if the change would improve safety.
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Appendix F
After considerable discussion about this list of cost drivers and possible solutions, the working group
decided to focus their efforts on several key areas and develop white papers. These white papers would
explain the issue and then provide a suggested solution for FAA consideration. White papers were
developed for the following:
FAA Conformity
Minor Change Approval
Applicant Showing Only
Use of Video Recordings in Testing
Design Organization / Production Organization Handbook including Simplified Production
Certification
The following discusses each white paper at a high level. Copies of each paper are provided in
appendices F.2 through F7.
Cost Savings Summary:
FAA Conformity Direct type certification conformity expense
savings on the order of 2 to 8 full time heads
depending on the complexity of the project.
Travel savings of $40,000 per year during routine
times to $200,000 per month during peak type
certification efforts.
Minor Change Approval One company that has a more onerous minor
change approval process stated they review
approximately 2000 minor changes per year. They
expect to save over $100,000 per year through this
proposed process.
Applicant Showing Only For a company with a single product line, this is
estimated to be on the order of $50,000 per
program. For a company with multiple product
lines, savings on the order of $250,000 per year
are anticipated. Additional savings due to the
ability to use critical designee resources for higher
level safety enhancing activities were not
quantified.
Use of Video Recordings in Testing Travel expenses for applicants could easily be
reduced by $40,000 or more per project
depending on the quantity of tests
Design Organization / Production Organization A new entrant to the aviation field could save
Handbook including Simplified Production $200,000 in their initial development of manuals
Certification and processes through the use of this document.
Additional savings for routine maintenance were
not quantified.
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Appendix F
FAA Conformity Process:
There was unanimous agreement by the working group that the FAA conformity process was the
number one cost driver in certification. The FAA conformity process is essentially a double check of the
applicant process, as the applicant is required to do 100% company conformity. It is interesting to note
that the FAA conformity process is unique to the FAA. For example, two of the other major certification
authorities, EASA from Europe and TCCA from Canada, do not require this second check of
configuration. The working group outlined the following objectives for a new process:
Replace individual component based conformity with a systematic approach to test article
configuration management that satisfies FAA conformity and safety requirements in accordance
with 14 CFR 21.33 and 21.53.
Streamline the test article inspection and conformity process to eliminate unnecessary and
redundant activities.
Maintain or improve safety for flight test pilots.
Consolidate and integrate records for as‐designed, as‐built and as‐tested configurations to
improve assurance that the as‐tested configuration is representative of the approved type
design, or serves the intended purpose of the test.
Consolidate and integrate records showing a company’s progression towards production
approval readiness for a new model and to facilitate expedient issuance of applicable
airworthiness certificates.
Utilize Configuration Management as an integral part of the production process.
The proposed solution was for the FAA to allow adoption of modern configuration management
practices. Configuration Management (CM) can be used to track the design throughout the life of the
test article and provides the same information as conformity about the as‐designed, as‐built and as‐
tested configurations, including any deviations and their disposition, at any time during the project. This
approach ensures the article is properly controlled through a CM system versus the current conformity
process which is only capable of managing configuration at the individual component level. This is
because a CM system manages the complete lifecycle of the article through an integrated system
whereas the FAA conformity process manages build configuration in discrete packages that require
manual reconciliation of configuration, which is often overly burdensome to manage. Further, under
FAA conformity, the business systems for managing as‐designed, as‐built and as‐tested configurations
are often separate systems (e.g. design and test configuration changes are often tracked separately
following the as‐built conformity inspection), which makes reporting difficult during the reconciliation
process.
Benefits of this process for the applicant would be reductions in:
a. Direct expenses caused by FAA conformity,
b. Indirect expenses caused by program delay, and
c. Operating expenses for designee or FAA inspectors to travel to witness FAA conformity
inspections.
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Appendix F
The white paper details direct type certification conformity expense savings on the order of 2 to 8 full
time heads depending on the complexity of the project as well as travel savings of $40,000 per year
during routine times to $200,000 per month during peak type certification efforts.
While the FAA also benefits from reduced cost of oversight and travel, some of the more intangible
benefits the FAA may see include:
Advisory Circular (AC) guidance that will standardize the CM procedure across applicants that is
created by industry participants to assure grounding in current practice (note there is significant
disparity between applicants implementing the FAA conformity process today).
More accurate revision control of test article configuration for applicants and Aircraft
Certification Offices that allow use of “…or later FAA approved revision” statements on Request
For Conformity because a CM process would allow the applicant or FAA to query article
configuration and compare to the required configuration at any time during the test program
rather than leaving an open‐ended conformity request.
Configuration management systems that enable documentation of the evaluation of mid or late
program design changes on previously accomplished testing
Three sections of 14 CFR part 21 apply to the conformity process: §§ 21.33, 21.35(a) and 21.53. The
white paper provides a brief discussion of each and the impact of this proposal. In summary, the
proposal to use configuration management meets the requirements of part 21 without further rule
change. FAA conformity is not discussed anywhere in the regulation, but instead has been used as one
method to meet the intent of § 21.33(a). This proposal would enable an alternative method to meet the
inspection and configuration management requirements of part 21.
The white paper proposes new guidance should be developed to provide a configuration management
and inspection standard that can be referenced by applicants and FAA personnel and provide the
minimum requirements by which to approve and audit the applicant’s program. The following Advisory
Circular should be developed to provide a complete description of the CM process:
Draft AC 21‐xx Configuration Management System for Control of Certification Test Articles,
Production, and other appropriate article configuration relevant areas (this will be drafted by
industry and proposed to FAA)
This AC should consider:
o The controlled data listed in FAA Order 8110.4C, Para 5‐3.d.
o The controlled data listed in FAA Order 8110.49, Para 4‐3 and 4‐4
o Description of Compliance Verification Engineer qualifications, functions, and
limitations.
o Improving guidance for completing Request for Conformity Special Instructions that
addresses the issue of generic Special Instructions that are insufficient to determine the
specific issue of concern to the requesting FAA ACO Engineer or designee.
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Appendix F
To avoid burden for applicants already using FAA approved inspection procedures for type certification,
the guidance should allow for inclusion of inspection procedures in the Quality Assurance Manual
(QAM), ODA manual or other FAA approved manual held by the applicant.
Minor Change Approval:
The working group compared the minor change approval process each ARC member company used and
noted a lot of variation, with some companies having a very onerous process and others a more
streamlined process. The working group compared the various processes and then selected best
practices from each to develop a proposed method for approval of minor changes to type design by an
airplane manufacturer. It should be noted the Alterations and Maintenance Working Group also
addressed this issue, but from an alteration perspective. The two groups worked together to develop
common definitions to the extent possible.
14 CFR 21.95 states that minor changes in a type design may be approved under a method acceptable to
the FAA before submitting to the FAA any substantiating or descriptive data. Further, 14 CFR 21.93
defines a minor change as one that has no appreciable effect on the weight, balance, structural strength,
reliability, operational characteristics, or other characteristics affecting the airworthiness of the product.
A significant area of concern to both working groups was the definition of “appreciable” in 14 CFR 21.93.
The white paper proposes what “appreciable” means for each of the 6 characteristics identified in the
rule (weight, balance…). The paper also offers guidance as to the types of changes that affect different
engineering disciplines. Lastly, the paper proposes a process for approval of a minor change to type
design.
The process relies on qualified personnel to determine if a change to type design is major or minor
based on 14 CFR 21.93 and the guidelines in the white paper which supplement 14 CFR 21.93 (i.e. the
definition of appreciable). The decision of major or minor for the change is determined for each affected
discipline, including consideration for the cumulative effect of minor changes. For the change to be
minor, it must be determined to be minor for all affected disciplines. The change evaluation rationale is
documented and retained.
The company completes any engineering activities associated with the minor change, including:
a. Any analysis is complete and company approved
b. Any company testing required to confirm no appreciable affect at the airplane level is complete,
documented, and company approved
c. The change to the type design drawing(s) are company approved
After completing these activities, the minor change is considered approved through this process. The
company retains evidence of completion of this process for every minor change. This evidence may be
reviewed during FAA audit activities.
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Appendix F
One company that has a more onerous minor change approval process stated they review
approximately 2000 minor changes per year. They expect to save over $100,000 per year through this
proposed process.
It is the working group’s expectation that the FAA will find the process defined in the white paper for
approval of minor changes to type design acceptable and issue a policy memo or other statement
supporting it as a “method acceptable to the FAA.” Each company can then decide to either stay with
their currently approved process or adopt this new one.
Applicant Showing Only :
The goals of the part 23 ARC were to reduce the cost of certification and to improve safety for the part
23 aircraft. This paper proposes a method to do both through:
a. Use of Safety Management tools the FAA is implementing, and
b. Less direct involvement of the FAA in determining compliance to the regulations as allowed
by 14 CFR 21.
A number of the FAA Safety Management Processes and Orders were considered when developing the
risk based process proposed in this paper for determining when an applicant can simply show
compliance without the FAA, a DER, or ODA unit member finding of compliance.
A recent change to 14 CFR 21 is the addition of the Statement of Compliance requirement of 14 CFR
21.20(b) and 21.97(a)(3) that increases the accountability of the applicant’s management to ensure that
compliance is properly shown as described in Advisory Circular 21‐51. Consequently, in addition to
there being economic incentive, there is further legal incentive for applicant management to ensure
compliance is properly accomplished without having to rely on the FAA, a DER, or ODA unit member to
find compliance.
This paper proposes a structure for when applicant showing only is sufficient as a function of the type of
applicant and the risk of improper test conduct / data analysis and the resulting potential impact on
safety. This proposal evaluates applicants based on three criteria:
1. Staff Competency – What is the skill level of the individual staff members of the company
working the certification activities? Are there sufficient DER’s or UM’s on staff to support a
complete aircraft design and certification project? Does the company have ready access to
specialists at suppliers or consultants as necessary to complement staff?
2. Company Competency – What internal organization and resources does the company have in
place to facilitate certification programs? Does the company management fully support the
staff training and access to resources necessary to keep the staff current with FAA policies,
regulations, and guidance related to certification activity?
3. Procedural Effectiveness – Does the company have adequate internal processes to ensure that
work product is thorough, consistent, well‐documented, etc.? Are the processes in place
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Appendix F
proven, industry best‐practices? Do the internal processes include a continuous improvement
process to evaluate the procedures on a regular basis and take corrective action as needed?
For each of three criteria, the paper details the characteristics for being rated low, medium, or high. An
applicant would work with the FAA to determine their rating for each of the three criteria. This rating
could be re‐evaluated on a regular basis as the company improves or concerns are raised. Either the
FAA or the applicant may request a re‐evaluation of the company’s rating. Based on the ratings for the
three criteria, an overall classification is established for the company based on the following:
Tier 1 would rank low in two or more of the criteria.
Tier 2 would rank medium in at least two of the criteria and high in the other.
Tier 3 would rank high in all three criteria.
For each of these company classifications, analysis and testing methods have been reviewed to assess
the risk of improper test conduct and the resulting potentially inaccurate data or potential errors in
analysis. The various analysis and tests were selected based on:
1. Analyses where:
a. The analysis method is well defined and understood – the method has been validated
and is proven; and
b. The likelihood that the analysis method will not adequately show compliance to the
requirements is very low.
2. Tests where:
a. Testing methods are well defined by either an industry standard, Advisory Circular, or
other accepted standard including company test procedures that are proven;
b. Testing methods are well understood and have little subjectivity;
c. Testing methods are repeatable – all variables that could affect the test are known and
are controllable and repeatable;
d. There are clear pass / fail criteria; and
e. The likelihood that the test method will not adequately show compliance to the
requirements is very low.
Table 1 provides the proposed work split between the applicant and the FAA for the three tiers of
applicant discussed above.
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Appendix F
Table 1 – Work Split Definition
Type Category of Applicant
Tier 1 Tier 2 Tier 3
Data Analysis Data Analysis
Data Analysis Performed by Applicant Performed by Applicant
Analysis Performed by Applicant
Analysis Approval Analysis Approval Analysis Approval
Approved by FAA (or DER) Approved by Applicant Approved by Applicant
Test Procedure Test Procedure Test Procedure
Approved by FAA Approved by Applicant Approved by Applicant
Conformity Conformity Conformity
Conformed by applicant, may Conformed by Applicant Conformed by Applicant
have FAA oversight (or DAR)
Testing Test Conduct Test Conduct Test Conduct
Conducted by Applicant Conducted by Applicant Conducted by Applicant
Test Witness Test Witness Test Witness
Witnessed by FAA (or DER) Witnessed by Applicant Witnessed by Applicant
Test Data Approval Test Data Approval Test Data Approval
Approved by FAA (or DER) Approved by FAA (or DER) Approved by Applicant
Table 2 of the white paper in Appendix F.5 identifies 24 types of analysis covered by this proposal.
Table 3 of the white paper in Appendix F.5 identifies 87 types of testing covered by this proposal.
It is suggested the FAA issue a policy memo, Advisory Circular, or FAA Order to endorse this proposal
with any adjustments as required. This would allow the use of the applicant showing only process
without waiting on further development of the FAA’s Risk Based Resource Targeting (RBRT) tool.
Use of Video Recording in Testing:
Objectives:
Acknowledge validity of utilizing video recording techniques for capturing key testing
information.
Improve quality and/or integrity of captured test data.
Improve utilization of FAA resources and designees by enabling remote witnessing.
Define parameters necessary for the successful utilization of video recordings for data capture.
Background Information:
The current primary method of data capture during certification testing is via real‐time witnessing by
appropriately delegated individuals. While this method of witnessing is sometimes augmented with
video recordings, the use of video is typically viewed as a “back‐up” to the physical presence and real‐
time witnessing of a human being. (Note that there are precedent instances where video has been
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Appendix F
utilized as the sole means of witnessing, but these have been rare and have required “special
dispensation.”)
The vast majority of test witnessing is performed by FAA designees, which places a burden on the
applicant to either hire consulting DER/UMs or obtain delegation of company DER/UMs. Regardless of
the nature of the designee, minimizing the time required of that person will have a direct corollary
effect on the financial impact experienced by the applicant.
For testing that takes place at or near the applicant’s place of business, direct travel expenses for the
applicant already will be minimal. However, if the applicant is utilizing consulting DER/UMs it is likely
that such individuals will need to travel in order to witness the test. In addition to the “base fee” for the
consultant’s time, the applicant will also incur travel, lodging, and meal expenses; also, many
consultants will charge for their on‐location time based on full‐day increments, even if the actual
witnessing efforts consume only a few hours. Even if company DER/UMs are utilized, some testing
requires travel to lab locations for witnessing; thus, the associated travel costs remain.
These effects can also significant consume FAA resources when the option is exercised to witness tests
with FAA personnel. Exercising this option normally involves traveling some distance to the test site,
incurring similar expenses to those discussed above due to either the distance traveled or the length of
the testing in question. This eventuality is more likely in the case of startup companies when confidence
in the company processes and procedures is still being assessed.
FAA test witnessing is conducted for one primary reason: to provide confidence in the validity of the test
setup, the test execution, and the ensuing results. It is possible to accomplish all of these requirements
through an alternate means to personal, real‐time witnessing – utilization of video recording.
The white paper details many potential uses of video recording and the advantages. The paper also
details the benefits to both the applicant and the FAA.
The paper identifies three primary areas that must be considered to make the use of video witnessing a
viable proposition; these are adequate coverage, video fidelity, and data integrity. The paper discusses
various requirements to consider when the FAA establishes the guidelines for video witnessing.
The paper reviews the part 21 requirements and concludes that there is nothing in the use of video as
described in the white paper that would violate any part 21 requirements; therefore, no modifications
to the FARs are necessary to allow the use of video witnessing.
A brief search of the available guidance material was conducted to see if any language was currently
being used that would preclude the use of video as described in the document; none was found.
However, two lines of reasoning were discovered that lend credence to the idea that video witnessing is
in line with the current philosophy underlying witnessing.
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Appendix F
In FAA Order 8110.37E, paragraph 2‐6.b, it states:
…DERs may be authorized to witness tests outside their area of authority provided that the DER (1) is
authorized to do so by the ACO, and (2) does not make the final compliance finding.
The implication here is that physically observing the test taking place is not necessary to find the data
valid. The importance is in monitoring the activity to ensure that the test plan was followed, no critical
errors were introduced, the data was appropriately collected, etc. Employing video witnessing as
described in the white paper can accomplish these same goals, enabling properly authorized individuals
to make final compliance findings although they were not physically present for the test.
Additionally, FAA Order 8110.37E, paragraph 4‐4.a states:
…Before witnessing the test, the DER must verify that the necessary FAA conformity inspections have been
accomplished, that the test article is in conformity, or that all unsatisfactory conditions have been
dispositioned. A DER is not required to witness an entire test to approve the test data. However, the DER
must coordinate with the ACO to determine which conditions are critical and must be witnessed in order to
ensure that all the data are valid. When DERs approve test data, they indicate that they witnessed those
portions of the test dealing with critical conditions, the test was conducted in accordance with the FAA
approved test plan, and the data are official test results that satisfy the test criteria for compliance.
The proper use of video witnessing would provide the ability to not only “witness those portions of the
test dealing with critical conditions”, but also the ability to review these critical events in detail. In
addition, non‐critical portions that may otherwise go un‐witnessed would be available for review at the
DER’s discretion. The utilization of video witnessing would not only meet the intent of the existing
guidance, but could be leveraged to actually enhance the witnessing coverage.
The white paper concludes that new guidance should be developed to provide a video witnessing
standard that can be referenced by applicants and FAA personnel, and to provide the minimum
requirements by which video witnessing can be successfully utilized. The following Advisory Circular
should be developed to provide a complete description of the video witnessing process:
Update policy to endorse the use of video technology in test witnessing
Endorse an industry standard developed by ASTM F44 on Video Witnessing of Certification Tests
This standard should consider:
o The types of testing that could most benefit from the use of video witnessing; and
o The minimum parameters discussed above regarding coverage, fidelity, and integrity.
Production Certification Manual:
Several airplane manufacturers of this working group provided a copy of their Quality Manual to show
how the 14 elements of 14 CFR 21.137 are satisfied to establish and maintain a production certificate.
These manuals were compared and best practices identified with an eye toward simplicity. The result is
a draft quality manual that provides new aviation business entrants a detailed starting point in
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Appendix F
developing and obtaining their own production certificate. This draft manual is part of the Design
Organization/Production Organization (DO/PO) handbook described in the next section.
Design Organization / Production Organization Handbook:
In a typical aviation company of today, different applicable sets of procedural, organizational, and
quality management/assurance requirements are satisfied by separate handbooks for different
segments of company. Most companies maintain separate TC and PC handbooks, and when operating
in different countries, sometimes slightly varying versions of these handbooks.
Current implementation of the regulations (by FAA Orders) asks for predefined handbook structures for
the individual operational segment that do not allow for a unification of the process world. Significant
effort is spent to establish and maintain separate handbooks resulting in high administrative burdens,
especially for small companies that maintain both TC and PC handbooks for one product, for one
company, under one roof. This gets more complicated when the same company acts as component
supplier under AS / EN 9100 approval with a third set of requirements and a third handbook. The
situation causes a direct basis for conflicting information with the connected risk of process errors in
daily work.
By comparing the requirements basis for existing accepted handbook samples, a harmonized approach
is identified that allows small companies to set up one single, integrated quality management process
satisfying all typical requirements, as an alternative to today’s interpretation indicated by the Orders.
The harmonized approach is manifested in a standard handbook template that can be utilized and
adopted to the individual company conditions.
The harmonized standard handbook implements several results of other ARC part 23 work group topics
with identified significant potential for optimization of today’s process in time, effort, cost and safety. By
including these results within a standard handbook, a level playing field is established with limited room
for local interpretation that might have negative impact for an individual company.
Throughout the process of generating the standard handbook approach, it has been verified that this
handbook is capable of complying with the regulations of different major Agencies. This levels the
playing field even beyond the limits of FAA jurisdiction.
The subject matter was identified within the Part 23 ARC activity as it highly relates to cost occurring
when certifying a new project or making changes or STC to an existing project. It is recognized that the
implementation is beyond the Scope of Work of the Part 23 ARC. Therefore, this paper is used to relate
the outcome of the intense discussions and subsequent work to a parallel Part 21 ARC process.
The level of completion of this task is such that the activity can be handed over to an industry standards
body. It is the recommendation of the task group to initiate this as the next step.
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Appendix F
Appendix F.2 ‐ PC/TC Work Group Cost Drivers List
The PC/TC Work Group brainstormed issues that were causing each of their company’s difficulties and
non‐value added costs in the certification process. The initial list below identifies 50 of these items.
Item
Cost Driver
No.
PART 21 SPECIFIC
1 Conformity – we need to adopt the Canadian and EASA approach and be configuration based.
We would still perform company first article inspections, but we don’t need FAA inspectors (or
designees) doing a second check of what the company has already done. Also, use the fact an
article has passed its functional test as a measure that the configuration is OK.
2 Remove the requirement for Function and Reliability testing. Leave it to the business to decide if
the airplane is ready for the marketplace or not. Don’t impose an additional 150 to 300 hours of
flight test time just flying around to continue to prove everything is working.
3 Part 21 requirements are in several areas disconnected from other industry standards. Industry
level QM certificates are a complete “parallel universe” with no transparency and repeated
effort, double documentation, partially conflicting.
FAA ORDER SPECIFIC
4 Current standard definition of major / minor changes suits large aviation, but is often overdone
for small aviation where some items can be less critical. This results in major changes, that could
be easily minor changes; but reclassification requires Agency interaction with all time
constraints.
5 ODA Order appears to require setting up completely independent TC and STC ODAs that
essentially have to have duplicate requirements for TC and STC ODA if a TC ODA holder desires
to create STCs for changes instead of doing an amended TC.
6 Having to send the FAA project notifications by letter is time consuming and delays getting
projects reviewed, responded to, and accepted by the FAA.
7 The procedures in FAA Order 8110.4 are stifling the certification process and choking both the
FAA and industry on unnecessary paperwork.
8 Make it easier to get all aspects of the unit design and qualification under TSOA as possible
irrespective of specific TSOA requirements. Often unless the TSOA has a mandated requirement,
credit cannot be taken for effort done by the TSOA supplier.
9 Unwillingness of ACO to accept electronic approvals of 8110‐3, 8100‐9, and other FAA forms
drives additional unnecessary costs and delays into certification process.
10 Software design assurance is also very expensive to conduct with minimal perceived safety
value. We rarely find anything wrong other than the documentation could be better. It either
passes the testing or it doesn’t.
11 The NACIP/RFC process is hugely cumbersome with very little value added.
DESIGN ORGANIZATION SPECIFIC
12 One of the biggest problems with the ODA process has been the ability to get an ODA manual
written and approved in a timely manner.
13 ODA Order manual requirements are not written to allow easy combination of multiple types of
ODAs. Some larger companies have TC, STC, PC, and MRA ODAs but manual structure
requirements make it difficult to use same procedures such as conformity and approvals for TC,
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Appendix F
Item
Cost Driver
No.
STC, PC, or MRA ODA’s without duplicating procedures in separate manuals within a manual.
The entire recommended manual structure is difficult and cumbersome to make work
efficiently.
14 No standard manuals for PO and DO available. For small companies standard handbooks can be
very beneficial, as differences between the company setups are little in this segment.
15 Eliminate the need for people with special authorizations (FAA or designees) as much as
possible. Accept company or supplier testing with no need for a special witness to the maximum
extent possible. Company approval of data should be sufficient.
16 Conflicting interpretations create unnecessary delays and costs in the certification process.
17 Orders and ACs are being enforced as de facto rules, and are often interpreted in direct
opposition to the actual rules (FARs).
18 Sequencing and the lack of FAA resources to work project issues early (while in sequencing) if
applicant is ready The FAA encourages applicants to better amortize project workload, but
sequencing pushes this workload off for 6 – 12 months or more.
19 Trend toward FAA requiring higher‐fidelity PSCPs from applicants (major issue seen w/ GAMA
Airframe Manufacturers Group members…i.e., the Wichita manufacturers)
20 Lack of repeatability in expectations amongst FAA staff (engineering and
manufacturing/airworthiness)…despite the goal, there is not ‘one FAA’
21 FAA maintains a paradigm that turbofan aircraft need to have a higher level of safety than
reciprocating and even turboprop aircraft, even though they acknowledge a turbofan’s much
better safety record
22 Establishing a product’s certification basis is probably more contentious than it needs to be in
many instances
23 Long duration to obtain the certificate requires effort and support and drives cost.
24 High demand to document staff qualification.
25 Qualification requirements for staff are very high and the same regardless if a small aircraft or
an airliner is produced. For small aircraft companies this increases qualification cost and salaries.
26 High demand to document supplier and design subcontractor qualification and continued
surveillance.
27 Consideration of DO and PO as independent companies, resulting in the need for an
independent setup and interface definition. In the world of small Part 23 manufacturers this is
an uncommon setup, the requirements overload the majority of companies for extremely few
companies that might have this split setup of TC holder versus PC holder.
28 Stepwise approval process, especially for the different organizations, generates repeated effort
and cost in own and contracted specialist staff.
29 <Validation Issue> EASA discourages early application and coordination from U.S. manufacturers
by imposing an annual fee after application. Many FAA applicants cannot shoulder the cost of
nearly concurrent EASA cert/validation, yet they would greatly benefit from early coordination
and issue resolution.
30 EASA world: Cost allocation for DO surveillance is defined on the basis of the staff (headcount)
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Appendix F
Item
Cost Driver
No.
at the Design organization. This is questionable, as the number of staff is not automatically
complicating the management system under surveillance. Therefore, the headcount at the
company is not automatically increasing the effort the Agency has when providing oversight.
31 Standards / suitable and pragmatic AMC for standard case qualifications are missing. This affects
load assumptions, test methods, system qualification.
32 Annual fee while in TC process results in a certification cost block that is time dependent and
cannot be predetermined. True workload is certification project related, not time related
33 Development of certification basis does not keep pace with technological developments.
34 Composite material certification requirements tend significantly to Part 25 aircraft requirements
and do not match the needs for small aircraft. Results in inefficient solutions or drives to
systems the small manufacturer cannot handle, resulting even in safety risks.
35 Validation of types for other countries often delayed due to non‐availability of representatives
abroad.
36 Strong focus on formal correctness, instead of technical and factual correctness results in
enhanced efforts with no technical result achieved or safety enhanced.
37 For organizations with an ODA, eliminate the Partnership for Safety Plan since nobody follows it
anyway.
38 ODA process does not seem to be functioning as was intended. In some cases there seems to be
less delegation than under the standard cert process being used prior to companies going over
to ODA.
39 Auditing is becoming more and more effort. We have many redundant audits and audits of
audits. It is obvious that there must be a robust means to ensure a company is doing what they
need to but we need to find a way where this can be done easier and with less redundancy.
40 Showing of compliance to regulations for small and simple aircraft (e.g. Class I and II).
PRODUCTION ORGANIZATION SPECIFIC
41 Certified Quality Standard – re‐write Part 21 to allow a general quality standard, such as ISO
9001 or AS9100, in place of a PC. However, don’t be prescriptive in writing this so that there is
the ability to comply in several different ways. For companies that also produce Part 25 business
jets, it would be nice to pull these into the Part 23 tiered system or develop a Part 24 for them
so that the same efficient production system that will be developed for Part 23 airplanes can
also be applied in the same factory to Part 25 business jets.
42 Undue Burden – getting out from under the FAA PC process will lessen the need for FAA audits
of foreign suppliers or the “belts and suspenders” approach required when the FAA doesn’t
have the budget to do the inspections. Using a Certified Quality Standard as mentioned above
would enable this. Let the industry control their suppliers wherever they reside.
43 Export of Parts – getting away from the FAA PC process would eliminate the re‐inspection of
supplier parts that are already fully inspected and the paperwork currently required. You would
still meet State Department requirements for export, and also inspect for damage or shelf life
before shipping. However, you would stop inflecting damage through this second inspection of
parts already fully inspected and packed appropriately by the supplier.
44 FAA oversight of the physical plant floor plan layout is stifling and creates unnecessary cost.
Which work bench is used for which work effort should be an internal business decision,
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Appendix F
Item
Cost Driver
No.
provided that the work product is properly controlled and identified. A great deal of time is
spent roping off areas and hanging signage to identify “non‐production work areas” – this adds
nothing to the safety of the final product.
45 Production ends with Form 52 (Statement of Conformity). In case of maintenance or repair
needs after signing this sheet, but prior to delivery, an approved maintenance organization is
required. Therefore, POs (at least in EASA world) must maintain in parallel a MO, which is again
another organization under again different oversight. Also valid for repairs after delivery – who,
if not the manufacturer, is best suited to do especially major repairs; why different organization
certificate required?
46 EASA world: Cost allocation for PC surveillance is bound to company turnover. This is
questionable, as the complexity of the organization under surveillance is not automatically
turnover dependent.
FAA SPECIFIC
47 Auditing by Authorities requires staff availability and generates travel cost, especially when DO
and PO are treated separately.
48 Waiting times for authority audits (due to capacity limitations and priority definitions at the
authority) cost serious money, as the staff must be held available while no privileges exist to
generate income.
49 Required repeating (scheduled) supplier and subcontractor audits bind capacity and generate
cost.
EASA SPECIFIC
50 In EASA World: Responsibilities for design and production surveillance are split between EASA
and national authorities. This causes significant raise in effort, justified by no safety gain at all.
How is situation in FAA world – is the identical section of FAA responsible for PO and DO, or is
this also split between different branches resulting in complete double work?
The work group narrowed the list down to 17 items that they felt were significant and that needed
further review. From the 17 items the group determined that they would concentrate on 5 items that
would provide the most benefit and could be accomplished with no regulatory changes but might
require policy papers or changes to Orders or issuance of new ACs.
Final List of Cost Saving Items Proposed
The following lists only the five issues the TC/PC group felt would provide significant cost savings and
could be accomplished without changes to part 21.
1. Establish acceptable major/minor criteria for changes. Minor changes shall be automatically
delegated to an organization who uses the procedures defined within this document or another
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procedure documented and accepted by the FAA. This led to the minor change approval white
paper.
2. A standard template for a production manual to cover production. The standard manual must
be detailed and complete enough and without duplications, that only minor customization is
required for a start‐up company to get it working and approved. The standard handbook shall
be structured to be most efficiently with a small company, that holds TC and PC in one hand,
and at one location. The handbook shall identify how it should be split when this is not the case,
without duplicating efforts for companies who have it all in one hand. Note: Standard
Handbook structured is recommended for new start‐up companies with only a TC application.
This led to the DO/PO Handbook template.
3. Finding of compliance in non‐complex projects by company delegates; Authority will only
perform spot checking. This led to the Applicant Showing Only paper.
4. Configuration control and verification of certification and test articles (e.g., conformity
inspections) shall be typically done by the organization, not by the Agency. Definition of a
proper standard process allows for this delegation. This led to the Configuration Management
paper.
5. The final issue was on Video Test Witnessing as presented in the Video Witnessing white paper.
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Appendix F
Appendix F.3 ‐ Conformity White Paper
Topic: FAA Conformity
Objectives:
Replace individual component based conformity with a systematic approach to test article
configuration management that satisfies FAA conformity and safety requirements in accordance
with 14 CFR 21.33 and 21.53.
Streamline test article inspection and conformity process to eliminate unnecessary and
redundant activities.
Maintain or improve safety for flight test pilots.
Consolidate and integrate records for as‐designed, as‐built and as‐tested configurations to
improve assurance that the as‐tested configuration is representative of the approved type
design, or serves the intended purpose of the test.
Consolidate and integrate records showing the company’s progression towards production
approval readiness for the new model and to facilitate expedient issuance of applicable
airworthiness certificates.
Utilize Configuration Management as an integral part of the production process.
Background Information:
The current method of implementation of the FAA conformity process results in significant redundancy
of conformity inspections and disposition of deviations. By regulation, the applicant must complete
100% inspection which is followed by applicant disposition of deviations. When applying the FAA
conformity process, the FAA may again conduct another inspection and must disposition deviations.
The FAA conformity process is:
Frequently being applied to 100% of components due to current interpretation of FAA
guidance found in 8110.4, although not required by Part 21, and
May be applied multiple times to a single component if used on multiple unrelated tests.
Both of these scenarios are discussed in more detail in paragraph a) of the Benefits section of this paper.
FAA designees are most commonly used for FAA conformity inspections, thus the burden is significant
on the applicant to either hire a DAR or employ a DMIR. Note: hiring of DMIRs is only an option
available to existing FAA production approval holders so the current FAA conformity inspection practice
is even more burdensome on new start‐up companies because they have to hire DARs.
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Appendix F
Significant FAA resources are also consumed by this process to manage FAA paperwork and support
designee oversight, especially when full delegation is not authorized for all conformity activity which is
often the case with new startup companies.
FAA conformity is conducted for three primary reasons: to ensure the test article complies with the type
design approved for the test; to ensure the article is in a safe condition for flight; and to monitor an
applicant’s progression towards obtaining a production approval for the new model. It is possible to
accomplish all of these requirements through an alternate means – configuration management.
Description of Change:
Configuration Management (CM) can be used to track the design throughout the life of the test article
and provides the same information as a conformity about the as‐designed, as‐built and as‐tested
configurations, including any deviations and their disposition, at any time during the project. This
approach ensures the article is properly controlled through a CM system versus the current conformity
process which is only capable of managing configuration at the individual component level. This is
because a CM system manages the complete lifecycle of the article through an integrated system
whereas the FAA conformity process manages build configuration in discrete packages that require
manual reconciliation of configuration, which is often overly burdensome to manage. Further, under
FAA conformity, the business systems for managing as‐designed, as‐built and as‐tested configurations
are often separate systems (e.g. design and test configuration changes are often tracked separately
following the as‐built conformity inspection), which makes reporting difficult during the reconciliation
process.
Most applicants do not use the idealized design‐build‐test‐report‐optional FAA spot check due to it
being too costly and time consuming. Rather they use a concurrent design‐build‐test‐certify process.
With this process the test articles are constantly evolving and changing configuration during the test
program. Without a compelling beneficial reason for an applicant to implement a robust CM system,
early in its certification efforts, both the FAA and the company relegate themselves to relying on a labor
intense and discrete FAA conformity inspection process verses an overarching conformity lifecycle
process such as that afforded by a CM system.
The CM system would be approved and audited by the FAA, removing the need to inspect and
document individual components and greatly increasing FAA and company efficiency. The applicant
would be required to document and manage the CM system to ensure integrity in the process is
maintained. This could be accomplished similar to Part 21 quality systems through an FAA approved
procedure, internal audits and corrective action for process non‐compliances. These audits would be
“spot‐checks” of the system to support continuous improvement of the processes and people involved.
Metrics would be maintained for measuring process maturity over time that could include compliance
percentage from process audits, turnaround time on corrective actions, personnel qualifications, or
missed inspection points from product audits. Further details for measuring CM system maturity will be
documented in the AC proposed later in this paper.
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Appendix F
The applicant would increase efficiency by removing redundancy in the inspection process and
combining activities into a single integrated process as opposed to the current multiple independent
processes. Further, use of a systematic integrated approach to managing configuration enables greater
efficiency during testing and reporting – a time when applicant schedule is most compressed and the
certification costs per day are the highest.
The applicant would use a FAA approved inspection system through an existing approval such as a
Production Certificate or specifically approved through FAA approval of the CM system itself. This would
enable equivalent FAA MIDO oversight as used for the current conformity inspection process. This
inspection system will be audited by the applicant and the FAA to ensure continued integrity. The
inspection system will require some form of standard guidance for new applicants that is described
below.
The applicant would also use a FAA approved configuration management system that would enable
equivalent FAA ACO oversight as used for the current RFC issuance process. This would be described in
a standard industry guidance document to establish the minimum requirements for configuration
management that maintains at least the same level of safety as the existing conformity process.
Documentation and FAA approval of both the inspection system and configuration management system
can be through a combination of a PSP (or ODA manual) and company procedural documents. New
applicants that lack a PSP or ODA could also achieve FAA approval through a project specific document
such as a PSCP or project conformity plan. Note: use of a CM process in lieu of FAA conformity requires
an applicant to demonstrate maturity of the process sufficient that it will satisfy the conformity
requirements of Part 21. Failure to demonstrate would require the applicant to default to the FAA
conformity process or to make appropriate changes in the process to ensure the appropriate capability
is added.
Benefits for Applicant:
Three different aspects are considered for the analysis of applicant benefits:
a) Direct expenses caused by FAA conformity,
b) Indirect expenses caused by program delay, and
c) Operating expenses for travel to witness FAA conformity inspections.
a) Use of an FAA approved CM system in place of the current FAA conformity process using individual
discrete Requests for Conformity will reduce applicant workload through reduction of redundant activity
already performed by the applicant during the inspection process. Due to inconsistency in applying the
FAA conformity process, two different scenarios have been experienced by applicants.
The first scenario consists of requiring FAA conformity only for critical components undergoing tests.
With this process, FAA conformity is applied against a specific test plan. Thus, if a single component is
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Appendix F
considered critical for more than one test plan, it may have an RFC for each test plan. This requires
redundant information on each RFC and redundant tracking and conformity of each individual RFC.
The second scenario applies FAA conformity to every component and/or drawing on the test article, but
only once regardless of how many tests it will be used for. This method is applied because the
applicant wants to reduce risk of failing to conduct FAA conformity on components the ACO may find to
be critical just prior to test. This conservative approach removes any uncertainty in having to decide
what is and is not critical for the test but adds significant unnecessary work.
The first scenario may result in fewer FAA conformity items, but the applicant is at risk of failing to
identify a critical item until just prior to testing, thus causing a delay in the test preparation and test
process. The second method reduces that risk at the cost of possibly applying more FAA conformity
than necessary.
For each FAA conformity request, a conservative direct savings to the applicant will be as follows
assuming designees have full authority of the FAA conformity process:
10 min – 8120‐10 form processing
5 min – 8130‐9 form processing
10 min – FAA inspection review
10 min – 8100‐1 form processing
5 min – copying, filing and transmittal of data to FAA staff
Total time = 40 min per conformity request
These procedural activities would not be required for managing conformity through configuration
management and are considered purely redundant to existing applicant inspection procedures. With a
mature inspection system, it is unlikely the DMIR/DAR inspection will find non‐conformances not
already identified by the applicant’s inspector. Further, most companies conducting FAA conformity
also use an electronic database to manage data. Thus, the data entry on the FAA forms is purely
redundant relative to a configuration management process.
Note this does not include resources for applicants also using the NACIP system, which could add
another 10 minutes to the data entry process. It is possible applicants using NACIP would discontinue
using one of the other business processes, but not guaranteed depending on the level of business
system integration of the other systems already in place.
A small aircraft company using the low‐risk approach to FAA conformity by applying it to every
component and drawing will require approximately 7500 conformity articles (3 flight test aircraft and
equivalent of 2 aircraft in ground test articles) for a new TC airplane. Total applicant savings would be
2.4 FTE (Full Time Equivalent). Savings on a more complex small aircraft project could be as high as
25,000 conformity articles, or 8.0 FTE.
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Appendix F
b) Another possible cost to an applicant is in program delay. Risk for program delay is increased for
applicants who do not have designees with authority to conduct portions of the FAA conformity process.
Program delays could be caused by applicants waiting for FAA to issue RFC forms, disposition deviations
or conduct conformity inspections. While it is expected the applicant coordinate with FAA personnel,
unanticipated events or non‐standard work may interfere with those plans and inadvertently cause
delay. An FAA approved configuration management and inspection process would mitigate this risk.
Program delays of a single day can run over $100,000 and have been calculated up to nearly $1,000,000
per day for higher‐end Part 23 aircraft. While it is difficult to quantify this cost or even determine the
probability that FAA conformity contributes to a program delay, the risk exists, and in fact has caused
significant delays on a number of programs.
c) The current FAA conformity process requires travel to the location of manufacture not only for the
applicant’s inspector but also for the FAA inspection designee. Under a CM process, the travel could be
reduced to a single person authorized by the FAA approved process. Travel expenses for applicants can
be reduced by $40,000 or more depending on quantity of suppliers.
In general, designee expenses for a TC program can be quite high to support FAA conformity as it exists
today. One company noted DAR expenses up to $200,000 per month and $15M throughout the entire
TC program. These expenses create a significant barrier for a new start‐up company—greater than the
expenses necessary to demonstrate objective evidence for adherence to a CM procedure. The approach
discussed in this paper that focuses on process control rather than on individual designees should
provide relief to applicants.
In conclusion, other workload activities associated with configuration management are typically already
conducted by applicants through other means and would have no impact on applicant costs. However,
configuration management should increase efficiency in test article control and creating final reports,
which isn’t taken into consideration in this proposal. Nor does this consider the efficiency gained by the
ability to better schedule and manage test activities to shorten the test schedule duration. Further, the
indirect costs of signature wait time associated with the FAA conformity process and loss of efficiency
due to multiple redundant activities and corresponding business system are not considered. Thus, the
savings shown above are assumed to be very conservative.
Benefits for FAA:
Assuming the FAA currently makes full use of designees during the FAA conformity process, the direct
FAA benefits will be limited to reduced oversight requirements and paperwork processing reduction.
The FAA will benefit even further for projects where the FAA takes a more active role during the
conformity process (e.g. ACOs making extensive use of FAA employees for issuing RFC and conducting
inspections). Thus, this estimate is conservative.
FAA will save approximately 15 minutes per conformity item in paperwork review and filing for closed
conformity paperwork (both ACO and MIDO). Thus, total savings will be 0.9 – 3.0 FTE during the TC
projects previously discussed. This will be balanced by inspection system oversight for applicants
without an approved inspection system under a PC (or other means). This oversight should require
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Appendix F
approximately 40 hours per year to audit the process or 160 hours (0.08 FTE) over a three‐year program.
To maintain conservatism in the model, this evaluation does not consider reduction in designee
oversight if the final process reduces the number of designees that are involved in the process.
Some more intangible benefits the FAA may see include:
AC guidance that will standardize the CM procedure across applicants that is created by industry
participants to assure grounding in current practice (note there is significant disparity between
applicants implementing the FAA conformity process today).
More accurate revision control of test article configuration for applicants and ACOs that allow
use of “…or later FAA approved revision” statements on RFC because a CM process would allow
the applicant or FAA to query article configuration and compare to the required configuration at
any time during the test program rather than leaving an open‐ended conformity request.
Configuration management systems that enable documentation of the evaluation of mid or late
program design changes on previously accomplished testing
Maintaining Safety:
Use of configuration management in lieu of the current conformity process will maintain or improve
safety of the test articles for those conducting the tests. Real time knowledge of exact test
configuration will be known, all inspections will be by the FAA approved process and deviations closed
by a Compliance Verification Engineer (A DER, UM, or other qualified and authorized engineer whose
qualifications, functions, and limitations will be defined in the AC). This accomplishes all major safety
checks found in the current conformity process. Additionally, if a database is used it can assist the
mechanics and shop in automatically identifying any open actions on the test article that now depend
on the mechanics to remember, or something written on a piece of paper that may be buried in a book
and overlooked.
Effects on Part 21:
Three sections of 14 CFR Part 21 apply to the conformity process: Section 21.33, 21.35(a) and 21.53.
The following provides a brief discussion of each:
Section 21.33: This rule requires that “each applicant must allow the FAA to make any inspection and
any flight and ground test necessary to determine compliance with the applicable requirements of this
subchapter. (21.33(a))” This does not require 100% FAA inspection of every article for every test. This
rule requires an applicant to conduct 100% inspections of the test article (21.33(b)), ensure the article is
under configuration control (21.33(a)(2)), and make the product available to the FAA for inspection and
testing (21.33(a)). There is no requirement for FAA inspection or testing. This FAA discretion unburdens
the FAA from having to inspect and test everything submitted by the applicant. Thus, there exists
latitude in the minimum requirement; enabling the FAA flexibility in how conformity is managed and to
what extent it is applied. Use of an FAA approved inspection and configuration management system is
one method to meet this rule.
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Section 21.35(a): This rule requires an applicant to conduct 100% inspections prior to flight testing.
There is no requirement in this rule that the FAA must also conduct inspections.
Section 21.53: Requires an applicant to submit a statement of conformity for each article to be tested.
Use of the singular implies a single statement for the entire article undergoing test is acceptable. There
is no requirement for FAA conformity nor does the rule specify how the statement of conformity is
submitted.
In summary, the proposal discussed herein meets the requirements of Part 21 without further change.
FAA conformity is not discussed anywhere in the regulation, but instead has been used as one method
to meet the intent of Section 21.33(a). This proposal would enable an alternative method to meet the
inspection and configuration management requirements of Part 21.
Effects on Existing Guidance:
The following FAA Orders were evaluated for applicability to FAA conformity: 8110.4C, 8110.41A,
8110.49, 8110.105, and 4040.26A.
FAA Order 8110.4C Type Certification:
The following paragraphs of this order discuss when FAA conformity is required.
Paragraph 2‐5.c. states the following:
“…FAA conformity process is a validation of the applicant’s conformity. During the
inspection, FAA manufacturing inspectors base the depth of their assessment on factors
such as quality of the applicant’s conformity paperwork, comparison of inspection
results, and magnitude and complexity of the inspection.”
Paragraph 2‐5.c.(1) states the following:
“The applicant is responsible for …conducting 100 percent applicant conformity…The
ACO is responsible for identifying features, attributes, and components critical to the
test results and for requesting FAA conformity on these test articles with special
instructions as necessary. The MIDO is responsible for determining what conformity
inspections will be necessary for processing production approvals.”
Paragraph 2‐6.b. states the following:
“Conformity inspections verify and provide objective documentation that the test
articles, parts, assemblies, installations, functions, and test setups conform to the design
data…It is the responsibility of FAA engineering personnel to determine the need to
conduct conformity inspections…”
All of these paragraphs together state that the ACO is required to determine when FAA conformity is
necessary and the MIDO is required to determine when an FAA inspection is necessary to establish FAA
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Appendix F
conformity. There is latitude within the guidance to accept the proposed change. With an approved
configuration management process, the ACO could accept the process based approach in place of the
FAA conformity process. Further, the MIDO could use its discretion to accept the approved inspection
process in place of a direct inspection.
Additionally, Section 5 provides extensive detail about how to conduct the FAA conformity process
when it is deemed necessary. As stated above, if determined that FAA conformity is not necessary, or
an approved procedure can be used in place of FAA conformity, much of this section is not applicable to
the proposed CM procedure. However, Section 5 should be revised to include reference to the CM
process and how ACO and MIDO personnel should conduct oversight of the system.
Recommendation: It is recommended 8110.4 be revised to provide description of the alternative
process proposed herein to explicitly state to FAA personnel how to manage test articles with the
approved configuration management and inspection procedures. This should be incorporated into
Section 5 as an alternative to the FAA conformity process.
Recommendation: Paragraph 5‐3.d should be considered when developing guidance for an
applicant’s inspection procedure and is identified in the final section of this paper.
FAA Order 8110.41A Aircraft Certification Service FAA Flight Test Responsibilities, Procedures, and
Training:
Paragraph 507 states the following:
“When applicant flight tests are performed early in a program (prior to TIA), before an
FAA conformity inspection is conducted, the resulting data may still be valid if it can be
established that the testing took place on an aircraft that was essentially identical to the
article that is later conformed to the type design and that no significant changes were
made between the time of the test and the subsequent conformity inspection.”
Through configuration management, this could easily be accomplished and would be in full compliance
with the expectations of this order. The TIA request would become a formality to establish the flight
test program, but would not prohibit applicant compliance testing prior to this gate review. This order
also states FAA conformity is established through the 8110‐1 for flight testing. This order omits
discussion of component level FAA conformity requests through 8120‐10. Thus, the CM process could
be used to establish complete test article configuration and the 8110‐1 would reference this data for
establishing top‐level article conformity. No change is necessary to enable the new process as
proposed.
FAA Order 8110.49 Software Approval Guidelines:
Section 4 of this order discusses FAA conformity when testing software for certification credit.
Paragraph 4‐2 states the following:
~ 138 ~
Appendix F
“A conformity inspection is required to determine that the applicant complies with 14
CFR § 21.33(b) and that the product and components conform to approved type
design.”
This statement is highly restrictive relative to the minimum requirement of 14 CFR Section 21.33(a) since
the only regulatory requirement is for an applicant to make the article available to FAA for inspection
and test. FAA conformity is discretionary and nowhere does regulation state FAA conformity is a
requirement. FAA employees that should have discretion in the process are stripped of that authority
when following this order. Further, this section does not give credit to applicant inspection process
maturity achieved through the DO‐178 process, assuming only FAA can ensure proper configuration
control. However, many of the controlled data listed in Paragraphs 4‐3 and 4‐4 could be used to provide
guidance for incorporation into the applicant’s approved procedures when managing software.
Recommendation: It is recommended 8110.49 be revised to remove the specific conformity
requirements found in Section 4 and replace it with a reference to 8110.4 for acceptable conformity
management procedures. This, combined with the recommendation for 8110.4, will provide either
the existing FAA conformity process or the new FAA approved CM system as methods for controlling
test article configuration.
Recommendation: The controlled data listed in paragraphs 4‐3 and 4‐4 should be considered when
developing guidance for an applicant’s inspection and configuration control procedure. This would
ensure the intent of these paragraphs will still be met through the applicant’s FAA approved CM
system.
FAA Order 8110.105 Simple and Complex Electronic Hardware Approval Guidance:
This order makes multiple references to “hardware conformity review” but does not differentiate
between applicant conformity and FAA conformity. Thus, the guidance provides flexibility in the process
to allow applicant conformity throughout. No change is necessary to enable the new process as
proposed.
FAA Order 4040.26A Aircraft Certification Service Flight Safety Program:
Appendix 2, Paragraph 4 requires the MIDO or a designee verify aircraft conformity in writing in
accordance with the TIA (FAA form 8110‐1), but does not require component level FAA conformity.
Similar to the discussion about 8110.41A, the TIA could reference the CM data when establishing top‐
level test article conformity. No change is necessary to enable the new process as proposed.
Recommendation for New Guidance:
New guidance should be developed to provide a configuration management and inspection standard
that can be referenced by applicants and FAA personnel and provide the minimum requirements by
which to approve and audit the applicant’s program. The following Advisory Circular should be
developed to provide a complete description of the CM process:
~ 139 ~
Appendix F
Draft AC 21‐xx Configuration Management System for Control of Certification Test Articles,
Production, and other appropriate article configuration relevant areas (this will be drafted by
industry and proposed to FAA)
This AC should consider:
o The controlled data listed in FAA Order 8110.4C, Para 5‐3.d.
o The controlled data listed in FAA Order 8110.49, Para 4‐3 and 4‐4
o Description of Compliance Verification Engineer qualifications, functions, and
limitations.
o Improved instructions on RFC Special Instructions that result in generic Special
Instructions that are insufficient to determine the specific issue of concern to the
requesting engineer.
To avoid burden for applicants already using FAA approved inspection procedures for type certification,
the guidance should allow for inclusion of inspection procedures in the Quality Assurance Manual
(QAM), ODA manual or other FAA approved manual held by the applicant.
~ 140 ~
Appendix F
Appendix F.4 ‐ Minor Change White Paper
The Type Design and Production Certification Working Group of the Part 23 14 CFR Reorganization ARC
compared the minor change process each represented company used and noted a lot of variation, with
some companies having a very onerous process and others a more streamlined process. The working
group compared the various processes and then selected best practices from each to develop a
proposed method for approval of minor changes to type design by an airplane manufacturer.
Applicable Rules:
Sec. 21.93 ‐ Classification of changes in type design.
(b) In addition to changes in type design specified in paragraph (b) of this section, changes in type
design are classified as minor and major. A "minor change" is one that has no appreciable effect on the
weight, balance, structural strength, reliability, operational characteristics, or other characteristics
affecting the airworthiness of the product. All other changes are "major changes" (except as provided
in paragraph (b) of this section).
Sec. 21.95 ‐ Approval of minor changes in type design.
Minor changes in a type design may be approved under a method acceptable to the [FAA]
before submitting to the [FAA] any substantiating or descriptive data.
14 CFR 21.95 states that minor changes in a type design may be approved under a method acceptable to
the FAA before submitting to the FAA any substantiating or descriptive data. Further, 14 CFR 21.93
defines a minor change as one that has no appreciable effect on the weight, balance, structural strength,
reliability, operational characteristics, or other characteristics affecting the airworthiness of the product.
One issue is the definition of appreciable in 14 CFR 21.93. This white paper proposes what appreciable
means for each of the 6 characteristics identified in the rule (weight, balance,…). This paper also offers
guidance as to the types of changes that affect different engineering disciplines. Lastly, the white paper
proposes a process for approval of a minor change to type design.
One company that has a more onerous minor change approval process stated they review
approximately 2000 minor changes per year. They expect to save over $100,000 per year through this
proposed process.
It is the working group’s expectation the FAA will find the process defined in this white paper for
approval of minor changes to type design acceptable and put out a policy memo or other statement
supporting it as a “method acceptable to the FAA.” Each company can then decide to either stay with
their currently approved process or adopt this new one.
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Appendix F
Proposed Method Acceptable to the FAA:
1. General ‐ the company must have and maintain access to the knowledge and technical
capability required to maintain the continued airworthiness of the product with respect to the
change as required by the CFR.
2. The change is evaluated by qualified company personnel to determine if the change is major or
minor and the evaluation rationale is documented and retained
3. Qualified Personnel include:
a. DERs or UMs
b. Other authorized personnel who have the endorsement of the head of Engineering on
the basis of the following recommendations:
i. Four years of applicable engineering experience including 2 years of regulatory
experience, and
ii. Knowledge of the minor change classification criteria and the applicable
regulations through directly related work experience, and
iii. Knowledge of the factors on how a change may affect different disciplines
c. Suppliers who:
i. Have a minor change determination process acceptable to the OEM, and
ii. Is audited by the OEM’s quality system on a regular basis, and
iii. Will only approve minor change within agreed parameters with the OEM
4. The disciplines affected by the change are determined based on the guidelines in Attachment 1
in conjunction with the engineering experience of the qualified personnel.
5. The minor change classification is based on 14 CFR 21.93. Attachment 2 provides guidelines to
supplement 14 CFR 21.93.
6. The decision of major or minor for the change is determined for each affected discipline,
including consideration for the cumulative effect of minor changes. Note: For the change to
be minor, it must be determined to be minor for all affected disciplines.
7. The company completes any engineering activities associated with the minor change, including:
a. Any analysis is complete and company approved
b. Any company testing required to confirm no appreciable affect at the airplane level is
complete, documented, and company approved
c. The change to the type design drawing(s) are company approved
8. The minor change is now approved through this process.
9. The company retains evidence of completion of this process for every minor change. This
evidence may be reviewed during FAA audit activities.
~ 142 ~
Appendix F.4
Attachment 1
Discipline WHEN AFFECTED
– New load paths
– New installations
– Box movements
– Change in fasteners or fastener
Structures pattern
– Cut outs
– Change in materials
– Antennae changes
– Weight or CG limit changes
– Changes affecting the fore or aft
Weights CG limits
– Change in max takeoff, landing, or
zero fuel weights
– New fabrics or materials
– Placards
– Seating arrangement changes
Interiors – Lavatory or galley changes
– In‐Flight Entertainment (IFE)
changes
– Flight Deck changes
– Engine related change
– Propeller related change
– Fuel system changes
– Bleed air changes
– Noise changes
Powerplant – Emission changes
– Electrical load changes
– Air conditioning change
– APU changes
– Thrust reverser changes
– Fire protection changes
– Bleed air changes
– Auto‐pilot changes
– Air conditioning changes
– Changes to FDR
Mechanical Systems – Changes to ice detection or
protection system
– Changes to wheels, tires, brakes
– Changes to flight control system
– Door mechanism changes
– Changes to nav or comm
– Auto‐pilot changes
Avionics – Software changes
– Changes to CVR / FDR
– Antennae changes
~ 143 ~
Appendix F.4
Attachment 1
Discipline WHEN AFFECTED
– Changes to IFE
– Changes to aircraft equipment
(e.g. TAWS, TCAS)
– Display changes
– Electrical load changes
– Wiring adds or deletions
– Circuit breaker changes
Electrical – Changes to SPDA / PDA’s
– Air conditioning changes
– Changes to CVR / FDR
– Changes to IFE
– Interiors changes involving
systems
– Powerplant changes: powerplant,
fuel system or accessory changes
– Mechanical Systems changes
– Avionics changes
– Software Changes
– AEH changes
System Safety – Electrical Systems changes
– Changes to installations that may
violate assumptions made in zonal
analyses and may otherwise
impact zonal analyses
– Operations and environmental
changes that impact failure rates,
mission duration, or criticality of
failure conditions
– Affects exterior materials,
installation methods,
configuration and coatings
– Affects fuel system; including
tanks
– Affects HIRF, Lightning, P‐static
and ESD protection
– Affects DO‐160 Sections 15, 18
EME (EMC, EMI, HIRF, Lightning, P‐Static, ESD) through 23 and 25 qualification
– Affects electrical bonding
– Affects ground jumpers, ground
straps and ground terminations
– Affects wire and coaxial cable
design and routing
– Affects system installation location
and methods
– Adds, changes or deletes functions
~ 144 ~
Appendix F.4
Attachment 1
Discipline WHEN AFFECTED
that have major, hazardous or
catastrophic failure conditions
– Electrical Systems
– Clock speeds
– Frequencies
Software – Adds functions
– Software filtering
– Loop gain
– Airborne Electronic Hardware
(AEH)
– Exterior changes
– Performance changes (airplane or
engine)
– Flight control changes
– Noise changes
– Auto‐pilot related changes
– Changes to ice detection or
Aerodynamics protection system
– Weight or CG limit changes
– AFM changes related to
performance or flight
characteristics
– Inertia changes affecting dynamic
characteristics
– Air data changes
– Wheels, tires, or brake changes
– Crew work load
Pilot – Lighting / glare
– Handling qualities
– AFM changes
– Engine performance changes
Noise – Aerodynamic changes
– Performance Changes
~ 145 ~
Appendix F.4
Attachment 2
Classification of changes in type design is discussed in 14 CFR 21.93(a), which states:
“A minor change is one that that has no appreciable effect on weight, balance, structural
strength, reliability, operational characteristics, or other characteristics affecting the
airworthiness of the product. All other changes are major...”
The following provides guidance on what the word “appreciable” means as applied to the six areas
identified in this rule at the airplane level. Major changes can be further assessed to determine if they
are also substantial or significant using the guidance in Advisory Circular 21.101‐1.
1. Weight: Appreciable changes are:
a. Changes increasing the certified maximum or decreasing the certified minimum weight
limits:
i. Max Taxi Weight
ii. Max Takeoff Weight
iii. Max Zero Fuel Weight
iv. Max Landing Weight
v. Minimum Flying Weight
2. Balance: Appreciable changes are:
a. Changes in the certified center of gravity (CG) limits
i. Decreasing the forward limit (i.e. move it more forward of the certificated
forward limit)
ii. Increasing the aft limit (i.e. move it further aft of the certificated aft limit)
3. Structural Strength: Appreciable changes are:
a. Changes to primary structure (structure that carries flight, ground, or pressure loads as
defined in AC 25.571‐1, Damage Tolerance and Fatigue Evaluation of Structure)
i. Changes in loads / load paths
ii. Changes in material
iii. Changes to method of construction
iv. Changes to stiffness
v. Changes to primary structure to accommodate appliances installed on the
exterior of the aircraft (i.e., Forward Looking Infrared (FLIR) equipment or
system, cameras, firefighting, agricultural dispensing equipment, etc.) (See the
current edition of AC 23‐17, Systems and Equipment Guide for Certification of
part 23 Airplanes and Airships, for guidance for the substantiation of
modifications involving installation of external equipment).
b. Changes to structural design speeds:
i. VA
ii. VFE
iii. VNE
iv. VD / MD
v. Stall speeds
~ 146 ~
Appendix F.4
Attachment 2
c. Substituting an engine or propeller (such as replacing a reciprocating engine with a
turbine engine).
d. Substituting or altering a reciprocating engine such that the net result is an increase of
more than 10 percent greater horsepower.
e. Substituting or altering a turbine engine such that the net result is an increase of more
than 10% greater thrust.
f. Internal cabin changes:
i. Changes that increase floor loading limits
ii. Changes to increase cargo compartment loading limits
iii. Changes to cabin configuration resulting in relocation of major items (galleys,
lavatories, etc.)
g. Other factors:
i. Changes to control surface deflections
ii. Changes in control system component weight, balance, stiffness, or mass
distributions
iii. Increasing the maximum differential pressure of a pressurized aircraft
4. Reliability: Appreciable changes are:
a. Changes to flight critical systems that decrease reliability at the product (aircraft,
engine, or propeller) level
5. Operational Characteristics: Appreciable changes are:
a. Airplane, engine, and propeller changes that affect the performance data presented in
the AFM (including the approval of different takeoff and landing surface conditions)
b. Engine cooling changes
c. Change in types of acceptable fuel
d. Changes to the basic engine or propeller design, or controls, which affect the product
operating limitations.
e. Changes to operating limits in the AFM, including changes to the ambient envelope
(altitudes and temperatures)
f. Changes that affect the flight characteristics of the airplane in a manner that is
perceptible to the pilot (e.g. change in control surface deflection and/or gearing;
thrust/power changes; external configuration changes, mass distribution changes)
g. Changes to flight‐critical electrical/electronic equipment and systems such as electronic
flight controls or the engine control system, full‐authority digital electronic control
(FADEC), electronic engine control (EEC), or fly‐by‐wire.
h. Changes to operating or imbedded software:
i. For operationally required equipment not made by the original equipment
manufacturer, or
ii. that invalidate the original aircraft level certification assumptions
i. Changes that alter the part 36 noise data in the AFM (consult Advisory Circular 36‐4C
Subpart A, Section 36.1(c) for a list of type design changes that might affect the certified
noise levels of the airplane)
~ 147 ~
Appendix F.4
Attachment 2
j. Changes in the part 34 emissions level
k. Changes that require the pilot to continuously monitor the added component, or
system, in order to ensure safe operation
l. Changes in the certified maximum seating capacity
m. Changes to unusable fuel supply
6. Other characteristics affecting the airworthiness of the product: Appreciable changes are:
a. Changes as a result of a unsafe condition that may result in an Airworthiness Directive
b. Changes to the limitations contained within the Airworthiness Limitations Manual
c. Interior changes that reduce passenger safety
d. Changes to systems or equipment that have a negative effect on safety or require the
pilot to continuously monitor the added component, or system, in order to ensure safe
operation.
~ 148 ~
Appendix F
Appendix F.5 ‐ Applicant Only Showing White Paper
Background
The goals of the Part 23 ARC were to reduce the cost of certification and to improve safety for the part
23 aircraft. This paper proposes a method to do both through:
1. Use of Safety Management tools the FAA is implementing, and
2. Less direct involvement of the FAA in determining compliance to the regulations as allowed by
14 CFR 21.
There are a number of FAA references to the FAA Safety Management Processes and Orders at the end
of this paper that were considered when developing the Risk Based Process proposed in this paper for
determining when an applicant can simply show compliance without having to have the FAA, DER, or
unit member finding of compliance.
A recent change to 14 CFR 21 is the addition of the Statement of Compliance requirement of 14 CFR
21.20(b) and 21.97(a)(3) that increases the accountability of the applicant’s management to ensure that
compliance is properly shown as described in Advisory Circular 21‐51. So now, in addition to there being
economic incentive, there is further legal incentive for applicant management to ensure compliance is
properly accomplished without having to rely on the FAA, DER, or unit member to find compliance.
There are a variety of applicants for type certification projects. At one end is the applicant who is very
competent, has successfully completed multiple certification programs, and holds an Organization
Designation Authorization (ODA). At the other end is a company lacking proven processes and
organizational competency relevant to the certification process; and everything in between. All
applicants, no matter what level of experience or competency, have a responsibility under part 21 when
executing a type certification project to:
1. Conduct all inspections and tests to show the compliance of the design and product (14 CFR
21.33(b))
2. Make all flight tests that the Administrator finds necessary (14 CFR 21.35(b))
3. Submit all data showing compliance (14 CFR 21.21(b))
4. Provide a statement certifying compliance (14 CFR 21.20(b))
As the applicant completes the showings of compliance detailed in steps 1 through 4 above, the FAA or
its designees:
1. Find upon examination of the type design that applicable requirements have been met (14 CFR
21.21(b)1)
2. Make any inspections and tests necessary to determine compliance of applicant’s design and
product (12 CFR 21.33(a))
The testing and analysis activities that make up a typical certification project also vary in difficulty and
risk. In 2007, the FAA proposed via Order IR 8110.102 that their level of involvement (or that of their
~ 149 ~
Appendix F
designees) could be minimized based on the level of risk, making use of a tool called RBRT (Risk Based
Resource Targeting). The type of risk considered in this paper is that due to either improper test
conduct or data analysis and the possibility of compromised data fidelity. In low‐risk projects or low‐risk
activities within a project, it may be acceptable from a risk perspective to accept the applicant’s showing
only with no further findings by either the FAA or their designees.
This paper proposes a structure for when applicant showing only is sufficient as a function of both the
type of applicant and also considering the risk of improper test conduct / data analysis and the resulting
potential impact on safety. It is suggested the FAA issue a policy memo, Advisory Circular, or FAA Order
to endorse this idea with any adjustments as required.
Proposal
This proposal evaluates applicants based on three criteria:
1. Staff Competency – What is the skill level of the individual staff members of the company
working the certification activities? Are there sufficient DER’s or UM’s on staff to support a
complete aircraft design and certification project? Does the company have ready access to
specialists at suppliers or consultants as necessary to complement staff?
a. Low –
i. There are no, or insufficient, DERs to support a complete aircraft project.
ii. There is no training program for DERs.
iii. The DERs do not have a strong working relationship with the applicant ACO.
iv. Access to FAA policy, regulations, and guidance is limited.
b. Medium –
i. There are sufficient DER’s to complete an aircraft project but internal and ACO
communications, cooperation and record‐keeping is weak.
ii. There is no training program beyond the required minimum to maintain status
as a DER or UM.
iii. Not all DERs have a strong working relationship with the applicant ACO.
iv. Access to FAA policy, regulations and guidance is satisfactory.
c. High –
i. There are sufficient DERs or UMs and internal and ACO communications,
cooperation, and record‐keeping is strong.
ii. The DERs and UMs are encouraged to take training in their discipline and on
regulations, policy, and guidance beyond the minimum required to maintain
their DER or UM status.
iii. The preponderance of DERs/UMs have a strong working relationship with the
applicant ACO.
iv. Access to FAA policy, regulations, and guidance is excellent.
2. Company Competency – What internal organization and resources does the company have in
place to facilitate certification programs? Does the company management fully support the
~ 150 ~
Appendix F
staff training and access to resources necessary to keep the staff current with FAA policies,
regulations, and guidance related to certification activity?
a. Low –
i. Management organization is incomplete or not structured and lacks clearly
defined responsibilities.
ii. Management does not support staff training and access to resources to keep
staff current with FAA policies, regulations, and guidance.
iii. Management does not require following written procedures.
iv. Management does not have a process for internal audits of processes or work,
corrective action, and continuous improvement of their procedures and
processes.
b. Medium –
i. Management organization is complete but structure and responsibilities are not
all completely defined.
ii. Management supports staff training and access to resources but limits
participation through budgetary restrictions.
iii. Management does not consistently support following written procedures.
iv. Management supports audits of processes and work, but does not have a
process for timely corrective action and continuous improvement.
c. High –
i. Management organization is complete and structure and responsibilities are
well defined and available to all of the organization.
ii. Management is fully supportive of staff training, is capable of providing their
own training, and includes training requirements as an objective on each
person’s yearly evaluation.
iii. Management supports following procedures for consistency, thoroughness, and
safety; and has a process for resolving procedures issues in a timely fashion with
appropriate corrective action.
iv. Management ensures staff has complete and open access to all FAA policy,
guidance, and regulations.
v. Management fully supports internal audits of processes and work; and ensures
timely corrective action and continuous improvement.
3. Procedural Effectiveness – Does the company have adequate internal processes to ensure that
work product is thorough, consistent, well‐documented etc.? Are the processes in place proven,
industry best‐practices? Do the internal processes include a continuous improvement process
to evaluate the procedures on a regular basis and take corrective action as needed?
a. Low ‐
i. Written procedures and processes don’t exist or have not been proven through
successful completion of an aircraft project.
ii. Procedures that exist are not rigorous or well defined with clear guidance and
expectations.
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Appendix F
iii. Procedures are not audited, or infrequently audited, and corrective action is
inconsistent or not timely.
iv. Management does not consistently insist on following set procedures.
b. Medium –
i. Written procedures and processes exist, but have not been completely proven
through use and audit.
ii. Procedures and processes state basic requirements, but lack sufficient detail to
allow the reader to completely understand the requirement without external
guidance.
iii. Procedures are audited on an infrequent basis and corrective action for
continuous improvement is frequently not timely or complete.
iv. Management generally supports procedures, but allows deviation from
procedures without justification and no corrective action to resolve issue(s).
c. High –
i. Written procedures and processes exist and have been proven through use and
audits.
ii. Procedures state requirements and provide sufficient guidance and instructions
to allow the reader to completely understand each requirement and the means
of satisfying each requirement.
iii. Procedures are audited on a regular basis and corrective action is timely and
complete.
iv. Management is fully supportive of following procedures and requires
justification for deviation with timely corrective action implemented to resolve
the issue(s).
An applicant would work with the FAA to determine how they rate for each of the three criteria above:
staff competency, company competency, and effective procedures. This rating could be re‐evaluated on
a regular basis as the company improves or concerns are raised. Either the FAA or the applicant may
request a re‐evaluation of the company’s rating. Based on the ratings for these three criteria, an overall
classification is established for the company based on the following:
Tier 1 would rank low in two or more of the criteria.
Tier 2 would rank medium in at least two of the criteria and high in the remainder.
Tier 3 would rank high in all three criteria.
For each of these company classifications, analysis and testing methods have been reviewed to assess
the risk of improper test conduct and the resulting potentially inaccurate data or potential errors in
analysis. The various analysis and tests were selected based on:
A. Analyses where:
1. The analysis method is well defined and understood – the method has been validated
and is proven; and
~ 152 ~
Appendix F
2. The likelihood that the analysis method will not adequately show compliance to the
requirements is very low.
B. Tests where:
1. Testing methods are well defined by either an industry standard, Advisory Circular, or
other accepted standard including company test procedures that are proven;
2. Testing methods are well understood and have little subjectivity;
3. Testing methods are repeatable – all variables that could affect the test are known and
are controllable and repeatable;
4. There are clear pass / fail criteria; and
5. The likelihood that the test method will not adequately show compliance to the
requirements is very low.
Table 1 provides the proposed work split between the applicant and the FAA for the three tiers of
applicant discussed above.
Table 2 provides a list of the types of analysis covered by this proposal.
Table 3 provides a list of the type of testing covered by this proposal.
These tables contain initial lists of analysis and testing and will be added to as experience is gained with
this process and as new technology becomes common place.
As illustrated in Table 1, “Tier 3” companies are given the maximum use of the applicant showing only
process. In many cases, a “Tier 3” company’s FAA designees will still be involved in the various elements
of the projects when doing applicant showing only, though they will be acting as company personnel
and not specifically as designees. Both the companies and the FAA will nonetheless benefit. This
process provides the needed flexibility to use other talented people within the companies who are
capable of doing the applicant’s role either completely or with the oversight of the appropriate
designees. When designees are involved, this process minimizes the volume of paperwork required.
This frees up the designees to focus on the higher value, safety enhancing activities, to support the
FAA’s goal of improving safety.
In order for the FAA to maintain its discretionary function, certification plans will identify any testing or
analysis or portion thereof where applicant showing only is proposed. The applicant will use tables such
as in this paper (once the FAA concurs with this proposal) as a basis for their certification plan proposal.
In accepting the certification plan, the FAA will have the opportunity to identify any activities where they
will exercise discretionary function and their level of participation through ACO engineers, DERs, or unit
members to make a finding of compliance.
As seen, this paper proposes a structure for when applicant showing only is sufficient as a function of
both the type of applicant and also considering the risk of improper test conduct / data analysis and the
resulting potential impact on safety. It is suggested the FAA issue a policy memo, Advisory Circular, or
FAA Order to endorse this idea with any adjustments as required. This would allow the use of the
~ 153 ~
Appendix F
applicant showing only process without waiting on further development of the FAA’s Risk Based
Resource Targeting (RBRT) tool.
Table 1 – Work Split Definition
Type Category of Applicant
Tier 1 Tier 2 Tier 3
Data Analysis Data Analysis Data Analysis
Performed by Applicant Performed by Applicant Performed by Applicant
Analysis
Analysis Approval Analysis Approval Analysis Approval
Approved by FAA (or DER) Approved by Applicant Approved by Applicant
~ 154 ~
Appendix F
Table 2 –Analyses
ELECTRICAL SYSTEMS ANALYSES
Electrical Load Analysis
MECHANICAL SYSTEMS ANALYSES
Oil system capacity and
Oil system heat rejection Cabin depressurization Ventilation rate
consumption
Temperature evaluation of
Proof & burst pressure
Tire burst analysis adjacent structure and Cooling of equipment bays
determination
equipment
System temperature
Bleed air extraction Temperature correction System pressure drop
capacity
Max pressure in closed
Max pressure in return Unusable fuel Transient pressure
circuits
Flight Control cable tension, Flight Control gearing and
Pitot allowable leakage rate Oxygen Duration Charts
deflection substantiation trim rates
Fuselage temperature due to
Oxygen quantity Duct temperature
heated pitot tubes and static
requirements determination
plates
~ 155 ~
Appendix F
Table 3 – Testing
MISCELLANEOUS TESTS
Flammability Testing
FLIGHT ANALYST TESTS
Air data system (altimeter TAT probe calibration and
RVSM Noise
and airspeed) calibration AOA system calibration
MECHANICAL SYSTEMS TESTS
DO‐160 Testing Endurance Testing Proof & Burst Testing Tire Burst Testing
Water /Waste system Component fatigue and
System Functional Testing Static Source error
Leakage test endurance tests
Fire extinguishing Indication and synoptic page Full Scale Static Test (flight
Bird strike tests
concentration functioning controls)
Complete Hyd. system
Verification of Cabin cooling
Drainage from Dedicated functionally tested on the
Failure condition testing analysis / Cabin
Zones Test airplane at 1.25 times
temperature survey
working pressure
Engine Exhaust
ECS System performance
Ventilation verification Cabin distribution verification Impingement Temperature
and heat load verification
Survey
Pitot Water Drainage Pitot Leakage Pass oxygen drop tests Operation of LG controls
Fuselage & Fuselage Fairing Nacelle Anti‐Icing System
Fluid Drainage Test Wind Tunnel Test
AVIONICS SYSTEMS TESTS
VHF Communications HF Communications Satellite Communications Cabin to Ground Telephone
Data Link Transmitters / Audio, Intercom, Passenger Traffic Collision Avoidance
Transponder
Receivers Address Systems System (TCAS)
Electronic Flight
Instruments including
Enhanced Ground Proximity Terrain Awareness Warning Aural Warning Tone
Primary Flight Display (PFD)
Warning System (EGPWS) System (TAWS) Generating Systems
and Multi‐Function Display
(MFD)
VHF Nav. Systems / Marker
Distance Measuring
Weather Radar Cabin Management System Beacon / Localizer /
Equipment (DME)
Glideslope
Automatic Direction Finder Global Positioning System Inertial Reference System
Air Data System
(ADF) (GPS) (IRS)
Radio Altimeter Flight Data Recorder (FDR) Cockpit Voice Recorder (CVR) Airshow Network
Secondary Flight Displays Engine Indication and Crew
Cabin Entertainment System Radio Management System
(Emergency) Alerting System (EICAS)
Emergency Locator Flight Management System Takeoff And Landing
DO‐160 Testing
Transmitter (ELT) (FMS) Distance (TOLD)
ELECTRICAL SYSTEMS TESTS
Auxiliary Power Generating
External Power Electrical Load Distribution Electrical Control Panels
Systems
Cabin Management and
Flight Deck Lighting System Passenger Lighting System Electrical Galley System
Entertainment Systems
Cargo & Service Lighting
Electrical Lavatory Systems Data bus Communication Flight Deck Lighting
System
Baggage Area Lights Navigation Lights Landing Lights Taxi Lights
~ 156 ~
Appendix F
FAA Safety Management Related Publications
The following documents provide guidance on the Safety Management process and may be used as
applicable to provide guidance on risk assessment in determining what an applicant can show
compliance to without the necessity of an FAA finding.
a. FAA Order 8000.369, Safety Management System Guidance, September 30, 2008
b. FAA Order 8040.4A, Safety Risk Management Policy, April 30, 2012
c. FAA Order VS 8000.370, Aviation Safety (AVS) Safety Policy, September 30, 2009
d. FAA Order VS 1300.2B, AVS Quality Management System, June 21, 2010
e. Joint Planning and Development Office (JPDO), Safety Management System Standard v1.4, July
30, 2008
f. International Civil Aviation Organization Annexes 1, 6, 8, 11, 13, and 14
g. International Civil Aviation Organization Document 9859, ICAO Safety Management Manual
h. International Civil Aviation Organization Document 9734, Safety Oversight Manual
i. American National Standard, Quality Management Systems – Requirements (Document Number:
ANSI/ISO/ASQ 9001‐2008)
~ 157 ~
Appendix F
Appendix F.6 ‐ Video Only Test Witnessing White Paper
14 CFR Part 23 Reorganization ARC – TC/PC Workgroup Recommendations
Topic: Use of Video Recordings in Testing
Objectives:
Acknowledge validity of utilizing video recording techniques for capturing key testing
information.
Improve quality and/or integrity of captured test data.
Improve utilization of FAA resources and designees by enabling remote witnessing.
Define parameters necessary for the successful utilization of video recordings for data capture.
Background Information:
The current primary method of data capture during certification testing is via real‐time witnessing by
appropriately delegated individuals. While this method of witnessing is sometimes augmented with
video recordings, the use of video is typically viewed as a “back‐up” to the physical presence and real‐
time witnessing of a human being. Since the majority of witnessing is performed by FAA designees,
The vast majority of test witnessing is performed by FAA designees, which places a burden on the
applicant to either hire consulting DERs or obtain delegation of company DERs. Regardless of the nature
of the designee, minimizing the time required of that person will have a direct corollary effect on the
financial impact experienced by the applicant.
For testing that takes place at or near the applicant’s place of business, direct travel expenses for the
applicant will already be minimal. However, if the applicant is utilizing consulting DERs it is likely that
such individuals will need to travel in order to witness the test. In addition to the “base fee” for the
consultant’s time, the applicant will also incur travel, lodging, and meal expenses; also, many
consultants will charge for their on‐location time based on full‐day increments, even if the actual
witnessing efforts consume only a few hours. Even if company DERs are utilized, some testing requires
travel to lab locations for witnessing; the associated travel costs remain.
Significant FAA resources can also be consumed by these effects when the option is exercised to witness
tests with FAA personnel. Exercising this option normally involves traveling some distance to the test
site, incurring similar expenses to those discussed above due to either the distance traveled or the
length of the testing in question. This eventuality is more likely in the case of startup companies when
confidence in the company processes and procedures is still being assessed.
FAA test witnessing is conducted for one primary reason: to provide confidence in the validity of the test
setup, the test execution, and the ensuing results. It is possible to accomplish all of these requirements
through an alternate means to personal, real‐time witnessing – utilization of video recording.
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Appendix F
Potential Uses of Video Recording:
There are a variety of examples where advantages can be realized through the utilization of video
recording. As mentioned above, current test witnessing may sometimes employ video capture to
augment the personal witnessing already taking place. For example, video recording may be utilized
during a static structural test; this video can then be used later to verify that an ultimate load was in fact
held for an appropriate amount of time prior to structural failure. However, there are instances where
the use of video recording can be used to great advantage in lieu of personal witnessing.
One area where video graphic methods can provide significant enhancements over traditional
witnessing is cases where multiple and/or high speed events are occurring. One such circumstance that
already employs the use of video recording is dynamic seat testing. High speed cameras are employed
from multiple vantage points, allowing subsequent review of the details of the event that take place far
too rapidly to be seen by the human eye. However, this idea of supplementing the abilities of the
witnessing agent can be expanded to other areas as well. For example, video recording of multiple
instrument readouts could be captured for later review; in this instance, although the test setup may be
such that one person could not simultaneously view and process all of the readouts real‐time, the use of
video capture would allow the various readouts to be synchronized and compared later – and at
whatever speed was convenient for observation. (This is not meant to imply that video would be able to
replace a sophisticated digital data acquisition system if one is required; nonetheless, it could be used as
an adjunct to such data acquisition to support witnessing.)
Another example that places the use of video in an even more prominent role is the case of “slow
speed” testing; that is, testing that takes place over an extended period of uninterrupted time.
Examples are long‐term pressure bleed‐off testing, HIRF and IEL testing, cyclical testing, etc. In this
scenario, there are two possible advantages to employing the use of video recording. Firstly, testing
could be allowed to continue monitored only by the video equipment. This would free up the
witnessing personnel to focus on other activities (or possibly go home for the night). Upon return, the
video could be reviewed at a higher‐than‐normal speed to locate any time periods that would require
further scrutiny; for example, a view of a pressure gauge could be recorded and the recording could be
reviewed later to determine the time at which a threshold pressure was reached. A second possible
advantage would be the enabling of remote monitoring. By employing web‐based video equipment, the
status of a test could be monitored even from remote locations; this would be very useful in the event
that it was necessary to periodically confirm that an automation system was performing properly, for
example.
The most compelling argument for the use of video recordings from a resource utilization standpoint is
that of remote witnessing. Depending upon the nature of the test and the video equipment used, the
remote witnessing may be performed real‐time or may be delayed; the advantages remain the same
regardless of the timing. The most obvious advantage is a reduction in travel expenses; by employing
the use of video recording, the physical co‐location of the test setup and the witnessing personnel
becomes irrelevant. There is also a secondary effect that must not be overlooked. Enabling the
utilization of truly remote witnessing mitigates the potential for scheduling conflicts due to travel
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Appendix F
availability, test facility availability, conflicting commitments, etc. Also, it opens the pool of potential
witnessing agents for a particular timeframe, allowing the applicant access to a wider base of experts.
Both of these secondary effects translate to a more efficient testing process for the applicant.
Benefits for Applicant:
There are two primary aspects to consider regarding applicant benefits: direct expenses incurred
through traditional real‐time witnessing, and indirect expenses caused by program delay.
Direct Expenses
The current witnessing process requires travel to the location of testing for the designated witnessing
DER. Using remote video witnessing, the travel could be significantly reduced or eliminated altogether.
Travel expenses for applicants could easily be reduced by $40,000 or more depending on the quantity of
tests, the variety of disciplines that must witness those tests, and the distance between the test sites
and the witnesses’ bases of operation.
In general, designee expenses for a TC program can be very high to support test witnessing as it exists
today. DER fees are quite high, approaching $200 per hour for some disciplines; consultant DERs
typically charge a minimum of 8 hours per day for the duration of their travel, even if their witnessing
duties consume only a small fraction of a single day. These expenses create a significant barrier for a
new start‐up company – far greater than the expenses necessary to procure adequate video graphic
equipment. The approach discussed in this paper would not only alleviate travel costs, but would allow
companies to incur only those costs associated with actual technical review of the video evidence.
Even in that event that a particular test is found to qualify for an “Applicant Showing Only” approach,
many tests must be performed at specialized laboratories that are often remote from the applicant’s
place of business. The proper use of video witnessing would allow travel expenses to be minimized if
not eliminated with no decrease in the veracity or validity of the evidence supporting the applicant’s
showing.
Indirect Expenses
Another possible cost to an applicant is in program delay. Risk for program delay is increased for
applicants who do not have company designees with authority to witness certification tests. Program
delays could be caused by waiting for a consultant DER to be available for travel or by waiting for a test
facility’s schedule to synchronize with a DER’s availability; these effects can be exacerbated in the event
that FAA witnessing authorities exercise their option to be present. Even if these various influences are
successfully initially mastered, unanticipated events may interfere with those plans and inadvertently
cause delay. The use of video witnessing would mitigate this risk. Program delays of a single day can
run over $100,000 and have been calculated up to nearly $1,000,000 per day for higher‐end part 23
aircraft. While it is difficult to quantify this cost or even determine the probability that traditional
witnessing contributes to a program delay, the risk exists – and in fact has caused significant delays on a
number of programs.
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Appendix F
Benefits for FAA:
Assuming the FAA currently makes full use of designees during the test witnessing process, the direct
FAA benefits will be limited. Nonetheless, the FAA will certainly benefit for projects where the ACOs
making extensive use of FAA employees for witnessing certification testing.
FAA will save a minimum of 3 days per witnessing agent when certification test witnessing is chosen; this
is based on an assumption of one day for travel to the test site, a minimum of one day for testing, and
one day for travel back to the ACO. While it is likely that multiple tests may be conducted during a
single visit, it is highly unlikely that all testing necessary for a certification project could be schedule for
such a timeframe. Assuming that the performance of multiple tests will increase a given visit to two
testing days, and further assuming that at least three such batteries of tests would be necessary over
the course of a certification project, the total savings would be a minimum of 12 work days, plus
associated travel expenses.
Some more intangible benefits the FAA may see include:
Historical archiving of the video evidence for future reference
Comparison of tests conducted for design change substantiation with similar tests conducted for
initial certification
Minimum Parameters:
There are three primary areas that must be considered to make the use of video witnessing a viable
proposition; these are adequate coverage, video fidelity, and data integrity.
Adequate Coverage
In order for video recordings to be reliably used for witnessing purposes, the information captured in
the recordings must be adequate to allow meaningful review. Guidelines must be developed to ensure
a minimum set of requirements are met. For example, for structural test witnessing it may be necessary
to utilize multiple cameras in a “3‐view” configuration. Additional viewing angles may be required to
adequately capture specific areas of interest. Video equipment should be located in such a manner that
obstructions are not an issue – whether from fixed test apparatus or from the movement of test
personnel into the camera’s field of view.
Video Fidelity
Adequate coverage will prove irrelevant if the resulting images are too blurred or of too low a resolution
to be clearly seen. The use of video recording as valid witnessing must address these issues. Adequate
lighting must be employed to prevent the presence of obscuring shadows. Adequate resolution must be
provided; for some tests the using of standard definition recording equipment may be acceptable, but
for others the use of high definition video may be required. Recording speed is also an important
consideration; if playback in slow motion will be required in order to appropriately perform the
~ 161 ~
Appendix F
witnessing tasks, high‐speed filming equipment may be required. Nonetheless, it must be recognized
that the primary argument for the use of video witnessing is to minimize the expenses associated with
real‐time witnessing by human beings; accordingly, the minimum acceptable video fidelity must really
be only that which would replicate the fidelity of the human eye.
Data Integrity
In order to gain the maximum benefits of video witnessing, the footage must be converted into a format
that is easily copied and distributed without significant degradation of image quality. This will typically
mean that the footage will be converted to one of the standard digital video formats; therefore, the
medium for capturing the “raw” footage must be selected with this final converted state in mind. Also,
the ability to time stamp the footage can improve the integrity and usefulness of the data; for example,
time stamps can allow multiple video streams to be synchronized with each other for chronological
comparison of events captured by different cameras.
Effects on Part 21:
Five sections of 14 CFR part 21 discuss FAA involvement with tests and/or the witnessing of tests. These
sections can be divided into two groups.
The first group, dealing with Type Certificates, involves §§ 21.33 and 21.123. While these sections deal
with different focuses of the Type Certificate process, they share common language with respect to
testing:
Each applicant must allow the FAA to make any inspection and any flight and ground test necessary to
determine compliance…
Each manufacturer of a product being manufactured under a type certificate must allow the FAA to make
any inspection or test, including any inspection or test at a supplier facility, necessary to determine
compliance…
In practice, the FAA deals with its right to “make any inspection or test” through the use of delegated
witnessing agents, or by witnessing the tests themselves.
The second group, dealing with Production Certificates, involves §§21.140, 21.310(a) and 21.610. While
these sections deal with different focuses of the FAA, they again all share common language with
respect to witnessing:
…must allow the FAA to inspect its quality system, facilities, technical data, and any manufactured …
articles and witness any tests, including any inspections or tests at a supplier facility, necessary to
determine compliance…
There is nothing in the use of video as described in this document that would violate any of these
requirements; therefore, no modifications to the FARs are necessary to allow the use of video
witnessing.
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Appendix F
Effects on Existing Guidance:
A brief search of the available guidance material was conducted to see if any language was currently
being used that would preclude the use of video as described in the document; none was found.
However, two lines of reasoning were discovered that lend credence to the idea that video witnessing is
in line with the current philosophy underlying witnessing.
In FAA Order 8110.37E, paragraph 2‐6.b, it states:
…DERs may be authorized to witness tests outside their area of authority provided that the DER (1) is
authorized to do so by the ACO, and (2) does not make the final compliance finding.
The implication here is that physically observing the test taking place is not necessary to find the data
valid. The importance is in monitoring the activity to ensure that the test plan was followed, no critical
errors were introduced, the data was appropriately collected, etc. Employing video witnessing as
described in this document can accomplish these same goals, enabling properly authorized individuals
to make final compliance findings although they were not physically present for the test.
In FAA Order 8110.37E, paragraph 4‐4.a, it states:
…Before witnessing the test, the DER must verify that the necessary FAA conformity inspections have been
accomplished, that the test article is in conformity, or that all unsatisfactory conditions have been
dispositioned. A DER is not required to witness an entire test to approve the test data. However, the DER
must coordinate with the ACO to determine which conditions are critical and must be witnessed in order to
ensure that all the data are valid. When DERs approve test data, they indicate that they witnessed those
portions of the test dealing with critical conditions, the test was conducted in accordance with the FAA
approved test plan, and the data are official test results that satisfy the test criteria for compliance.
The proper use of video witnessing would provide the ability to not only “witness those portions of the
test dealing with critical conditions”, but also the ability to review these critical events in detail. In
addition, non‐critical portions that may otherwise go unwitnessed would be available for review at the
DER’s discretion. The utilization of video witnessing would not only meet the intent of the existing
guidance, but could be leveraged to actually enhance the witnessing coverage.
Recommendation for New Guidance:
New guidance should be developed to provide a video witnessing standard that can be referenced by
applicants and FAA personnel, and to provide the minimum requirements by which video witnessing can
be successfully utilized. The following should be developed to provide a complete description of the
video witnessing process:
Update policy to endorse the use of video technology in test witnessing
Endorse industry standards on Video Witnessing of Certification Tests
A video test witnessing standard should consider:
o The types of testing that could most benefit from the use of video witnessing; and
o The minimum parameters discussed above regarding coverage, fidelity, and integrity.
~ 163 ~
Appendix F
Appendix F.7 – Production Certification Manual
~ 164 ~
Appendix F
PREFACE
This preface is not intended to be included in a finished manual but to provide guidance on how to go
about creating a Quality Procedures manual for a new startup aircraft company. The intent is to allow
this document to satisfy the requirements for a Quality Assurance Manual of a new startup company,
but in such a way that it will integrate with the more comprehensive requirements of a DO/PO Design
Handbook without major changes, should one be desired in the future.
This document is an attempt to provide guidance for new start‐up aircraft companies in establishing
their procedures for how they will conduct their aircraft production operations. It combines information
that different existing companies and the FAA MIDO have provided on how to organize procedures. The
guidance is intended to be organized in such a way that a new company with only a few employees
could start with this and easily modify it to accommodate growth of the company and eventually
separating different functions into different departments as appropriate. The following diagram is taken
from the DO/PO Design Handbook Template. By using the guidance in that Handbook and this
document it should be relatively easy to create a Quality Assurance manual that will be a standalone
document for a new startup company but then allow the manual to become an integral part of the
company’s TC/PC Handbook should they evolve to the point where they need such a document.
This document provides only the basic general information and each company must determine how
much to add to or modify to satisfy their needs.
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Appendix F
Quality
Assurance
Level 1 Policy
What you have to do and
why. Any Company or
Regulatory requirements Design Production
will be identified at this Handbook Handbook
Level 2
Process Descriptions
How you meet regulatory
or company requirements
Level 3
Work Instructions
Detail instructions
Level 4
Forms Templates Records
Specific for
Figure 1 – Requirements and Procedures Hierarchy
Figure 1 is a depiction of a way to structure a company’s procedures to start with something minimal
and then be able to expand it over time. Some companies may be tempted to start at the bottom and
write process descriptions and work instructions or forms and templates and then try to figure out how
it all satisfies requirements later. This is not a good idea. A better way is to start at the top and work
down because all of the processes and work instructions should flow back and satisfy either a company
or regulatory requirement. Think of it as a tree with the roots and trunk being level 1 and the branches
and leaves being levels 2, 3, and 4. This does not mean that a new startup company should create all of
those procedures but if you should plan for the possibility that you may want to at some time in the
future it will save a significant amount of time and effort to do so when the time comes.
For this document requirements will be driven by the 14 CFT 21.137 requirements. This may seem like
overkill for a new startup company and indeed you may not want to develop procedures to satisfy all of
those requirements in the beginning but you should at least be aware of them and what you might have
to do if you want to at some point put the aircraft into production and issue airworthiness certificates.
~ 166 ~
Appendix F
This paper will not discuss the certification aspects at this point but will focus on the production aspects.
If you look closely at 14 CFR 21.137, it is the requirements for obtaining a production certificate to allow
you to produce and license an aircraft. It may seem like overkill to some not familiar with all that you
should consider when producing an aircraft but for the most part every paragraph in 14 CFR 21.137 is
general requirements and should be something that anybody contemplating producing and selling an
aircraft should be doing regardless of whether they plan on getting a production certificate or not. If the
decision is made later to go for a production certificate it will be much easier to do so. Plus, regardless of
whether a company decides to go for a production certificate or not, it will make it much easier for the
FAA to inspect the company and ensure they are performing in an acceptable manner.
Another key consideration should be whether to break the requirements into department level
procedures and requirements. Where the procedure in fact does only affect one department this may
be acceptable. However, the problem with breaking procedures that affect multiple departments into
department level procedures is that with time they have a tendency to drift apart and in fact may
eventual be in conflict with each other. Plus it can be very confusing, time consuming, and difficult to
have to jump from one department’s procedures to other department’s procedures to determine what
the total requirements are for any one aspect. A startup company cannot afford to have a department
whose sole purpose is to manage and coordinate their procedures unless they can show how it reduces
cost and time. It is generally better to keep the joint procedures in a single high level procedure that
establishes the requirements and then let lower level work instructions satisfy the department level
requirements. This forces the departments to always make sure their activity stays aligned with the
overall company requirements and that they don’t create silos with tall walls for their activities that
make it difficult for other departments to work with them.
Particularly for the small companies, a better solution is an integrated single set of procedures that
address each requirement with the specific responsibilities distributed to the appropriate positions
within the departments. It is much easier to reassign a responsibility than it is to write a procedure for a
separate department and ensure it stays synchronized with the procedures for the same requirement in
a different department. This will require that all of the departments have input into the procedures but
it will better keep the procedures synchronized with the requirements than to have independent
departments writing their own procedures for each requirement.
Another key to keeping things simple is to avoid the creation of more forms than are necessary. The
more forms that are created, the more administrative burden and cost that will be placed on the
company with little or no benefit. This does not mean that everything can be put on one form but look
at the requirements before creating a form and see if another form can be modified slightly to serve
multiple purposes. Every time a new form is created that uses data from another form there is at least a
50% chance that something will not be copied correctly from one form to the next. This simply adds
unnecessary cost and confusion into the process.
This paper will use the fictional “ABC Aircraft Company” for illustration purposes only. The organization
chart for the “ABC Aircraft Company” does not show the typical “boxes” for all of the sub‐departments,
since a small manufacturer would most likely need to cross‐utilize personnel to achieve the most
~ 167 ~
Appendix F
economical operation. The user of this manual may arrange the sub‐organization functions in
departments that best suit the specific needs, with one person's name appearing in more than one of
the boxes.
The intent of the organization chart showing Receiving Inspection and Production Inspection reporting
to the Director of Manufacturing instead of the Director of Quality Assurance (which may be considered
“traditional”) is to have one company focal point instead of two, with the responsibility to establish the
requirements for staffing (including inspectors), facilities, equipment, scheduling, and cross‐utilization in
order to most effectively meet the company budgetary and production goals. The Director of Quality
Assurance still has the major responsibility of controlling the issuance of inspection stamps and
inspection credentials only to persons the Director of Quality has found experienced and properly
qualified, and to closely monitor the inspector’s performance. The Director of Quality Assurance is also
responsible for auditing all production functions and facilities to ensure compliance with established
procedures and to ensure that corrective action is taken promptly when discrepancies are found.
The control and tracking systems described in the Operating Procedures Manuals (OPMs) may be
purposely very fundamental (e.g., index cards) and they serve the purpose, but a manufacturer having
computer capability may find it more convenient to use computer generated systems that meet the
same goals. Computerized systems allow the same data to be input once and used in multiple
applications without the potential for it being erroneously entered or interpreted from paper forms.
The process may make use of things like EXCEL Spreadsheets or simple databases that can significantly
improve efficiency and reduce time and cost to accomplish tasks.
The Engineering OPM describes a system for documenting minor changes with “Advanced Change
Notices “ (ACN), up to 5 before the basic drawing is updated. This ACN system would benefit a small
manufacturer by keeping the cost of changing and printing complete drawings to a minimum, while still
providing a means to document, identify, and control minor changes to the design.
~ 168 ~
Appendix F
FORWARD
This Quality Assurance Manual (QAM) and the Operating Procedures Manuals (OPMs) referenced herein
describe the quality assurance requirements for the ABC Aircraft Company, 1350 Willow Road, Wichita,
Kansas, 67215, for showing compliance with the applicable Federal Aviation Administration (FAA)
regulations and industry consensus standards governing the manufacturing of aircraft. Changes to this
manual and/or changes to the quality assurance system are made available for review by the
appropriate airworthiness authority, upon request.
The ABC Aircraft Company Director of Quality Assurance is responsible for implementing the provisions
of this manual.
APPROVED BY:
ABC Aircraft Company: ________________________________
Director of Quality Assurance
________________________________
Date
~ 169 ~
Appendix F
ORGANIZATION CHART AND FUNCTIONAL RESPONSIBILITIES
PRESIDENT
DIRECTOR DIRECTOR ENGINEERING DIRECTOR QUALITY
MANUFACTURING ASSURANCE
FUNCTIONS FUNCTIONS FUNCTIONS
Work Instructions Work Instructions Work Instructions
Purchasing Test Procedures Quality Manual
Production Inspection Materials Review Inspection Records
Measure & Test Process Specifications QA System Changes
Equipment
Materials Specifications QA Audits
Manufacturing Planning
Service Difficulties Supplier Control
Production Control
Data Change Control Airworthiness Certification
Receiving Inspection
Production Flight Test Materials Review
Storage & Issuance
Production Ground Test Statistical Sampling
Non‐conformances &
Materials Review Supplier Qualification Inspector Qualification
Production Flight Test Forms Inspection Stamp Control
Production Ground Test Production Inspection
Inspection Records Inspection Stations
Inspection Stations Forms
Forms
~ 170 ~
Appendix F
REVISION CONTROL
Revision Number Change Approved (signature) Date
~ 171 ~
Appendix F
QUALITY ASSURANCE MANUAL
ABC AIRCRAFT COMPANY
1350 Willow Road
Wichita, Kansas 67215
COMPANY QUALITY ASSURANCE POLICY
The ABC Aircraft Company is dedicated to maintaining a quality assurance system that will assure
conformity of each aircraft at all stages of fabrication and assembly to the applicable Federal Aviation
Administration (FAA) regulations and industry consensus standards governing the manufacturing of
aircraft.
ORGANIZATION
The organization (less administration and accounting) consists of three departments, ENGINEERING,
MANUFACTURING, and QUALITY ASSURANCE. Each department is further subdivided as necessary to
achieve the most efficient use of manpower as needed to maintain the established production rate for
completed aircraft. The Organizational Chart and Functional Responsibilities chart on page 7 shows the
major departments and the potential functions for which each is responsible.
PROCEDURES AND FORMS
The ABC Aircraft Company operating procedures may be contained in separate Operating Procedures
Manuals (OPMs) that by reference become a part of this Quality Assurance Manual or for a very small
company may all be included in the Quality Assurance Manual. For a company just getting started it
may be more appropriate to have the Quality Assurance Manual and the Operating Procedures in a
single manual but organized and structured in such a way that they can be easily separated later. This
document will show them combined. In this paper the Quality Assurance manual would be the
requirement followed by a brief compliance statement. Everything after the compliance statement
could be retained in the Quality Assurance Manual or pulled out to separate Operating Manuals. But
again a word of caution is in order. When that information is put in separate manuals there must be a
process to ensure that it stays aligned with the requirements in the Quality Assurance Manual.
Detailed step‐by‐step instructions to supplement an OPM procedure may be issued by individual
departments as Operating Instructions (OIs). Each such OI must be identified with the OPM number and
with the OPM paragraph upon which the OI is based, and must be signed by the Director of the
department involved. The first OI to be issued for an OPM would be titled, for example, “OPERATING
INSTRUCTION.
BASIC PROCEDURE REQUIREMENTS FOR A SMALL STARTUP COMPANY
Responsibilities
A clear definition of responsibilities must be established prior to issuing procedures as this will establish
who in management is responsible for what activities and procedures. The position title that will be used
in this paper for the heads of the organizations will be Vice President but that could be Director or any
~ 172 ~
Appendix F
other appropriate title as determined by the company. Also, in some companies Manufacturing is
referred to as Operations. Either term may be used in this document to mean the same thing.
Each Vice President:
a. May delegate functions or tasks but not responsibility for compliance with regulatory or
company legal requirements. Any delegation of a legal responsibility must be in writing from a
person legally authorized to make such a delegation on behalf of the company.
b. Must ensure procedures that affect another Vice Presidents organization or operations are
coordinated with that organization prior to implementing.
c. May also be responsible for the following or other requirements:
Vice President of Engineering
The Vice President of Engineering is responsible for ensuring:
a. That all new designs or design changes meet the provisions of the appropriate regulations
and/or consensus standards, as applicable.
b. That a process is defined to ensure that all drawings and specifications defining the type design
of the product are created, approved, released, and controlled in a manner that when followed,
results in a product that meets the approved configuration of the specific model and serial
number being built.
c. That the appropriate documents are distributed to Manufacturing and Quality Assurance,or any
other applicable department within the company.
d. Selection and training of personnel to ensure that certification and approvals are conducted in
accordance with the approved procedures and regulations.
e. There is close coordination with the Vice Presidents of Manufacturing and Quality assurance in
ensuring that procedures remain coordinated between the departments and no conflicts are
created between those procedures.
f. There is a process for coordination between the other Vice Presidents and with the appropriate
regulatory authorities as required to resolve safety of flight and service difficulty issues and, as
necessary, generating safety directives.
Vice President of Operations
The Vice President of Operations is responsible for ensuring:
a. The planning for, and construction of, the product to meet the type design of the model and
serial being built from the purchase of raw material to the final production flight test.
b. The product is inspected and a record of that inspection is retained and provided to the Quality
Assurance department for verification.
c. That processes are in place within the manufacturing operation to provide Material Review
Board (MRB) feedback to engineering using the appropriate forms or mechanism on any issues
that manufacturing finds that requires corrective action on the part of engineering.
d. Close coordination with the Director of Quality Assurance in performing those functions that
require inspection duties. Inspection personnel may report administratively to the Director of
Manufacturing when such reporting results in more efficient use of company personnel,
however, the responsibility for oversight of all inspection functions remains with the Vice‐
President or Director of Quality Assurance, as applicable.
e. Selection and training of personnel to ensure that operations are conducted in accordance with
the approved procedures.
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Appendix F
Vice President of Quality Assurance
The Vice President of Quality Assurance is responsible for:
a. Establishing qualifications for and approving inspection personnel and issuing the appropriate
stamps or other means for approving parts to approved personnel.
b. Verifying and documenting that the proper documents have been used for building and testing
the model and serial being built.
c. Verifying that the model and serial meets the approved type design requirements specified by
those documents.
d. Establishing a Material Review Board process in conjunction with Engineering to ensure
production issues are properly identified and dispositioned, including changes to engineering
where required.
e. Maintaining the Quality manual and notifying appropriate personnel of any changes in the
quality assurance system that may affect the inspection, conformity, or airworthiness of ABC
aircraft.
QUALITY ASSURANCE PROCEDURES
The following quality assurance requirements will be used by the ABC Aircraft Company.
DESIGN DATA CONTROL – 14 CFR 21.137(a)
Requirement
Procedures for controlling design data and subsequent changes to ensure that only current,
correct, and approved data is used.
Compliance
This is a joint effort between engineering, manufacturing, and quality assurance. A defined
set of procedures is required to ensure that only released and approved type design is used in
the construction and inspection of a specific model and serial of a product and also so that any
service difficulties can be quickly and appropriately addressed. This set of procedures must
address the needs of engineering, operations, and quality assurance and will be described in
the following sections.
Type Design Control
All drawings and specifications defining the (Can substitute any product as defined by part 21
here.) aircraft will be controlled in such a manner that the specific configuration is defined for
each model and serial number. This includes all drawings and specifications for new products
and changes to either new products or existing aircraft.
Change Requests
A Change Request (CR) will be required to initiate any new product or a change to an existing
type design. The change request should have at least the following information:
a. Description of a new product design when used to initiate a new product. (Although it
could be argued that a change request is not needed for a new product there is also some
logic to using one since the change request can be the vehicle used to initiate a new
project and it keeps a consistent process in place for initiating any project. The change
request for a new product will contain the management approvals for the project and
other information necessary to create a project so this should be considered before
arbitrarily dismissing it as additional unnecessary paperwork.)
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b. Description of what needs to be changed on existing type designs.
c. Why the new product is required or an existing product needs to be changed, i.e. affects
safety, affects ability to fabricate, part no longer available, etc.
d. Who requested or needs the change.
e. The impact of not changing.
Note: Some companies use forms other than the CR to identify change requests coming from
manufacturing planning or quality assurance for changes to drawings or documents that are in
work and which do not have final approval. This is acceptable but a word of caution is in
order. Just remember that each form that is created will add to the amount of administrative
work required. A properly designed Change Request form can easily handle those types of
planning or quality assurance requests as well as a different form.
Change Request Procedure
To maintain an orderly process between engineering, manufacturing, and quality assurance, a
documented process to identify, control, disposition, and track all change requests and make
that information available to all affected organizations within the company. The following
procedures will apply to change requests:
a. A CR may be initiated on ABC Form XXXX by anyone. It is not restricted to engineers. They
may come from management, manufacturing planning, manufacturing Material Review
Board (MRB) action, Quality Assurance, the service organization, or any other organization
within the company. They may also indirectly come from an authority through the
certification office.
b. A CR form is completed by the person requesting the change.
c. The CR is routed to Engineering.
d. Engineering will enter CR into CR Tracking Tool.
e. CR will be assigned to an engineer to determine if the request is valid and if it should be
accomplished.
f. A priority will be established for completing the CR. Safety issues should be highest
priority. Issues that affect production or the field should normally be the second priority.
Issues that are more inconvenience issues should be the lowest priority.
g. CRs that are deemed a safety issue will be approved by the head of engineering. CRs that
affect production or are convenience issues will be approved by the engineering manager
in charge of the aircraft.
h. If the change needs to occur on a specific serial that will be identified on the CR.
i. If request is valid it will be noted in CR Tracking Tool and assigned to the appropriate
engineer to accomplish.
j. The associated Engineering Change Record (ECR) will be linked to it in the CR Tracking
Tool.
k. The Change Request will be closed in the tracking tool when either it has been rejected or
all of the engineering is released that resolves the issue.
Type Design
The Director of Engineering is responsible for ensuring the type design is adequate to build the
aircraft and the compliance documents show compliance to the applicable regulatory
requirements. The type design consists of all drawings and process and material specifications
used to define the product. The compliance documents substantiate that the design meets
the regulatory requirements and are also considered part of the type design.
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1.6.1 Drawings
The drawings will convey the description of the parts, assemblies, and installations that make
up the aircraft design and the appropriate dimensions, specifications, and notes to allow parts
to be fabricated and assembled. The drawing requirements will be defined and published and
will consist of at least the following items on the face of the drawing:
a. Title Block providing:
i. Drawing number.
ii. Drawing Title
iii. Approval Block
iv. Drawing Size
v. Standard Tolerances
vi. Standard Specifications Applicable
b. Revision Block
i. Revision Number/Letter
ii. Revision Description
iii. Revision Date
iv. Revision Approvals
c. Zones
i. Vertical zones
ii. Horizontal zones
d. Notes
A designated area on the face of the drawing where notes may be written to provide
additional information on fabrication, assembly, or installation.
1.6.2 Process Specifications
Process specifications required to be used in the fabrication or assembly of a part, or parts,
will:
a. Be industry consensus standards where possible.
b. Be developed by engineering with input from Operations and Quality Assurance where
industry standards do not exist or are inadequate.
c. Will be included in the Notes section of the drawing.
d. Will be released and made available to Operations and Quality Assurance using the same
procedures as all other type design documents.
1.6.3 Material Specifications
Materials specifications will:
a. Will use industry standard specifications where applicable and appropriate.
b. Define the type of material to be used for each part.
c. Define any specific characteristics of the material such as heat treat, etc.
d. Be developed by engineering if industry standards do not exist or are inadequate.
e. Will be released and made available to Operations and Quality Assurance using the same
procedures as all other type design documents.
Type Design Changes
Type design changes will be classified as major or minor in accordance with 14 CFR 21.93 or a
significant change in accordance with 14 CFR 21.101 for aircraft being certified under part 21.
Even for LSA aircraft the changes will be classified as major or minor using essentially the
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same guidelines as found in 14 CFR 21.93 or the ASTM F37 requirements. There will be a
place on the Change Request for documenting both the major/minor and the significant or not
significant determination and identifying the person(s) making those determinations.
In general, type design changes that affect the flight manual, any limitations, structure, or
equipment that requires re‐testing to establish compliance or that may affect safe operation
of the aircraft will be major changes.
Design Change Notices
Design Change Notices (DCN):
a. Are interim changes to a drawing to provide a change to type design prior to incorporating
it into the drawing.
b. DCN paper size will be either 8 ½ x 11 or 11 x 17. Any change requiring more than 11 x 17
will require a drawing revision.
c. Will be identified by a sequential number that is related to the affected drawing, i.e. the
first DCN released against a drawing will carry the number 1, succeeding DCNs will carry
the numbers, 2, 3, 4, etc.
d. Will include the issue date.
e. Will include a description of the change.
f. Carry the same authority and approval requirements as a revision to a drawing.
g. Will have serial effectivity assigned just as a drawing revision would.
h. Can be revised themselves.
i. Are Engineering changes that are recorded on a separate form from the drawing but
become attachments to that drawing until incorporated into the drawing.
j. Are related to the drawing that is being changed and must identify the affected drawing
and drawing revision.
k. Are related to an ECR.
l. Are for minor changes.
m. Are expeditious ways of getting a change to the planning and quality assurance
departments without having to revise and re‐issue the entire drawing.
n. Will be incorporated into the drawing when more than 5 DCNs have been released against
that drawing.
o. Detailed change information identifying what the current configuration is and what the
new configuration is, i.e. for a dimension it should be stated “3.57 inches was 3.47 inches”
and identify the part and zone of the drawing where the dimension is called out.
p. Will be approved by the applicable engineering personnel. This includes the person
making the DCN, his supervision including the project engineer, and any specialists that
must approve the specific type design changes.
q. Will include the date(s) approved.
r. Will be released and stored in the company document storage facility that includes a
tracking system for identifying the deviations and the associated drawings, when checked
in, when checked out, and by whom.
Deviations
Deviations:
a. Are for temporary changes to type design that may be to accommodate use of an
alternate material for a part for a short period, a minor dimensional difference that is
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acceptable on a limited number of parts, substitution of another part in an assembly due
to availability, or any number of other reasons.
b. Deviation paper size will be 8 ½ x 11 or 11 x 17 only.
c. Will carry sequential numbers related to the applicable drawing in the same manner as
DCNs.
d. Will carry the issue date.
e. Will be reviewed and approved the same as any other type design change.
f. Will have serial effectivity recorded if it is a major change or it is desired to be able to find
the products the deviated parts were installed on for any reason at a later date. Minor
changes do not require serial effectivity unless they could require finding and removal at a
later date.
g. Are linked to the drawing which they affect.
h. Will not be incorporated into the drawing but will remain attachments to that drawing
forever.
i. Will be approved by the engineering specialist responsible for that component and by the
project engineer for the aircraft.
j. Will include the date of approvals.
k. Will be released and stored in the company document storage facility that includes a
tracking system for identifying the deviations and the associated drawings, when checked
in, when checked out, and by whom.
Project Number
A number that is unique to the company will be established to collect all of the activity
associated with a specific new product or change. This project number can be used:
a. To collect cost, engineering data that is used for both development and certification or
approval and keep it separate, project schedule, or any other appropriate project related
information.
b. In place of an FAA Project number in accordance with FAA Order 8110.115.
Engineering Change Record
The Engineering Change Record (ECR) is the document that collects all of the drawings,
specifications, reports, manuals, and any other documents required to document compliance
to the regulations associated with a specific new product or a change to an existing product.
The ECR may be used in the following ways:
a. For a new product, multiple ECRs may be issued with each ECR covering specific parts of
the aircraft, such as wing structure, power plant installation, electrical installation, etc. In
this case there may be a collector ECR that all of the ECRs feed into simply as a way to
manage all of the individual ECRs, or they may simply be linked to the Project Number
which is the primary project management tool.
b. For a significant serialized change to an existing product where all of the documents
associated with the change are listed on a single ECR.
c. For a collection of minor changes that do not require identification of the serial on which
they are incorporated. This may involve multiple CRs.
Engineering Change Record Content
An Engineering Change Record (ECR) will be created to record all engineering for either a new
product or a change to an existing product. This ECR will contain a list of drawings,
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specifications, reports, manuals, or any other documents associated with the new design or
change. It will provide as a minimum:
a. Description of the new product or change
b. Reason for the change
c. Model Number(s)
d. Serial Effectivity by Model
e. Document Number
f. Document Title
g. Document Revision
h. Document Revision Date
i. Other information may also be added to the ECR if deemed necessary or appropriate.
Multiple ECRs may be used for large projects to break the project down into smaller
segments. These ECRs are frequently for specific functional areas, such as collecting the
engineering associated to the propulsion system, or the electrical system. Some
companies use the project number to collect multiple ECRs associated to a project and
some companies use a top collector ECR. Using the Project Number is usually a better
solution but each company needs to make the decision based on their processes.
Frequently a specific document will be revised multiple times throughout a project. Each
revision associated to that ECR must be recorded on the ECR.
The ECR must be approved, released, distributed, and controlled in a manner similar to type
design and reports.
Type design
Type design is all drawings, specifications, and documents supporting the certification or
approval of a product. The type design will be company approved, released, distributed, and
controlled.
When a new document or a change to a document is required, the document number, title,
and revision will be checked out and listed on the appropriate ECR. This will provide visibility
to others of any documents that are either in the process of being created or revised.
Approval
All type design and supporting documents will be company approved prior to release.
Company approval documents that the company, through its authorized engineering
personnel, have reviewed the documents and agree that the type design meets the applicable
regulations or design standards. This company approval documents the company has satisfied
the regulatory or standard requirements and legal acceptance of responsibility for the
product. The persons making these approvals must have appropriate experience and integrity
and be approved by the Director of Engineering.
When documents need FAA, FAA designee, ODA Unit member, or other authority approval
they will be released prior to that approval. This would not apply to light sport aircraft
processes but would apply to any aircraft certified under the part 21 rules. All such approvals
will be retained by the certification organization within the engineering department. This
approval simply provides evidence of agreement by the FAA, the FAA designees, the ODA UM,
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or other regulatory authorities of the company approval. In FAA terms this is a Finding of
Compliance.
Release
A release procedure will document when the document is closed to any additional changes.
Once released, a document cannot be changed or modified in any way except through a new
revision to the document. The document number, title, revision, and release date will be
entered on the appropriate ECR.
Document Control
The engineering department is responsible for document control of all documents created
within engineering. The document control process will include the following:
a. Date an original document is checked out so the originator can construct the document.
b. Document number and revision, including DCNs and Deviations.
c. What ECR the document is assigned to.
d. Name of person checking it out.
e. Document release date.
f. Document type, i.e. paper or electronic.
g. Identification of where the original document is stored:
i. Paper documents will be stored in a vault or secured fireproof and waterproof file
cabinet.
ii. Electronic documents will be stored on two separate servers, one of which will not be
within the same building as the first or is off site.
h. Identification of all DCNs or Deviations against each drawing or specification.
i. Document release information identifying who is notified of the document release unless
the information is automatically available to all affected persons and organizations when
the document is released.
j. Access to either paper or electronic document originals is controlled to prevent
unauthorized changes being made to either except through a formal checkout process.
Distribution
Document distribution will occur only after the document is released and will be by either
paper or electronic means. If documents are distributed by electronic means the downstream
users may simply request notification of when new documents, or revisions, are released. It is
then their responsibility to obtain copies as needed. Normally the distribution, or use of
documents, will be in accordance with the following:
a. Drawings and specifications defining type design will be distributed, or made available, to:
i. Manufacturing Planning
ii. Shop Floor
iii. Quality Assurance
b. Functional Test Procedures defining production test procedures will be distributed, or
made available, to:
i. Manufacturing Planning
ii.
Quality Assurance
c. Compliance Reports will normally not be distributed except as requested for specific
reports.
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Control of Document Copies
All type design drawings and specifications used in the manufacturing planning or shop areas
will:
a. Be maintained in a secure area with appropriate limited access if the originals are paper
documents.
b. Be maintained on a secure server with appropriate limited access if the originals are
electronic.
c. Have all copies permanently marked to identify the date when it can no longer be used for
planning or production purposes. This date will be 20 calendar days after it was produced.
d. Be the responsibility of the person using the drawing or specification to ensure that it is
within the acceptable date range.
e. Be the responsibility of the person using the drawing or specification to ensure that all
applicable DCNs and/or Deviations are included with any drawings checked out for use on
the shop floor.
f. Be the responsibility of the person using the drawing to ensure that an out of date
document is removed from the floor and destroyed.
g. Be the responsibility of Quality Assurance to ensure that all drawings, DCNs, Deviations,
and Specifications used in the fabrication of an article were the correct number and
revision for the affected model and serial.
DOCUMENT CONTROL – 14 CFR 21.137(b)
2.1 Requirement
Procedures for controlling quality system documents and data and subsequent changes to
ensure that only current, correct, and approved documents and data are used.
2.2 Compliance:
The Quality Assurance procedures for controlling quality system documents and data will:
a. Approve documents for adequacy prior to issue.
b. Review and update documents as necessary and re‐approve revised documents.
c. Ensure that changes and the current revision status of documents are identified.
d. Ensure that relevant versions of applicable documents are available.
e. Ensure that documents remain legible and readily identifiable.
f. Ensure that documents being used in production are not beyond the allowable date
printed on the document.
SUPPLIER CONTROL – 14 CFR 21.137(c)
Requirement
Procedures that:
(1) Ensure that each supplier furnished product or article conforms to its approved design; and
(2) Require each supplier to report to the production approval holder if a product or article has
been released from that supplier and subsequently found not to conform to the applicable
design data.
Compliance
Supplier control involves all three organizations and it will involve an integrated process with
the involvement of each organization at the appropriate time in the process.
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3.2.1 Engineering
It is the responsibility of engineering to:
a. Identify on the bill of material for any product or article any parts to be obtained from a
supplier.
b. Identify the part(s) by supplier name, supplier part number, and/or the OEM part number
when used, as well as the specific version as described by the supplier’s drawing revision.
c. Identify when parts will require part serialization, modification number, or other unique
means of identifying a specific part.
d. Identify for inclusion on the Purchase Order the conformity requirements for the part or
parts. (This will be done for production parts as well as parts to be used in development
or certification testing.)
3.2.2 Manufacturing
It is the responsibility of manufacturing through their planning and purchase order to:
a. Identify on the Purchase Order the part number as defined by the Supplier along with the
drawing number and revision level the part is to be built to.
b. Identify any serialization, modification number, or other appropriate means of identifying
a specific part,
c. Identify any conformity requirements such as FAA Form 8130‐3, 8130‐9, etc. that is
required by either manufacturing or engineering.
d. Any other instructions necessary to ensure the part received by ABC satisfy their
requirements.
e. Ensure that the supplier is made aware of his responsibility to report to the purchaser, any
product or article that has been released from the supplier and subsequently found not to
conform to the applicable type design. This requirement should be included in any
contract with a supplier and reiterated on the Purchase Order.
3.2.3 Quality Assurance
It is the responsibility of Quality Assurance to:
a. Verify that the parts received match the requirements on the Purchase Order.
b. Retain all records of supplier provided parts, including any conformity paperwork
provided by the supplier, to that ensure they meet the required type design.
c. Ensure the parts are installed on the applicable model and serial product.
Supplier Qualifications
All suppliers providing parts, materials, assemblies, or services affecting the type design of all
parts included in the approved type design of the product will:
a. Be evaluated and approved by Engineering and Quality Assurance to ensure that all
products or articles the supplier provides will consistently conform to the approved type
design and quality requirements. This will be accomplished using ABC‐XXXX form that will
be signed by the representatives of both engineering and quality assurance who
conducted the evaluation.
b. Be included on the Approved Suppliers List maintained by Quality Assurance.
c. Be re‐evaluated yearly, or at any time the Director of Quality Assurance determines a
need based on quality of products received, to ensure they continue to provide
satisfactory parts or materials.
d. Provide ABC with the required inspection documentation as defined on the purchase
order for each product or article or lot of products or articles.
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e. Maintain records of the inspection results of each product or article or lot of products or
articles and make those records available to ABC upon request.
f. Implement a process to identify deviations from the required type design and a process to
identify root cause and corrective action for those deviations.
g. Implement a process to identify and report products or articles to ABC that have been
released to ABC and have been subsequently found to not conform to the applicable type
design data.
Delegation of Authority to Suppliers.
When a supplier has demonstrated that they can comply with the requirements in 3.1 they
may be delegated to perform conformity on their products and provide that information to
ABC.
3.4.1 The Director of Quality Assurance is:
a. Responsible for ensuring each supplier is evaluated to determine if they are eligible for
delegation and the extent and type of delegation.
b. Responsible for ensuring the results are reviewed with the Engineering and Operations
Directors or their representatives to obtain agreement from them.
c. Responsible for ensuring the delegation information is added to the Approved Supplier
List when approved.
d. Notifying the Supplier of the delegation authority and any specific requirements or
limitations that may apply.
3.4.2 Delegations to suppliers may include:
a. Major inspections of parts or assemblies that cannot be completely inspected by ABC
Receiving Inspection upon receipt.
b. Materials Review actions at the supplier facilities. When this function has been delegated,
ABC Engineering and Quality Assurance are responsible for reviewing each such action
after the fact to ensure that the dispositions are in accordance with ABC policy and
procedures. If the function is not delegated, each MRB action by the supplier must be
reviewed by ABC Engineering and Quality Assurance, and approved before the action is
implemented.
c. Direct shipment of a domestic supplier’s product to ABC aircraft operators. This authority
is delegated ONLY when:
i. The supplier is one of high integrity in the industry.
ii. Has demonstrated for at least 2 years that the parts/materials furnished are
consistently in conformity with the Purchase Order specifications.
iii. The Directors of Engineering and Operations have concurred with the Director of
Quality Assurance that direct shipment may be authorized.
MANUFACTURING PROCESS CONTROL – 14 CFR 21.137(d)
Requirement
Procedures for controlling manufacturing processes to ensure that each product and article
conforms to its approved design.
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Compliance
This is a joint requirement of engineering, operations, and quality assurance and compliance
will be as defined in the following sections.
4.2.1 Engineering
It is the responsibility of engineering to define on the drawing any parts, , materials, and
manufacturing processes that must be followed and controlled to ensure the end product
complies with the type design. This includes the writing of process specifications to define to
manufacturing and quality assurance any such requirements.
4.2.2 Operations
It is the responsibility of manufacturing to ensure their planning includes the appropriate work
instructions and process controls to ensure the part or assemblies satisfy the type design
requirements for the applicable aircraft serial.
4.2.3 Quality Assurance
It is the responsibility of quality assurance to verify that manufacturing has complied with the
manufacturing process requirements defined on the engineering and the manufacturing
planning and work instructions for applicable aircraft serial.
Approved Parts List
The parts list will contain all of the parts, assemblies, and installations as necessary to
completely assemble the finished article. All parts lists must be approved by the appropriate
engineering personnel prior to being issued to manufacturing.
Materials Evaluation
4.4.1 The ABC Engineering Department is responsible for:
a. Evaluating all materials to be procured from suppliers that require chemical or physical
analysis to verify that the material meets the design specification and documenting the
results on ABC‐XXXX form signed by the evaluating engineer.
b. Forwarding the findings of the analysis, whether satisfactory or rejected, to Quality
Assurance for further investigation of the suppliers qualifications.
c. Recommending adding the supplier to the Approved Parts List if acceptable.
4.4.2 The ABC Quality Assurance Department is responsible for:
a. Reviewing the engineering evaluation and if acceptable add the material to the
Approved Materials List containing at least the following information:
i. The specific material identification.
ii. The material specification, including revision, identification.
iii. The date approved.
iv. The specific supplier name and address.
b. Implementing a review of the supplier, and/or the material, if the results are not
acceptable.
c. Adding the supplier to the Approved Parts List if acceptable.
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Supplier Parts or Assemblies Evaluation
4.5.1 The ABC Engineering Department is responsible for:
a. Evaluating all parts and assemblies procured from suppliers that require analysis or
testing to verify that the parts or assemblies meet the design specification and
documenting the results on ABC‐XXXX form signed by the evaluating engineer.
b. Forwarding the findings of the analysis or testing, whether satisfactory or rejected, to
Quality Assurance for further investigation of the suppliers qualifications.
c. Recommending the part/assembly supplier be added to the Approved Parts List if
acceptable.
4.5.2 The ABC Quality Assurance Department is responsible for:
a. Reviewing the engineering evaluation and if acceptable add the parts or assemblies to
the Approved Parts List containing at least the following information:
i. The specific part or assembly identification.
ii. The part or assembly type design drawing, including revision, identification.
iii. The date approved.
iv. The specific supplier name and address.
b. Implementing a review of the supplier, and/or the part or assembly, if the results are
not acceptable.
Purchase Order (PO)
ABC Form PO‐100, is written for all parts and materials purchased for use in:
a. Production aircraft.
b. Test articles to be used for development or certification purposes.
4.5.1 Purchase Order Issuance
The Purchasing Officer will issue Purchase Orders for materials and parts only to:
a. Suppliers listed on the Approved Suppliers List maintained by Quality Assurance for
production aircraft.
b. Suppliers listed on the Approved Suppliers List or as specifically identified and approved
and approved by Engineering for development or certification testing requirements.
4.5.2 Purchase Order Data Requirements
The Purchasing Officer will specify on the PO:
a. The materials or parts that are shown on the approved supplier drawings.
b. The supplier drawing number and revision applicable to the materials or parts.
c. Any applicable specifications, including the design and quality requirements applicable
to the parts or material.
d. Any special conformity requirements such as FAA Form 8130‐9 or 8130‐3.
e. The documents required to be included with the parts or material.
f. A requirement that the supplier must notify and obtain approval from the ABC
Engineering Department for any changes in the design from that defined by the drawing
and revision identified on the PO.
g. Shipping Instructions.
h. The required delivery date.
i. Any special instructions.
j. Reminder to all suppliers to ABC Aircraft Company that they are subject to
inspection/surveillance by ABC Aircraft Company at any time.
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4.5.3 Substitute Materials on PO
The Purchasing Officer will obtain the approval of the Engineering Department before writing
a Purchase Order (PO) for substitute materials.
4.5.4 Direct Ship Instructions
The Purchasing Officer and Director of Quality Assurance will provide instructions for direct
shipment on the PO when a domestic supplier has been found by Quality Assurance to be
qualified for making such shipments. Suppliers selected to make direct shipments will be
authorized by the Director of Quality Assurance to place the following statement on invoices,
as evidence to the purchaser that the materials or part(s) are approved:
“The materials or part(s) covered by this invoice has (have) been produced under ABC
Aircraft Company authorization and conform(s) to the approved design.”
4.5.5 Purchase Order Distribution
The PO will be distributed as follows:
a. Original to permanent file.
b. Two for the supplier.
c. One for the “open PO” file.
d. One for Receiving Inspection.
Receiving Inspection
The Directors of Operations and Quality Assurance are responsible for receiving all products
and services procured from suppliers. This responsibility includes the following:
a. All materials and parts will be delivered to the receiving area to be initially processed.
b. The PO identified on the Packing Slip will be pulled to verify the order matches the PO.
c. The Receiving Inspector will verify that any documents such as material certifications,
affidavits, or conformity paperwork is included.
d. The Receiving Inspector will check the condition of the shipment to ascertain if there is
any damage.
e. If there is damage or the shipment does not meet the PO requirements, the Receiving
Inspector will complete a Rejection Slip, ABC Form J‐100, and the shipment will be
routed to the Material Review Board for disposition.
f. If the shipment is in good condition, the Receiving Inspector will inspect the items for
compliance with the applicable drawings and specifications.
g. Raw materials will be visually inspected for condition, and must be accompanied by the
certifications or affidavits as required by the PO.
h. The Receiving Inspector will stamp or tag raw materials before releasing to the
stockroom.
i. Any included documents attached to parts to be used in production will be attached to
the PO.
j. Any included conformity documents to be used for development or certification work
will be forwarded with the part to the experimental department.
k. When the shipment has met the PO and inspection requirements, a Receiving Report,
ABC Form RE‐100 will be completed and distributed to:
i. One copy attached to the PO copy and held by Receiving Inspections until final
completion of the Receiving Report.
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ii. One copy to Production Control.
iii. One copy to permanent storage.
iv. One copy to Accounting.
l. When a shipment has been rejected for any reason, the Receiving Inspector will send all
copies of the Receiving Report with the shipment to the Materials Review area for
disposition on the Receiving Report which will be returned to the Receiving Inspector for
distribution in accordance with k.
m. If the Material Review Board rejects a shipment, the shipment will be returned to the
supplier.
n. When a PO has been completely filled, the PO copy held by Receiving Inspection and all
attached documents will be returned to the Purchasing Office and filed for the record
with the original PO.
Production Control
4.8.1 Shop Travelers
Production control will be maintained though issuance of Shop Travelers, ABC Form ST‐100, by
Manufacturing Planning. The Shop Traveler will:
a. List the work items for manufacturing detail parts, and for all subsequent assembly or
installation operations.
b. Be based on the latest drawings and specifications applicable to the parts, assemblies, or
installations for the applicable aircraft serial. It is the responsibility of Planning to ensure
they have the latest applicable drawings or specifications.
c. When revisions to Shop Travelers are necessary, the shop will be notified of a pending
revision so they can plan accordingly.
d. When a revision to a Shop Traveler is issued, the superseded Shop Travelers will be
removed from the production areas.
e. Shop Travelers will be released at the appropriate stages of production to ensure that no
work items will result in areas on an assembly that cannot be inspected.
f. Have each work item stamped and dated in the space provided on the Traveler by
production employee upon completion of that work item.
g. Be presented to Production Inspection along with the applicable drawings and
specifications for conformity with the drawings and for condition and workmanship.
h. When found to be in conformity, each work item on the Traveler will be stamped and
dated in the place provided by the Production Inspector.
i. When a work item on a Shop Traveler is not in conformity:
i. The inspector will prepare a Rejection Slip, ABC Form RJ‐100.
ii. Route the rejected part back to the shop for corrective action either through
engineering approved rework or Material Review action.
iii. The part or assembly will not be released for delivery to the next operation until the
rejected item has been cleared and satisfactorily inspected.
j. When a Shop Traveler has one or more open work items because of parts shortages or
other valid reasons, the part or assembly may be released to the next production
operation, if:
i. The incomplete Shop Traveler is posted in a prominent place in the appropriate
Inspection Station to ensure that subsequent assembly operations cannot be finally
cleared until the open item(s) on the open Shop Traveler have been satisfactorily
completed and stamped.
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ii. Production Control has a process to continually review Shop Travelers with open
work items to ensure that completion of a subsequent work operation will not
render the open item “not inspectable” such as by enclosing the area in which the
open item is to be completed.
iii. “Working around” an open item is kept to a minimum and used only in extenuating
circumstances to preclude shutting down production.
iv. Shop Travelers with open items may follow an aircraft through final assembly and
flight test if necessary but must be cleared before an aircraft is licensed and
delivered.
k. When all the work items for detail parts or assemblies on the Shop Traveler have been
satisfactorily completed and inspected:
i. The Inspector will stamp each part or assembly.
ii. The parts or assemblies will be routed to the next assembly area or to storage for
later assembly or installation.
iii. The Shop Traveler will be routed to Quality Assurance for filing.
l. When all the work items for a final assembly Shop Traveler have been completed and
inspected:
i. The Inspector will stamp and date each work item.
ii. The Shop Traveler will be filed in a master file for each aircraft is shop complete and
satisfactorily flight tested.
iii. The completed master file will be routed to Quality Assurance for filing.
4.8.2 Work Instructions
The Director of Manufacturing is responsible for ensuring that clear and concise work
instructions are provided to all personnel involved in production fabrication and assembly
operations. Work Instructions may:
a. Be initiated by any ABC person involved in production operations at any level,
b. Be reviewed by that person’s supervisor and submitted to the Director of Operations for
approval.
c. Be added to the Operations Manual upon approval by the Director of Operations.
d. Be issued as Operating Instructions if the new work instructions concern only details to
supplement specific items in the Operations Manual.
INSPECTING AND TESTING – 14 CFR 21.137(e)
Requirement
Procedures for inspections and tests used to ensure that each product and article conforms to
its approved design. These procedures must include the following, as applicable:
(1) A flight test of each aircraft produced unless that aircraft will be exported as an
unassembled aircraft.
(2) A functional test of each aircraft engine and each propeller produced.
Compliance
Creation of the Functional Test Procedures will be a joint responsibility of Engineering,
Operations, and Quality Assurance. This will help ensure that the testing can be conducted in
an efficient and expeditious manner and the proper results are obtained. A single Functional
Test Procedures document will be utilized to ensure that Engineering, Operations, and Quality
Assurance have all reviewed and agreed on the test procedures and requirements. This will
save considerable effort and eliminate much confusion and misunderstanding of the
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requirements. In some cases the test procedure may utilize a consensus standard to help
ensure the testing is in agreement with accepted practice.
Functional Test Procedures Requirements
The production functional test procedures requirements will include a checklist that contains
the following:
a. A place for recording:
i. Product model.
ii. Product serial number.
iii. Specific test procedure document number, name, and revision.
iv. Specific test equipment used along with make, model, and serial or other
identification to allow finding the equipment later in the event of a question about
the data.
v. Dates of all tests.
vi. Signoff by the person performing each test attesting to performing the test in
accordance with the procedure and the results are as recorded on the checklist.
vii. Signoff by the quality assurance person verifying each test was conducted in
accordance with the procedure and results are as recorded on the checklist.
viii. In the case of flight tests where a quality assurance person is not on board the
aircraft during a flight test, the quality assurance signoff should be by the flight test
engineer accompanying the test pilot.
ix. A place for recording unusual difficulties, questionable results, or potential safety
issues with the product or the test that can be fed back to engineering, operations,
and quality assurance to determine if changes need to be made to the product, test
procedures, equipment, etc.
b. A detailed and sequential checklist of the steps to be taken in each test, or phase of the
test if the test is long or may be performed at different stages of production.
c. The parameters that must be measured and the acceptable values for each parameter
identified and recorded. Avoid calling for specific equipment to be used in measuring
parameters unless absolutely necessary as this can drive costs up. Instead specify the
measuring range, accuracy, or other pertinent requirements of the equipment as much
as possible to provide operations with the option to obtain equipment that is acceptable
and may be used for other testing.
d. Clear pass/fail criteria must be identified for each test. In some cases this will be
measured values whereas in flight testing this may be more subjective and depend on
the skill and experience of the pilot to determine if the results are satisfactory.
e. When a test requires a subjective evaluation, the person performing the test must have
proper training to ensure that they can determine acceptability of the test results and
be approved by the head of engineering to perform such tests. In these cases it may be
appropriate to identify acceptable characteristics that can be described and evaluated
with criteria for when a second pilot may be called on to provi de a second opinion. The
training requirements for the pilots conducting these tests must be identified in the test
requirements and documented in the individuals personnel records.
f. When a test fails, or a potential safety issue with the product is identified:
The cause must be determined and documented in the test results.
A solution must be agreed to between engineering, operations, and quality assurance.
Approved by engineering and quality assurance signing the document defining the issue
and the resolution.
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g. When a test fails, or the system being tested is disturbed in any way, there must be
clear instructions for what portions of a test must be repeated.
h. All checklists, either ground or flight, containing the results will become a permanent
production record for that model and serial will be routed to Qualtiy Assurance and be
retained by Quality Assurance.
Test Facilities, Equipment, and Personnel
It is the responsibility of Operations to provide facilities, equipment, and personnel to conduct
the required testing.
INSPECTION, MEASURING, AND TEST EQUIPMENT CONTROL – 14 CFR 21.137(f)
Requirement
Procedures to ensure calibration and control of all inspection, measuring, and test equipment
used in determining conformity of each product and article to its approved design. Each
calibration standard must be traceable to a standard acceptable to the FAA.
Compliance
It is the responsibility of the Directors of Operations and Quality Assurance to ensure the
calibration and control of all inspection, measuring, and test equipment and production
tooling used in determining conformity of each product and article to its approved design.
This requirement applies to all inspection, measuring, and test equipment, whether owned by
the company, its employees, or on loan or provided by the customer or a supplier.
Applicable Devices
These requirements apply to.
a. Any production tooling that, when used, establishes the conformity to the drawings or
specifications of the part or assembly made with the tool.
b. Any devices that monitor temperature, pressure, time, humidity, etc. that is required
either in production or for storage of materials.
c. Any devices used to measure materials by volume, weight, etc. when those parameters
are critical to ensuring the fabricated parts conform to type design.
Equipment Management
To satisfy these requirements the following procedures will be followed:
a. A measuring equipment and production tooling tracking tool will be created to:
i. Identify each piece of equipment or production tool with a permanent identification
number.
ii. Link the identification number to the specific piece of equipment by make, model,
serial number, date procured, and source.
iii. Identify storage location.
iv. Identify calibration dates.
v. Identify maximum time period between required calibrations.
vi. Identify who performed the calibration.
vii. Identify when next calibration is due and when recall is issued to ensure equipment is
returned in time to satisfy calibration schedule.
viii. Identify issue dates and who issued to.
ix. Identify check‐in dates and by whom.
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x. Any other information pertinent to the maintenance of the measuring equipment.
b. All gages and other measuring and testing equipment are the responsibility of the
Operations department to:
i. Procure
ii. Maintain.
iii. Store.
c. All gages and measuring equipment that is sensitive to environmental conditions must be
stored in areas or containers that protect the equipment from those environmental
conditions that could cause the equipment to provide unacceptable measuring capability
to ensure the products or articles inspected with the equipment meet the approved type
design.
d. All calibration of measuring equipment must be performed by agencies or laboratories
that use certified measurement standards traceable to the National Institute of Standards
and Technology.
e. The tracking tool will be reviewed weekly to determine which devices need to be recalled
that week.
f. Upon recalibration a sticker will be attached identifying the date it was calibrated and the
next due date.
INSPECTION AND TEST STATUS – 14 CFR 21.137(g)
Requirement
Procedures for documenting the inspection and test status of products and articles supplied or
manufactured to the approved design.
Compliance
Compliance with this requirement will consist of the following:
a. Production Orders will contain sufficient definition of the product to be manufactured
that all parts, assemblies, installations, and tests will be included on Shop Travelers.
b. The Shop Travelers used to fabricate all parts and assemblies and perform installations
document conformity results.
c. Functional test procedures provide documents to record the results of all functional
testing to ensure that tests satisfy the type design requirements.
d. All inspection or test operations will be at points in production where accurate
determinations can be made and documented.
e. This information will be contained in the Quality Assurance files and documented in the
Production Inspection Record (PIR) for each aircraft manufactured
NONCONFORMING PRODUCT AND ARTICLE CONTROL – 14 CFR 21.137(h)
Requirement
(1) Procedures to ensure that only products or articles that conform to their approved design
are installed on a type‐certificated product. These procedures must provide for the
identification, documentation, evaluation, segregation, and disposition of nonconforming
products and articles. Only authorized individuals may make disposition determinations.
(2) Procedures to ensure that discarded articles are rendered unusable.
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Compliance:
ABC maintains procedures to assure that articles which do not conform to specified
requirements are prevented from inadvertent use or installation. When articles are initially
found to be nonconforming, it shall be examined, promptly recorded, and conspicuously
identified. In accordance with XXX – Control of Nonconforming Material, identified
nonconforming articles shall be controlled until dispositioned, to prevent unauthorized use.
This control includes, but is not limited to, the identification, documentation, evaluation,
segregation, and disposition of articles. Nonconforming articles shall be subjected to review
by designated persons to determine an appropriate final disposition. Persons carrying out the
review shall consist of qualified members of Quality Assurance, Liaison Engineering (when
referred to MRB), and a customer representative when applicable in accordance with criteria
established in XXX and XXX – XXX Material Review Board Membership List.
Nonconforming articles dispositioned as scrap shall be processed as necessary to preclude
production use in accordance with XXX – Mutilation of Scrap Material.
MATERIAL REVIEW
The Materials Review Board (MRB) will consist of the Directors of Engineering, Quality
Assurance, and Operations, or their qualified appointees. A qualified appointee will have:
a. An engineering degree and 4 years’ experience in the area for which he/she will be making
dispositions, or
b. Eight years of experience in the area for which he/she will be making dispositions.
8.3.1 Facility and Equipment Responsibilities
The Director of Operations is responsible for providing:
a. An enclosed area(s) with a lockable entry to be used for storing nonconforming items
awaiting MRB disposition.
b. Bins or containers marked in red with the word REJECTIONS, located in the fabrication and
subassembly areas where items awaiting material review action or damaged detail parts
will be placed until transported to the Materials Review area.
c. Facilities and/or tools as may be required for physical mutilation or destruction of items
that are rejected by the Material Review Board.
8.3.2 MRB Responsibilities
The MRB will:
a. Review rejected parts and materials.
b. Make decisions as to their disposition. Final decisions of the MRB will be for one aircraft
only and will not be used as repetitive decisions and be applied to other parts or materials
for review.
c. Ensure that the causes of non‐conformances are determined promptly, and that
appropriate corrective or remedial action is taken by the responsible Director.
d. Maintain records of causes, trends, and individual causes it acted upon and prepare
individual records for summaries of action taken.
e. Establish a follow‐up system to ensure the timeliness and effectiveness of all corrective or
remedial action.
MRB Process
The MRB process will:
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a. Receive the Rejection Slips and parts or assemblies from receiving inspection or
production.
b. Review the rejection and determine which of the following actions to be taken:
i. “Use As Is” for parts with minor discrepancies that have no effect on the physical
strength or the function of the part or assembly that would create any safety issues.
ii. “Rework/Repair” with detailed instructions of how to rework the part to make it
acceptable.
iii. “Replace” when the discrepancy cannot be satisfactorily resolved for the particular
installation but it may be able to be reworked to satisfy other requirements.
iv. “Reject” when the part is beyond the capability of being able to be reworked to a
satisfactory condition for use.
c. Record the recommended action on the Rejection Slip.
d. Have the Rejection Slip signed and dated by the MRB members.
e. Return the Rejection Slip and the part(s) or assembly(ies) to the issuing department.
f. Have non‐conforming parts or materials that cannot be reworked, repaired, or otherwise
salvaged by approved modifications scrapped and destroyed, or in the case of supplier
furnished parts will be returned to the supplier.
g. Have the MRB recommend to engineering that the design data be changed when:
i. A rejection becomes chronic.
ii. Is of a major magnitude that could affect other related parts or materials,
iii. Is of a nature where the corrective action would result in a product improvement.
h. Mark an item with the word REJECTED, in lieu of mutilation of the rejected part, ONLY
when the item might still be usable as part of a prototype mockup by the Engineering
Department.
i. Items that are determined to be SCRAP will be placed in a locked container, preferably
colored red, until they can be mutilated by cutting with tools or torch, or smashing with a
hammer in such a way that the item cannot possibly be repaired or otherwise refurbished
and used on an aircraft.
j. Require the Director of Operations to be responsible for ensuring that no rejected item
will be sold as scrap by the ABC Company until mutilation has been carried out.
k. Ensure a copy of each Rejection Slip processed by the MRB is attached to the affected
Shop Traveler for use by shop personnel when rework or repair is required and for the
permanent aircraft record.
l. Ensure all Rejection Slips:
i. Are in a file maintained by the engineering department.
ii. Will be made available to auditors upon request.
CORRECTIVE AND PREVENTIVE ACTIONS – 14 CFR 21.137(i)
Requirement
Procedures for implementing corrective and preventive actions to eliminate the causes of an
actual or potential nonconformity to the approved design or noncompliance with the approved
quality system.
Compliance
Corrective Action Response and Review Requirements addresses the requirements for
answering and reviewing Corrective Action (CA) requests generated by Quality Assurance.
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Appendix F
Actions shall be taken as outlined in XX – Preventive Action to prevent occurrence of
nonconformance’s relating to articles, processes, or the Quality Management System.
HANDLING AND STORAGE – 14 CFR 21.137(j)
Requirement
Procedures to prevent damage and deterioration of each product and article during handling,
storage, preservation, and packaging.
Compliance
The Director of Manufacturing will establish standards and procedures for stocking and
handling production parts. This will include but not be limited to the following:
a. Ensuring Purchase Orders have a quality clause to specify marking, handling,
documentation, transportation, and delivery requirements for all parts and materials.
b. Receipt of materials and parts from suppliers to ensure they meet requirements of
Purchase Order.
c. Ensuring documents received with materials or parts are properly filed for record
retention requirements.
d. Ensuring materials and parts are properly labeled or marked to avoid any confusion in use.
e. Ensuring materials and parts have appropriate protection from damage while in storage or
in transit between operations.
f. Ensuring materials are stored in facilities meeting any environmental requirements for the
materials or parts.
STORAGE AND ISSUANCE
The Director of Manufacturing is responsible for ensuring the storage, issuance of materials
and supplies, and maintenance of records for all materials is in accordance with the following:
a. Storage area(s) must be provided that will provide for protection against deterioration or
damage to products in storage, and that handling devices, environmental control
methods, and transportation vehicles are suitable for the products involved and are
loaded as required to prevent damage.
b. Raw materials are checked for proper identification and stored in an area appropriate for
their condition and packaging,
c. When special packaging requirements or storage environments (refrigerators, freezers,
etc.) must be maintained, packages are labeled to indicate this condition, with the labeling
requirements shown on the Purchase Order, ABC Form PO‐100.
d. Upon receipt of a shipment from Receiving Inspection, the shipment is accompanied with
a copy of the Receiving Report, ABC Form RE‐100 that indicates satisfactory acceptance
and the report is filed in the appropriate storage area.
e. Items that are labeled with expiration dates (O‐rings, seals, composite materials, etc.) will
be stored in properly identified bins. A file will be maintained to ensure that the oldest
items are issued first, and that items that have expired are routed to the Materials Review
segregated area for disposition.
f. Items that require environmentally controlled storage, (“icebox” rivets, sealants,
composite materials, etc.) will be:
i. Stored in refrigerators or freezers with appropriate temperature controls and
recording thermometers installed to ensure that the temperature requirements are
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Appendix F
maintained and recorded daily to ensure that the temperature has remained within
limits,
ii. If a discrepancy is found, such as due to a power failure or a faulty refrigerator or
freezer a Rejection Slip, ABC Form RJ‐100 covering all of the material involved is
created,
iii. The Rejection Slip is routed to the Materials Review area for action by the Materials
Review Board, and
iv. The contents of the refrigerator or freezer will not be used in production until
corrective action or rejection has been determined by the Board.
g. All completed or semi‐completed detail parts and/or subassemblies are routed to storage
pending eventual use in further stages of production and ensuring that:
i. A shop traveler, ABC Form ST‐100 accompanies the item to indicate its inspection
status at the time of routing to storage.
ii. The Shop Traveler remains with the item in storage to be issued with the item when it
is eventually requisitioned by production, and
iii. Notification to production inspection if a Shop Traveler is not with the semi‐
completed detail parts and/or subassemblies.
h. Maintaining all storage areas in a clean and orderly condition.
i. Conducting monthly checks to ensure appropriate disposition of all out‐of‐date items are
properly dispositioned.
j. Ensuring that large or unwieldy items are secured and properly protected from damage
when placed in transport vehicles and during delivery to work areas.
k. Maintaining storage booths and/or storage bins, for small parts that are located in the
production shop areas and ensuring that such booths or bins are adequately stocked to
meet production needs by ordering replenishments before the supply is exhausted.
l. Ensuring proper handling of composite materials, and separation of composite storage
areas from the rest of the manufactured items.
CONTROL OF QUALITY RECORDS ‐ 14 CFR 21.137(k)
Requirement
Procedures for identifying, storing, protecting, retrieving, and retaining quality records. A
production approval holder must retain these records for at least 5 years for the products and
articles manufactured under the approval and at least 10 years for critical components
identified under § 45.15(c) of this chapter.
Compliance:
The Director of Quality will ensure the Appropriate records are maintained to demonstrate
achievement of quality requirements and to verify the effective operation of the Quality
System. General requirements for control of records are provided in the Records
Management Instructions Manual, maintained electronically on the XXX home intranet page.
In all cases, the following requirements shall be assured:
a. Quality records shall be legible and identifiable to the article or service involved as
outlined in XXX – Forms and Their Use and other QA documentation requirements.
b. Quality records shall be stored and maintained so they are readily retrievable in facilities
that provide a suitable environment to minimize deterioration or damage and to prevent
loss.
c. Retention times of quality records shall be established, documented, and observed.
Where agreed contractually, quality records shall be made available for evaluation by the
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customer for an agreed period.
INTERNAL AUDITS – 14 CFR 21.137(l)
Requirement
Procedures for planning, conducting, and documenting internal audits to ensure compliance
with the approved quality system. The procedures must include reporting results of internal
audits to the manager responsible for implementing corrective and preventive actions.
Compliance
ABC will establish and conduct internal audits meeting the requirements described in the
following sections.
Responsibilities
a. The Director of Quality Assurance is responsible for ensuring a master audit plan for
conducting audits of all production and quality areas and activities on a regular basis will
be established.
b. The Director of Engineering is responsible for ensuring a master audit plan for conducting
audits of all engineering areas and activities on a regular basis is established.
Audit Master Plan Requirements
The master plan will contain:
a. A general schedule with the ability to conduct spot audits at any time.
b. Identification of how the audits will be coordinated.
c. Identification of what the audits will cover.
d. The frequency of audits or how to establish the frequency.
e. How the results will be documented.
f. A process for identification of any safety issues and the required action.
g. A process of notification of the Director of Engineering and the FAA of any safety issues.
h. A process for identification and resolution of isolated versus systemic issues.
i. Who and when the results will be reported to.
j. A process for determining root cause of any discrepancy.
k. A process for determining corrective action, who is responsible for the corrective action,
and when it will be completed.
l. A process for closure of any findings.
Instructions:
A major function of the Quality Assurance Department is to maintain a system and schedule of
annual audits of all ABC Aircraft Company facilities and activities, including selected suppliers,
to ensure that the Quality Assurance data and procedures approved for the manufacturing of
aircraft are being adhered to. These audits will cover the following, in addition to any special
audits deemed necessary by Quality Assurance in individual cases:
a. Fabrication and assembly areas
b. Receiving and storage.
c. Processes and controls.
d. Materials Review Board Areas.
e. Measure and Test Equipment Control.
f. Selected suppliers, generally of critical items.
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Appendix F
Audit Follow‐Up Action
The audit findings will be recorded on Correction Sheets, ABC Form QA‐100, and routed to the
appropriate department for corrective action, which must be accomplished within 5 working
days by the department receiving the form. The Correction Sheet will then be stamped by
production and returned to Quality Assurance, who will verify that the item has been
resolved. In the case of suppliers, the audit findings will be transmitted by letter to the
supplier.
The Quality Assurance Department is responsible for ensuring that prompt corrective action is
taken by the applicable department on any discrepancies found by the auditor(s).
Third Party Audits
The Quality Assurance Department is the focal point for the ABC Company in all matters
related to scheduled third party audits. Quality Assurance will provide a room, desks, and
copies of all ABC technical data, including the Quality Assurance Manual, the Operating
Procedures Manuals, Process Specifications, and Operating Inspections that have been issued
by ABC departments, as well as any other material or data requested by the auditor(s).
IN‐SERVICE FEEDBACK – 14 CFR 21.137(m)
Requirement
Procedures for receiving and processing feedback on in‐service failures, malfunctions, and
defects. These procedures must include a process for assisting the design approval holder to:
(1) Address any in‐service problem involving design changes; and
(2) Determine if any changes to the Instructions for Continued Airworthiness are necessary.
Compliance
ABC will establish procedures to receive feedback from customers and the FAA to address
service difficulties.
Responsibilities
13.3.1 The Director of Engineering is responsible for establishing and maintaining the ABC Customer
Support Department, which is the focal point for all communication involving customer
services with operators of ABC aircraft. ABC Company does not prohibit direct communication
with operators by either Engineering or Quality Assurance, however, such direct
communication is held to a minimum, and copies are routed to Customer Support for
information.
13.3.2 The Customer Support Business Unit has final authority in all matters relating to customer
relations, warranty policy administration, customer satisfaction, and technical support (in
coordination with the Product Development and Engineering Business Unit) concerning
commercial articles as outlined in Customer Service procedure XXX. These customer
communications may include article information, enquiries, contract or order handling, and
customer feedback, including customer complaints.
Production Aircraft List
The Customer Service Department will maintain a current listing of ABC aircraft in service by
model and serial number and FAA registration number, together with the name and address
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Appendix F
of the owner/operator, or have access to the information through the FAA aircraft registration
records.
Service Issues
Product Support coordinates corrective actions and response to the customer including
service information documents in accordance with XXX – Issuance of Service Information
Documents for Delivered Products.
Specific technical issues raised by the operators, a regulatory authority, or any other person
are reported to the Model Specific Technical Group as Field Condition Reports, call logs, direct
reports, etc. These issues are assigned to the appropriate engineering technical group for
evaluation and resolution. The related information may be entered into a Field Corrective
Action System where the issue is reviewed, prioritized, and staged for completion.
Engineering will develop the appropriate response to the issue.
Service Publications
The Director of Engineering is responsible for the development of publications that advise ABC
aircraft operators of service problems that have been reported and that may affect other
aircraft in the fleet, and of the corrective action for such problems. The Engineering
Department will promptly investigate all reported failures, malfunctions, and defects and
develop the appropriate corrective action. As determined by the magnitude of the service
problem, the publication subsequently distributed to the operators will be:
a. SAFETY DIRECTIVE. Issued when an unsafe condition exists that may also exist in other
aircraft in the fleet. All Safety Directives issued by ABC Engineering will be distributed to
all operators and made available to the appropriate airworthiness authority. Safety
Directives are considered mandatory and must be performed and documented in the
aircraft permanent records.
b. SERVICE BULLETIN. When no unsafe condition exists, but a service problem has become
repetitive, ABC Engineering will develop a design change that will contribute to the safety
of ABC airplanes and issue a Service Bulletin containing information on the design change
for distribution to all operators of ABC aircraft. Service Bulletins may also be issued for
minor changes considered product improvements. Service Bulletins are not considered
mandatory.
c. SERVICE LETTERS. ABC Engineering will also issue Service Letters on any subject that is
considered helpful to operators. Such letters are intended to maintain a good rapport
with the operators, to encourage feedback on service or other problems, or to circulate
items of interest that an operator may feel would be of value to all operators. Service
Letters are not considered mandatory.
NOTE: AIRWORTHINESS DIRECTIVE (AD). An AD will be used when an unsafe condition is
found to exist in a type‐certificated product or component installed in the aircraft. The FAA
processes and issues ADs, however, ABC Engineering is responsible for full cooperation with
the FAA in providing design data for rework that may be required, in conducting static or flight
tests to verify the adequacy of corrective action, and any other assistance that may be
requested by the FAA, such as making available ABC engineering or quality assurance
personnel to participate in accident scene investigation.
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Distribution of Service Documents
Customer Support will distribute Safety Directives, Service Bulletins and Service Letters issued
by ABC Engineering. Customer Support may also issue Service Letters with information that
does not require engineering evaluation or action.
QUALITY ESCAPES – 14 CFR 21.137(n)
Requirement
Procedures for identifying, analyzing, and initiating appropriate corrective action for products
or articles that have been released from the quality system and that do not conform to the
applicable design data or quality system requirements.
Compliance
Quality escapes released from the ABC quality system will:
a. Be identified.
b. Be evaluated.
c. Have root cause determined.
d. Have corrective action initiated.
e. Require notification of the FAA within 24 hours.
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Appendix F
Appendix A
FACILITY DIAGRAM
A facility diagram should be provided that identifies where major functions are located such as
Engineering, Production, and Quality Assurance. Do not make it so detailed that every move of
equipment or activities results in having to revise the diagram. It should be sufficient to get a person to
the main location of a function where people can then provide directions to specific areas.
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Appendix F
Appendix B FORMS
This section shows examples of forms used by the ABC Aircraft Company in the production process.
These should be modified as required to suit the needs of the company.
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Appendix F
PURCHASING AGENT
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Appendix F
(PURCHASE ORDER REVERSE SIDE)
AGREEMENTS AND CONDITIONS
Acknowledgment ‐ This order shall not be effective nor shall Buyer be obligated to pay any monies called
for hereunder unless and until Seller shall have signed and returned written acknowledgment and
acceptance.
Seller’s Conditions ‐ No conditions laid down by Seller in accepting or acknowledging this order shall be
binding upon Buyer if in conflict with any instructions, agreement and/or condition herein stated, unless
expressly accepted by Buyer in writing.
Invoices ‐ Seller must mail invoices for each shipment to Buyer on date of shipment.
Shipping Instructions ‐ Seller shall make no charges for boxing, crating, or carting unless previously
agreed to in writing by Buyer. Seller shall comply with the shipping instructions specified on the reverse
side hereof. All articles shall be suitably packed or otherwise prepared for shipment to prevent damage
in transit and to meet carrier’s requirements. All articles shall also be suitably packed and classified to
assure lowest transportation and insurance rates consistent with full protection against loss or damage.
Cash Discount ‐ The cash discount period will date from the receipt in Buyer’s main office of Seller’s
invoice accompanied by waybill, and not from date of Seller’s invoice. Buyer may pay Seller’s invoice
before delivery and complete inspection or test of the article and thereby avail itself of the cash
discount. By such payments, Buyer does not waive its right to reject the articles and may charge the
account of Seller for any loss, shortage, defect or failure in performance, delay, or other default.
Cancellation ‐ If the Seller refuses or fails to make deliveries of the articles within the time specified in
this order or any extension thereof, Buyer may terminate the right of Seller to deliver the articles,
except when delay of Seller in delivering articles is due to unforeseeable causes beyond the control and
without the fault or negligence of Seller, including but not restricted to, acts of God or of the Public
Enemy, acts of Government, fires, floods, epidemics, quarantine restrictions, strikes, freight embargoes,
but not including delays caused by subcontractors or suppliers; provided that Seller shall, within ten (10)
day from the beginning of such delay, notify Buyer in writing of the cause of delay; and provided further
that if delay due to such unforeseeable causes exceeds a total period of sixty (60) days, Buyer may
terminate the right of Seller to deliver the articles.
In the event of any suspension of payment, or the institution of proceedings by or against either
party, voluntary or involuntary, in bankruptcy, or insolvency, or under provisions of the United States
Bankruptcy Act, or for the appointment of a receiver or trustee or an assignee for the benefit of
creditors, of the property of either party, the other shall be entitled to cancel this contract forthwith by
written notice.
If any of the articles ordered herein purports to be protected by one or more patents, and a
decree of judgment be entered in a court of competent jurisdiction holding invalid any such patents or
any of the protection which it purports to give, this contract may forthwith be canceled by the Buyer.
Specifications ‐ Except as otherwise stated, all material or equipment for aircraft construction listed
herein, to which Government or Buyer’s specifications are applicable, must comply with such
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Appendix F
specifications current as of date of this order. Should such specifications be revised prior to shipment,
Seller, by first obtaining consent of Buyer, may furnish such material or equipment in accordance with
revised specifications.
Where a specification number is noted for supplies ordered, Seller must supply in triplicate a notarized
report confirming manufacture of materials to the specification. This report must bear Buyer’s purchase
order number and description of materials shipped. This report must be mailed at time of shipment
direct to Buyer, one copy of same to accompany shipment.
Patent Protection ‐ By accepting this order, the Seller agrees to indemnify and hold harmless and protect
the Buyer, its successors, assigns, customers, and the users of its products from and against all loss,
liability, claims, demands, and suits of law or equity for actual or alleged infringement of any patent or
patents by the normal use or sale of such material or goods. No patent application is to be made by
Seller in connection with design development during the manufacture of items of Buyer’s original design
unless prior written approval is given to Seller by Buyer.
Warranties ‐ The Seller warrants that the articles to be supplied under this contract are fit and sufficient
for the purpose intended; that they are merchantable, of good quality and free from defects, whether
patent or latent, in material and workmanship; and that material or equipment for aircraft construction
conforms to required specifications as outlined in paragraph 7.
The Seller warrants that is has good title to the articles supplied and that they are free and clear from all
liens and encumbrances. These warranties, together with their service warranties and guarantees shall
run to Buyer, its successor, assigns and/or to persons to whom the materials or articles may be resold.
Inspection ‐ All materials or articles ordered will be subject to final inspection and approval at the plant
of Buyer. Any articles which do not comply with this order or which contain defective material or
workmanship may be rejected by Buyer irrespective of payment therefor. The Buyer may hold any
articles rejected for cause for the Seller’s instructions, or he may return them to the Seller at Seller’s
expense.
Confidential ‐ The Seller shall not disclose any information concerning the order to any third party
except as herein specified without first obtaining the written consent of the Buyer.
Seller as Independent Contractor ‐ In filling this Purchase Order, the Seller shall be considered as an
Independent Contractor, and in no sense or case an agent of the Buyer.
Assignment ‐ Neither party may assign this contract without first obtaining written consent of the other
party; provided that consent is hereby given to such assignment to any corporation with which either
party may merge or consolidate or which may succeed to its business.
Interpretation ‐ This Purchase Order is to be governed by the laws of the state in which it is issued.
All warranties herein shall be construed as conditions as well as warranties
~ 204 ~
Appendix F
RECEIVING REPORT
CODE PART
ITEM QTY DESCRIPTION
NO. NO.
By
RECEIVING INSPECTOR
~ 205 ~
Appendix F
EXAMPLE
ABC Form ST-100
Page ___ of ____
SHOP TRAVELER
Stamps
Item No. Work Operation Shop Insp
(continue as needed)
~ 206 ~
Appendix F
Description of Defect:
Evaluated by (Engineer):
date
Materials Review Required? (Yes or No)
Final Disposition:
Use as is Rework/Repair Replace Reject
~ 207 ~
Appendix F
DURING FLIGHT
1. Full throttle RPM at best rate of climb IAS 75 mph RPM __________
2. Cruising RPM 2350 altitude ________ OAT ________ IAS ________
balance
oil temp _______ oil pressure _______ fuel pressure (engine ________
electric) ________
3. Top level flight IAS ________ RPM ________ Altitude ________
4. Stall power on ________ IAS Power off ________ IAS Altitude
________
5. Dive VG (135) RPM ________
~ 208 ~
Appendix F
~ 209 ~
Appendix F
Shop/Department Audited:
FINDINGS
(First stamp blocks indicate findings. Second stamp blocks
indicate that corrective action has been completed.)
Stamps
Item No. Discrepancy Insp. Date
(continue as needed)
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Appendix F
Appendix F.8 ‐ Standard DO/PO Handbook
14 CFR Part 23 Reorganization ARC
Type Design & Production Certification ‐ Working Group
Whitepaper:
Standard DO/PO Handbook
Applying Streamlined and Standardized Company Procedures
Issue date: 08 Jan 2013
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Appendix F
Table of Contents
Table of Contents ............................................................................................................................. 212
1. General ..................................................................................................................................... 213
1.1. Requirements Basis ........................................................................................................... 214
1.2. Desired Effects .................................................................................................................. 214
2. Standard Process Environment ................................................................................................ 217
3. Handbook Analysis .................................................................................................................. 220
3.1. Data Basis .......................................................................................................................... 220
3.2. Analysis Results ................................................................................................................ 220
3.3. Analysis Conclusion .......................................................................................................... 222
3.4. Standard Handbook Structure ........................................................................................... 222
4. Proposed Steps for Implementation ......................................................................................... 227
5. Cost / Benefit Analysis ............................................................................................................ 228
5.1. Safety Effects .................................................................................................................... 228
5.2. Cost Effects ....................................................................................................................... 229
6. APPENDIX 1 - Handbook Analysis ........................................................................................ 232
6.1. ODA Handbook Structure ................................................................................................. 232
6.2. PC Structure ...................................................................................................................... 233
6.3. AS / EN 9100 Structure ..................................................................................................... 235
6.4. EASA Design Organization Structure............................................................................... 237
Appendix 2 – Standard TC/PC Handbook ....................................................................................... 239
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Appendix F
1. General
In a typical aviation company of today, different applicable sets of procedural, organizational and quality
management / assurance requirements for different segments of company activity are satisfied by
separate handbooks. Companies maintain separate TC and PC handbooks, when operating in different
countries sometimes in slightly varying, parallel versions.
Current implementation of the regulations (by FAA Orders) asks for predefined handbook structures for
the individual operational segment that do not allow for a unification of the process world. Significant
effort is spent to establish and maintain separate handbooks resulting in high administrative burdens,
especially for small companies that maintain both, TC and PC of one product, for one company, under
one roof. This gets more complicated when the same company acts as component supplier under AS /
EN 9100 approval with a third set of requirements and a third handbook. The situation causes a direct
basis for conflicting information with the connected risk of process errors in daily work.
By comparison of the requirements basis with existing accepted handbook samples a harmonized
approach is identified, that allows for small companies to set up one single integrated quality
management process satisfying all typical requirements, as an alternative to today’s interpretation
indicated by the Orders.
The harmonized approach is manifested in a standard handbook template, which can be utilized and
adopted to the individual company conditions.
The harmonized standard handbook implements several results of other ARC Part 23 work group topics
with identified significant potential for optimization of today’s process in time, effort, cost and safety. By
including these results in the standard handbook a level playing field is established with limited room for
local interpretation that might have negative impact for an individual company.
Throughout the process of generating the standard handbook approach it has been verified, that this
handbook is capable to comply with the regulations of different major Agencies. This levels the playing
field even beyond the limits of FAA jurisdiction.
The subject matter was identified within the Part 23 ARC activity, as it highly relates to cost occurring
when certifying a new project or making changes or STC to an existing project. It is recognized that the
implementation is beyond the Scope of Work of the Part 23 ARC. Therefore, this paper is used to relate
the outcome of the intense discussions and subsequent work to a parallel Part 21 ARC process that
would reduce the cost of certification with no negative impact on safety and potentially some positive
impact through more consistent procedures across a company.
The level of completion of this task is such that the activity can be handed over to an industry standards
body. It is the recommendation of the task group to initiate this as the next step.
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Appendix F
1.1. Requirements Basis
The following requirements sets must be considered for ODA / PC activity:
14 CFR part 21 (general TC, STC, repair requirements)
14 CFR part 21, Subpart G (PC)
14 CFR part 183 (ODA)
The equivalent requirements on EASA basis are:
COMMISSION REGULATION (EC) No 748/2012, Part 21 (general TC, STC, repair requirements)
COMMISSION REGULATION (EC) No 748/2012, Part 21, Subpart G (PC)
COMMISSION REGULATION (EC) No 748/2012, Part 21, Subpart J (DOA)
The equivalent Transport Canada requirements are:
Canadian Aviation Regulation (CAR) 521 (TC, STC, PDA, repair design approval requirements)
Canadian Aviation Regulation 561 Manufacturer Approvals
Airworthiness Manual (AWM) Chapter 505 Delegation of Authority, Subchapter E (DAO)
Other Agencies have comparable requirements that typically match one of the above systems.
Applicable Industry Standards are:
AS 9100
EN 9100:2009
1.2. Desired Effects
During the discussion it has been recognized, that the current costs in time and money spent do mostly
not originate from the wording of part 21 as such. This is true for the FAA system, as well as for the
other systems investigated. Those aspects that result in increasing time consumed and cost spending
originates from the interpretative material, such as ACs, Orders, AMC or GM.
Identification of the key cost and time killers in the current process identify the following working areas
where the approach must provide more efficient guidance. All serve as success criteria to check the
resulting proposal:
6. Establish acceptable major/minor criteria for changes including a usable definition of the term
“appreciable effect” when used within changes classification. Finding of Compliance for Minor
Changes shall be delegated to an organization who uses the procedures, once the company is
approved by the FAA.
The Minor / Major process has been developed within a separate ARC part 23 task and is identified by a
separate whitepaper. Once completed, this process shall be implemented to the standard handbook.
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Appendix F
7. One set of processes, established in one company, must be capable of satisfying all types of
design and production efforts that can occur (TC, STC, changes, MRA, and production under PC).
By implementing the unified handbook this is ensured.
8. Rules for the usage of electronic approvals shall be defined. The possibility shall be considered
within the handbook. Transport Canada and EASA currently run prototype procedures with
companies that seem to work well. The handbook can pick up this experience and implement.
9. The Standard manual must be detailed and complete enough and without duplications, so that
only minor customization is required for a start‐up company to get it working and approved.
This requires proper boilerplate language, that in some cases can offer different case‐dependent
variants. The applicant will then select the relevant version.
10. The level of qualification for nominated staff shall be defined, so that staff can be trained and
verified by the company or by third party consultants for as many cases as possible, and not
necessarily through FAA training. The company shall be entitled to nominate staff on the basis
of such training, not necessarily through the Agency. The requirements for qualification
documentation shall be unified and kept reasonable, simple and straightforward.
11. Finding of compliance in non‐complex projects by company delegates, once the company is FAA
approved. FAA shall only perform spot checking. This directly links to the separate ARC part 23
effort defining an Applicant Showing Only process. Once completed the process will be
implemented to the standard handbook.
12. Configuration control and verification of certification and test articles shall be typically done by
the organization, not by the Agency. Definition of a proper standard Configuration Management
Process allows for this delegation. This directly links to the separate ARC part 23 effort defining a
Conformity Management process. Once completed the process will be implemented to the
standard handbook.
13. Provide structure and contents for certification programs that are adequate for small / simple
projects and allow the required scaling for complex projects. This item requires further work.
Parallel EASA efforts shall be analyzed for usability in this effort.
14. Provide standard compliance checklists for simple products in template form to directly support
simple projects, and to serve as example cases for more complex projects. This task requires
further work.
15. Provide standard approach on supplier documentation and evaluation. Generate the ability to
share supplier information across users to minimize burden on suppliers. Auditing activity
should only be required when reasonable doubts exist. Having a standard process shall create
the ability to take credit for another OEM’s audit findings of the supplier. From the supplier’s
perspective, he currently must host numerous audits by different customers, which becomes a
burden to repeat the same exercise for each customer. The supplier might chose an
independent, third party auditor that will share results with each customer who has
implemented the process defined in the standard handbook, instead of hosting repeated
individual audits by OEMs. It is understood that a separate industry – Agency working group has
been started to deal with this aspect. The task group generating this whitepaper will coordinate
with the other working group.
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Appendix F
16. Standard handbook shall be structured to be most efficiently with a small company that grows
into TC and PC, holding it in one hand and at one location. The handbook shall identify how it
should be split when this is not the case, without duplicating efforts for companies who have it
all in one hand. This desired effect is linked to item 4, above.
17. Provide standard forms (e.g. conformity and quality functions, supplier audits, major/minor
change classification, etc.) that strongly support / focus on factual correctness, not formal
efforts. The forms shall be such that they automatically guide step by step through the process,
so that a potential process implementation failure is minimized. In the end, an employee shall
be able to satisfy the related process automatically by following the template, without need to
re‐iterate the actual process language. This item requires further work.
18. Allow for joint auditing of PC and TC to reduce auditing efforts. Having one unified handbook
ensures a consistent process landscape. On this basis, FAA could jointly schedule their ODA
audits with the ACSEP assessment to reduce company costs/burden. This is also the entry point
for later possible third party audits by qualified / accredited Auditors like AS9100 auditors.
19. Use industry QM standard philosophy wherever reasonable. Only exceed where absolutely
unavoidable to meet the basic requirements of the regulations (not the Orders).
(Discussion during Nov KC ARC meeting: Some sort of initiative where FAA expresses buy‐in to industry
efforts. Linkages between part 21 and AS9100. FAA: What credit do you get for ISO? Answer: None, or
basically none. However, now FAA is an ISO organization, position could be reviewed. More use of ISO
in the certification procedure requirements would encourage procedures standardization that can
better control schedule and costs. Companies growing from other business segments can get benefit of
having ISO qualifications already in place. Start‐up companies would be encouraged to obtain ISO
qualification as first and affordable step for a new installed quality system rather than jumping in one
leap to the full part 21 compliant system which helps control risk associated cost for the company.
Companies that use AS9100 might in future use third party audits rather than exclusively FAA audits.
Current audit practices set by internal policy within the FAA so could be reviewed without a rulemaking
exercise.)
20. Keep company infrastructure definition in the standard handbook pragmatic and reduced to
what really has effect on the compliance and quality of the product. Avoid overly detailed floor
plans. FAA could advise those auditing the systems of the minimum acceptable level of detail. It
starts with the first approval of the quality manual.
21. Allow for maintenance / repair on products that have shown compliance, but are still under
control of the production organization. Used to be called a manufacturer’s maintenance facility.
Today the product moves through production until a certificate of conformity/standard
certificate of airworthiness/certificate of airworthiness for export is issued. Once that occurs,
the product falls under maintenance rules of alteration and repair. The process needs to be
more flexible. While the product is still in production control, a company should be able to do
maintenance, alterations and repairs under the existing production organization processes. This
would allow coverage for damage on the production line, during storage or in shipping. The
process would allow the production organization to take back the part, repair and maintain
conformity under the PO without having to have a part 145 approval. Take the part back to the
~ 216 ~
Appendix F
line, process it as any other part going through production, still resulting in a new part and not in
a reworked part. Today, once the conformity tag is issued, the part crosses the line from
production to service. A production organization can’t touch a part today once it is issued its
conformity tag. If damage happened in final inspection, PO could issue an MRB to repair
damage. With the changed process in effect the company would remove the conformity tag (in
a documented way), do what the MRB would normally do to repair the damage, then issue a
new conformity tag.
- Level 1: AS 9100 Quality Manual,
- Level 2: AS 9100 Procedures,
- Level 3: AS 9100 Instructions and
- Level 4: AS 9100 Records.
When unifying the handbooks to a joint industry standard handbook, this 4 level model shall be used as
basis. The graphical representation of this model is as follows.
~ 217 ~
Appendix F
Quality
Management
Handbook
Level 1
= the unified DO/PO
Handbook
Design Production
Handbook Handbook
Level 2
Process Descriptions
Level 3
Work Instructions
Level 4
Forms Templates
In this model:
- The first level unifies general QMM, Design Handbook and Production Handbook. All three
logical sections have wide overlapping, joint sections, and each one has limited amount of
individual sections.
o The three handbooks are merged to one consistent handbook.
o The relation to the three logical sections is given through compliance checklists for the
three individual requirements sets AS9100, part 21 PC and part 21 TC, STC, Changes /
part 183 ODA.
o It is possible to leave out one of the two segments Design Handbook and Production
Handbook when a company only covers one aspect.
o Design Handbook and Production Handbook form part of the top level Quality
Management Handbook that may reach beyond (certificated) aviation activities. Design
~ 218 ~
Appendix F
and Production specific items are clearly identifiable. Cross‐cutting items need only be
defined once, and potential for conflicting definitions is eliminated.
- Design and Production handbook are prescriptive to a certain extent.
o The generic manual shall hold sufficient minimum prescriptive information to
unmistakably identify an efficient process flow that satisfies the applicable
requirements, without overly complicating it.
o For a simple company with non‐complex undertaking the wording within the
handbooks, together with process flow oriented templates, must be sufficient to ensure
compliance with the requirements, without need for separate Process Descriptions in
Level 3.
o For a company with a more complex undertaking, the handbook sections remain in
place but are enhanced by separate Process Descriptions in Level 3.
- Level 4 contains all applicable Forms and Templates.
o Forms and templates are provided as separate documents with identifier. This way the
handbook remains generic and international, and specifies what kind of information
must be provided, not how the form looks and how to fill the form.
The discussion above differentiates between simple and complex “undertaking”. Discussion of the
handbook subject did show that the deciding factor for the required process complexity is not related
just to either product complexity or company size, but to the complexity of the undertaking a company
has, explicitly with respect to the activities covered by the handbook. The importance of this
consideration is visible when looking at the following examples:
- A very small company conducts all its activities in one location. The product is by product
definition complex. The company relies in many areas upon suppliers holding their own
approvals. The company produces very few aircraft per year, with very few workers. Even having
a complex product, such a company can clearly operate within a very pragmatic and slim
process environment. The undertaking of the company is simple.
- A small company operates in different locations. Engineering, component production and final
assembly are separated, maybe out of cost reasons even in different countries. The company
produces very simple and basic products with no system complexity. The company runs several
variants in parallel, maybe even different types and delivers to many countries, the overall
annual production number is high. Even having a small company and non‐complex products,
such a company will require a detailed process structure that considers the challenges from its
spread‐out setup and the parallel products on production. The undertaking of the company is
complex.
~ 219 ~
Appendix F
3. Handbook Analysis
3.1. Data Basis
To analyze the current situation and identify the need for improvement, the task group has analyzed
and compared a variety of handbooks from industry operating on an international basis, in different
segments of part 23 and with different levels of privileges. The Following handbook structures were
made available for analysis, several in different company versions:
Type Requirements Basis
ODA TC handbook FAA part 21 and 183, subpart D
ODA PC Handbook FAA part 21 and 183, subpart D
FAA PC QMS FAA part 21
FAA PC generic structure; no handbook FAA part 21
but required contents listing
Engineering Process Handbook non‐ ODA FAA part 21
EASA DO Handbook EASA part 21
Quality Management Manual EN 9100
Generic structure QMM AS 9100
Generic structure QMM LSA ASTM F2279
3.2. Analysis Results
With the detailed summary of the comparison provided in Appendix 1, the following observations are
done for Design Handbooks:
1. The same is covered in each variant of design handbook. But:
a. AS/EN 9100 handbook consolidates design processes very much. Therefore, using a pure
9100 handbook might not be sufficient to satisfy expectations of the Authorities.
Does this “more” add value?
Not always, but there is a clear risk for “too little”
b. ODA handbook is extremely detail oriented and breaks the requirement into very fine
steps that are predefined. This includes very fine detailed ODA staff functions and
involved “committees” / meetings. This shows more of a procedure guide (work
instructions), than a process guide.
Does the much finer procedural guidance / oversight result in higher reliability
/ quality of the development results?
No, it does not.
c. ODA handbook groups all design related procedures in one block with no real
substructure. This section includes again partially generic procedures.
~ 220 ~
Appendix F
d. AS/EN 9100 handbook has economics related overhead that is not requested by part 21
(company commitment, management review, customer focus, planning, …)
Does this “more” add value?
This “more” builds sound company culture, and therefore can be considered
added value that generates an improved basis for lasting quality, being the
basis for lasting safety.
2. As soon as one looks at handbooks of approved companies, the handbooks follow a somewhat
similar structure in logical blocks. However, some handbook samples are efficient in this
(AS9100), some not (ODA). The typical blocks you can find are:
a. Generic / normative issues and introductions
b. Organizational aspects, org charts, staff and roles, training, HR
c. Approval related information, privileges, delegations, validities, requirements for update
and communication to maintain validity
d. QM generic functionalities, document handling, auditing, changing the QM;
improvement
e. Development process incl. showing of compliance either
i. integrated for the tasks design, changes, STC
ii. in separate blocks for the tasks design, changes, STC
f. Instructions for Continued Airworthiness
g. Occurrence Management (COSM)
h. Production Interface
i. Appendices with detailing information for the individual company, that may change
while the process remains the same (staff assignments, facilities, locations, detail org
charts, subcontractors, …)
j. Appendices with forms, or references to form documents
With the detailed summary of the comparison provided in Appendix 1, the following observations are
done for Production Handbooks
1. PC structure and AS9100 structure have a high overlap.
a. AS/EN 9100 handbook consolidates production processes very much. Therefore, using a
pure 9100 handbook might not be sufficient to satisfy expectations of the Authorities.
~ 221 ~
Appendix F
i. Does this add “more” value?
Not always, but there is a clear risk for “too little”
b. AS/EN 9100 handbook has economics related overhead that is not requested by part 21
(company commitment, management review, customer focus, planning, …)
i. Does this add “more” value?
This “more” builds sound company culture, and therefore can be considered
added value that generates an improved basis for lasting quality, being the basis
for lasting safety.
3.3. Analysis Conclusion
Analysis shows that:
- The topics dealt with in all process worlds are comparable enough to allow unification.
- The level of detail is different. The proper balance must be found that provides sufficient
guidance to ensure compliance, but does not overburden the “small” or new applicant.
- The generic structure of DO and PO handbooks are comparable enough that a unification in one
handbook is possible, with a generic block, a DO related block, a PO related block. Several
procedures affect both business segments in the same way. This approach allows split‐up when
only one function shall be covered.
3.4. Standard Handbook Structure
The standard handbook structure resulting from this discussion shall be as follows. Only one chapter
structure is used, to keep consistency between AS 9100, part 21 TC and part 21 PC worlds. To generate
this structure, the typical AS 9100 structure was used as starting point, matched with part 21
requirements, carefully enhanced and refined, as required.
The markings in the table below show which sections of the handbook are intended to provide
compliance for which company “functionality”. As can be seen, incorporation of AS/EN 9100 to what is
used today in order to comply with part 21 or 183 even carefully enhances the scope of the handbook
and adds general accepted practices for quality management and assurance, in addition to plainly
satisfying the product oriented results. Implementing this into the standard handbook adds significant
value, as it actively ensures a quality management culture within the organization. Such a QM culture in
itself ensures detection and correction of potential, future quality problems before they get visible on
the product, and better implements customer satisfaction.
~ 222 ~
Appendix F
~ 223 ~
Appendix F
~ 224 ~
Appendix F
~ 225 ~
Appendix F
~ 226 ~
Appendix F
Starting from here, a compliance checklist can be created, defining the minimum content per chapter.
This is the basis to define the general philosophy that is envisaged per chapter.
It is the proposal of the task group formed under the Part 23 ARC, that significant cost and time benefit
can be obtained while maintaining or even enhancing safety, by initiating AC, Order, AMC and GM
changes to implement this approach. Needs to be finally verified, but from today’s point of view the
most significant achievements can be obtained without regulation change, as the language in part 21
and part 183 (and others) allows for sufficient leeway.
The current proposal comprises the method and the outline of the future standard handbook,
represented by the chapter structure, allocation of chapters to requirements and key items to be
considered in each chapter. It is proposed, at this level of detail, to hand off the generation of the actual
standard handbook template to an Industry Standards body. Using an industry standard as vehicle will
ensure that the boilerplate text sections and the associated templates are truly acceptable in a most
efficient way for the every‐day development and production work of the companies. Through the
participation of the major Authorities in the industry standard processes, conformity to regulations can
be easily ensured in this process, without the need to invest massive resources from the Agency side.
As a further reaching outlook, such a standardized approach opens up possibilities for potential future
acceptance of third party auditing for design‐ and/or production organizations with products in the low
performance / complexity aircraft segment. This would further allow for a smooth and harmonic
connection to the segments ranging “below” part 23 scope, such as the Light‐Sport Category where the
current experience already leads to a similar system. Utilization of third party audit also supports joint
Design and Production audit in one step, which was identified as one of the cost drivers.
Remaining open items yet to be addressed are:
1. Rules for the usage of electronic approvals shall be verified on the basis of Transport Canada and
EASA.
2. Provide structure and contents for certification programs that are adequate for small / simple
projects and allow the required scaling for complex projects.
~ 227 ~
Appendix F
3. Provide standard compliance checklists for simple products. Serves as usable template for
simple projects, and serves as example cases for more complex projects.
4. Provide standard templates that strongly support / focus on factual correctness, not formal
efforts.
All those items can be well addressed by the standards body.
1. Having multiple case‐relevant procedures in one enterprise is known to create an environment
where procedures are considered “paper‐tigers” that are applied only in Audit situations, and
not in daily life. Therefore, daily life shows repeated omissions in vital processes. Having a
unified handbook for Design and Production activities, where the common procedures are not
defined repeatedly but only once and applicable for all areas of the enterprise, eliminates the
risk for conflicting procedures, and therefore the risk for procedural omissions. The single
procedure is more likely to be truly applied throughout the company operation. This
immediately increases the safety level of the designed and produced aircraft, part or
component.
2. Handbook structure that satisfies AS/EN 9100 and part 21 requirements allows for company
growth, starting from components / PMA up to full aircraft development and manufacturing.
This removes the need for process change within the company as consequence of an actual
growth step. This increases the acceptance of the involved personnel from the start, resulting
in increased professionalism, directly reducing the possibility for mistakes and thus increasing
safety.
3. Consideration of AS/EN 9100 requirements enhances the company process landscape towards
a quality management culture and orientation towards customer satisfaction. Enhanced quality
management automatically drives product safety to a higher level. Instead of just detecting
mistakes and correcting them, these aspects are commonly accepted principles to help avoid
mistakes before they happen. Typically this is not covered by handbooks purely satisfying part
21 or part 183 requirements. By adding this layer to the process landscape of a company, a
direct increase of product quality and with this safety is achieved.
4. Enhancing the possibility for delegation / privileges on company side, on the basis of
qualification and agreed processes, allows a company to move faster in a project. As
consequence, design updates or production improvements can reach the product on a faster
timeline, thus also making safety improvements available to the market earlier. Having more
flexibility to move will also encourage companies to actually make and implement safety
improvements timely, instead of delaying them in order to avoid the associated authority
interaction effort.
5. Enhancing the use of true delegation to the company, including finding of compliance and
verification of conformity in selected or wide areas significantly increases the responsibility of
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Appendix F
the Applicant. Having no third‐party corrective step following the company’s task completion
will drive the companies to even more thorough working and verification principles.
6. The proposed streamlined processes that get implemented to this unified handbook
significantly reduce the timeline and therefore cost associated with new developments or
product changes. This significantly improves the ability for small companies to conduct such
changes, and therefore bring safety enhancing technology to the market earlier, allowing for
faster associated safety enhancements.
5.2. Cost Effects
Cost reduction is achieved for Agency and Applicant in different aspects:
1. Having a standardized Agency agreed process environment to start from reduces effort on
applicant and Agency side during the manual/handbook acceptance process.
2. Especially small cost sensitive companies with lower staffing are required to hire consultant
labor force for the generation of an acceptable handbook. Typically support is required for 2 –
4 years for an initial approval. With the proposed standard handbook template, the applicant is
able to set up his process environment with very low risk of need for iterations. Having the
mature standard handbook, efforts for the individual company reduced by as much as half.
3. On the FAA side, efforts for re‐negotiating questionable company proposals is expected to
reduce by half.
4. Reduced duration to achieve first approvals for a new company effectively shortens the project
duration for a first product.
5. Reduction of the project duration has direct effect to the expenditure to get the product up to
certification, which directly results in more efficient product cost. Especially production
certification efforts are due towards the end of the certification project, where monthly costs
are highest.
6. Handbook structure that satisfies AS9100 and part 21 requirements allows for company
growth.
7. Companies may start as component supplier following AS 9100 setup, and grow into making
own complete products without change of the applied quality system. As consequence,
repeated efforts for establishing and implementing quality systems do not occur, new training
and losses due to temporary inefficiency is not required.
8. Companies that have to satisfy different systems need to maintain only one manual.
9. This efficiency gain starts with daily work to one procedure set only, continues through internal
auditing and need for repeated and parallel qualification.
10. Making use of delegations for the finding of compliance through company nominated staff
instead of FAA staff.
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Appendix F
11. This approach allows optimization of the timeline for the certification program of the company.
This has direct and increasing cost effect on the company side. To a certain extent this is
compensated by raised effort for the company to make the required qualified nominated staff
available, but remains to be a significant savings potential.
12. This aspect has significant cost savings potential to the FAA, as the required staff for time
critical finding of compliance is reduced. One part of this staff will be used in the surveillance of
company procedures instead, but independent from project schedules and therefore with
significantly reduced intensity, ensuring a lasting saving for the Agency.
13. Optimized Supplier Management and Auditing process allows for streamlining the associated
effort.
14. The amount of possible cost savings is highly dependent from the complexity of the supplier
environment of the company, but is based on the reduced frequency of supplier auditing,
resulting in reduced labor and travel expenses for both, company and supplier.
15. Unified definition for Staff Qualification Requirements, enhancing the possibility for company‐
internal training and qualification instead of mandatory FAA qualification.
16. Cost reduction is obtained for the company by being able to react faster to upcoming needs
and better tailoring the required training schedules to the actual company needs.
17. Cost reduction on Agency side is achieved by reducing the need for qualification and training.
18. Minor / Major process with privilege for minor changes
19. Cost reduction is obtained for the company by being able to move faster with changes. Savings
potential has been evaluated under a separate work item. The Standard handbook is the
vehicle to make this process transparent and available to the companies.
20. Implementation of a Configuration Management System instead of repeated and disjointed
conformity inspections
21. This step will result in significant cost saving, as has been identified in the separate
Configuration Management white paper. The Standard handbook is the vehicle to make this
process transparent and available to the companies.
22. Applicant showing only
23. Savings potential has been evaluated under a separate work item and appears for company
and for FAA. The Standard handbook is the vehicle to make this process transparent and
available to the companies.
24. Qualification through a qualified body (Accredited entity, AS/EN 9100 qualified auditing entity
or similar) is considered acceptable also for Agency approval.
25. Cost effect on company side is in two directions. Implementation of a commercial third‐party
(accredited) Auditor generates direct cost to be taken by the applicant. In return, the available
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Appendix F
market for these auditors offers significantly improved availability compared to FAA staff alone,
allowing for the applicant to significantly save project time. As approvals are needed especially
towards the end of a development project, the added cost for the third party auditor are easily
compensated by the project duration related cost savings.
26. This aspect also brings significant cost saving for the Agency, when the amount of staff required
to audit companies where this alternative may be offered can be reduced.
27. Joint Auditing of Design and Production Quality System
28. By allowing and supporting single audits that cover both, Design and Production aspects
installed under one company roof, the effort for Audit preparation and support by the
company is significantly reduced. Especially for smaller companies where the processes are
highly connected this is a significant cost effect that can be easily leveraged. Usage of third
party auditing will automatically lead to this option, as auditing bodies, that for example
typically do AS 9100 audits, are fully set up to audit both aspects in one audit.
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Appendix F
ODA handbook structure is repeatable between the companies in its general outline. Order 8100.15A,
Appendix B, defines this structure.
There is one headline for all the procedures. Within this single headline the majority of the contents is
included that defines the real implemented processes, and varies significantly between the companies.
The typical structure is:
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Appendix F
Formal and Normative Aspects
Authorization I
Organization and Staff
Self‐ Auditing
Guidance Material
Authorization II
FAA Auditing
COSM
Completeness of all Procedures,
unstructured
Records
Corrective Action
Activity Reporting
Appendices (Forms, Templates,
Nominations, …)
6.2 PC Structure
PC handbook structure is derived from § 21.137, where the required content is identified. This is used as
handbook structure. Procedures are grouped in separate blocks. Some topics repeat at different
positions.
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Appendix F
Formal and Normative Aspects
Organization
Authorization
General Processes I
Supplier Control
Manufacturing Process
Inspection and Testing
Non‐Conforming Articles I
Corrective Action
Handling and Storage
General Processes II
Auditing
COSM
Non‐Conforming Articles II
Appendixes
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Appendix F
6.3 AS / EN 9100 Structure
AS/EN 9100 does not mandate a handbook structure, but it is common practice to re‐build the
requirements structure as handbook structure. The handbook provides clearly structured blocks that
allow for the representation of the procedures to conform to the actual process‐flow.
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Appendix F
General Processes
Responsibilities, Authorization,
Control of the QM System
Human Resources, Organization
Product Specification
Design and Development
Procurement
Production
Analysis of QM System, Design,
Product, Internal Auditing, Non‐
Conforming Products
Improvement
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Appendix F
6.4 EASA Design Organization Structure
EASA Part 21 does not mandate a handbook structure. The sample handbook provides structured blocks
with very little repeating information. The process flow follows the real sequence of events.
Administrative information is mostly at the beginning.
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Appendix F
Formal and Normative Aspects
Organization, responsibilities,
nominations
Authorizations, all information
related to the Approval
Internal and Agency Auditing
Development of New Product
Type Design Changes
ICA, COSM
General Processes
Subcontracting
Lists of Nominations and
Subcontracting
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Appendix F
7. Appendix 2 – Standard TC/PC Handbook
FAA ARC Part 23
Type Design & Production Certification ‐ Working Group
Appendix 2 to Whitepaper:
Standard DO/PO Handbook
Applying Streamlined and Standardized Company Procedures
Issue date: 20 Dec 2012
Note 1:
The contents of this document provides the starting point for a unified quality management manual
that covers design and production aspects for an aviation company. This version is intended as
starting point for a Standardization Activity that will develop the actual handbook. The level of
detail in this current draft is intended that it defines what the final handbook will support / provide,
how the efficiency will be increased by this and how cost will be reduced while increasing safety.
Having one unified manual will allow a new company to start with a setup that allows for growth
without re‐structuring of the quality system, and without having parallel systems in place for
different products.
This manual is structured following the guidance in AS / EN 9100, carefully modified and enhanced
to meet the requirements of Part 21 and 183. In some few cases this leads to deviations in the
sequence / structure compared to AS 9100, but in no case removes contents needed to meet AS
9100. It is the purpose of this standard manual to provide a usable template that satisfies all, ISO
9001, AS/EN 9100, ASTM standards for quality assurance on LSA aircraft, Part 21 and Part 183
requirements.
The manual must satisfy the requirements of Parts 21 and 183, as appropriate, but will not
necessarily satisfy the guidance in the FAA Orders.
Note 2:
General Note on Level of Detail of this draft // intended Next Steps:
1) This is not yet a finished standard manual.
2) What is presented here:
a) Provides the structure of the intended standard manual,
b) Provides the majority of references to the normative sources that shall be covered under
each headline
c) Provides the keywords that shall be enhanced to fill the individual sections.
d) Provides more detailed guidance at those points where today’s practice shows that:
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Appendix F
i) There is ambiguity in the understanding which leads to conflicting interpretations /
implementations in different companies
ii) There has been established an interpretation that overshoots the truly needed
compliance
iii) There has been established an interpretation that undershoots the truly needed
compliance
iv) There is conflict potential between the different normative references and guidance
shall be given how to bring this to a common denominator
3) Background for the efficiency gain is to allow for a unified handbook to satisfy several related
normative bases in one step, allowing for easy growth and also stepwise implementation
without need to change the system or to maintain parallel systems.
4) Background of the safety gain is to allow for implementation of one single system within a
company that satisfies all needs at the appropriate level, which makes it much more possible for
the company to follow this system and to gain the desired effect, than when having a company
that has multiple systems that can be conflicting in different areas. This often leads to the result
that the systems are defined on paper but are not lived.
5) Background of the cost saving is to allow for a modular system with growth potential that is
properly guided and can be implemented with little local effort by simple customization to the
individual case. Surveillance of one unified system reduces parallel efforts for multiple systems.
Consistent system allows for proper delegation of authorities again reducing effective cost.
Note 3:
This manual template is designed to allow usage as a whole, or by applicable segments, when the
company does not cover all aspects (scope) the handbook offers.
Normal font will be used to identify possible text for the manual. Italicized wording is general
explanatory notes and guidance and should be removed from the finished manual.
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Appendix F
0.1 List of Revisions
a) Each revision will be assigned a sequential number starting with “0“ the for the original issue of
the manual.
(Note: Revisions can be either letters or numbers. If letters are used revise this template
accordingly for your specific process.)
b) Revisions will be listed in tabular form by section of the manual
c) Record the name of the author of the manual and revision.
d) Record the name(s) of the persons to check / approve the manual or revisions.
Generation and checking of the manual shall be done by two different persons. Approval does not
need a new person. Identify which company function (person role) is needed to generate, check and
approve.
e) Record the date when each revision was approved
0.2 Distribution List
a) All individuals or organizations, including addresses as needed, required to receive a
paper copy of the manual and all revisions are listed below.
b) An electronic copy of the manual will be posted on the company website at the location
shown here (Insert link to website here) along with instructions on how to access it. The
website will be available for all users to access the manual 24/7.
This way of distribution may not be needed in all cases.
0.3 Table of Contents
(Note: If a particular section in this standard does not apply it does not need to be included.
In some instances it may be desirable to leave a place holder using “Reserved“ to indicate a
potential future use for that section.
0 General .............................................................................................................................. 241
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Appendix F
0.1 List of Revisions .......................................................................................................... 241
0.2 Distribution List .......................................................................................................... 241
0.3 Table of Contents ....................................................................................................... 241
0.4 Scope .......................................................................................................................... 246
0.4.1 Documenting Compliance ................................................................................... 246
0.4.2 Determining Compliance .................................................................................... 246
0.4.3 Production to Approved Design .......................................................................... 246
0.4.4 Maintenance of Type Design and Compliance Documentation ......................... 247
0.4.5 Identification and Correction of Process Deviations .......................................... 247
0.4.6 Customer Support ............................................................................................... 247
0.5 Normative Reference ................................................................................................. 247
0.6 List of Abbreviations .................................................................................................. 247
0.7 Definitions and Terms ................................................................................................ 248
0.8 List of Referenced Documents ................................................................................... 248
0.8.1 Regulations .......................................................................................................... 248
0.8.2 Procedures .......................................................................................................... 248
0.8.3 Instructions ......................................................................................................... 248
0.8.4 Forms and Templates .......................................................................................... 249
1 QUALITY MANAGEMENT SYSTEM ..................................................................................... 249
1.1 General Requirements ............................................................................................... 249
1.2 Documentation Requirements ................................................................................... 249
1.2.1 General ................................................................................................................ 249
1.2.2 Document Management ..................................................................................... 249
1.2.2.1 Document Identification .............................................................................. 250
1.2.2.2 Document Control........................................................................................ 250
1.2.2.3 Document Notification and Availability ....................................................... 251
1.2.2.4 Document Storage ....................................................................................... 251
1.2.2.5 Documentation Interface between Design and Production Entity ............. 252
1.2.2.6 Documenting of Approvals .......................................................................... 252
1.2.3 Changes to this Handbook .................................................................................. 253
1.3 Guidance Material ...................................................................................................... 253
1.4 Records ....................................................................................................................... 254
1.4.1 Design Related Records ...................................................................................... 254
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Appendix F
1.4.2 Production Related Records ............................................................................... 255
2 MANAGEMENT COMMITMENT ........................................................................................ 255
2.1 Management Commitment ....................................................................................... 255
2.2 Customer Focus .......................................................................................................... 255
2.3 Quality Policy .............................................................................................................. 256
2.4 Planning ...................................................................................................................... 256
2.5 Scope of Work ............................................................................................................ 256
2.6 Responsibility, Authority, and Communication ......................................................... 256
2.6.1 Responsibility ...................................................................................................... 256
2.6.2 Authority ............................................................................................................. 256
2.6.3 Authorized Functions and Limitations ................................................................ 257
2.6.3.1 Scope of Work .............................................................................................. 257
2.6.3.2 Delegations/Privileges ................................................................................. 257
2.6.3.3 Authority to Sign .......................................................................................... 258
2.6.4 Internal Communication ..................................................................................... 258
2.6.5 Communication with the Authority .................................................................... 258
2.6.6 Application for (changes) to Design and Production Certificates ....................... 259
2.7 Management Review ................................................................................................. 259
3 RESOURCE MANAGEMENT ............................................................................................... 259
3.1 Provision of Resources ............................................................................................... 259
3.2 Human Resources ...................................................................................................... 259
3.2.1 General ................................................................................................................ 259
3.2.2 Competence, Training, and Awareness .............................................................. 259
3.2.2.1 Competence ................................................................................................. 259
3.2.2.2 Training ........................................................................................................ 260
3.2.2.3 Awareness .................................................................................................... 260
3.2.3 Nomination of Staff ............................................................................................. 260
3.3 Infrastructure ............................................................................................................. 260
3.4 Work Environment ..................................................................................................... 261
4 PRODUCT REALIZATION .................................................................................................... 261
4.1 Planning of Product Realization ................................................................................. 261
4.1.1 Project Management .......................................................................................... 261
4.1.2 Risk Management ............................................................................................... 261
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Appendix F
4.1.3 Control of Work Transfers .................................................................................. 261
4.2 Configuration Management. ...................................................................................... 262
4.3 Customer Related Processes ...................................................................................... 263
4.3.1 Determination of Requirements Related to Product ......................................... 263
4.3.2 Review of Requirements Related to Product ..................................................... 263
4.3.3 Customer Communication .................................................................................. 263
4.4 Design and Development ........................................................................................... 263
4.4.1 Design and Development Planning ..................................................................... 263
4.4.2 Design and Development Inputs ......................................................................... 263
4.4.3 Identification of the Certification Basis .............................................................. 264
4.4.4 Design and Development Outputs ...................................................................... 264
4.4.5 Design and Development Review ....................................................................... 264
4.4.6 Design and Development Verification and Validation ........................................ 264
4.4.6.1 Testing .......................................................................................................... 264
4.4.6.2 Flight Testing ................................................................................................ 264
4.4.6.3 Verification and Validation Documentation ................................................ 265
4.4.7 Control of Design and Development Changes .................................................... 265
4.4.7.1 Changes Classification .................................................................................. 265
4.4.8 Showing and Finding of Compliance ................................................................... 265
4.4.8.1 Applicant Showing Only ............................................................................... 265
4.4.8.2 Applicant Statement of Compliance ............................................................ 265
4.5 Supplier Management ................................................................................................ 265
4.5.1 Purchasing Process .............................................................................................. 266
4.5.2 Purchasing Information ....................................................................................... 266
4.5.3 Verification of Purchased Product ...................................................................... 266
4.5.4 Reporting of Non‐Conforming Purchased Products ........................................... 266
4.6 Production and Service Provision .............................................................................. 266
4.6.1 Control of Production and Service Provision ...................................................... 267
4.6.1.1 Production Process Verification ................................................................... 267
4.6.1.2 Control of Production Process Changes ...................................................... 267
4.6.1.3 Control of Production Equipment, Tools, and Software Programs ............. 267
4.6.1.4 Control of Work Transferred, on a Temporary Basis, Outside the Organization’s
Facilities ....................................................................................................... 267
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Appendix F
4.6.1.5 Control of Service Operations ...................................................................... 267
4.6.2 Post‐Delivery Support ......................................................................................... 267
4.6.2.1 Repairs ......................................................................................................... 268
4.6.2.2 Alteration ..................................................................................................... 268
4.6.2.3 Maintenance ................................................................................................ 268
4.6.3 Validation of Processes for Production and Service Provision ........................... 268
4.6.4 Identification and Traceability ............................................................................ 268
4.6.5 Customer Property .............................................................................................. 268
4.6.6 Preservation of Product ...................................................................................... 269
4.6.7 Product Conformity ............................................................................................. 269
4.6.7.1 Determination of Conformity ...................................................................... 269
4.6.7.2 Issuance of Airworthiness Approvals/Certificates ....................................... 269
4.6.7.3 Issuance of Flight Permits ............................................................................ 269
4.7 Control of Monitoring and Measuring Devices .......................................................... 269
5 MEASUREMENT, ANALYSIS, AND IMPROVEMENT ............................................................ 269
5.1 General ....................................................................................................................... 269
5.2 Monitoring and Measurement .................................................................................. 269
5.2.1 Customer Satisfaction ......................................................................................... 269
5.2.2 Audits .................................................................................................................. 270
5.2.3 Monitoring and Measurement of Processes ...................................................... 270
5.2.4 Monitoring and Measurement of the Product ................................................... 270
5.2.4.1 Inspection Documentation .......................................................................... 271
5.2.4.2 First Article Inspection ................................................................................. 271
5.2.4.3 Tests on Manufactured Products ................................................................. 271
5.2.4.4 Flight Test on Manufactured Products ........................................................ 271
5.3 Control of Nonconforming Product ........................................................................... 271
5.3.1 Quality Escapes ................................................................................................... 272
5.3.2 Manufacturer Maintenance or Repair ................................................................ 272
5.4 Analysis of Data .......................................................................................................... 272
5.5 Improvement ............................................................................................................. 272
5.5.1 Continual Improvement ...................................................................................... 272
5.5.2 Corrective Action ................................................................................................ 273
5.5.3 Preventive Action ................................................................................................ 273
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Appendix F
5.5.4 Continued Airworthiness (CA) ............................................................................ 273
5.5.4.1 Instructions for Continued Airworthiness (ICA) ........................................... 273
5.5.4.2 Continued Operational Safety Monitoring (COSM) ..................................... 273
Appendix 1 ‐ Procedures ........................................................................................................ 273
Appendix 2 – Instructions ...................................................................................................... 274
Appendix 3 – Forms & Templates .......................................................................................... 274
0.4 Scope
This handbook is established and maintained by <company name> and includes:
a) The scope of the quality management system, including details of and justification for any
exclusions,
b) The documented procedures established for the quality management system, or reference to
them, and
c) A description of the interaction between the processes of the quality management system.
By doing this:
d) The handbook describes, directly or by cross‐reference, the organization, the relevant
procedures and the products or changes to products to be designed. (EASA.21.A.243(a)),
e) The handbook describes the quality system that ensures that each product and article conforms
to its approved design and is in a condition for safe operation. (21.137),
f) The manual will define the process by which compliance with the minimum requirements called
out in 14 CFR 21, Subpart B and Subpart G, 14 CFR 183, Subpart D, and AS/EN9100 is shown,(Ref
183.53(c)(2)), and
g) The handbook will be amended as necessary to remain an up‐to‐date description of the
organization, and copies of amendments shall be supplied to the Agency. (EASA.21.A.243(c))
0.4.1 Documenting Compliance
The manual defines the process by which compliance with the appropriate airworthiness
regulations applicable to the products listed in the Scope of Work is documented.
(183.53(c)(2))
0.4.2 Determining Compliance
The manual will define the process by which compliance with the appropriate airworthiness
regulations applicable to the products listed in the Scope of Work is assured. (183.53(c)(2))
0.4.3 Production to Approved Design
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Appendix F
The manual will define the process by which production aircraft will be produced and shown to
conform to the approved type design and issued a standard airworthiness certificate in
accordance with the requirements of 14 CFR 21, Subpart F or G, and 14 CFR 183 Subpart D, as
appropriate. (183.53(c)(2))
0.4.4 Maintenance of Type Design and Compliance Documentation
Within this manual processes are defined by which all of the documentation required for
determination of compliance is maintained, submitted, and stored in accordance with the
requirements of 14 CFR 21.123 and/or 14 CFR 21.137, and 14 CFR 183, Subpart D, as
appropriate. (21.123, 21.137, 183.61
0.4.5 Identification and Correction of Process Deviations
Within this manual processes are defined by which all deviations from any of the processes are
identified and corrected. (21.137, 183.53(c)(2))
0.4.6 Customer Support
Within this manual processes are defined for obtaining feedback from the customers and
resolving service issues. (183.53(c)(2))
0.4.7 Normative Reference
Part 21 Subparts B, D, E, F, G, and H, Part 183, Subpart D, and AS/EN 9100.
Note: enhance with revision numbers / issue references. When the revision number differs
from paragraph to paragraph, list the highest applicable revision number / issue reference.
With this the revision level is intrinsically identified for all paragraphs.
0.5 List of Abbreviations
All abbreviations used in this manual will be listed and defined in the following table along with
the source from which they were obtained.
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Appendix F
0.6 Definitions and Terms
21.1(b)
All items used in this manual that are not a part of ordinary everyday use will be listed and
defined in the following table along with the source from which they were obtained.
(Note: The items shown above are typical items and may or may not be applicable to your
requirements. The applicant making use of the standard manual should add or remove
items to fit your needs.)
0.7 List of Referenced Documents
All documents referenced in this manual will be listed below in one of the appropriate sections.
The documents will be in alphabetical order in each section.
Regulations
a) 14 CFR 21, Certification Procedures for Products and Parts
14 CFR 183, Subpart D, Organization Designation Authorization TBD
Procedures
(Reference is either to a separate document, or to the applicably entry in the applicable
Appendix.)
a) TBD
b) TBD
Instructions
(Reference is either to a separate document, or to the applicably entry in the applicable
Appendix.)
a) TBD
~ 248 ~
Appendix F
b) TBD
Forms and Templates
(Reference is either to a separate document, or to the applicably entry in the applicable
Appendix.)
a) TBD
b) TBD
1.2.1. General
(21.137(a)(b)(k), 183.53(b) and 183.53(c)(10).)
The (Company Name) requirements for managing all documents and records required for the
functions for which it has been approved are defined in this section.
a) Design Data Documents 21.137(a)
b) Quality Documents
c) Quality Records
d) Company (organizational) records.
~ 249 ~
Appendix F
a) Be identified with a unique name, number or alpha/numeric combination
b) Have a revision number or letter to identify the specific version, and
c) Have a means to identify the affectivity with each revision. In some cases this may be by
serial affectivity but in most cases it will be by means of an Engineering Change Record
(ECR) or other means that allows the serial to be changed without having to revise the
drawing or document. That process must be identified here.
d) Identify the persons who authored and checked the document either on the front page
or in a prominent and consistent place within the document. The names must be
identified along with their role in the organization. Author and Checker must be two
different persons. Further Approval identifications may be added as reasonable or
required by company policy.
This will require that:
a) The original document(s) will be stored in a controlled file with access limited to only
those persons authorized to have access to it or check it out for the purpose of revising
it. ,
Therefore, all documents will:
a. Require the person desiring to create or make a change to an original to record
their name and the project identification or ECR to which it is associated prior to
being given authority to create an original document or access to the original for
the purpose of changing it,
b. Be approved by the Engineer(s) responsible for the type design and the Project
Engineer prior to release,
c. Be formally released with the release date linked to the document revision and
the document locked from further changes after the release without creating the
next revision,
d. Have access to the original document or electronic file controlled to prevent
unauthorized changes or damage to the document or electronic file
b) Copies are made available to those organizations responsible for producing test articles,
or production parts or articles,
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Appendix F
c) Copies are made available to those organizations responsible for inspecting the test
articles or production parts or articles, and copies are made available to engineering for
approving as part of a production document approval or a test article document
approval.
a) Identified on a list made available to the appropriate organizations as needed through
publication of the document release information. This information will be published
daily and will identify the type of document, the document identification, the revision,
and the affectivity.
(Note: Each company must insert the means by which the release information is published
and/or distributed. It may be published electronically with notification being automatically
pushed out as soon as it is released or it may be left up to each organization to query the
release file to determine if any new documents have been released that may affect them.
Or the release information may be published on paper or other means but the means and
frequency must be identified.)
b) Made available to the appropriate organizations.
(Note: Each company must identify how the documents are made available. Electronic
documents may be “pulled“ as needed by the using organization or they may be “pushed”
to persons or organizations. For paper documents there may be a distribution list created
that identifies which organizations need to be provided the different types of documents
and the quantity.)
a) For paper or other documents in a physical form stored in a manner that will protect the
documents from environmental effects such a fire, water, sun, or other degradation that
might render them unusable,
b) For electronic documents they shall be stored on at least two independent servers that
are not located at the same facility or location such that destruction of one facility due
to acts of nature, fire, or access by unauthorized users cannot result in the loss or
corruption of the data. It must also identify the frequency of the backup.
c) Be retained for the time shown in the table below:
(Add additional documents and their retention period as required.)
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Document Retention Period
Products and articles manufactured under the 5 years
approval
Critical components identified under 14 CFR 45.15(c) 10 years
Type design (drawings and specifications) Permanent
Compliance showing documentation (Reports, etc.) Permanent
record of each periodic audit and any corrective 5 years
actions resulting from them
record of any reported service difficulties associated 5 years
with approvals or certificates issued
application and data required to be submitted to 2 years
obtain the certificate or approval
data and records documenting the approval or 2 years
determination of compliance
All in all we have three layers that must be covered:
1) All documents, regardless what type, must be identifiable, must have revision numbers
or letters as required by company directive and must have information on model and
serial effectivity.
2) All types of documents at the relevant revision must be made available in a controlled
way for actual use. This includes distribution as per distribution lists, retrieval of not
actual data, marking of wild data as ”uncontrolled“.
3) Controlled handover between design and production, so that production has no chance
to build to not actual and approved design data. This includes production initiation with
proper reference to the Type Design revision level for traceability.
This we must spread correctly to the headlines in this section 1.2, having no gap and no
overlap. Requires more detail wording to provide guidance.
Approval may be granted providing a hand written signature on the original printout of a
document or an electronic approval as agreed to by the regulator. Abbreviated signatures /
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short signs may be used when they are uniquely identifiable. Any approval may only be given
along with noting the date of approval. For the generation of small data volume pdf
documentation it is acceptable to use typed short signs along with the approval date, given the
original paper exists and is archived following the procedures of this handbook.
Approval may be granted remotely by unmistakably expressing the approval in a documented
way, provided the means allows to clearly reference the approval back to be provided by the
originator and the time of approval. In this sense, submission of email approvals to the person
responsible for document control, with unmistakable reference to the document identifier and
version, and stored along with the document is acceptable. In a similar way, database
supported approvals are acceptable. When granting remote approvals, the person responsible
for document control completes the formal signature table, with reference to this electronic
approval.
This way of accepting remote approvals represents the way EASA is handling this in first test
cases. The basis for this process is that the procedure must clearly identify how the remote
approval may be given, and how the evidence has to be stored. There is a significant
difference in the required level of originator authentication compared to banking
applications, for example. The system does not need to try to prevent criminal activity in
falsification of approvals. The system must be only such that mistakes by simple error or
simple negligence are avoided.
Changes to this handbook are classified as editorial or non‐editorial.
Editorial changes are all those changes that do not affect the Quality Management System as
such, the availability or qualification of required staff, or the scope of work. These changes do
not need to be coordinated with the Agency.
All other changes are considered non‐editorial. Non‐editorial changes require communication
and approval through the Agency. Application for approval shall be requested in a form and
manner acceptable to the Agency.
Procedures will be established to:
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a) Identify the appropriate guidance material necessary to support the certification and
production activities,
b) Describe the procedure to obtain the correct, applicable, and current requirements
from the official sources,
c) Ensure a change to any of the guidance material is not overlooked, and
d) Ensure the material will be readily available in a timely manner to all who have need of
the information when it is needed.
1.4. Records
(1) Any records generated and maintained while holding a previous Authority delegation
under subpart J or M of part 21, or SFAR 36 of this Subpart D of Part 183.
(2) For any approval or certificate issued (except those airworthiness certificates and
approvals not issued in support of type design approval projects):
(i) The application and data required to be submitted to obtain the certificate or
approval; and
(ii) The data and records documenting the approval or determination of
compliance.
(3) A list of the products, components, parts, or appliances for which a certificate or
approval has been issued.
(4) The names, responsibilities, qualifications and example signature of each nominated
staff.
(5) A copy of each manual approved or accepted, including all historical changes.
(6) Training records for nominated staff.
(7) Any other records specified in this Handbook.
(8) This handbook including all changes.
(9) A record of each periodic audit and any corrective actions resulting from them; and
(10) A record of any reported service difficulties associated with approvals or certificates
issued.
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For airworthiness certificates and approvals not issued in support of a type design approval
project:
(11) The application and data required to be submitted to obtain the certificate or
approval; and
(12) The data and records documenting the approval or determination of compliance.
For all above records:
(1) Records and data are made available to the Administrator for inspection at any time;
(2) Records and data are submitted to the Administrator upon surrender or termination
of the authorization.
(3) Any report required by the Administrator to exercise his supervision of the
organization is compiled and submitted.
(4) Records shall be maintained for unlimited time, unless defined different in Section
1.2.2.4c of this manual.
2. MANAGEMENT COMMITMENT
The requirements of this manual are binding on all employees and (Company Name)
management is committed to supporting those requirements. Management will follow the
requirements of this manual when giving directions and the employees must object when they
receive a conflicting order.
(Company Name) management is committed to supporting the needs and welfare of the
customer with respect to the products and articles offered to the customer.
Note: refer to ICAO Safety Management Manual – would it make sense to carefully
implement a Safety Management Focus here? ICAO SMM Section 7 describes nicely the
difference between QMS and SMS and how they complement. This is an addition in scope,
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but adding this scope proactively allows control of the extent it gets included, such that we
gain benefit and do not create undue burden.
2.4. Planning
Planning is a key factor in being able to meet the quality standards (Company Name) is
committed to. Procedures will be established to ensure that projects are planned and executed
in an orderly and controlled manner to produce quality products and articles. Planning is
required by management for product realization, details see Section 4.1, but also for Quality
Objectives and for the Quality Management System as such.
2.6.1. Responsibility
An Accountable Executive of (Company Name) will be responsible for ensuring compliance with
the requirements in this manual and making the required certifying statements to the Agency
on behalf of the company.
Here we must clearly define the minimum of „roles“ that must be allocated. This is more
than the Accountable Executive, at least includes the independent Quality Management
Representative and may be enhanced in complex companies, but the bare minimum and
their responsibility and authority must be made clear, as this is one section where the
complexity can be easily overdone. Reference AC 21‐51, Applicant’s Showing of
Compliance and Certifying Statement of Compliance for guidance on what needs to be
addressed in this section.
2.6.2. Authority
The names of those to whom an authority is granted will be defined in Appendix ?? of this
manual.
Here we must clearly define the minimum of „roles“ that must be allocated. This may be
enhanced in complex companies, but the bare minimum and their responsibility and
authority must be made clear. Attention must be paid to what is included in this section as
this is one section where the complexity can be overdone. A proper means to clarify
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Authorities is to have a signature matrix that identifies, which role is approved to sign off
which documents / work results on what level and that may be sufficient. .
The (Company name) holds Type Certificate(s) __________ (or Supplemental Type
Certificate(s) ________________) (or Rights to the benefits of TC ____ (or STC _____) under
the following licensing agreement in accordance with the requirements of 14 CFR 21.132.
Same with ongoing developments to be listed.
2.6.3.2. Delegations/Privileges
(183.53(c)(1))
Note: This is US specific wording. Either find internationally applicable wording that is also
OK for US use when the way of delegation is comparable, or provide selectable contents per
CAA.
This is a very important part to be predefined now and here for this draft. This has major
trigger on effort / time / cost of designing, certifying, building aircraft and keeping them
airworthy
The Administrator may delegate any function determined appropriate under 49 U.S.C.
44702(d). The functions delegated to (Company Name) will be based on the organization‘s
qualifications and will be identified in the procedures. (Company Name) will perform only
those functions so delegated.
The limitations will consist of those items that are inherently retained by the Agency and any
other limitations that the Agency deems appropriate based on the qualifications of (Company
Name) personnel and the ability of the procedures to ensure compliance with the
requirements.
Following are the functions granted to (Company Name):
a) ??????
b) ?????
c) ?????
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Match to the finally required functions, documents and signature needs within the company
Make sure to cover development, production and CA contacts. Make clear who is the focal point for
any information flow and specify time constraints when needed.
Predefined milestones where communication with the Agency is mandatory should be summarized
here in a kind of overview, providing transparency. This is another critical item where effort and cost
can be affected by avoiding unnecessary communication, hence waiting times for Agency responses.
Strongly linked to Delegations / Privileges.
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3. RESOURCE MANAGEMENT
(183.51, 183.53(c))
The management of (Company Name) will provide adequate staff to ensure that the capability
authorized by the (Authority) is properly supported. (Company Name) will notify the (Authority) when
the staffing in numbers and / or qualification goes below the minimum agreed staffing and understands
that when that occurs it may result in the loss of those privileges affected by that staffing reduction.
(Note: wording to allow international use and AS9100 use)
3.2.1. General
(Company Name) understands its responsibility to have and maintain sufficient resources and staff to
perform the functions for which it is authorized and will establish procedures to ensure satisfying that
requirement. (183.47(a), 183.51)
3.2.2.1. Competence
Procedures will be established to ensure the persons nominated to positions have the necessary
competence to perform the activities required of the position.
Here we must define adequate qualifications for the minimum roles defined in 2.5.1. It was one of
the cost drivers identified in the beginning of the ARC that the hurdles to fill a function is often set
too high or inadequate. So this is a trigger that must be defined now.
Either spec out the key procedures here, or have a separate procedure and reference from here.
Recommended to spec out the principles here, and if an applicant has a more complex system, he
can replace with his specific and more detailed separate procedure.
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3.2.2.2. Training
Training appropriate for the job will be made available to the persons performing authorized functions.
This training will include any (Authority) required training plus training available from the company or
third parties necessary to ensure the persons are kept current with the regulations, guidance, and
policies of the (Authority).
Here we must define adequate training for the minimum roles defined in 2.5. It was one of the cost
drivers identified in the beginning of the ARC that the hurdles to fill a function is often set too high
or inadequate. So this is a trigger that must be defined now.
Either spec out the key procedures here, or have a separate procedure and reference from here.
Recommended to spec out the principles here, and if an applicant has a more complex system, he
can replace with his specific and more detailed separate procedure.
3.2.2.3. Awareness
Procedures will be established to ensure the employees are aware of the consequences of their actions
and the importance of reporting any incidents to the appropriate management without fear of reprisal.
Define who may nominate to what role, and how the nomination is documented.
This must cover Development staff as well as Certifying Staff in production.
Nomination is possible for internal and for external staff. In the case of external staff, additional
contract work between company and external staff is required (work share agreement or similar),
spec out, how this shall be done.
Either spec out the key procedures here, or have a separate procedure and reference from here.
Recommended to spec out the principles here, and if an applicant has a more complex system, he
can replace with his specific and more detailed separate procedure.
3.3. Infrastructure
(183.51, 183.53(c))
(Company Name) will provide adequate facilities and infrastructure to ensure that the activities
authorized by the (Authority) can be performed. The infrastructure description will be included in this
manual and will provide the company the flexibility to arrange work in an efficient and productive
manner.
This was also one of the cost drivers. It must be given more guidance here to what detail level it
must be defined at all, otherwise we do not gain the desired effect here.
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This is broader than what is shown and also affects the true environment, so health, safety at work,
cleanliness and waste, working methods, working climate (environmental), resources etc. Without
this we fall short of AS/EN9100.This section might be broken into appropriate sub‐sections to
address the other items mentioned in this note.
4. PRODUCT REALIZATION
(21.137(e)(f), 183.53(c). 8100.15(8‐6))
(Company Name) will develop planning procedures to ensure that certification and other related
activities can be conducted in an efficient and timely manner by both the company and the (Authority).
There are two aspects of risk management that should be addressed. There is the risk to
successfully completing the overall project and the individual safety related risks of any tests, not
just flight tests. Each needs to be addressed early and a mitigation plan developed. Normally the
project risks and mitigation should be addressed in the certification plan and the safety risks and
mitigation should be addressed in the test plans.
This has also cost effect, especially when it comes to supplier auditing. In several cases this does not
work and is not possible / supportable by suppliers, therefore a proper guideline is required, here, to
keep cost affordable. Includes, what the company may audit on their own, and when Agency
involvement is required.
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Either spec out the key procedures here, or have a separate procedure and reference from here.
Recommended to spec out the principles here, and if an applicant has a more complex system, he
can replace with his specific and more detailed separate procedure or reference it here.
(21.137(e)(f)(h))
Configuration Management System is installed to ensure that the configuration of each produced
product is identifiable and traceable. The Configuration Management Process affects design and design
change by making the configuration of the product always properly identifiable, leads to production by
ensuring that the configuration of every produced product is managed, documented and controlled
throughout the production process, and leads to Continued Operational Safety Management by holding
all essential configuration information available for delivered aircraft or products.
Note: When implemented to the full extent, this is considered as Product Lifecycle Management.
The configuration of the approved design must always be identified with proper correlation to the date
of validity.
When an individual aircraft or product production is formally initiated, the specific order must be linked
to the design data configuration revision.
Two methods are possible: 1. PO section does always have current data on file, means a ”document
control“ entity must ensure to issue and retrieve production data from the production floor, along
with exactly controlling the S/N effectivity of a change. Sometimes tricky but normal in bigger
companies. 2. PO section does not have drawings continuously on the shop floor and the complete
set of valid production drawings is issued in a big folder to production together with the relevant AC
specification. This set is to be returned with the production documentation when AC finished.
Returned drawings get sent out with next order as long as they are not changed. This allows very
efficient control of S/N effectivity of changes but requires more paper handling.
Configuration management will track all changes, both intended and unintended, that occur to a part or
article to ensure:
a) All unintended changes (non‐conformities) have been properly dispositioned using the non‐
conformity disposition process defined in (ref),
b) The article or part is in a configuration acceptable for intended certification testing,
c) The article or part configuration is known at any point in time and may be used for future
substantiation that might not be known at the time the configuration was established, and
d) The article or part is representative of the configuration approved for production.
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Appendix F
Make sure this links properly to the non‐conformity and concession process, covering intended and
unintended changes.
With the full configuration management installed and active, product conformity may also be verified
and declared on the basis of the documentation in the configuration management system, as alternative
to a specific conformity inspection that can add significant time to conformity process.
Continued Airworthiness, including the related communication with the customer, is defined in Section
5.5.4.
This is where a Certification Program must be set up and communicated with the Agency. As this is a
wide open topic that highly triggers efforts, this should be specified closely here, along with
meaningful templates.
Sharing the information is not the scope of this section; here the scope is only how to plan the
activity, and in what form to have the information available.
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Scope of this section is to define the outcomes, what must it contain, how documented, what is part
of Type Design, how is it structured and come all together, ….has a strong link to Configuration
Management and to Production Release of new (changed) design data. Sharing the information is
not the scope of this section; this is covered in 1.2.2 Document Control.
Procedures will be established to perform validation and verification of the design through analysis,
review of the design, or testing as required.
This includes independent review to be applied during generation and verification on any design
documentation. At least this bit must be predefined.
4.4.6.1. Testing
Procedures will be developed to define the process to be used when conducting verification and
validation tests.
This section must include risk assessment and mitigation for all tests, how the test setup and
conduct must be specified, verified (independent checking, and by which qualification), conducted
and documented. Very close link to configuration management. Includes not only configuration of
the part but also of the setup, things like scales calibration, weight items calibration etc. Should be
predefined here and now as this is the basis to be able to make tests without Authority
participation.
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In case of tests, documentation must include all proof of calibration and configuration.
In case of analysis, the method applied, and the program used, including revision information. Input,
output and program configuration parameters, as applicable, must be documented.
Procedures will be developed to ensure that changes that occur as a result of analysis, review, or testing
are incorporated into the approved production design.
Procedures will be defined for how compliance will be demonstrated and found, and the responsibility
for each.
Link to the proper templates and definition who is allowed to do which finding.
Complete
a) A process is in place to identify suitable suppliers. This may include supplier auditing or proof by
qualification (AS/EN9100 or similar) of the supplier,
b) A list of acceptable suppliers selected on the basis of a risk management assessment, including
definition for surveillance (Audit need / trigger for Audit / Audit schedule) per each supplier.
c) For all active suppliers, supply agreements must be in place that specify the way of interaction
between supplier and company name), as far as it affects the fulfillment of duties of (company
name) as per this Handbook. In accordance with 14 CFR 21.137(c)(2), each supplier will report to
the production approval holder if a product or article has been released from the supplier and
subsequently found not to conform to its approved design.
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Appendix F
d) A process is in place to conduct a regular review of suppliers to determine their continued
acceptability, and
e) A process is defined for action that must be taken when a supplier is not meeting its
requirements.
Supplier Audit as such is dealt with in Section 5
Define purchasing process
The (Company Name) Quality Assurance department will ensure that all products or articles received
from a supplier comply with the approved design data of the product or article as specified on the
Purchase Order in accordance with the requirements of 14 CFR 21.137(c)(1). The results of the
inspection will be documented on the appropriate Quality Assurance Forms.
This must be specified in much more detail:
- There can be a huge difference between a yard supplier and an AS9100 approved supplier in
level of effort you must put into this.
- Provide definitions for a classification of components by criticality. Dependent from
criticality, verification effort is scaled.
This manual will satisfy the requirements of 14 CFR 21, Subpart G, for Production Certificate holders and
the applicability requirements listed in 14 CFR 21.131.
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Appendix F
Refer to AS/EN9100 for a complete list of details. This section will structure into further subsections
that cover the different production aspects and processes.
Procedures will be established to define how service operations will be controlled.
Procedures will be established to define how post‐delivery support will be provided.
Section requires completion. Give special focus towards differentiation between repair and
alteration. Often, when doing a repair on an older aircraft, improvements that have been
implemented to later production serial on can be implemented to the older aircraft as part of the
repair. Reasonable procedures must be defined that allow for this consideration, avoiding the need
for a separate treatment of the same work step (in the customer workshop() as repair and change,
in parallel.
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Appendix F
4.6.2.1. Repairs
Section to include provision of instructions for Repair. Includes classification of repairs, link to design
process, submission to customer.
4.6.2.2. Alteration
Section to include provision of instructions for Alteration. Includes classification of alterations, link to
design process, delivery to customer.
4.6.2.3. Maintenance
Section to include provision of instructions for Maintenance.
Allow for maintenance / repair on products that have shown compliance, but are still under control
of the production organization, as within the former manufacturer’s maintenance facility. While the
product is still in production control, the company shall be able to do maintenance, alterations and
repairs under the existing production organization processes. This allows to cover for damage on the
production line, during storage or in shipping. The part is taken back to the production line by
invalidating the conformity tag, then repaired and conformity maintained under the PO like with
any other part that has not yet achieved a conformity tag in normal production, without having to
have a Part 145 approval.
A procedure will be defined by which all parts will be identified and traced as appropriate for their
criticality to satisfy the requirements of 14 CFR 21.137(n).
On the basis of the identified criticality, requirements for product marking are applicable. 14 CFR
45,Subpart B.
Spell this out more what this exactly means. The basis for the component classification must be
given here. Identifying the significance of a component and applying relaxation to traceability
requirements for non‐critical parts is an uncommon approach to some and is a means to
significantly reduce administrative burden, hence cost.
This section must also include how the requirements for product and component markings shall be
satisfied. This affects the need for marking of manufacturer, product, part number and serial or lot
number. Make clear that marking of the part revision number may be omitted when the numbering
system is defined in a way that requires a new part number as soon as either form, fit or function of
the part are affected.
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Appendix F
This normally a requirement in a repair or alteration operation but for small manufacturers, a
customer may provide a specific piece of equipment that he wants installed and there needs to be a
process to manage this.
Define here what is reasonable for the standard cases, to avoid over and undershoot.
5.1. General
Procedures will be defined to measure customer satisfaction and to address and/or provide responses
to each issue identified in accordance with the requirements of 14 CFR 21.137(m). The procedures will:
a) Address any in‐service problem involving design changes, and;
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Appendix F
b) Determine if any changes to the instructions for Continued Airworthiness are necessary.
5.2.2. Audits
(21.137(l), 183.53(c))
(Company Name) will conduct internal and supplier audits to ensure compliance with the requirements
of 14 CFR 21.137(l) and 183.53(c)(5) & (6) for the production process and for the certification process(s)
as defined in this manual. The audit procedures :
a) Will ensure the audit is completely independent and free from influence by management,
b) Will ensure that no person will audit their own work,
c) Require the organization being audited to cooperate with the auditor to ensure freedom of
access to any and all documents necessary to support the audit,
d) Requires identification of any non‐ compliance with the requirements of this manual,
e) Requires determination of root cause and corrective action and preventive actions for each non‐
compliance,
f) Requires reporting of all non‐compliances to the manager responsible for implementing the
appropriate action,
g) Requires establishing a closure date for all audit findings, and
h) Requires reporting of any aircraft safety issues to the Agency
i) Requires review of audit results and identification of any trends or issues that identify changes
that can be made to improve the processes by which the products are designed, certified, or
built.
Make sure this also covers Design Subcontractors.
To satisfy the requirements of 14 CFR 21.137(d) and 183.59, manufacturing processes and procedures
will be defined and controlled to ensure that each product and article manufactured using the defined
process conforms to its approved design.
Enhance with same sense to be applicable for Design processes.
Inspections and tests will be conducted to ensure that each product and article conforms to its approved
design. These procedures will include a flight test of each aircraft produced unless that aircraft will be
exported as an unassembled aircraft.
(For engines or propellers replace the last sentence with “These procedures will include a functional test
of each aircraft engine (or propeller) produced.“)
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Appendix F
Procedures will be established for the documenting and test status of products and articles supplied or
manufactured to the approved design in accordance with the requirements of 14 CFR 21.137(g).
The measurement requirements for product acceptance are documented by checklists and protocols.
The checklists and protocols provide:
a) criteria for acceptance and/or rejection;
b) the sequence of measurement and testing operations that have to be performed;
c) the required records of the measurement results;
d) information on specific measurement instruments required and any specific instructions
associated with their use.
Procedures will be established in accordance with 14 CFR 21.137(h) to:
a) Ensure that only products or articles that conform to their approved design are installed on a
type‐certificated product. These procedures will provide the identification, documentation,
evaluation, segregation, and disposition of nonconforming products and articles. Cases are
defined where it may be acceptable to use a initially non‐conforming component, by doing a
design evaluation / qualification / verification, providing design approval for that specific case
and granting a concession. In this case the initially nonconforming product or article must be
found conforming with the definitions provided with the concession.
b) Ensure that only authorized individuals may make disposition determinations.
c) Ensure that discarded articles are rendered unusable.
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Appendix F
Maintenance or repair during production must follow approved methods. Approved methods have to be
established in coordination with the design entity responsible for the affected product. Generation and
approval must follow the same procedures as the generation of the design, including approval steps.
Standard maintenance and repair procedures that have clear definitions for their applicability, may be
applied directly by the manufacturer without consultation of the design entity. Those standard
procedures must be approved once and form part of the Type Design.
Maintenance or repair following the completion of the production, while the product stays under
continuous control of the manufacturer and has not yet been issued a Certificate of Airworthiness, may
be conducted by the manufacturer in conformance with the established procedures for maintenance
and repair during production. To do this, the issued Conformity Declaration must be revoked from the
product , and the product gets inserted to the production sequence at the same step as would be when
the need for the same maintenance or repair would appear during the production process.
Subsequently the product has to undergo all required steps to obtain a new Conformity Declaration.
Maintenance on products that have left completely or temporarily the continuous control of the
manufacturer may only be conducted by an adequately authorized maintenance or repair facility (14
CFR Part 145).
Procedures will be established for analyzing the data obtained from production and the customers to
identify issues that may require action and distributing the results to the appropriate department for
action.
5.5. Improvement
(21.137(l))(m), 183.63(a)‐(d))
Procedures will be established to identify issues that may require changes to the product through design
or manufacturing or the operation in order to continually improve the product.
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Appendix F
Procedures will be implemented to identify when corrective actions are required to eliminate the causes
of an actual or potential nonconformity to the approved design or noncompliance with the approved
quality system to satisfy the requirements of 14.CFR 21.137(i).
Procedures will be defined to identify when preventative actions should be taken to eliminate the
occurrence, or re‐occurrence, of a potential production, service, or operation issue.
- which types of ICA are to be provided,
- how they are named,
- what they shall cover,
- how these documents have to be structured. Link to meaningful ICA templates that unify
the appearance of this documentation, for simplified infield understanding and therefore
enhanced safety.
- How they are distributed, distinguish between new delivery, updates, Notifications, …
Critical item: How are Notifications distributed.
- How in‐service feedback is to be obtained
- What the sources for in‐field feedback are
- How to analyze incoming information, risk assessment
- Definition, what is a „unsafe condition“
- Duties to report to Agency
- Way of reaction to (Agency issued) ADs
Appendix 1 ‐ Procedures
Important: The contents of the handbook itself shall provide sufficient process definition for
companies with non‐complex undertakings. For these companies no separate procedures shall be
required and this Appendix is not required. Only for companies with more complex undertakings
addition of separate procedure documents shall be necessary. In this case, the separate procedures
apply the system that is defined by the handbook itself, and extend it to match the individual
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Appendix F
company undertaking complexity. Therefore, separate procedures are not intended to be part of the
standard handbook boilerplates. In any case, focus shall be to require as little separate procedures
as possible.
When applicable, detail procedures may be added here to the handbook, as part of the handbook.
Alternatively they may be treated as separate documents, linked at the beginning of the handbook.
Appendix 2 – Instructions
Detail instructions may be added here to the handbook, as part of the handbook. Alternatively they
may be treated as separate documents, linked at the beginning of the handbook.
Focus shall be to require as little separate instructions as possible. The sections provided in this
standard handbook shall provide enough detail for a small and low complexity entity to have all
required instructions. Only for growing companies with increasing complexity of the undertaking,
enhancing the general instructions from this handbook in separate instructions is considered an
option and may be helpful. Therefore, separate instructions are not intended to be part of the
standard handbook boilerplates.
Forms required for DO functions:
- FAA Form 8100‐13, ODA Statement of Qualifications
- FAA Form 8100‐9 Used For ODA Data Approval
- FAA Form 8100‐11, Statement of Completion
- Conformity Inspection Plan
- Minor / Major Classification Matrix
… to be completed
Templates required for DO functions:
- Change Request
- Certification Program
- Compliance Checklist
- Engineering, Test and Compliance Report
- Service Bulletin
- Audit Report
- Non‐Conformity Report
… to be completed
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Appendix F
Forms required for PO functions:
… to be completed
Templates required for PO functions:
… to be completed
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Appendix G
APPENDIX G – ALTERATIONS / MODIFICATIONS WORKING GROUP PAPERS AND
PROPOSALS
Appendix G.1 – Preventive Maintenance
Preventive Maintenance
Alterations & Maintenance Working Group
This is a report on the subject of Preventive Maintenance from the Alterations & Maintenance Working
Group to the full 14 CFR Part 23 Aviation Rulemaking Committee. It includes a statement of the issue
considered by the Working Group, discussion of the issue and specific recommendations to the FAA
proposed for ratification by the ARC.
Issue
The part 43 provisions on preventive maintenance are outdated, inflexible and confusing, resulting in a
reduction of pilot performance of preventive maintenance below optimal levels.
Discussion
Background
Section 43.3(g) permits certificated pilots (with the exception of sport pilots) to perform specific
preventive maintenance (PM) operations on aircraft that they own or operate under part 91. These PM
operations are limited to those listed in part 43 Appendix A Section (c). Other sections of part 43 permit
the pilot to return the airplane to service following performance of PM and establish record keeping
requirements. In addition to the rules, there are also two Advisory Circulars with content on PM: AC 43‐
9C Maintenance Records and AC 43‐12A Preventive Maintenance.
Preventive maintenance is defined by § 1.1 as follows: "Preventive maintenance means simple or minor
preservation operations and the replacement of small standard parts not involving complex assembly
operations." Section 1.1 further defines maintenance as follows: "Maintenance means inspection,
overhaul, repair, preservation, and the replacement of parts, but excludes preventive maintenance."
Thus, it is clear that preventive maintenance is entirely distinct from “ordinary” maintenance for the
purposes of the regulations.
At present, part 43 does not include “other operations acceptable to the Administrator” in its definition
of preventive maintenance. This language is often included in the regulations in order to grant the FAA
flexibility in dealing with rapidly changing or extraordinary circumstances. Because it is not included
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here and because the list of authorized preventive maintenance operations is contained within the
regulations, it is difficult and time consuming for the FAA to adapt to technological (and other) changes.
With the introduction of sweeping new content in a revised part 23, the FAA will face such a situation of
change. Moreover, the incorporation of new technology on airplanes has already led to difficulties in
this area. Additional advances in technology may be inhibited if the regulatory criteria governing
preventive maintenance are not modernized. The stated objective of the part 23 rewrite is to improve
the safety of small airplanes. A supporting objective is the reduction of the cost of airplane acquisition
and ownership, allowing owners to more easily afford the purchase of safety‐related components and
systems. Thus, changes to part 43 that increase the safe availability of pilot‐performed preventive
maintenance are supportive of the ARC’s goals.1
General Rulemaking Concerns
Any change to rules, guidance or policy holds the potential to have unexpected and undesirable results.
For example, even where the intent is only to clarify compliance requirements, it may be the case that
practices that have historically been judged compliant may be found to be non‐compliant. Conversely,
changes or clarifications that, in the eyes of some, appear to liberalize the rules or the conventional
interpretations of existing rules may meet with strenuous opposition. Accordingly, an extremely
conservative view of revisions is sometimes recommended.
The Alterations & Maintenance Working Group has attempted to strike an appropriate balance between
the risks inherent in change and the potential benefits of the specific changes we considered.
Nevertheless, others may see this balance differently. It is our hope that the discussion that follows will
allow others to consider alternate, and perhaps more valuable, approaches than we have recommended
toward the resolution of these issues.
Regardless of the level of change adopted, the success of these proposals depends also on the cultural
application of those changes. The intent of PM authorization and of the changes must be understood,
respected and exploited in order for the hoped‐for economic benefits to be realized, facilitating
operator investment in safety‐related improvements to the affected airplanes.
Content and Location of the Basic List of Authorized PM Operations
As mentioned above, the current list of authorized preventive maintenance items is in part 43
Appendix A. The fact that this list is in the regulations contributes to the difficulty in revising it – the full
rulemaking procedure must be followed.
1 It is reasonable to question whether or not Part 43 rules and guidance fall within the purview of the
Part 23 ARC. The rulemaking process includes the concept of “coordinated rule changes”, wherein
changes to one Part require or suggest changes to another Part. To ensure consistency, these changes
are made in a single rulemaking activity. Thus, from a procedural standpoint, recommendations that
fall outside of Part 23 would seem to be in order. Indeed, it seems likely that recommendations for
changes to Parts 1 and 21, and perhaps others, are likely to arise out of the deliberations of the ARC.
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In order to grant the FAA additional flexibility in maintaining this list, the Working Group considered
recommending that the list be moved from part 43 into a guidance document (likely a new revision of
AC 43‐12). Doing so would not only simplify and speed up the change process but would also make it
possible to maintain the list items and robust descriptions of their intent in a single document.
Concerns were raised that removal of the list from the regulations would inevitably weaken the
“promise” of availability of these items to the pilot. It is the nature of guidance documents that their
content is not absolute, where regulations are.
After considering both sides of the issue, the Working Group decided that the guaranteed availability of
these operations outweighed the advantages of flexibility offered by moving the list into guidance.
Additional operations can potentially be introduced in guidance and, as warranted, moved into the
regulations after a trial period.
The majority of the items in the list appear at first reading to be simple and easily understood. Upon
close examination, however, there are many issues of interpretation that might arise in the application
of the rules. Most of these issues arise as a result of the use of seemingly simple terms that, being
undefined in the regulations, might reasonably be interpreted differently by different readers. A
selection of these issues include:
Part 43 Appendix A identifies preventive maintenance as being the listed items “provided it does
not involve complex assembly operations.” There is no definition of what constitutes complex
assembly operations, however, nor does it prohibit performance of items where complexities
other than in assembly may be present. Indeed, AC 43‐12A CHG 1 specifically assigns
responsibility for determining whether an operation is complex to owners and pilots, indicating
that they “must use good judgment when determining if a specific function should be classified
as preventive maintenance.” It provides no examples to illuminate this guidance.
Many of the list items permit removal and replacement of aircraft components (such as wheels
and tires, engine cowls, windows, safety belts, etc.). It seems from context that some of these
anticipate replacement of the removed component with a substitute component (windows, for
example) rather than reinstallation of the removed component itself, but in other cases (engine
cowls) it is unclear. Moreover, when replacement with a substitute component is permitted, it
is unclear whether it must be identical to the original component or whether use of a different,
but compatible, component is authorized. Some might think it reasonable, for example, to
allow replacement of a common tungsten‐filament landing or taxi lamp with a compatible LED
lamp, while others would consider such an operation to be an unauthorized and unacceptable
expansion of PM into the realm of alterations.
Some of the items are identified as “servicing” (such as oleo strut air and oil) and “replenishing”
(such as hydraulic fluid) but there are other similar items (such as engine oil) that are not
addressed in this list or elsewhere in the regulations.
It is the opinion of the Working Group that AC 43‐12() should be revised to include clarification of these
and similar items. We recognize that there is a danger that clarification might result in a narrowing of
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the items as viewed by some, but believe that greater clarity will generally benefit pilots by giving them
a clearer, more reliable understanding of the PM items that they are authorized to perform.
Authorization of Additional PM Operations
At present, the only means by which the list of authorized preventive maintenance operations can be
modified is through rulemaking. There is no allowance for additional authorizations in guidance or by
policy, nor is there any allowance for authorization of type‐ or installation‐specific preventive
maintenance. This poses a substantial impediment to the safe and effective conduct of an increased
variety of PM operations in the field.
We recommend the addition of language to the regulations to permit authorization of operations
beyond those listed in part 43 Appendix A. This language could be added to § 43.3 or to the list itself.2
Once appropriate language is added to part 43, additional PM items can be authorized for general use in
guidance or policy documents. Furthermore, type‐ or installation‐specific items can be accepted based
on manufacturers’ procedures, perhaps in an ICA. We see numerous attractive opportunities for safe
and economical additions to existing PM authorizations by this route, including installation of databases
other than those authorized in part 43 itself and installation of software, where procedural simplicity
and aircraft configuration allow.
We are concerned that some manufacturers might try to limit or eliminate pilot‐performed preventive
maintenance on their products once coverage of PM issues in ICAs becomes common. This is not the
intent of these proposals, obviously enough, and we recommend that the FAA be sensitive to this issue
in developing an acceptance process for relevant ICA content.
Competence to Perform PM
There is not now any requirement for training before a pilot is authorized to perform the operations
listed in part 43 Appendix A and subsequently return an aircraft to service. By way of contrast, certified
mechanics must perform these same items under supervision before they are permitted to return the
aircraft to service. This seems odd, in that it is reasonable to assume that even the least qualified
professional mechanic is more skilled than the average pilot.
Nevertheless, it is the opinion of the Working Group that a regulatory requirement that pilots be trained
in some fashion prior to conducting PM operations should not be added. The Working Group members
are collectively unaware of any data that would suggest that safety issues due to improper conduct of
2 The list of preventive maintenance operations in part 43 Appendix A Section (c) is shared by two
separate regulations: § 43.3(g), which authorizes PM by pilots of aircraft in non-commercial service,
and § 43.3(h), which authorizes certain rotorcraft commercial operators to perform those PM
operations contained in the list while in the field. Thus, the addition of “other operations acceptable to
the administrator” to the list in Appendix A would affect both non-commercial aircraft operators and
some commercial rotorcraft operators, while adding it to § 43.3(g) would affect only the former.
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PM are present in significant numbers under the current rules, so we see no compelling need for
additional regulation.3
We would recommend that the FAA consider the complexity of any operations proposed for
authorization as well as the adequacy of the manufacturer’s instructions and any supplementary
training material prior to acceptance of the proposal. We would note that some such operations might
be deemed acceptable only with a prior demonstration of competence. It is our belief that these
recommendations are fully supported by a regulatory framework authorizing “other operations
acceptable to the Administrator.”
PM Guidance
The FAA has issued two pilot‐directed guidance documents with content pertaining to preventive
maintenance: AC 43‐12() Preventive Maintenance (last modified in 2007) and AC 43‐9() Maintenance
Records (last modified in 1998). While these documents are reasonably good at describing the basic
regulations that authorize the performance of PM operations by pilots and the approval for return to
service, along with the attendant documentation requirements, they do little to address the lack of
clarity in the regulations (and specifically the basic list of authorized PM operations in part 43 Appendix
A). For example, as noted earlier, AC 43‐12A CHG 1 specifically avoids addressing the issue of what
constitutes “complex assembly operations”, stating that “Owners and pilots must use good judgment
when determining if a specific function should be classified as preventive maintenance.”
The Working Group believes that this lack of clarity and the delegation of responsibility to the pilot is
likely to intimidate and to inhibit the performance of PM operations by pilots as intended. We believe
that the AC, rather than merely quoting the regulations and stating all of the conditions that apply to
their use (which we acknowledge to be an important contribution in itself) should strive to clarify both
the basic regulations and (most importantly) the list of authorized PM operations.
As was noted earlier, the provision of clarifications of these operations may serve to expand some
readers’ understanding of the regulations and narrow the understanding of others. Both may prove
problematical in terms of acceptance in the field. Nevertheless, we feel that the advantages that accrue
from increased numbers of pilots taking advantage of these regulations as a result of improved
understanding outweighs any potential disadvantage.
In addition, if our other recommendations are followed, we believe that the AC is an appropriate place
to introduce new universally authorized PM operations without the overhead of rulemaking (perhaps to
be introduced to the rule after a trial period) and to establish that aircraft and equipment manufacturers
may propose PM operations for FAA acceptance as part of their service documents.
3 The Working Group recognizes that this statement is not especially compelling without additional
evidence and is attempting to obtain additional objective data.
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Recommendations
1. Part 43 should be changed to include “other operations acceptable to the Administrator” as
preventive maintenance under § 43.3(g).
2. The basic list of preventive maintenance operations contained in part 43 Appendix A should remain
in the regulations so as to guarantee availability of a well‐defined minimum set of authorized
operations.
3. AC 43‐12() should be revised to:
a. Emphasize the availability of preventive maintenance operations to pilots,
b. Clarify the basic list of authorized PM operations,
c. Establish conditions under which aircraft and equipment manufacturers may propose
additional PM operations and procedures for their safe performance for FAA acceptance, and
d. Encourage manufacturers to propose such operations and procedures.
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Appendix G.2 – STCs and Alterations
This is a report on the subject of STCs and Alterations from the Alterations & Maintenance Working
Group to the full 14 CFR Part 23 Aviation Rulemaking Committee. It includes a statement of the issue
considered by the Working Group, discussion of the issue and specific recommendations to the FAA
proposed for ratification by the ARC.
Issue
After manufacture, airplanes may be altered by means of Supplemental Type Certificates (STCs)
developed under part 21 and by means of major and minor alterations under part 43. With the
introduction of the new part 23, it is essential that these means be maintained for both new and legacy
airplanes in order to insure continuing access to safety improvements as airplanes remain in service.
Discussion
Background
Existing regulations and guidance include substantial descriptions of the processes necessary to gain
approval for alterations made to type certified products after their initial delivery.
Part 21 states that “A ‘minor change’ [to type design] is one that has no appreciable effect on the
weight, balance, structural strength, reliability, operational characteristics, or other characteristics
affecting the airworthiness of the product. All other changes are ‘major changes’... If a person does not
hold the TC for a product and alters that product by introducing a major change in type design that does
not require an application for a new TC under § 21.19, that person must apply to the appropriate
aircraft certification office for an STC.”
In addition to alterations based on STCs, part 43 allows airplanes to be returned to service following
either major or minor alterations. Part 1 defines a major alteration to be “an alteration not listed in the
aircraft, aircraft engine, or propeller specification (1) that might appreciably affect weight, balance,
structural strength, performance, powerplant operation, flight characteristics, or other qualities
affecting airworthiness; or (2) that is not done according to accepted practices or cannot be done by
elementary operations.” Part 43 Appendix A further contains an enumerated list of major alterations.
Alterations that fall outside these two definitions are, by definition, minor.
Irrespective of the path by which an alteration is defined and approved, the airplane must continue to
comply with the applicable rules under which it was certified or, in some cases, newer or added rules
applicable to the specific alteration.
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These provisions are potentially complicated by the adoption of the new part 23, both as they are
applied to newly manufactured airplanes and to legacy airplanes, and the removal of elements of the
current part 23 to one or more Airworthiness Design Standards (ADS) maintained by industry. In
particular, determining whether an alteration developed under the new regulations meets the
compliance requirements applicable to an airplane produced under older regulations (whether legacy
regulations or an earlier amendment of the new part 23), while conceptually simple, is potentially
problematical in practice. The revised regulations, supporting guidance, and resulting changes in
behavior of all involved parties could result in the emergence of unanticipated safety issues or (and, we
believe, more likely) unacceptable impediments to the use of these rules.
Due to the lengthy service life of airplanes (decades, in most cases) and the rapid pace of safety‐related
technological development combined with anticipated changes in equipment needed to meet the needs
of the evolving operational environment, it is imperative that upgrades to in‐service airplanes be
facilitated. At present, a robust industry of STC developers and maintenance facilities services this need.
Competition among vendors ensures both diversity of offerings and, within the usual norms of our
industry, a measure of economy.
As the new part 23 and supporting guidance (both FAA and industry) are developed, sensitivity to the
needs of the aftermarket must be shown to maintain and advance owners’ ability to make safety related
improvements to their airplanes after delivery. These needs include workable establishment of the
boundary between compliance requirements (the regulations) and means of compliance (industry
standards and others), clear and appropriate establishment of the certification basis for the airplane as
manufactured, provision of essential information facilitating alterations in the TCDS and aircraft service
records, and publication of guidance for applicants and FAA personnel on the proper interpretation and
application of it all.
Certification Basis and TCDS for Newly Manufactured Airplanes
The certification basis of an airplane describes the airworthiness regulations and other provisions –
exemptions, equivalent level of safety (ELOS) findings and special conditions – that apply based on the
airplane’s configuration, powerplant, equipment, intended use and other characteristics [Order
8110.4c 2‐3d(4)]. The certification basis is proposed by the TC applicant and finalized in consultation
with the FAA. The applicant also proposes means by which compliance with each of the items in the
certification basis will be shown prior to certification of the airplane. These means of compliance may
include reports, analyses, tests and other procedures. They may be proposed by the applicant directly in
response to the regulations or they may take advantage of specific methods recognized by the FAA,
generally by means of Advisory Circulars (ACs) and sometimes including recognition of industry
standards (e.g., RTCA/DO‐160, DO‐178 and DO‐254).
Because the certification basis is strictly regulatory and is agnostic with regard to the means of
compliance, it follows that it must contain only rules, exemptions, ELOS findings and special conditions.
Thus, under the new part 23, the certification basis cannot (and should not) identify either the industry
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standard(s) employed or particular provisions of the industry standard(s) that are found to be applicable
– any more than we would do so for Advisory Circulars or existing industry standards today.
The type certification data sheet (TCDS) is a publicly available document written by the FAA based on
information provided by the aircraft manufacturer and is identified by § 21.41 as part of the type
certificate. It contains specific information about an aircraft (or multiple aircraft produced under a
common type certificate) including the certification basis and an enumeration of many of the factors
described above as influencing the certification basis. This information is a key input to the
determination of the certification basis for subsequent alterations.
The specific contents and format of the TCDS are listed in FAA Order 8110.4(). The Order states that
“The TCDS is the part of the TC documenting the conditions and limitations necessary to meet the
certification airworthiness requirements of the regulations (14 CFR)” and requires the inclusion of the
following items for each domestic airplane model included on the TC:
1. Engine
2. Fuel
3. Engine limits
4. Propeller and propeller limits
5. Airspeed limits
6. Center of gravity (CG) range
7. Empty weight C.G. range
8. Datum
9. Leveling means
10. Maximum weights
11. Minimum crew
12. Number of seats
13. Maximum compartments weights
14. Fuel capacity
15. Oil capacity
16. Maximum operating altitude
17. Control surface movements
18. Manufacturer’s serial numbers
19. Certification basis
20. Production basis
21. Equipment
22. Notes
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Appendix G
As the certification requirements contained in part 23 are simplified and as aspects are moved into
industry standards, it is important that sufficient information remain in the TCDS to permit STC
applicants and the FAA to clearly and accurately identify the certification basis for the alteration; the list
above may not suffice and the Order may require revision to incorporate additional items. As argued
above, incorporation of specific information on means of compliance (i.e., identification of any industry
standards used in whole or in detail) is not appropriate. Rather, the characteristics of the airplane that
lead to determination of both the certification basis and choices of compliance path within the industry
standards should be required TCDS contents. This is particularly important with regard to airplane
characteristics for which tiered means of compliance are identified in the ADS or other supporting
documents. For example, specification of the airplane’s maximum gross weight and G‐loading limits
(already required elements of the TCDS) lead directly to a variety of structural compliance issues. The
means by which those compliance issues are addressed in the original certification need not be known;
appropriate means within either the original (unknown) standard or some other acceptable standard
can be identified based solely on knowledge of the essential characteristics.
Certification Basis and TCDS Information for Alterations
When airplanes are altered after initial delivery, whether under an STC or not, the same range of
airworthiness concerns may arise as in original certification. Consequently, compliance with the
relevant provisions of the airworthiness regulations must be assured on the altered airplane.
Responsibility for identification and resolution of compliance issues falls largely on the installer, who,
depending on the nature and classification of the alteration, may rely on approved or accepted data
provided by a manufacturer or on standard methods.
Identification of airworthiness compliance issues can become complicated as an airplane ages. It’s rare
for an airplane of any substantial age to maintain its configuration. Components, systems and
equipment are added or replaced in order to deal with failures or obsolescence, adapt to changing
operational requirements and increase the utility of the airplane. As these alterations are made, it is
often the case that there is no single reliable data source regarding the airplane’s configuration and
aggregate certification basis.
As described above, the information provided in the TCDS is an important contributor to the installer’s
ability to identify airworthiness compliance issues that apply to the airplane as originally manufactured.
Comparable information on airplanes that have been altered, however, can be difficult to find.
One potential solution would be the maintenance of an “In‐Service Aircraft Data Sheet” (ISADS) as part
of the airplane’s permanent records. At the time of manufacture, this would be nothing more than a
transcription of the relevant information for the particular model from the TCDS. As the airplane was
subsequently altered, the ISADS would be updated as part of return to service. If this practice was
followed, it could be assured that the information listed above would be consistently available in a
convenient format. (This information, of course, isn’t everything needed to identify potential
airworthiness issues with regard to a proposed alteration, but it’s a start.)
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The regulations (most notably part 43) require that certain specific records be kept of maintenance,
alterations, inspections and other actions affecting the airworthiness of the airplane. Similar records are
required for engines and propellers. Neither the regulations nor any existing FAA guidance mandates
the form or format of these records. Most commonly, these records are maintained in the form of a
logbook, in chronological order. The logbook is sometimes divided into separate sections for
maintenance activities and inspections. In addition, it is sometimes supplemented by additional records,
such as an Airworthiness Directive compliance log, for easier access to information that must be
periodically reviewed.
As proposed above, the ISADS may contain information that is, today, normally kept in the airplane’s
logbooks. This proposal is not intended to create substantial new recordkeeping requirements. Rather,
it is intended to suggest a reorganization of existing information (not all of which is normally kept in the
logs) to allow owners and service facilities to more easily determine the altered configuration of the
airplane. The ISADS can be used as the sole detailed record in this regard, directly in support of
regulatory recordkeeping requirements, with references to its contents from the primary airplane logs
as needed for clarity.
We believe that a regulation mandating the use of such an ISADS would not be supported by either the
FAA or industry due to sensitivity over increases in the paperwork burden associated with return to
service and the absence of persuasive evidence that the current system is inadequate. We do, however,
believe that voluntary use of an ISADS might be achievable given some level of FAA support. This might
take the form of an Advisory Circular, perhaps supported by an industry document, giving the
recommended content and organization of the ISADS and indicating which existing regulations would be
supported by its use as a part of the airplane’s permanent records. A well maintained ISADS would
simplify both preparation for new alterations and the records check portion of the annual condition
inspection.
New Regulations, Industry Standards and Their Application to STCs and Alterations
As the new part 23 is developed, it is anticipated that portions of it will be restructured and that some of
the more detailed requirements will be moved into one or more industry‐maintained standards that
effectively form the top level means of compliance with the regulations. As these regulations, industry
standards and accompanying guidance documents are developed, it is important that their structure
and content continue to effectively support the development of STCs and the alteration of individual
airplanes.
The current part 23 is divided into seven subparts that deal with different subject matter (General;
Flight; Structure; Design and Construction; Powerplant; Equipment; and Operating Limitations and
Information). Each subpart is, in turn, divided into sections that address divisions of the subject matter
of the subpart. For example, Subpart E, Powerplant, is divided into sections titled General, Fuel System,
Fuel System Components, Oil System, Cooling, Liquid Cooling, Induction System, Exhaust System,
Powerplant Controls and Accessories, and Powerplant Fire Protection. The regulations, then, are
organized under these sections.
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The individual regulations tend to have well defined topics, to have well defined scope and stay within it,
and to be free of interdependencies and cross references. As the new regulations are developed, it is
important that these properties are preserved. The exact organization of the regulations need not
necessarily be preserved, but it is essential that the individual regulations be focused and self‐contained.
Moreover, the industry standards and other guidance documents (both FAA and industry) underlying
the regulations should also have these properties plus one more: The individual provisions of each
document must be traceable to the regulations they support. Poorly constructed documents could
easily result in an inability on the part of both applicants and the FAA to determine what minimum
combination of activities constitute an acceptable means of compliance for a specific regulation. This
situation must be avoided at all costs.
Applicants must be allowed to exercise freedom in choosing from among recognized ADS. In addition, if
multiple ADS are recognized as means of compliance with particular regulations, the applicant must be
permitted to choose from among them without regard to the ADS chosen for other regulations. Use of
one ADS in a project must not obligate the applicant to use that ADS in any other aspect of the project.
Of course, the applicant’s proposed certification basis and means of compliance are subject to FAA
review and concurrence as part of the certification planning process. These recommendations are not
intended to interfere with that process of joint agreement, but are intended to identify guidelines
applicable to such an agreement.
AML STCs
The use of Approved Model List (AML) STCs as described in AC 23‐22 is
crucial to the efficiency of alterations in the aftermarket. This is
especially true for avionics systems, where support of many airplane
types by a single system is normal and the potential for safety
improvement is high.
Because the airplanes listed in an AML will inevitably have differing
certification bases, the common practice is to develop the STC to the
latest amendment of the regulations (or, depending on the classification
of the change under § 21.101, to the latest amendment appearing in the
certification bases of the listed airplanes) and to the most stringent requirements applicable to the listed
airplanes.
This practice must still be applicable under the new part 23. Any choice of certification basis currently
allowed under § 21.101 must continue to be supported, from retention of the original certification basis
of the airplane to adoption of a later amendment to the regulations, depending on the specific nature of
the proposed alteration and the applicant’s preferences.
In particular, compliance with the new part 23 (if elected by the applicant), irrespective of the chosen
means of compliance, must be regarded as sufficient with regard to airplanes originally certified under
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(1) an earlier amendment of the new part 23, (2) the old part 23, (3) CAR 3 or (4) any predecessor
regulation or standard applicable to airplanes that would currently fall under part 23. If a regulation
included in a previous amendment of part 23 or any predecessor regulation has been eliminated from
part 23 (presumably because it has been moved into an ADS), compliance with that regulation cannot be
required in subsequent projects.
In addition, tiering should be accomplished wherever possible in both the regulations and the underlying
industry standards in such a way as to allow compliance in a higher tier to also fulfill compliance
requirements in all lower tiers with respect to the same regulation.
Tiers may be defined in several ways: by means of quantitative parameters (for example, maximum
gross weight or stall speed in the landing configuration), by means of qualitative parameters (such as
VFR/IFR/day/night operation or primary structure material) and by surrogate parameters (such as
number or type of engines as a surrogate for complexity or mission capability). In the case of
quantitative parameters, “cumulative compliance” is relatively automatic. In the case of some
qualitative parameters, it may be easily achieved (for example, IFR equipment requirements include and
augment VFR equipment requirements) but in the case of others it may be nearly impossible (for
example, specific hazards relating to potential delamination of composite materials may have no analog
in metal construction, while fatigue considerations may apply only to metal and not to composites). In
the case of surrogate parameters, cumulative compliance should be possible when measured against
the parameter for which the surrogate is standing in.
Beyond accommodations of the new part 23, modest changes to existing AML practices would add
flexibility and reduce cost. At present, AC 23‐22 states that “The AML STC process should not be applied
to those systems whose installation configuration varies significantly among various serial number
aircraft of the same model, or those systems that can directly control the aircraft. For example, an AML
STC would not be suitable for autopilot installations [where] there may be serial number specific
airplane‐rigging problems... Another example would be a Reduced Vertical Separation Minimum (RVSM)
STC approval.” Inasmuch as there is already plenty of content in the AC directed at the identification
and resolution of variability in installation considerations, these exceptions do not seem to be justified.
Their removal (and the elimination of the attendant uncertainty associated with the general caution
beyond the specific examples) would result in greater efficiency in these programs without substantial
additional risk.
Field Approvals
At present, there are many cases where concerns about the categorization of proposed alterations
result in minor alterations being treated as major and major alterations being made under STCs. As the
new part 23 is introduced, the conservatism currently found in the system could very well increase,
negating the hoped‐for increases in efficiency. If efficiency is to be improved, a combination of updated
guidance and targeted training for both FAA and industry personnel will be required. In addition, close
coordination between Flight Standards, the ACOs and SAD will be required to facilitate minimum‐cost
resolution paths for common introduction problems.
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Alternate Means of Compliance
As previously noted, the industry‐developed Airworthiness Design Standards (ADS) are expected to
constitute top‐level means of compliance with the new part 23. As with any recognized means of
compliance, the use of alternates, including direct compliance with the rules, has to be permitted. As is
now the case, alternate means of compliance must be permitted at lower levels, as well.
In the current culture, the use of alternate means of compliance tends to be mostly impossible. Even
though it’s permitted in principle (and supported, typically, by the ubiquitous “one means but not the
only means” clause in the Advisory Circulars recognizing the means), the FAA often has difficulty
accepting concrete proposals.
A prominent example is the use of DO‐178B in connection with systems development. DO‐178B is
recognized as a means of compliance with the software‐related aspects of § 23.1309. Alternate means
of compliance are offered by AC 20‐115B and AC 23.1309‐1E, both of which give recognition to DO‐
178B, and by DO‐178B itself. Nevertheless, concrete proposals of alternate means tend to be either
impossible or expensive to pursue, leaving no true alternative to full compliance.
In general, the FAA’s inability to approve alternate means stems from the fact that DO‐178B is not based
on analysis, it’s based entirely on a consensus of expert opinion. The expected results of compliance
with DO‐178B cannot be analytically related to the § 23.1309 requirements; the link between the two is
AC 23.1309‐1E, which relates safety objectives to compliance items based on a second layer of expert
opinions. It is understandably challenging to determine what judgments form an acceptable substitute
for the original decisions. Nevertheless, in order to make the promise of “one means but not the only
means” be real, that’s exactly what must happen.
As we transition toward greater and greater reliance on industry standards, this situation will certainly
repeat. Just as we need a genuine and effective openness to the efficient use of alternate means to
presently accepted means (DO‐160G, DO‐178B, DO‐254, ARP 4754, various ACs, etc.), we will need the
same for the new ADS and future supporting documents.
Role of the Aircraft Manufacturer
Certain aspects of the development of the new part 23 are loosely modeled on the experience gained in
the development of the Light Sport Aircraft (LSA) approval process. In particular, the establishment and
maintenance of industry Airworthiness Design Standards has a direct analog in LSA. There are, however,
significant differences as well.
LSA are not type certificated under part 21. All airworthiness standards are maintained by industry and
recognized by the FAA. Many LSA manufacturers are relatively inexperienced and the majority are
foreign. Since there is no type certification, there is no STC process for LSA.
As a consequence of these and other factors, it is a requirement that all alterations to LSA be approved
by the aircraft manufacturer.
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It might be tempting to impose this same requirement for airplanes certificated under the new part 23
based on the fact that a portion of the detailed airworthiness requirements are expected to move into
ADS. It is our belief that such a move is unnecessary based on the fact that the essential airworthiness
requirements will continue to reside in part 23. Moreover, an extensive infrastructure of STC
developers and shops is already in place to support part 23 airplanes.
Imposition of a manufacturer approval process for alterations to part 23 airplanes would substantially
inhibit development and use of safety related improvements to airplanes in the fleet and should be
avoided.
Recommendations
1. Recognized industry‐maintained Airworthiness Design Standards (ADS) must be strictly regarded as
acceptable means of compliance. All compliance showings are made only with respect to the
regulations.
2. ADS and other means of compliance are not included in the certification basis and need not be listed
in the TCDS.
3. Airplane specifications, performance, operating limitations, etc., that lead to compliance decisions
within the ADS (and supporting documents), including tiering, must be listed in the TCDS.
Conversely, ADS and other documents must wherever possible base alternative compliance paths on
data that are listed in the TCDS.
4. Comparable information with regard to alterations (particularly alterations made under STCs) should
be available as part of the airplane’s permanent records.
5. An STC or alteration must be shown to comply with the regulations by means of any acceptable
means of compliance. Use of the specific ADS (and/or other documents) of the unaltered airplane is
not required.
6. If an existing design approval (TC, STC) is amended, use of the ADS previously used to establish
compliance with the regulations may be preferred (to the extent that it is applicable to the change)
but is not required. Upgrade to the latest revision of an ADS may be required only under the
conditions that would require a cert basis upgrade under § 21.101.
7. ADS should be regarded as separable. If multiple standards are recognized in overlapping areas,
compliance with the regulations may be shown using them in any combination as long as all of the
compliance requirements applicable to any particular regulation within the chosen standard are
fully met.
8. ADS must be written in such a way as to make it clear what portions address which part 23
requirements. Portions of an ADS that address different part 23 requirements must be kept
separate as much as possible.
9. The approval of an aircraft's manufacturer must not be required in order that an STC or alteration
can be approved.
10. Guidance must clearly indicate that the new part 23 is acceptable for all changes to any airplane
certified under part 23 or any predecessor regulations. (21.101(a) indicates that the most recent
amendment can always be used if the applicant so elects.) In particular, if a rule in the cert basis of
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an airplane has been dropped from the new part 23, continued compliance cannot be required,
though compliance with its replacement or equivalent can.
11. A process must be available by which an AMOC to a recognized standard can be used.
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G.3 – Certification of Systems and Equipment
This is a report on the subject of Certification of Systems and Equipment from the Alterations &
Maintenance Working Group to the full part 23 Aviation Rulemaking Committee. It includes a statement
of the issue considered by the Working Group, discussion of the issue and specific recommendations to
the FAA proposed for ratification by the ARC.
Issue
Installed systems and equipment have the potential to contribute greatly to the safety of flight, both as
installed at the time of manufacture of the airplane and as installed throughout the airplane’s service
life. The articles themselves, however, and their installation tend to be costly, inhibiting their
installation on airplanes at all levels. If these cost barriers can be lowered without compromising safety,
increased adoption rates can result in safety improvements within the fleet.
Discussion
Background
The stated objective of the part 23 rewrite is to achieve a 50% improvement in the overall safety of
part 23 airplanes while (or possibly by) reducing the overall cost of certification by 50%, making
airplanes and equipment more affordable. A part of the underlying premise of this objective is that
incorporation of new technology (primarily in electronic systems, but also in structures, propulsion,
cabin furnishings, etc.) has the potential to improve safety, but that it has to be cost‐reduced from
traditional levels in order to achieve an effective level of market penetration.
While it might be expected that changes made in the new part 23 would primarily benefit new
production airplanes, attainment of the safety improvement goal within any reasonable period of time
will require that the existing fleet be considered as well. Based on readily available industry figures
reflecting the service life of small airplanes, current fleet size and makeup, and production rates, it is
likely to be at least forty years before airplanes certified under the new part 23 comprise a majority of
the fleet. This being the case, it is essential that those factors that most directly influence safety and
certification cost be directly considered, and that the availability of new certification approaches be
made available to the existing fleet and not only new production airplanes. In many cases, the costs
associated with design, manufacture and installation of these items are largely determined by the
applicable certification requirements. If these certification requirements can be reduced without posing
a direct threat to safety, the resulting cost reduction may actually result in an overall safety
improvement as a result of increased adoption.
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With regard to systems, many of these cost drivers result from the following items, some of which are
regulatory in nature and some of which result from FAA accepted, conventional means of compliance:
System Safety Assessment and supporting compliance items, including DO‐160(), DO‐178() and
DO‐254.
Prescriptive safety requirements, such as defined failure classifications and development
assurance levels in TSOs and guidance documents.
HIRF and lightning compliance
Many of these requirements have their origin in the air transport world. Some have been modified for
use with small airplanes, while others have not. In some cases, concerted efforts have been made to
rationalize certification requirements for small airplanes, but it is our feeling that additional steps can,
and should, be taken.
Equipment categories
Equipment on airplanes can be categorized in certain ways that are potentially useful in determining
appropriate safety standards. Specifically, the following overlapping categories may be considered:
1. Required vs. non‐required
Required equipment is identified as such in either the aircraft certification regulations (in the
present case, part 23) or the operating rules (most often part 91, but possibly part 135)
applicable to the airplane. Any equipment not so identified is non‐required equipment.
Equipment that is required is generally essential to the safe operation of the airplane in an
identified environment. For example, part 23 requires that all airplanes be equipped with an
airspeed indicator, an altimeter and a magnetic direction indicator. These requirements (and
others) are repeated in part 91, which also requires that airplanes to be operated at night be
equipped with position and anti‐collision lights, and that airplanes to be operated in instrument
conditions be equipped with suitable flight instruments, navigation and communication
equipment.
While intuition suggests that required equipment should follow more stringent safety standards
than non‐required equipment (and, indeed, this is sometimes the case), the consequence of
failure of a given article is actually more important than the existence of a requirement for its
installation. For example, the in‐flight failure of a required position light is essentially
inconsequential – the airplane is perfectly capable of flying to its original destination without
difficulty, though additional vigilance in traffic spotting and position reporting might be advised.
One noteworthy example of non‐required equipment is the handheld GPS. These have become
ubiquitous over the last fifteen years or so, incorporating numerous functions (moving map
display, satellite weather overlay, flight planning and navigation, terrain avoidance) that have
obvious utility and potential for safety improvement. In fact, there is considerable
circumstantial evidence that the use of handheld GPS units has caused a significant decline in
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the number of CFIT accidents in small airplanes. These units, being non‐installed, are of
commercial quality and have no certification pedigree whatsoever. That owners who choose to
install similar panel mount equipment should suffer an economic penalty that often runs to over
$10,000 seems ridiculous.
2. Safety‐related vs. non‐safety‐related
Safety‐related equipment is equipment that has the potential to improve the safety of an
operation or has the potential, by means of its failure, to degrade safety. Non‐safety‐related
equipment is equipment whose potential contribution to operational safety, either positive or
negative, is negligible.
In any realistically usable safety‐related article, the potential for safety improvement must
exceed the likelihood of safety degradation (which is related to the potential consequences of a
failure, considering the operational environment, and the likelihood of that failure).
One good example of non‐required safety‐related equipment is an installed carbon monoxide
detector. The potential for safety improvement is obvious, and the hazard associated with any
reasonable failure rate is completely negligible.
3. Original vs. replacement
In order to achieve the top‐level safety improvement goals of the ARC within a reasonable
timeframe, consideration must be given not only to the safety of new production airplanes but
to installation of potential safety‐enhancing equipment on existing airplanes. Many of these
existing airplanes have old, “low technology” systems that have failure rates well in excess of
those required on new airplanes.
Current guidance requires that new systems installed on older airplanes meet the same
requirements as on newer airplanes. In many cases, the residual value of the older airplanes is
such that the investment required to upgrade to current‐standard equipment is untenable. As a
matter of basic logic, it seems appropriate that the standard applicable for installation of
replacement equipment on any airplane, regardless of age, should be “at least as good as that
which is being replaced.” This is, in fact, the basic logic behind the changed product rule, but it
is not consistently carried forward into other related guidance or used in practice.
4. Emergency use only
Addition of redundant or supplementary equipment can contribute significantly to safety and
may be permissible at significantly reduced cost if the equipment is provided for use only in case
of emergency.
An example might be an emergency auto‐land system. Such a system might be engineered so as
to guide the airplane to a survivable landing in cases of pilot incapacitation or other
emergencies, not under normal conditions.
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Sections 23.1306, 23.1308 and 23.1309 compliance
Much of the cost of airborne systems results from the requirements of §§ 23.1306 (lightning), 23.1308
(HIRF) and 23.1309 (system safety). The costs include extensive and intrusive development process
assurance activities, expensive and sometimes difficult compliance testing, specific design features,
aircraft‐level configuration and protective measures in the installation.
By any normal measure, these three regulations and accompanying guidance have been created or
updated in the very recent past, the oldest being § 23.1308 in 2007 (its introduction). This is largely the
result of the rapid incorporation of “glass cockpit” systems and electronic engine controls into part 23
airplanes in the last twelve years or so. As higher criticality systems were introduced, concerns arose
that they were not fully addressed by the existing regulations. As a result, issue papers were routinely
used to establish certification criteria responsive to potential failures under exposure to HIRF and
lightning, as well as other perceived risks. Coincidentally, even as §§ 23.1306 and 23.1308 were in
development, § 23.1309 was simplified (both in the rule itself and in the form of guidance changes
facilitating compliance) and more effectively directed at these newly emerging systems.
Compliance with each of these regulations has, as its starting point, elements of a system safety
assessment (SSA). The SSA starts with a functional hazard assessment (FHA) in which each function of
the equipment is categorized as to the severity associated with its failure. Two top‐level failure modes
are generally considered for each function: loss of the function and unannunciated failure (or
misbehavior) of the function. Of the two, unannunciated failure is generally the more severe failure
mode. A five point scale is used for this exercise, each failure mode being classified as “catastrophic”,
“hazardous”, “major”, “minor” or “no safety effect.”
This classification of failure modes determines which of the detailed requirements of these three
regulations apply to the equipment. Generally, the greater the hazard associated with the failure of the
equipment, the more stringent the requirement.
Because of the scope and importance of these regulations, a host of guidance documents provide
interpretation (generally in the form of FAA advisory circulars) and offer acceptable means of
compliance (generally in the form of industry standards recognized by the ACs).
FAA guidance is provided in AC 23.1309‐1E, which identifies acceptable means of compliance for
§ 23.1309; AC 20‐136B and AC 20‐155, which identify acceptable means of compliance for § 23.1306;
and AC 20‐158, which identifies acceptable means of compliance for § 23.1308. Industry standards that
provide detailed means of compliance and are accepted by these ACs (and others) include SAE ARP
4754A, ARP 4761, ARP 5412A and ARP 5414A; and RTCA DO‐160(), DO‐178B and DO‐254.
As previously noted, compliance with all three rules depends on the classification of hazards by severity.
Since this classification is made in the FHA and since related guidance is presented in the context of
§ 23.1309, it is sensible to consider that rule first. AC 23.1309‐1E interprets the rule, associating the
provisions of the rule with the five failure categories identified above and defining each in terms of the
effects of a failure in that category on the airplane, its function and safety margins, the crew and the
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other occupants. It then identifies compliance requirements of two types for each failure category:
numerical allowable failure probability requirements and development assurance levels (DALs). The
allowable failure probability applies to overall system performance but in practice is generally met by
estimating the reliability of the conventional electromechanical and analog electronic hardware and the
gross reliability of the digital electronic components, ignoring the contribution of all programmable
digital electronics. The latter is met by development assurance methods.
Prior to the issuance of AC 23.1309‐1C, the association of allowable failure probabilities and DALs with
particular hazard levels was uniform across all part 23 airplanes (and, in fact, matched the requirements
for part 25 airplanes). AC 23.1309‐1C introduced four “classes” of airplane under part 23 with increasing
complexity and capability. The most complex and capable airplanes, Class IV, are the Commuter Class
airplanes and continue the traditional relationship between failure categories, allowable failure
probabilities and DALs. As airplanes become less complex and capable, a “sliding scale” of numerical
allowable failure probabilities and DALs was introduced with the objective of rationalizing the safety
requirements for smaller airplanes in order to make safety‐enhancing systems more affordable. (If that
goal sounds familiar, it should. The success of this AC was the model for the broader activities of the
current ARC.) This sliding scale has been retained without major modification in more recent versions of
the AC.
AC 23.1309‐1E recognizes ARP 4754A as providing useful guidance on the determination of DALs but
cautions that its approach is directed more at part 25 and may, in some areas, be inconsistent with the
most appropriate practice under part 23, especially in the lower airplane Classes. It recognizes DO‐178B
(through AC 20‐115B) and DO‐254 (through AC 20‐152 and Order 8110.105) as providing acceptable
means of compliance for software and hardware development assurance activities, respectively. It also
references DO‐160() without comment.
In the case of lightning, there is some question as to whether the requirements are unrealistically
stringent given the exposure seen by the GA fleet. A study published as part of NASA’s Advanced
General Aviation Transport Experiments (AGATE) program (Evaluation of Harmony Between the Threat
of Lightning and FAR 23 Requirements; James Griswold, August 1999) suggests exactly that. This study
analyzes a considerable base of accident data and concludes, to be succinct, that the GA lightning‐
related accident history does not justify the level of expense required to comply with the then‐current
rules. Since that time, several things have happened: the rules have changed, there has been a
tremendous increase in the installation of safety related electronic systems on small airplanes and the
portion of the fleet made up of composite construction airplanes has vastly increased. It would seem
that at least a reconsideration of the subject would be appropriate.
Protection of safety related systems generally requires considerations at the system level, the
installation level and the aircraft level. Considerable specialized knowledge and experience is required
even to comprehensively determine the compliance requirements. While the current guidance material
is complete and well structured, the subject is still beyond all but the most experienced engineers. As a
consequence, most small companies and new applicants use one of a small number of consulting DERs
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to assist in the process. Lightning compliance testing is expensive and time consuming and can be done
at only a small number of test labs nationwide. It is often destructive, too.
If conservative guidance were available offering standard, acceptable solutions to identifiable situations,
it could greatly cut down on the cost of compliance, both in money and in time. For example, if
reference circuit designs or installation designs were available (much as standard alteration techniques
are identified in AC 43.13‐2B), an applicant could make the choice between a standard approach that
might be more expensive, larger, or adverse in some other way but was low in certification cost and risk,
or could choose to do the additional work necessary to engineer and qualify a custom design. As always,
there is a risk that a standard solution presented in guidance could become seen as “the” solution; this
situation would have to be avoided at all cost.
With the harmonization of US and European requirements and the incorporation of responsive test
levels in DO‐160(), HIRF compliance for small airplanes has become fairly routine for experienced
applicants. (Helicopters are a different matter.) The design features and practices needed to produce
compliant equipment and installations are not exceedingly costly or time consuming. Nevertheless, the
same questions of exposure apply here as in the case of lightning, especially in the US. A reexamination
of the issue is probably warranted.
Comparative risk
The existing guidance describes safety‐related certification requirements in relation to the risk
associated with deployment of a given system into the fleet. That risk is estimated based on a functional
hazard assessment and mitigated based on the results of a design and installation appraisal or system
safety assessment, depending on the level of risk.
The existing guidance, however, fails to address the risk associated with a failure to deploy. Specifically,
safety related functions may have the potential to reduce the accident rate associated with the specific
flight hazards that they address. Any risk associated with the deployment of systems that assist the pilot
in avoiding specific hazards may be offset by the avoided risk to operators and their passengers
associated with those hazards in the absence of the systems.
Thus, an appropriate way to judge the net safety impact of a given system would be by assessing the
comparative risk associated with its deployment and non‐deployment. Systems that have the potential
to address hazards that are especially significant in GA (such as loss of control) would merit
consideration at lesser estimated reliability (i.e., higher risk) than might be considered for less significant
hazards.
Note that the analysis should consider the risk associated with the hazard in the absence of any
advanced technological mitigation. Failure to do so would mean that the first introduced system could
be given an unfair competitive advantage, in the form of relaxed certification requirements, over
subsequently introduced systems of equal or greater capability.
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As an example, a number of years ago the FAA looked at the issue of installation of shoulder harnesses
on airplanes not so equipped at the time of manufacture. Their conclusion was that the use of shoulder
harnesses dramatically reduced the likelihood of head injury in accidents and that their installation was
inhibited by unrealistically costly and unnecessary (based on examination of the comparative risk of
non‐installation versus installation) compliance requirements. With no rule change, but with the
introduction of new policy and guidance, these requirements were simplified, affording the pilots and
passengers of many legacy airplanes safety benefits that they previously couldn’t afford.
DO‐178() and DO‐254
Both DO‐178B (soon to be C) and DO‐254 use the concept of “development assurance” as a response to
safety requirements. It is axiomatic under both that beyond a certain level of complexity, designs
cannot be rigorously verified and, therefore, are likely to contain defects. (Conversely, below a certain
level of complexity it should be accepted that designs can be rigorously verified. This concept is
currently supported by the guidance recognizing DO‐254. So called “simple” programmable devices may
be verified by conventional means, employing comprehensive tests at the pins and comparatively simple
documentation. No corresponding guidance exists, however, for DO‐178(). This is a deficiency worthy
of correction.) Development assurance methods prescribe process requirements in an attempt to
reduce the number of design defects in released products. Both standards describe a number of
“development assurance levels” (DALs) with increasing process requirements in order to reduce the
likely number of design defects as safety requirements increase.
It is also axiomatic, though, that the design defects in a given product, being unknown, can have an
unknown safety effect, up to the most severe hazard category associated with the product. The
relationship between development assurance levels and safety is extremely indirect – the prescribed
methods in the standards strive only to reduce the design defect count as the development assurance
level rises, not to ensure in any way that the remaining design defects have an acceptable consequence.
The presumption is that reducing the number of design errors also reduces the likelihood that any really
important ones remain.
Because of the unknown relationship between the exact number and nature of design defects
remaining, system safety analysts and software development theorists rigidly refuse to use DAL as
predictive of reliability. While this is appropriate in theory, it leads to tremendous difficulties in
practice. Most importantly, the fact that the true significance of compliance with a given DAL is largely
unknown and isn’t related to reliability in a commonly accepted way makes it very difficult to make
reasoned judgments about DALs. Much of the literature on system safety assessment and many of its
methods are forced to take a “dual track” approach, following a logical and rigorous approach to
determination and combination of numerical reliability and a more ad hoc, less reasoned approach to
development assurance levels.
The relationship between the DALs defined by DO‐178B and DO‐254 and the hazard classifications
identified for part 23 airplanes in AC 23.1309‐1E is somewhat arbitrary. It has its origin in the traditional
relationship between the five commonly defined hazard classifications (catastrophic, hazardous, major,
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minor and no safety effect) and the five DALs (Level A, B, C, D and E), established for use under both part
23 and part 25 at the time of introduction of DO‐178B. This relationship between hazard classifications
and DALs is based solely on the collective judgment of software development and verification experts
with the knowledge that the tie to the safety objectives was very indirect; no analytical basis for the
relationship was attempted, and development of such an analytical basis is regarded as impossible.
When AC 23.1309‐1C introduced the “sliding scale” of numerical reliabilities and DALs assigned by
airplane class, an analysis was presented giving some justification for the chosen numerical reliabilities,
but no justification whatsoever was offered for the revised DALs. New judgments were substituted for
the original, again without any direct relationship between the hazard classifications and the process
requirements assigned to address them. (This is not to denigrate those judgments or demean the
subject matter experts who made them, but rather to point out that alternate judgments made in the
light of historical data, additional insights into the overall certification process and installation‐specific
considerations might well lead to other judgments. Indeed, while seldom applied, this concept is
supported by the guidance.)
Since that time (and, in fact, since the introduction of DO‐178B), the number of accidents in which
software implementation error was identified as a factor has been negligible. The prevailing theory is
that systems engineering errors (which are not governed by DO‐178B or DO‐254) are larger overall
contributors to significant systems failures.
This suggests that a further relaxation of the existing requirements for DO‐178B and DO‐254 compliance
could be made without significant safety impact. It does not, however, suggest that DO‐178B and DO‐
254 (or some other appropriate process) should be abandoned, since the positive accident history has
been accumulated in an era in which DO‐178B compliance is essentially universal.
Despite the fundamental differences between numerical reliability and development assurance levels,
we believe that the history accumulated in the twenty years that DO‐178B has been in use offers a
simplified treatment. Specifically, we believe that the FAA could, based on engineering judgment,
accept that each DO‐178B development assurance level satisfies a particular numerical reliability
requirement. This, in turn, would eliminate the necessity of following dual tracks in the system safety
assessment process, adding clarity and flexibility. It would also allow a single line of reasoning to be
used in establishing a revised sliding scale for use with part 23 airplanes.
The significance of this change should not be underestimated. At present, judgment must be applied
repeatedly in determining appropriate DALs, at different times and at different levels, both in
determining the appropriate association of DALs with hazard classifications (primarily for guidance
purposes) and in determining the DALs that should apply under existing guidance. This requirement for
repeated judgments is problematical due to the fact that the original judgments were essentially
arbitrary and provide no basis for follow‐on judgments. Both industry practitioners and certification
authorities are reluctant in practice to make judgments in this space that are not firmly grounded in
accepted practice; process innovation is nearly impossible. By way of contrast, if a specific relationship
between DALs and numerical reliability is accepted, every other aspect can be handled analytically; a
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single judgment made by the FAA eliminates the need for judgments at numerous other levels. It also
simplifies existing practices in the system safety process. As previously noted, in current practice, fault
tree analysis examines dual paths, one for “conventional” system components subject to numerical
reliability requirements and another for “complex” system components subject to development
assurance methodologies. If the proposed change is implemented, the need for dual path analysis will
disappear and the relationship between potential failure contributions of “conventional” hardware
systems, software systems and “complex” hardware systems will be clarified. (Note that it is not
intended that FTA be used below the level of the software or hardware component. That is, unless a
partitioned architecture is used, FTA is not the appropriate means by which the internal structure of a
software or complex hardware component would be validated. In a partitioned architecture, FTA or the
analogous Functional Fault Path Analysis can be used to establish appropriate numerical reliability
requirements for internal structural elements.)
While DO‐254 has a shorter history, having been introduced only twelve years ago, we nevertheless
believe that its similarity to DO‐178B warrants similar treatment.
Exposure
The present guidance grants no credit for hazard exposure in the assignment of development assurance
levels.
Exposure describes the fraction of overall flight time during which a given failure would result in a
hazard. The failure of an attitude indicator, for example, is hazardous only in instrument meteorological
conditions (IMC), when the pilot cannot maintain attitude by reference to the actual horizon. Exposure
is used in the estimation of failure rates for comparison with the numerical reliability requirements
(using guidelines that are, some would argue, excessively conservative, such as the guideline that an
airplane certified for IFR use should be assumed to be in IMC at all times) but is not made a factor in
determining the appropriate DALs. We would attribute this fact to the previously mentioned difficulty in
interpreting the indirect relationship between DALs and predicted reliability.
One very significant influence on exposure which isn’t accounted for in the guidance is level of equipage.
The calculations proposed in the guidance essentially assume that the system under consideration is
installed on all airplanes in the fleet and that all airplanes in the fleet are exposed to potential failure of
the system. In GA, especially, this is a faulty assumption. Because of the diversity of airplane types and
ages in GA, a given product is very unlikely to be installed in even 10% of the fleet, reducing the overall
exposure to its failures. As the level of equipage increases, the cumulative service history obtained
would enhance (and, in many ways, be of greater value than) the understanding of the system’s overall
reliability and failure modes based on development assurance methods alone. We believe that credit
should be given for the reduction in exposure associated with reasonably anticipated initial level of
equipage for a given system subject to certain considerations. First, for systems with a potential
contribution to higher level failures (catastrophic failures, to be sure, and possibly hazardous failures as
well), some prescriptive minimum numerical reliability requirement would be appropriate irrespective
of the anticipated level of equipage. This will serve to prevent degenerate cases in which inordinate
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credit is given to very low levels of estimated initial equipage with a resulting high level of exposure to
potential catastrophic events on the small number of airplanes so equipped. Second, the manufacturer
must have a means whereby failures detected in the field are recorded, classified and dispositioned in a
manner appropriate to their classification (by means of documentation or system update). Third, a
means must be identified by which owners of early systems can be informed of failure modes
discovered in service so that they have the opportunity to upgrade their systems to conform more
closely to the higher levels of numerical reliability required as the level equipage increases. Lastly, the
adequacy of the Airworthiness Directive and SAIB processes to deal with potential safety and
serviceability issues must be considered in light of the (theoretically) greater potential for latent errors
to be released to the field. We further believe that service history alone should be regarded as sufficient
to allow continued installation beyond the initial estimated quantity, so long as the feedback and failure
report dispositioning requirements described above are met.
Alternate means of compliance (AMOC)
The FAA provides assistance to applicants by a number of means, including publishing Advisory Circulars
that both clarify the often abstract rules, providing specific compliance criteria, and offer means of
compliance by which the applicant can show that those criteria have been met. As noted previously,
these acceptable means of compliance are often supported by industry standards, such as RTCA
DO‐160(), DO‐178() and DO‐254(). Indeed, some ACs serve no purpose other than to identify an
industry standard as acceptable means by which compliance with some rule, or some aspect of a rule,
may be shown.
In order to avoid “regulating by guidance” (which is illegal under the statutes that govern the FAA’s
operation as a Federal agency) these ACs invariably include language indicating that they constitute
“one means but not the only means” by which compliance with the regulation can be shown. Thus,
applicants are free to propose other paths, generally known as alternate (or alternative) means of
compliance (AMOC)4. AMOC may partially follow the methods given in the FAA guidance or industry
documents, but differ enough as to prevent the applicant from making an unconditional statement of
compliance based on the AC.
In actuality, however, the means given in an AC are often the only practically acceptable means. Every
applicant can cite a time when he has proposed something else and an FAA engineer has responded that
“That’s not the usual way it’s done” or “I’ve only seen it done one way” or even “My preference is to see
you do it like this”, followed closely by “Of course, you can do it another way if you like, but it will be a
lot more work.”
This almost invariably indicates a closed minded attitude toward the use of AMOC in general. This
attitude is understandable, in that the use of the AC without deviation can often be acceptable based on
4 Note that “AMOC” is also used in the context of Airworthiness Directives, where some party proposes
means of compliance with the AD other than those contained within, or referenced by, the AD itself.
Because ADs have their own regulatory structure apart from Part 23, this is a somewhat different,
though related, case. It is not the intent of this paper to fully address the AD case.
~ 301 ~
Appendix G
a single compliance statement without further consideration, at least with an experienced applicant. By
way of contrast, the use of an AMOC requires that the engineer have a detailed understanding of the
intent of the regulation, clearly identify the compliance issue, determine that the proposed means of
compliance are sufficient and review the compliance data to ensure that the planned means were truly
followed. As a result, the workload on the FAA engineer is increased – possibly greatly so – by the
applicant’s use of an AMOC. Moreover, resources outside the ACO may be required in support of the
approval.
To some extent, it is to be expected that an applicant proposing an AMOC will have to do some extra
work. After all, the work that was invested in the development of the AC and any underlying industry
standards is at least partly lost when an AMOC is employed. In particular, a given acceptable means of
compliance may identify specific risks underlying the rule. While an applicant’s proposed AMOC should
not be judged for point‐by‐point equivalence to the FAA’s identified acceptable means, but the specific
risks may need to be addressed.
Notwithstanding the potential difficulty, an applicant proposing an AMOC ordinarily does so because he
believes it to be more appropriate to his situation than the usual means, and this normally implies that
he believes it will be more efficient overall, whether within the course of the project in which its first
used or including successive projects. For efficiencies to be realized, the FAA must be a willing ‐‐ or
even enthusiastic – partner in the endeavor; reason must prevail on both sides. Even though a given
applicant’s AMOC is proprietary, the experience gained in evaluating it and approving it has significant
value to the FAA.
Use of service history for certification credit
Service history should not only be creditable for new systems but should also be creditable for
previously developed systems, primarily as a means of allowing systems shown to be reliable on less
complex airplanes to be used on more complex airplanes as well. Historically, the FAA has had very
limited ability to evaluate and accept service history arguments for DAL upgrades, blocking this path.
For many systems, this has the effect of denying access to highly reliable and functional equipment due
to the economic barriers associated with DAL upgrades.
In all cases where the use of service history for certification credit is proposed, certain problems arise.
These include:
Determination of the relevance of the service history to the newly proposed application.
Changes in aircraft configuration, equipment interfaces, pilot usage or environment can, in
principle, expose new execution paths and latent errors in the software or hardware.
Acceptance of a reliability‐based argument for acceptance. As previously noted, there is not a
generally accepted relationship between design assurance levels and reliability. If such a
relationship is accepted as proposed above, however, it should be reversible. That is, a certain
demonstrated level of reliability in an appropriate environment should be creditable against DAL
requirements. (This is not intended to suggest that accumulation of the required “10‐X” number
~ 302 ~
Appendix G
of hours of trouble‐free operation would be used as fully equivalent to a particular DAL. Rather,
some number of hours of operation with a known, acceptable problem history would be given
partial credit for development assurance methods. Combined with actual performance of other
elements of a development assurance methodology, this might be judged sufficient to allow a
DAL upgrade, facilitating installation on more complex airplanes.)
Determination of the manner and amount of credit to be given. There is no obvious way in
which to relate service history (quantitatively or qualitatively) to specific development assurance
activities. It seems logical that service history might represent an acceptable substitute for
some or all of the verification activities required by DO‐178B and DO‐254 in a given
circumstance, but there is no analytical way to determine which or how much.
Historically, service history hasn’t gotten much traction as a substitute for development assurance
activities, despite the existence of well written, FAA‐sponsored research papers on the subject. Its use
has been sufficiently controversial that applicants and FAA personnel have been reluctant to propose it,
even where it seems appropriate from a risk perspective, out of fear that projects that otherwise have
merit will meet with obstruction. As a matter of policy and common sense, it would seem that we
should gain some experience on which to base future practice.
In one such example, an equipment vendor proposed to upgrade the software in a system from DO‐
178B Level D to Level C through the application of service history. The system incorporated a “black
box” commercial operating system that could not be made Level C compliant by ordinary means. The
systems had been in commerce (albeit with different software versions) for many years on a wide
variety of part 23 airplanes with only minor problems, none of them safety related. With input from a
research paper commissioned by the FAA and written by two well‐known, widely respected consulting
DERs, the applicant proposed to use this service history for credit against Level C objectives that could
not be met conventionally due to the closed operating system. The FAA assigned personnel from
several offices, including Headquarters, SAD, TAD and others to evaluate the proposal. After lengthy
discussions and several rounds of PSAC rework by the applicant, the project collapsed in stalemate. This
was primarily due to one FAA member’s inability to understand how “if you don’t have the required
number of hours of service history [corresponding to the numerical reliability requirement] you can
propose to use your service history to show Level C equivalence.” The applicant had been clear in
establishing that service history was proposed as a supplement for other fully‐compliant processes, but
this stumbling block (which was essentially rooted in excessive conservatism and an inability to think in
innovative terms) proved to be insurmountable.
Use of functional standards for DAL credit
At Level D, both DO‐178B and DO‐254 essentially require only functional verification (with some
additional documentation, configuration management and quality assurance requirements). Mike
DeWalt has observed that compliance with third party functional standards (such as, for example, TSO
MOPS) could be regarded as equivalent to compliance with Level D. Since the step function of cost from
“no compliance required” to Level D is very large (especially for companies not yet selling certified
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Appendix G
products), there are correspondingly large advantages to be gained by formally recognizing such
compliance as sufficient.
For example, because collision avoidance in the National Aerospace System (NAS) is predicated on a
“see and avoid” philosophy, failure of a TCAS I or TAS system is generally recognized as representing
only a Minor hazard, for which DO‐178B Level D is sufficient. As such, compliance with the MPS
requirements of TSO‐C118 (TCAS I) or TSO‐C147 (TAS) might be regarded as sufficient without a separate
showing of compliance with DO‐178B.
Cultural issues
In the end, the single most important factor in determining the success or failure of a regulatory
structure is the culture in which it is applied. If the regulations are thoroughly understood, if the
supporting guidance is clear and if those in the culture embrace the regulations, abiding by the
requirements and using permissions granted to them to their advantage, great successes are possible.
If, however, the regulations are largely ignored, if the supporting guidance is unclear or unsubstantiated
in terms of the regulations, and if those in the culture operate on the basis of tradition and uninformed
intuition rather than on the basis of the true regulatory intent, the results are sure to be negative,
frustrating and costly to all involved.
As noted several times in this paper, many of the decisions made in the course of the development and
certification of systems and equipment are based less on analysis and more on judgment. One of the
goals of this paper is to make it possible to reduce the scope and number of judgments that must be
made and to allow greater use of analysis instead. The need for judgment cannot, however, be
completely eliminated.
Due to rightful concerns over the safety ramifications that might result from faulty judgments, there is a
tendency toward extreme conservatism when judgments must be made. For the most part, we try to
mitigate these concerns through the development of guidance material that can reduce the problem to
one of making focused decisions along a prescribed path rather than making broader judgments based
on a more general examination of the situation at hand. This guidance material is often extremely
conservative, geared toward worst‐case situations. It tends to be highly prescriptive rather than
instructive, providing formulaic responses to situations that may not be a good fit for the project at
hand, while failing to explain the reasoning behind those responses. This leaves those who would use
the guidance powerless to understand its applicability to the situation at hand and to make related
judgments that may not exactly match those reflected in the guidance material.
For the proposals in this paper to succeed, it is imperative that they be fully and clearly supported in
guidance and policy. Moreover, they must be publicized and training must be available to FAA
personnel, designees and applicants in order to ensure their proper use. In certain cases (the use of
service history, for example), it may prove desirable to identify specific pilot projects in which the
concepts can be tested for both efficacy and efficiency.
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Appendix G
In addition, the current culture – at all levels – is one of extreme conservatism. This is best illustrated by
examining the relationship between owners, their shops and Flight Standards. Shops are reluctant to
make most any changes as minor alterations for fear of recourse. Their inspectors are reluctant to field
approve anything. (This is a slight exaggeration, but only slight.) STCs have become a de facto
requirement for everything. Much of this is not based on the regulations, any existing guidance (more
on this in a moment) or policy. In fact, some of it is directly contrary to existing policy that states that
STCs will not be granted for minor alterations. Owners are understandably confused as to what they can
and cannot do with what level of difficulty and expense.
The extreme conservatism even makes its way into guidance from time to time. FAA Order 8900.1
Chapter 9 contains instructions to Flight Standards personnel on “determining the category of a repair
or alteration and ensuring that the aircraft, engine, or accessory can be returned to service in
accordance with the field approval process”. Following 25 pages of discussion, the Order presents
tables that “indicate which method(s) may be used for approving major alterations” to part 23 airplanes,
rotorcraft and part 25 airplanes, each in its own table. In fact, the tables serve mainly to indicate that
certain alterations are not automatically eligible for field approval; in the part 23 table, every entry lists
an alteration that must be approved by STC, with ACO assistance or with unusual evaluation by Flight
Standards. None of the individual entries include a rationale, so the reader is often left to guess at the
reasoning employed in making the judgment, yet the reader is cautioned that “These lists are not all‐
inclusive, and each alteration should be evaluated on a case‐by‐case basis”; one can neither reliably
extend the logic of the table to other situations nor assume that those situations can be treated as being
“automatically eligible” for field approval by their absence from the list. In those cases where an
applicant (a shop, presumably) disagrees with the classification of an alteration as requiring an STC, a
lengthy passage dictates that the applicant make an appeal to the FSDO which, in all likelihood, will
involve the ACO, AIR‐100 and the applicable Directorate in determining whether reclassification is
appropriate!
This conservatism is attributable, in our opinion, to a number of factors. Among these are fear of
adverse consequences in oversight; inexperience with decision making due to high levels of technical
specialization and cultural influences; and an excessive focus on process rather than on results.
Here’s an unsolicited, un‐redacted observation made recently by a highly experienced A&P mechanic on
an aviation related mailing list that reflects the problem:
I believe the culture in many FSDOs is not conducive to modifications of any sort without a great
deal of supporting paperwork. The persons making the approvals must be able to cover their
butt and the more paper the better. Nothing new really but the culture has been inbred to the
point it is now policy.
This mentality is contagious. Many IA's are infected also. They no longer are willing to perform
or exercise their privileges and abrogate them by passing the buck up to the dead end FSDO.
The interpretation offered by a previous poster is a perfect example of how the system should
work. As my first PMI told me, “Do not come to us to do your job. We will make things difficult if
~ 305 ~
Appendix G
you insist on us doing your job.” That being said, there is always going to be exceptions to the
above.
It’s not an exaggeration to suggest that the current culture has a stranglehold on the industry. It
promotes burdensome misapplication of the regulations at all levels. It results in bottlenecks at the
FAA, such as project sequencing, that could easily be avoided if fewer unproductive hours were devoted
to compliance activities. It stifles innovation and the installation of safety related improvements in small
airplanes. It is the single most important roadblock standing in the way of the realization of the vision of
the Part 23 ARC.
Recommendations
1. Existing guidance should be revised or new guidance written to simplify certification requirements for
non‐required, replacement and emergency‐use‐only systems and equipment. The emphasis should be
on improvement in overall fleet safety from the prevailing level, not attainment of any arbitrary level of
reliability or system function.
2. Certification requirements as expressed in guidance should expressly consider the adverse effects
that accrue from failure to install to offset risk exposure from potential systems and equipment failure.
3. Guidance should recognize “simple” software and provide simplified compliance criteria not based on
DO‐178().
3. Consideration should be given to amendment of AC 23.1309‐1() to generally relax the DO‐178() and
DO‐254() development assurance level requirements applicable to part 23 airplanes.
4. Guidance should recognize an accepted relationship between probability requirements and
development assurance levels and permit their use interchangeably in the system safety assessment
process.
5. Realistic credit should be given for all factors related to hazard exposure in showing compliance with
probability and DAL requirements.
6. The existing lightning and HIRF requirements should be re‐evaluated in light of current historical data
and projected installation trends and re‐justified in terms of the environmental exposure of GA
airplanes.
7. Consideration should be given to the provision of standard protective circuits for lightning protection
as acceptable means of compliance.
8. Guidance should be introduced providing a framework for the use of both aviation and non‐aviation
service history for certification credit.
9. A suitable showing of compliance with an established functional standard should be regarded as
equivalent to compliance with DO‐178() or DO‐254 Level D.
10. Alternate means of compliance must be allowed in practice, not just in theory. The FAA must foster
a culture and a process whereby AMOC can be encouraged and realistically evaluated with regard to the
basic regulations, not just in comparison to existing acceptable means.
11. The FAA must ensure that regulations, guidance, training and management combine to create a
culture that is focused on safety, not process, as the goal. Application of judgment must be encouraged
~ 306 ~
Appendix G
and supported at all levels. Owners, operators, maintainers, manufacturers, designees and FAA
personnel must all be able to determine from clear guidance what’s permitted with what level of
compliance effort.
~ 307 ~
Appendix G
Appendix G.4 – Primary Non‐Commercial Category Proposal
~ 308 ~
Appendix G
~ 309 ~
Appendix G
8M-bround
The joint GAMA I FAA Snnll Aircraft Aviation R.ulem•king Making Co""'"- (ARC) has been tasked
with doubling aircraft s afety while at the s ame time reducing certification costs by hal£.
Cunently, there are over 190,000 General Aviation aircraft registered in tbe United States - bO\\'e\W
corresponding production ofD.e"W replacement aire.raft is ooly apptoxiw.a.tely 1000 units a year when averaged
over tbe last several decades. (General Alian·o n Mamifacturers Association Statislical Databook & lndus&y
Outlookpages 30 ontl 24 rssp«ril'e:(>•- S611 Attachment D) Uofortuo.ately, at this pM-e, it mn tab almost
lOO year.s to re-plaC'e the ex:i->ti:Dt Cenenl .'\ ,iatioo fleet.
Coosequeotty, even 'With the most optimistic rates of productioo, it may be decades before the improvements
pioo.eered by the ARC for new aircraft design will yield any measunble safety improvements or cost
reductioo.s for the General A'iation Fleet as a whole. Therefore, any effective Safety I Cost solution must
address both New and Existmg Aircnft, The oaly way of realizing the safety and cost goals is by l everagiog
the concepts developed by the ARC for use in new airc::raft certification in a way that would have an
immediately felt positive s aftty effect on tbe existing Geoeral A\iation fleet The Primary N co-Commercial
recommendation resulted fran this necessity.
The Priuwy Non-Commercial Category is intended for the private owner to operate his or her aircraft in a
substantially Jess burdensome and costly ma.nDer by reduciDg the level of compliance to FAA mainteo.an.ce and
alteration requiremeots to a le-.rel more appropriate for a privately owned vehicle.
Oowucn o£ ~ c.aksorY aircraft that an mon: than t....alty yean old could dec:t to redclipa.k: their
aire.ra.ft as "Non Commercial.. use. This would enable 0\VD.KS to maintain their a.ircra.ft in a manner similar to a
Light Sport or amateur built ucra.ft:. This would include owu.er mainteo.aoce privileges (ooce a FAA aceepted
class is passed) and use of ooo PMA I TSO parts. A.ireraft would be subject to a yearly "condition inspection ..
by an A&P mechanic which certifies tbe a.ircra.ft is in a coodition for safe operation, identica) to the
requirements for Ama- Bwlt l!xperimeutal Aircraft.
While some may argue anecdotally that the creation of a Non Coau::oerci.al category with its associated
pril.;leps will detrimentally affect s afety, bctual data irldicates otherwise. First, this class follow.
Intematiooal Precedent by )e,.,..g;.g tbe «mcepts oftbe Canadian O.W.... MajJI!enance CategOJY, w!Uch has a
proven s afety record over the last decade (SH attacbmemt C). Secoodly, this concept uses tbe m-Vntenance
training principles of tbe high.iy successful LSA program which has a proven safety record. Incorporation of
this new category will offer the FAA a rare opportunity for im.plemeotatioo ofsound Safety Cootinuum
principles paired with iotematiooal harmonization.
In addition, by allowlog a pradical and workable path to retum Non Coau::oerci.al aircraft to Staod.ard Category
through dual airworthiness certificates, owners 'Will ba\-e a Large FinmciallDcentive to keep their aircraft near
to type design to avoid OO'alting their airc.ra.fl This is a significant Safety A<h·antap over the Canadian
System where it is nearly impossible to return to Standard Category - therefore affording no incentive for
owners to keep aircraft compljant to safety proven type design
Finally, the principles set forlh in tbe GAMAI FAA "Prima!y Non
Commercial Category.. Recommendation exclusively leverage
existmg US regulations witb proven safety records. The
recommeodation simply takes successful existing regulatory
practices and combines them into the new Primary N oo
Commercial Category. For example, Maintenance Training aod
Certification comes from LSA.. Airworthiness Certification comes
from dual certificated Standard I Restricted CategOJY aircraft and
Non Coau::oerci.al use from l!xperimeutal Airc::raft. There is nothing
oew or novel proposed. . . except for the unlimited potmtial for
safety aod cost improvements that would be available for users of
tbe PrimaJy Non Coau::oerci.al class.
~ 310 ~
Appendix G
Apeticabilitv
• The owner of a fixed wing. oon turl:li:oe pcn.-ered Pan 23 aircraft or Pan 23 glider, 20 yean or older, may e1e<t
to redesignate bis other aircnft as a Primary Non-Commetcial (see draft regulations 21.24 a:od 21.184)
• Airtnft io Ibis category am be maintaioed by the CrAooer wdb a repail:mans cenificate, similar to aureody
establisbed procedures for LSA airctaft repairmen. (see draft regulation 65.108)
• Replacemem or Alteration P:'uts should be appropriate for aircraft use, bowe\--er oeed 1101 be PMA I TSO
antborized. (see draft regulation 21.24)
• Owners can alter lbeir CJIIW. aircnft without lbe requ:ir:emmt for FAA Appro\•ed da!a. (bowe\w, some alterations
may require "phase 1" flight· testing similar to E:q~eritnemat AB requiremeots) (see draft regulation91.328)
• Primary Non Com!DertUl C.u.gory AUaaft ""' requ;r.d 10 OO...Ve tbe FAA Approved .AiruJ1I Ftigbt Manual
Operariooal Limitations a:od or required placard limitations esaablisbed fOr lbe Sca:oclard Category (see draft
regulatiOilS 91.328)
• AirmUt ~be used to amy persons fOr hire, this iDc.h»cks aircraft rental, but allows an owuer to recei\--e
flight instruction in their CrA'Il airaaft. (see draft regulation 91.328)
• Airworthiness Direai\•es are applicable as auteD1iy allcrA'ed for Experimental Amattm B wlt aircraft
• Aircraft owners must maintain a list in the airttaft logbook of ALL applicable ADs and lbeir compliaDce sr.aras.
This list would be used to biPligbt tbe o"WDerS p •areoess of the ADs e::tisttDCe and doa:uDeot their choice of
compliance. This list would be used to facilitate tbe coo\tenion of the airttaft back to :oo:anal category. (draft
regulation 21.24)
• Aircraft owners must maintain a list in the airttaft logbook of ALL alterations perfOrmed that are DOt FAA
apprmoed and All. :oon PMAed I TSO parts installed. 'Ibis list would be used to facilitatJe tbe COO\tenion of tbe
airaaft back to oormaJ. categ_ory. (see draft regulation 21.24)
• IDcomplete or Fnuctuleut MaiDteoalxe log book eDDies rtSUlt m lbe m--ocatioo.of the aircraffs staodard
am.'O!thi:aess certificate. (see draft Order 8130.2)
• BefOre origiDal com.wsioo, tbe aircraft IDilSt ba\--e a rurreat amrua1 inspection - aU applicable ADs must be
complied v.itbaurent amma1 inspection (see draft regulation 21.24}
• Airplane owners must either· add tbe prefix of"'NCO' to the airaaft registtatioo. number or af6Jt a "'Non-
Commerrial" placard readily \isible to aU passengers (see draft regulation 45.22)
• The airaaft must ba\•e a yeaJiy cooditioo inspection by an A&P Mechanic cenifyillg that the airaaft is " in
coodition for safe operation."' (see draft regulation 91.328)
• Upon tnnsfer of airttaft owuenhip, the Non-Commercial Ainvonb.iness Certificate mn.st be reissued mtbe new
owne.r"s Dame. (see draft regulation 21.184}
• AirmUt operated 1l:Dder a Primary Non Commercia) Ainvorthilless Certificate would be GW cen:ificated in bocb
the Normal and Non Commerria1 categories, as is common place fOr Restricted Category aircraft (see draft
regulation 21.184)
• Aircraft in the Primary Noo-Commerrial category can be operated in the
Stmclard category, pto\'ided the aircraft meets it type design dab includmg
comptiance v.itb all ADs, removal of all Non PMA I TSO pans and
replacemeut wdb cen:i.6ed tmi!s and the remt:J\--al of an DOD-Certified
alterations (see draft 21.24, draft Order 8130.2)
• The con\wsion can be accomplished by an lA mechaDic wdb a complete
and tbotough ammal inspeaion a:od Jog book audit Upon successful
~Jetton tbe aUcndt could be openled Ullde< il's Swldard Airw•Xlhilles~
Certificate. 1be Procedure is \"'elf common wdb Restricted Category
airaaft and bas proven both safe and successful (see draft Order 8130.2)
~ 311 ~
Appendix G
Attachment A
Sec. 21.24
!sstWJ<:e of type certificate: Primary category aircraft and Primary Non-Commercial Category
(a) The applicant is entitled to a type certificate for an aiicraft in the primary category if--
(1) The aircraft--
(i) Is unpowered; is an airplane powered by a single, naturally aspirated engine with a 61-knot or less
V~ stall speed as defined in Sec. 23.49; or is a rotorcraft with a 6-pound per square foot main rotor
disc loadine.limitation. under sea level standard dav conditions:
[(ti) Weighs not more than 2,700 pounds; or, for seaplanes, not more than 3, 375 pounds;)
(til) Has a maximum seating capacity of not more than fuur persons, including the pilot; and
(iv) Has an unpresswized cabin.
(2) The applicant has subntitted--
(i) Except as provided by paragraph (c), a statement, in a form and manner acceptable to the [FAA],
certifying that: the applicant has completed the engineering analysis necessary to demonsttate
compliance with the applicable aiiworthiness reqnirements; the applicant has conducted appropriate
flight, structural, propulsion, and systems tests necessary to show that the aircraft, its components,
and its equipment are reliable and function properly; the type design complies with the aiiworthiness
standards and noise requirements established for the aiicraft under Sec. 21.17(1); and no feature or
characteristic makes it unsafe for its intended nse;
(ti) The flight manual required by Sec. 21.5(b), including any information required to be funtished
by the applicable aiiworthiness standards;
(til) Instructions for continued aiiworthiness in accordance with Sec. 21.50(b); and
(iv) A report that: summa.rizes how compliance with each provision of the type certification basis
was determined; lists the specific documents in which the type certification data information is
provided; lists all necessary drawings and documents used to define the type design; and lists all the
engineering reports on tests and computations that the applicant must retain and make available
under Sec. 21.49 to substantiate compliance with the applicable aiiworthiness standards.
(3) The [FAA] finds that-
(i) The aiicraft complies with those applicable aiiworthiness requirements approved under Sec.
21.17(1) of this part; and
(ti) The aircraft has no feature or characteristic that makes it unsafe for its intended use.
(b) An applicant may inclnde a special inspection and preventive maintenance program as part of the
aiicraft's type design or supplemental type design.
(c) For aiicraft manuJactured outside of the United States in a country with which the United States
has a bilateral aiiworthiness agreement for the acceptance of these aircraft, and from which the
aiicraft is to be iinported into the United States--
(!) The statement required by paragraph (a)(2)(i) of this section nmst be made by the civil
aiiworthiness authority of the exporting country; and
(2) The required manuals, placards, listings, instnnnent markings, and documents required by
paragrapbs (a) and (b) of this section nrust be subntitted in English.
Primary Non-Commercial
~ 313 ~
Appendix G
(a) The Primary Non-Commercial Category consists of aircraft which hold a Type Certificate in
another Category defined by 14 CFR 23.3. Aircraft owners may elect to make application for
a Primary Non-Commercial category auworthiness certificate subject to the pri•ileges and
ilimitations outlined by this part. Primary Non-Commercial fonns a separate group, therefore
Sections (a) and (b) of this subpart do not apply to section (c) aircraft.
(b) The Primary Non-Commercial Category does not constitute type design or a certification
basis.
(c) Aiicraft certificated in the Primary Non-Commercial category are dual certificated in both
the original Type Certificated Category and the Primary Non Commercial category.
However, the pri\lileges of the Standard Category Airworthiness Certificate may not be
utilized unless the aircraft meets the type design and maintenance requirements required for
that certificate.
~ 314 ~
Appendix G
and detail of 14 CFR part 43, appendix D, and was fonnd to be in a condition
fol" safe operation."
(3) Not withstanding the above, all aircraft maintenance must be perfonned by an
indi>idual properly certificated for the activity onder 14 CFR 43 or by the aircraft owner
if he/ she has completed an FAA Accepted Training for an Primary Non-Commercial
Category repairman' s certificate.
~ 315 ~
Appendix G
Sec. 21.184
I Issne of special airworthiness cei!ificates for primary category aircraft and primary non-commercial
category aircraft
(a) Nqw primary caJI!f!.OTY aircraft manufactured under a production certificate. An applicant for an
original, special aiiworthiness cei!ificate-primary category for a new aiicraft that meets the criteria
of Sec. 21.24(aX1), manuJactured under a prodnction cei!ificate, including aiicraft assembled by
another person from a kit provided by the holder of the prodnction cei!ificate and under the
supervision and quality control of that holder, is entitled to a special aiiworthiness cei!ificate without
further showing, except that the [FAA) may inspect the aircraft to determine confollllity to the type
design and condition for safe operation.
(b) Imported aircraft. An applicant for a special aiiworthiness cei!ificate-primary category for an
imported aircraft type cei!ificated under Sec. 21.29 is entitled to a special airworthiness cei!ificate if
the civil airworthiness authority of the country in which the aircraft was manuJactured cei!ifies, and
the [FAA) finds after inspection, that the aircraft conforms to an approved type design that meets the
criteria of Sec. 21.2 4(aXl) and is in a condition for safe operation.
(c) Aircraft having a cuTTent standard airworthiness certificate. An applicant for a special
airworthiness cei!ificate-primary category, for an aircraft having a current standard aiiworthiness
cei!ificate that meets the criteria of Sec. 21.24(aX1), may obtain the primary category cei!ificate in
exchange for its standard airworthiness cei!ificate throngh the supplemental type certification
process. For the purposes of this paragraph, a current standard airworthiness cei!ificate means that
the aircraft conforms to its approved normal, utility, or acrobatic type design, complies with all
applicable airworthiness diiectives, has been inspected and found airworthy within the last 12
calendar months in accordance with Sec. 91.409(aX1) of this chapter, and is found to be in a
condition for safe operation by the [FAA).
(d) Other aircraft. A:n applicant for a special aiiworthiness cei!ificate-primary category for an
aiicraft that meets the criteria of Sec. 21.24(a)(I), and is not covered by paragraph (a), (b), or (c) of
this section. is entitled to a special airworthiness cei!ificate if--
(1) The applicant presents evidence to the [FAA) that the aircraft confonns to an approved primary,
noJDJa!, utility, or acrobatic type design, including compliance with all applicable aiiworthiness
directives~
(2) The aircraft has been inspected and found aiiworthy within the past 12 calendar months in
accordance with Sec. 91.409(a)(l) of this chauter and:
(3) The aircraft is found by the [FAA) to conform to an approved type design and to be in a
condition for safe o;peration.
(e) Multiple-category airworthiness certificates in the primary category and a:ny other category will
not be issned; a primary category aircraft may hold only one aiiworthiness ceatificate.]
(f) Issuance of an airworthiness certificate for a Primary Non-Commercial category aiicraft.
(I) Pwpose. The FAA issues a Primary Non-Commercial airworthiness cei!ificate to
operate a Primary Non-Commercial aircraft
(2) An owner of an aiicraft rel!istered within the United States mav apolv and is entitled
~ 316 ~
Appendix G
L Men than twenty years have elapsed since the aircraft's date o f manufacture.
3. The aU-craft has a cwrmt =ual iaspedion (14 CFit 91.409) at the time of
application for original issuance.
4 . The airer.tft must be in condition for safe operation (14 CFR 91328) for
retssuance.
(3) Duntion
2. The aircraft may be operated under it's original standard category airworthioess
certificate provided it mHts it type design aod has a current inspection as required
noder 14 CFit 91.409(a), (b) or (d).
3. If tbe aircraft does not meet it>s type design requirements, but is in condition for
sa& operation, it may be operated noder its' Prim.uy Non-Commercial
Airworthiness Certificate pn,,•ided the a.ircraft has a current iD:spection as required
noder snbsection (d)(l) ofthis part.
~ 317 ~
Appendix G
( 9an 91 GENERALOPERATINGANDFUGHTRULES
jsubpan D-Spe<W Fti&ht OpentioltS ;=c=:=,N:,:e=-=; egula:.:o.:.n- - - - - - - - 1
w R;;.:-:'7b
Sec. 91.328
Airc::raft having a special airworthiness certificate in tbe Primary Noo Commercial category: OperatiDg
limitations.
( I) Prim.uy Non Commercial Ca,.goty Aircraft an required to obson·e tbe FAA Approved
Aircraft Flight Manual basic flight operating limitatioas and or required placard
timita.tioQS established for the Staod.ard Category airc::raft unless otherwise FAA
Approved via a Supplemental Type Certificate, Field Apprm·al or other means acceptable
to the adninistrator.
(2) No person may operate Non CoUliDel'cial aircraft for canying persons for ccmpens ation
or hire.
(3) The pilot in command of a Primary Noo Commercial aircraft must ad\'lse each passenger
of the Primary Non Commercial nature of the aireraft, and explain that it does oot meet
the certification requirements of a standard certificated airc::raft.
(4) This aircraft mustc:ootain tbe plaoarck ormazkings, as required by 14 CFR § 91.9.
(5) The aircraft must display, near eac:h -.nee to tbe cabin, c:odpit, or pilot station, in
letters not less than 2 incbe:s nor more than 6 Uxbes high. tbe words "'Primary Noo
Commelcial" or display mazkings as required in 14 CFR 45.22(b).
(6) The pilot in c:ocnmand ofa Prim.uy Noo Commercial aircraft must bold a pilot oertifioa,.
or an authorized imtructor•s logbook endorsement. 1he pilot in command also must meet
tbe requD.m- of 14 CFR § 6131(e), (!), (g), (h), (i), and G), as appropriate. !£
requUed, tbe pilot in command also must bold a type rating in accordance mtb14 CFR
part 61, or an LOA issued by an FAA Flight Staodarck Operatioos lnspedor.
(6) When filing Instrument Flight Rules (IFR), tbe Prim.uy Non Commercial oategcny o f this
ain:raft lDUSI be listed in tbe remazks seotinn oftbe flight plan.
(/) Noo ColDIDeroial (AB) Aircraft require a Plwe I flightiest program as detailed in 14
CFR 91.319 (b) and 14 CFR91305.
(8) Noo ColDIDefoial (IC) Aircraft that ba;-e been altered an extent that would be ooosidered
a Major Clw>ge to Type Design as defined by 14 CFR 21.93 require a Phase I flight ,.st
program as detailed in 14 CFR 91.319 (b) and 14 CFR 91.305.
~ 318 ~
Appendix G
Sec. 45.22
(a) When display of aircraft nationality and registration marl<s in accordance with Sees. 45.21 and
45.23 through 45.33 would be inconsistent with exhibition of that aircraft, a U.S.-registered aircraft
may be operated without displaying those marl<s anywhere on the aircraft if:
(I) It is operated for the pwpose of eahibition., including a motion picture or television production.,
or an airshow;
(2) Except for practice and test fights necessary for e:duOition pwposes, it is operated only at the
location of the e:duoition., between the exluoition locations, and between those locations and the base
of operations of the aircraft; and
(3) For each !light in the United States:
(i) It is operated with the prior approwl of the Flight Standards District Office, in the case of a !light
within the lateral boundaries of the surlace areas of Class B, Class C, Class D, or Class E airspace
designated for the takeoff airport, or within 4.4 nautical miles of that airport if it is within
Class G airspace; or
(ri) It is operated under a flight plan filed under either Sec. 91.153 or Sec. 91.169 of this chapter
describing the marl<s it displays, in the case of any other !light.
(b) A small U.S.-registered aircraft built at least 30 years ago or a U.S.-registered aircraft for which
an eaperimeotal certificate bas been issued under Sec. 21.19l (d) or 21.19l (g) for operation as an
exhibition aircraft, as an amateur-built aircraft and which has the same eaternal configuration as an
aircraft built at least 20 years ago or a Primary Non-Commercial Category aircraft may be operated
without displaying marl<s in accordance with Sees. 45.21 and 45.23 through 45.33 if:
(I) It displays in accordance with Sec. 45.2l(c) marl<s at least 2 inches high on each side of the
fuselage or vertical tail surface consisting of the Roman capital letter ''N" followed by:
(i) The U.S. registration number of the aircraft; or
(ri) The symbol appropriate to the airworthiness certificate of the aircraft ("C", standard; "R",
Primary; "L", linrited; or "X", eaperimental or "C" for Prim.uy Noo-Commercial followed by the U.S.
registration number of the aircraft; and
(2) It displays no other marl< that begins with the Jetter "N" anywhere on the aircraft, unless it is the
same marl< that is displayed under paragraph (bXl) of this section.
(c) No person may operate an aircraft underparagraph (a) or (b) of this section--
(!) In an ADIZ or DEWIZ descnOed in Part 99 of this chapter unless it temporarily bears marl<s in
accordance with Sees. 45.21 and 45.23 through 45.33;
(2) In a foreign country unless that country consents to that operation; or
~ 319 ~
Appendix G
Sec. 65.108
(a) To be eligfble for a Antique Non-Commercial Vintage repa.innan certificate you must meet the
following;
e. Complete a 16 hOW' training course acceptable to the FAA oo inspecting Antique Non 4
Commercial Vintage
(b) The holder of a repainnan certificate (Primary Non-Commercial) may exercise it's pm-ileges on aoy
Antique Non-Commercial Vintage aittnfl: that is owoed by the bolder.
(c) Privileges:
(I) Approve and retwn to sen>ice an aircraft that has been issued a special airworthiness
certificate in the Primary Non-Commercial category under §21.196 of this chapter, or any part
thereof, after perfonning or inspecting maintenance.
(d) Limitations
~ 320 ~
Appendix G
Attachment B
~ 321 ~
Appendix G
National Policy
4005. ~n•raL The procedures in !his section provide guidance for the issuance ofFAA Form8130.7
for aircraft type certificated in the primuy oon..:ommercial category in accordance with 14 CFR §21.24
and21.184.
b. Under the provisioos of 14 CFR § 2124, an applicant for an airworthiness certificat• in the
l'rimai)• oon..:oiiJillefcial category is tnlitled. to the certificate if compliance is shown with the
requirements of 14 CFR 2124 and 21.184.
4006. Ctrtification Proctdures. The FAA represemative should follmv the appropriate procedures
outlined in pazagraph 4002 of!his order.
4007. Eligibility.
a. Tbe following aircraft are eligible for a special airworthiness certificate, in the Primuy
category, are as follov.~:
10. The aircraft must hold or has held an Airworthiness Certificate in aooiher Category
defined by 14 CFlt 23.3
4009. Stattment of Conformity. As the Primuy Non-Commercial Category does not define a type
design, no statememofconformity to !his category is required. For initial issuance, the last properly
completed ammaJ inspection per 14 CFR 91.409 is considered sufficient evidence of confomlity to type
design Forreissuance, the last properly completed ammaJ condition inspection per 14 CFR 21.24 is
consider sufliciem.
4010. Optrating Limitations. All aircraft type certilicated in the Primuy non..:ommercial category
must be operated in compliance with the limitations prescribed in 14 CFR § 91.328.
4012. Airn·orthiness Certificate. When an application is made for a Primuy oon..:oiiJillefcial category
airworthiness certificate '1'rimary Non-CoiiJillefcial" will be entered in block A ofFAA FOllll 8130.7.
Carriage of people for c~tion or hire is prohibited by 14 CFR § 91328 for any Primuy non.
coiiJillefcial category cpentiOOL FAAFonn8130.7 DmSt ha\'e the following words entered in block A
Primuy Non-Commercial ; SEE ATIACHED LIMITATIONS."
~ 322 ~
Appendix G
4013. Display ofMMks {PrimalJ') . The FAA IWSt deten:nine !hat the airCiaft displays natiooality and
registtation marks in accordance wi1h 14 CFR § 45.21, 45.22 and 91.328.
b. Airworthiness Certificates issoed to Primary Non-Commercial Air<nft are nol tr.msfenble. Upon
transfer of ownership the current owner may apply for reissuance of tbe Prim.aJy Non-Commercial
Airwort:hiDe:ss Certificate..
a. If!he airCiaft does not CUireDtly hold a Airworthiness Certificate for a category listed in 14
CFR 23.3, but bas previously held such a certificate, 1he aircraft is eligible to operate under a Primaiy
Non-Commercial Airworthiness Certificate provided !hat i1 is in condition fur safe operation as desaibed
in paragraph 4009.
b . The a.ircraft may be operated UDder it•s original standard category airworthiness certificate
pro\ided it meets it type design and bas a cunmt inspectioo as required undet-14 CFR. 9 1.409(a) , (b) or (d).
Properly documented and completed inspectioos as pre\~ously noted are tbe ooly ev-id.eoce required for
coofotlXWl.<:'e to type design and coostitute the autborizatioo for tbe aire.raft to operate it's original stmd.ard
airworthiDe:ss certificate.
c. If the a.ircra.ft does not meet it's type design requirements, but is in coodition for safe operatioo, it
may be operated onder ils' Primary Non-CoiiJlllel'cial A.ilwof'tbiness CertUicate p=ided the aircraft bas a
cwnnt inspection as required under subsection (d)( I) of this part.
4017. loadeqnate Ol' Fl-.udolent Maintenance Logbook Entries \lhile Operated in the Noo-
Commeccial Catego1-y. Proper Maintenance record keeping as defined in 14 CFR 21.24(d) and 14 CFR
43.9 is essential for 1he safe recoo\..-sion of a Primaiy Non-Cooimerual to standard category. In cases
where there bas been either Inadequate or Fraudulent Maintenance Logbook Entries the airCiafts standard
category airworlhiness certificate should be revoked.
~ 323 ~
Appendix G
1. PURPOSE. This order assigns the Small Airciaft Directorate (SAD) and Airciaft Maintenance
Division, AFS-300, jointly as the responsible offices to accept, maintain, and monitor the industry-
de,'eloped training for Primary Non Comma-cia~ Category repaiimen. It also piO\oides guidance to SAD I
AFS-300 for aooepting industry-de\'eloped training fur Antique Non Omnnen::ial VIntage repainnen
maintenmce rating.
2. DISIRIBUTION. This order is distributed to the director le\'01 in Washington headquarters and the
cen!ers; to all regional administratots; to branch 1""'01 in the Fligbt Standards Sen<ice and the Airciaft
Certification SeMoe; to branch le\'01 in the regional Flight Standards Divisions; and to all Fligbt
Standards field offices.
3. BACKGROUND. The Flight Standards SeMoe director, AFS-1, has assi@led the Small Airciaft
Directorate (SAD) and Airciaft Maintenanoe Division, AFS-300, jointly the responsibility for Primary
Non Comma-cia~ Category repairman programs. This includes aocepting and monitoring required
industry-provided training for Primary Non Comma-cia~ Category repairman.
a. 14 CFR 21.26 establishes oertificates fur operating Primary Non CoiiJDlefcial Category aircraft.
For the pwpose of this order, the follO\\oing definitions will apply:
(1) Pritruuy Non Commerci>J Categot-y airct-aft These types of airaafhWI be identified as
ANV for the pwpose of this order.
b. 14 CFR 65108 establishes a new Primary Non CoiiJDlefciaJ Category oertificate. The
specific training requirements for these ratings are as follows:
(1) An ANV repainnan oertificate is issued to an individual upon successfully oompleting an
FAA-accepted training oowse of at least 16 hours in length. This rating will allow the repainnan to
perfozm all required maintenance on an ANV airaaft owned by him or ber - It however DOES NOT
allow the holder to cooduct the required mona! condition inspection specified by 14 CFR 91.409.
4. DISCUSSION. This order contains the policy to be nsed jointly by the Small Airciaft Directorate
(SAD) and Airaaft Maintenance Division, AFS-300 for the acceptmoe and monitoring of industry-
de,'eloped training for the Antique Non-Commercial Vintage repairman. CirCIIIDSimoes not covered by
this orde.-should be referred to AFS-300 for policy determinations.
~ 324 ~
Appendix G
(1) Regulations and other guidance applicable to f>J'IV airaaft, review of openting limitations,
ammal coodition inspection record entry, a review ofFAA AirwOllltiness Directi\'es (AD) and
manufacturer'S safety direCI:i\'eS.
~ 325 ~
Appendix G
(4) Use of an inspection clleddist prO\oided by 1he marntfacturer or found in FAA AC 90-$9A, Amateur-
Built Airaaft and Ultralight Flight Testing Handbook, appendix A
(S) Student cowse e\'aluation (critique).
(6) A required final test that will OOiltlin no less than 50 questions with llllllfiple-choice answ..-s.
NOTI:: Appticmt mnst achien an SO percent score ot· bightt· on the final test to pass
the cow-se. If the appticnt fails, the cow-se must he cetaken in its entirety.
b. Requirements for FAA Acceptance of a 16-Hour lnspec.tion Rating Cow-se. An applicant
suhmitting a 16-hour I>J'IV airaaft repaiman rating coorse lllliSI submit the following infurmation to
AFS-300/SAD.
(1) A letter of request, identification of the person..- company, location, telephone llUIIlber,
contact person, and the class of Antique Non Commercial Vintage 1he applicanl "ishes to teach. If
instructors are added or removed from 1he coorse, 1he course prO\oider lllliSI submit a letter to AFS-
300/SAD, explaining 1he change at least 2 weeks hefure presenting the next coUISe. Included in the
applicant's letter of request is a statement that the applican:t will allow FAA access to any location where
the training is being held.
(2) A disk with Microsoft~mpattble files containing 1he following:
(a) Course outline =ering the subjects taught and 1he length of time each subject is taught.
The course should be 75 percemlecture and 25 percen1 pmctical training.
(b) Description of !he training aids used, copy of !he Powai'oinl (or similarprogr.tm)
presentations, and a list of the videntapes, pariS, tools, etc~ nsed in 1he course.
(c) Handbooks and hand-ool material.
(d) Desaiption on how 1he training "ill he provided, and how names of students and each
test score result v.ill be maintained for a 2-year period.
~ 326 ~
Appendix G
(g) A schedule of where and when 1he training will be provided over the next l 2 months.
{i) Iflbe coorse "ill be presented at multiple locations natiormide, the applicant lllliSI provide
AFS-300/SAD "ith:
' <\)A schedule ofclasses and locatio.ns fur the fust 12 months.
(B) A scbedule of classes and locatiom for 1he se<XlOld 12 months, at least 30 days
before the I year annhoersary date of 1he letter of aooeptance.
(q A general description of how training is provided at each location
(ii) If the comse "ill be presented at a fixed location, the applicant IWSI pro~<ide AFS-
300/SAD"ith:
(.<\)A scbednle ofclasses for 1he fust 12 months.
(B) A scbedule of classes for the seoorul12 months, at least 30 days before 1he I
year annivmary date oflbe letter ofaoceptance.
(q A desaiption of the filcility.
NOTI:: Tht appliunt mmt notify AFS-300/S.'\D 'lrithin 7
11·orking days of any chang• t"' the schedult (e.g., a com'Se is
added o•· canceled).
(h) A list ofthe make and models of AntiqueNon.COIIllllBCial Vmtagethat will be nsed for
1he practical portion of 1he training.
(i) Explanation ofhow the comse piO\ider willl assign a proctor to collect 1he student course
critiques, and send tbem in a self-addressed and postage-paid em'e!ope to AFS-300/SAD. A proctor is a
studem who agrees to perfonn 1he task identified above. (See Appendix I for a sample student comse
critique)
(j) A description of how 1he comse pro~<ider "ill track studem attendance and how make-up
time "ill be addressed All make-up time lllliSI be completed within 7 days after 1he scbeduled erul of 1he
COUISe.
(2) AFS-300 I SAD "ill assign an identification (ID) lllllllher to each cOUISe. The comse ID \\ill
contain four •lemenl'r tbe prefix "ANVR" fortheANV aircraft repairman.
NOTI:: The conrst prolider is required to dispby the FAA's letter of acctptance at
each location whtl'f" the.course is gh·en. The originallttte•· of acceptance can ~.
displayed on the waD, or a photocopy can be displayed in tht stndtnt's workbook.
~ 327 ~
Appendix G
(3) AFS-300 I SAD will maintain a computer database record on all accepted training providers,
including training COU!Se ID lllllllhers fur each cowse.
(4) Ifm applicant does not meet the mininn!Dl training cowse requirements, AFS-300 will mail a
letter of denial to the applicant within 30 wodcing days after receipt of the application. If a !etta- of
acceptance has been issued but FAA field SIU\oeillance finds the training provide< course is substandard,
AFS-300 may suspend ar revoke the letter of acceptanoe by notifying the training prm.ida-, in writing,
within 5 wodcing days and include the date when the suspension or revocation becomes eflective. AFS-
300 will immediately notify and revoke the Antique Non Commercial Vintage repairman certificate of
my indi\oidual who attended my training provider's cowse dwing the period of substmdard instruction.
No credit will be gi\oen to individuals wbo ful to complete a training cowse.
~ 328 ~
Appendix G
APPENDIX!.
ANTIQUE NON COMMERCIAL VINTAGEREPAIRJil<\N lRAINING COURSE
EVALUATION
Courst Namt: _ _ _ _ _ _ _ _ Course Numbtr: - - - - - - - - -
Instructor: Instruc.tot·:
Instructor: lnsh11c.lot·: - - - - - - - - - - -
Date: Namt (Optio.W): - - - - - - - -
~ 329 ~
Appendix G
Attachment C
~ 330 ~
Appendix G
The Owner-Maintained Airoaft Certification category was created by Ttartspon Canada on April 17, 2000 t i a means to
allow 0\l'DeB of cenain private aircraft to coutinue to operate their airctaft safely in an e:tl\Wamem lll"bere replacement
pans are diffiadt, if DOt imposSl"'ble to obtain.
1. This ategory allows an aircnft co be COil\'ened from r)'pe-<enific.ated aiJwonbioess cen:ificatiao to a special
certification category where 0\\'DSS become re:spoosibJe for maintaining tbeir owua:ircnft, in a uwmer \-el)'
similar to our experimental amateur~ and light-span aircraft categories.
2. Once COil\'ened to tbe Owraer-Maimained certification category 1he OWDet is prohibited fromcoo\rerting it back
to a type-ceni6carioo.
3. Ovroer-MaintaiDed Airoaft are limited to a gliders (CmadianA\iation Regulation (CAR) SUDdard 522) and
small a.iJpbDes (CAR standard 523) that meet these spec.:ific criteria:
a. T)'Jit ceni6cate does DOt autboJize IDOI'e Ibm foar occupants;
b. Maximum ceni6cated t:ake-offweigbt does DOt exceed 1,814 k.g (4,000 pounds);
c. Aircnft is of a type and modellhat bas DOt beell mauufactnred daJillg lhe precedi:Jic: 60 mollihs;
d Fewer than 10% of Canadian airaaftof~ rype and model cODCemedare operating in Canadian
commercial 2ft service at the time of application;
e. P<m'Ued by a single. oormally aspirated, pistoo eDgiDe and is~ and
t. Excepl tDrgUOers, powered gllden or aucratlwub a1r1:1amesocwoooencoo.suucaou, tile alradtype
and toodeJ bas a fixed laDdiDg gear and a find pitch propeller (grotmd adjustable propeUers are
coo.sidered fixed pttc.h propellers).
The 0\'enll accideut tteDds aDd mes indicate that tbe Owraer-~Wmained aitcn:ft category is a s:afe fLeetlll-ith accident
mes comparable 10 Stmclardcateg_ory. 'Ibe foUowiDg is an overview of Canattim 0-M accident rates and iDc.ludes a
comparison to accidents rates for tbe Cmadian Ci\.U Fleet as a wbole. Data Source BAA unless otberllli.se DOted
~ 331 ~
Appendix G
In mos1 ~m the 0-M acddeo.t rate appem to below the rate for stmdard category aUaaft iD geoeral. While tbe oumber
of0--).{ airttaft is staris1:icall)• sigui6cam, DCIIlDl1 random fluctuarioo.s could accOWit for this mu:nber. As tbe number of
0-M acddents is small,. it is possible to n""lhwe tbemoo iodi\-"idnal. basis to~ the OWDeJ m.ainteDalxe privilege
coottibwtd to lbe accid:e:Dts.
It is illusa:ati\·e to ~ that in oo case bas tbe fact that the Aircraft is OM'Del' MaiD!aiDed or tbe use ofDOlKenified pans
been a major or cCllltlibwing factor to any of tbe accidents listed.
1be accident rate data from the Cenamm Oil'Dtl' Maimeoance Category CO\'ers 0\'er a decade of e:xperieoce with a
statistic.ally sigDific.ant fleet size. It indicates that both in te1:1m of accideot rate 8Dd cause, OWDet majntlmence category
aircraft are as safe or safer dlm. stalldlud category airaafl Neither tbe Owner Mainrerwv-e Program nor the use of DOD
cenified CCl"J''P"'l"'" has coam.Duted to en accideat in tbe Cmadien O·M fleet in tbe last decade.
It is si.pificent that io many of tbe yean looked at the 0-M airoaft actnally bad a better (safer) accident rate tbeo.the
StaDdard Category aircraft Likely this is not due directly to the 0-M program. but as en iDdirect effect. lt is likely that
because of tbe Jo\\w costs and greater invoh-emem: of tbe aircraft owne:r:s, usage rates impro\~ which comr:ibtlred
towards pilot cmreDC)'. In eddil:ioD. 0\\'Ders may ba\•e replaced compoDeUts more frequently due to the taA·er cost thus
impm!jng tbe 0\'en:Il mainteoaace of tbe aircraft. Funbe:r, it ts also likety that many of tbe ei:rcra:ft an equipped with
impmred avionics s~ allowing safer flight, than comparable stPDdard c.etegory aircraft beantse of the ltss
burdeDsome appnn.•al p:roc:ess aDd lower cost
1herefore it is safe to coochde that tbe Calladi.aD 0-M system bas ooc denUnemaDy impacted safety eod it ts tikety that
it actually iD dUealy impro\'Od safety.
~ 332 ~
Appendix G
~ 333 ~
Appendix G
Attachment D
~ 334 ~
Appendix G
Active U.S. General Aviation and On-Demand FAR Part 135 Aircraft by Type (2010)
Rotorcraft 10.102
Gliders 1.899
Lighter-Than-Air 3.785
Experimental 24.784
RGURE 1.2 U.S. Manufactured General Aviation Airplane Units and Billings (1 974-2011)
~ 335 ~