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TECHNICAL AIRWORTHINESS MANAGEMENT MANUAL


SECTION 3 INTRODUCTION AND GUIDELINES TO BECOMING AN AEO Applicable Regulations: 1. 2. 3. Application of Regulations and Procedural Rules Type Certification, Service Release and Design Acceptance Authorised Engineering Organisations INTRODUCTION 1. This chapter serves as an introduction to guidance chapters within this section by providing a cross reference between regulations and guidance. It also provides amplification of the regulatory framework under which an organisation is certified as an AEO. PURPOSE 2. The purpose of this chapter is to provide guidance to organisations on the requirements to obtain an Engineering Authority Certificate (EAC) to operate as an AEO. SCOPE 3. This chapter is applicable to SAO and commercial organisations seeking to operate as an AEO, to conduct design or engineering management activities for State aircraft and aircraft-related equipment. It must be noted that where any conflicts occur between the guidance and the regulations, regulation takes precedence. REGULATION TO GUIDANCE CROSS REFERENCE 4. The regulation to guidance cross-reference detailed in Table 1 provides the location of further background information for particular regulations. It must be noted, however, that the guidance should be read within the context of the applicable regulation to which it refers. This is because the guidance is based upon engineering concepts rather than individual regulatory requirements, therefore some regulations are covered by multiple guidance references. Where guidance is considered Not Applicable, this generally reflects that the regulations are either self explanatory, provide a statement of fact, or are referenced in another publication. LEAFLET 1

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UNCONTROLLED IF PRINTED TERHAD Table 11 Regulation to Guidance cross-reference Regulation 1 Title APPLICATION OF REGULATIONS AND PROCEDURAL RULES 1.1 1.1.1 1.1.2 1.1.3 1.1.4 1.1.5 1.1.6 1.2 1.2.1 1.2.2 1.2.3 1.2.4 1.2.5 1.2.6 1.2.7 1.3 1.3.1 1.3.2 1.3.3 1.3.4 1.3.5 1.3.6 2 2.1 2.1.1 2.2 2.2.1 2.2.2 2.2.3 2.2.4 2.2.5 2.2.6 www.dgta.gov.my General Applicability Rule making Application of these regulations Exemptions Authoritative airworthiness advice Rules of interpretation Design Acceptance Representatives Applicability Application for delegation as a DAR Scope of delegation Eligibility Certificates of authority Duration of certificates Delegation of DAR responsibilities Airworthiness Standards Representatives Applicability Application for delegation as an ASR Eligibility Certificates of authority Duration of certificates Delegation of ASR Responsibilities TYPE CERTIFICATION, SERVICE RELEASE AND DESIGN ACCEPTANCE General Applicability Type Certification Applicability Issue of a Type Certification Recommendation Issue of a Design Acceptance certificate for new aircraft or major changes RMAF Statement of Requirements (SOR) for new aircraft or major changes Airworthiness standards for new aircraft or major changes Statement of Operating Intent 3.1 - 2 of 23 TERHAD Not Applicable Not Applicable Not Applicable Not Applicable Chapter 7 Chapter 7 Chapter 7 Chapter 7 Chapter 7 Not Applicable Not Applicable Not Applicable Chapter 1

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Section 3 Guidance

Chapters 1 and 2 Chapter 5 Not Applicable Not Applicable Not Applicable Not Applicable Chapter 2 Chapter 2 Not Applicable Not Applicable Not Applicable Not Applicable Not Applicable Not Applicable Not Applicable Not Applicable Not Applicable Not Applicable

UNCONTROLLED IF PRINTED TERHAD 2.2.7 2.2.8 2.2.9 2.2.10 2.2.11 2.3 2.4 2.5 2.5.1 2.5.2 2.5.3 2.5.4 2.5.5 2.5.6 2.5.7 2.5.8 2.5.9 2.6 2.6.1 2.6.2 2.6.3 2.6.4 2.6.5 2.7 2.7.1 2.7.2 2.7.3 2.7.4 3 3.1 3.1.1 3.1.2 3.2 3.2.1 3.2.2 3.2.3 Recognition of prior acceptance Type Design Type Records Reserved Compliance findings Special Flight Permits Service Release for Major changes to Type Design Changes to the Type Design Applicability Design Acceptance system for changes to a Type Design Classification of changes in Type Design Changes requiring a new MSTC Supplemental Type Certification Design Acceptance for minor changes to Type Design RMAF Statement of Requirements for minor changes Airworthiness standards for minor design changes Assumption of Design Acceptance certification Other Certification Issues Changes to Planned Withdrawal Date Changes to SOI Issue of Certificate of Airworthiness Reserved Notification of unairworthy conditions Civil Leased Aircraft Definition Applicability Recognition of civil aviation regulatory systems Continued Compliance AUTHORISED ENGINEERING ORGANISATIONS General Applicability Exemptions Engineering Authority Certificates Applicability Certificate required Sponsor AEO requirements 3.1 - 3 of 23 TERHAD Not Applicable Not Applicable Chapter 1 Not Applicable Not Applicable Not Applicable Chapter 7 Chapter 7 Chapter 7 Not Applicable Chapter 7

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Chapters 7 and 14 Chapter 14 Not Applicable Not Applicable Chapter 7 Chapter 7 Not Applicable Not Applicable Chapter 7 Chapter 5 Not Applicable Chapters 2 and 7 Not Applicable Not Applicable Not Applicable Chapter 2 Not Applicable Chapter 2 Not Applicable Not Applicable Chapter 16 Chapter 16 Chapter 16

Chapters 1, 2, 3 and 4 Chapter 1

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UNCONTROLLED IF PRINTED TERHAD 3.2.5 3.2.6 3.2.7 3.2.8 3.3 3.3.1 3.3.2 3.3.3 3.3.4 3.3.5 3.3.6 3.3.7 3.3.8 3.3.9 3.3.10 3.4 3.4.1 3.4.2 3.4.3 3.4.4 3.4.5 3.4.6 3.5 3.5.1 3.5.2 3.5.3 3.5.4 3.5.5 3.5.6 3.5.7 3.5.8 3.5.9 3.5.10 3.5.11 3.5.12 3.5.13 3.5.14 3.5.15 3.5.16 Audits Issue of a Certificate Duration Engineering Management Plan General Requirements of Issue Definitions Personnel Design Support Networks Design control system CI management system Data Equipment, tools and facility requirements Records EMS internal evaluation system Documentation control Design Control Design control system Data Management Issue of Design Approval certification Design Review Judgement of Significance Design Acceptance CI Management Applicability Technical Information Review Maintenance Engineering Analysis Aircraft Structural Integrity Management Engine Structural Integrity Management Modifications Substitutions Deviations Aircraft stores clearance and certification Aerial Delivery Clearances Special Technical Instructions (STIs) Incorporation Approval Service Release for Minor changes to Type Design Management of type design data Instructions for continuing airworthiness Flight manuals and aircraft operating instructions

PU 2103 Chapter 1 Annex A Chapters 2 and 3 Chapter 1 Chapter 2 Chapter 1 Not Applicable Not Applicable Chapters 1 and 2 Chapter 1 Annex A Chapters 2 and 4 Chapters 2 and 6 Not Applicable Chapters 1 and 9 Chapter 1 Annex A Chapter 9 Chapter 2 Chapter 9 Not Applicable Chapter 6 Chapter 9 Chapter 6 Chapter 6 Chapter 6 Chapters 2 and 7 Not Applicable Not Applicable Chapter 5 Chapter 8 Chapter 11 Chapter 17 Not Applicable Not Applicable Not Applicable Not Applicable Not Applicable Chapter 8 Chapter 10 Chapter 10 Chapter 9 Chapter 8 Chapter 8 Chapter 10 Chapter 19

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UNCONTROLLED IF PRINTED TERHAD 3.5.18 3.6 3.6.1 3.6.2 3.6.3 Non destructive testing Operating Requirements Continued compliance Changes to an AEOs organisation Inspections and audit TYPES OF AEO Not Applicable Not Applicable Chapter 2

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Chapter 1 Annex A Chapter 2 Chapter 3

5. How the regulations are applied, and therefore how an organisation is certified as an AEO, is not the same in every case. The process will vary depending on the nature of the work to be performed, and the organization performing that work. As a general rule, however, there are three broad categories, and they are explained below along with an explanation of the general process to be followed for certification. 6. For off-aircraft applications, note that Section 1 Chapter 5 provides guidance on tailoring of the regulations. Depending on the application, tailoring of the regulations may include relaxation of the requirement for the organisation to be an AEO. Note also that for design changes classified as Minor in accordance with regulation 2.5.3, regulation 2.5.6 provides some scope for these designs to receive Design Acceptance certification by the DAR from a non-AEO. SAO AEO 7. SAO AEOs are generally established from scratch, and therefore free to establish an Engineering Management System (EMS) based on literal compliance with the regulations. SAO AEOs will find that the bulk of this chapter, including much of the guidance contained in other chapters within this section, will be directly relevant. Refer to para 16 below for a toplevel amplification of the regulations. 8. SAO organisations requiring an EAC are to submit a formal request to DGTA in accordance with Regulation 3.2.4. The submission is to include an EMP and copies of all referenced plans and procedures. Note that DTA staff will normally provide guidance on development of the submission through preliminary review of draft documentation. Commercial AEO for initial design and production (OEM) 9. An aircraft or major system OEM is in almost all cases an established manufacturer of aircraft and/or related equipment; without such a standing it is unlikely to have been awarded a contract with the Government of Malaysia. The basis for AEO certification of OEMs relies on the determination as to whether its existing systems and processes meet the intent of the regulations. 10. The OEMs existing design control system may already be certified by other recognised military forces or NAAs listed in regulation 2.2.7. Existing certifications provide greater confidence in the organisation, and may assist to reduce both the requirements as well as the amount of effort necessary for AEO certification. Despite this, it is important to ascertain the relevance of the existing certification(s) to the SAO scope of work, whether the team assigned to the SAO contract is covered under that certification, and whether the certification is maintained by an adequate surveillance program. 11. An OEM is recommended for AEO certification by the sponsor AEO or SAO Project Office (PO) responsible for the contract. The format of documentation submitted by the OEM is an EMP. The EMP is to contain:

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a. a cross-reference matrix between the regulations and where the OEMs existing system of procedures meets the regulations intent; b. a description of the OEMs organisational structure, particularly those elements and locations that are to be assigned to the Government contract; and c. a statement by the Senior Executive declaring that the management system documented in the EMP will be applied to the Government contract. 12. The OEM may not always be willing to make fundamental changes to their management system to demonstrate literal compliance with the regulations, therefore an initial evaluation of an OEM for AEO certification is frequently an EMP improvement exercise. This provides the opportunity to gain further insight into the OEMs existing system, to ensure that it is adequately described and referenced in the EMP. Further, it is expected that the OEMs EMP will be quite a small document, likely less than 10 pages. 13. Sponsor AEO responsibilities are described in more detail in Section 3 Chapter 4. Note that this chapter mandates DGTA staff involvement in initial AEO evaluations for new aircraft types and substantial upgrades to existing types. Sponsor organisations are encouraged to contact DGTA staff for advice. 14. Alternative means of compliance. Alternate means of compliance with the regulations in Section 2 are available when certification against alternate regulatory systems or standards can be demonstrated. For these alternative systems, providing certification is maintained via an ongoing surveillance program, compliance with the intent of some regulations may be assumed. The TAR has assessed alternate regulatory systems against the regulations in Section 2; an alternative means of compliance strategy can be found for these alternate systems beginning at Annex C. Commercial AEO for in-service support 15. For commercial organisations providing in-service support, many of the principles of AEO certification for an OEM apply. The key difference, however, is greater variation in how the organisation has been established to service the contract. Even in the event that the OEM is involved via its Malaysian Government subsidiary, the contracted organisation may share little in common with the OEM itself. Therefore, the existing quality, stability, and certifications of the OEM cannot necessarily be applied to the in-service contractor. Initial evaluations (in particular) are generally more involved as a result. For further guidance, refer to Section 3 Chapters 3 and 4. In particular, the TAA has mandated DGTA staff involvement for initial and surveillance activities for specific commercial AEOs. DGTA staff are available for further advice. TOP- LEVEL AMPLIFICATION OF REGULATIONS Organisational Requirements 16. The TAR assigns EA to organisations based on an evaluation of their competence and capability. This evaluation conforms to the OPPD model, that is, an Organisation is authorised by the TAR if it has competent Personnel, documented Processes and access to authoritative Data. Further amplification of these requirements is provided in the following paragraphs. Organisational Systems 17. Organisations must implement a system (or framework) within which engineering activity will be conducted. While an ISO 9001 quality system forms the basic standard, the TAR prescribes additional requirements to assure technical airworthiness. www.dgta.gov.my 3.1 - 6 of 23 TERHAD

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18. Quality Management System (QMS). An organisation-wide QMS is fundamental to any assignment of EA as it establishes a level of control and consistency over an organisations activities. Certification to SIRIM ISO 9001 or equivalent is the minimum standard of QMS required, however since ISO 9001 does not meet all of the TARs technical airworthiness requirements by itself, Regulation 3.2.6 requires organisations to have both a certified QMS and an Engineering Management System (EMS) acceptable to the TAR. The EMS can be considered an extension of the base QMS for engineering activities within the SAO aviation environment. 19. Engineering Management System (EMS). An organisations EMS comprises the organisational structure, responsibilities, processes, procedures and resources that it applies to the conduct and management of engineering. The TAR requires that an AEO must have an EMS with the following key elements: a. Engineering Management Plan (EMP). All AEOs must maintain an EMP that encompasses the entire engineering organisation forming the AEO. An EMP provides a reference to the engineering plans, processes and procedures with which the organisation must comply and thus provides a baseline for initial assessment of the organisation as an AEO. EMPs are approved by the applicants SDE and accepted by the TAR as part of the evaluation process leading to provision of an EAC. Annex A contains guidance on preparing an EMP in accordance with Regulation 3.2.8. b. Design Support Network (DSN). Few, if any, AEOs will have the internal resources necessary to conduct engineering activities autonomously. As a result, AEOs must establish a formal network of external organisations to fill the gaps in their engineering capability. Such a network, referred to as a DSN, is an essential element of an AEOs EMS and must be described in the AEOs EMP. DSN requirements are more fully described in Section 3 Chapter 4. c. Senior Design Engineer (SDE). Each AEO must identify one person, the SDE, responsible to the Senior Executive for ensuring compliance of the organisation with the TARs regulations. SDEs are responsible for assigning EA to individuals within the AEO to perform design and CI management activities. SDEs are also responsible for Design Approval certification of designs generated within their AEO, either personally or by monitoring compliance by staff with approved procedures. The role of SDEs is prescribed in Regulation 3.3.2 and described further in Section 3 Chapter 2. AEOs may further choose to nominate Deputy Senior Design Engineers (DSDEs) to perform a range of SDE-level functions as a means to improve organisational efficiency, however, the use of DSDEs is not mandatory. Further, the appointment of DSDEs does not remove the singular responsibility of the SDE for overall management of the AEOs EMS and its compliance with the regulations. Personnel 20. The TAR requires that EA is only assigned to personnel with appropriate qualifications, training and experience for the scope and level of authority to be assigned. To assign internal EA in accordance with Regulation 3.3.2, SDEs must firstly define an engineering organisational structure as a subset of the overall structure of the parent organisation. (Note that the engineering organisational structure may include individuals external to the immediate AEO where required. For example, limited EA may be assigned from the SDE of an AEO to an external organisations Senior Maintenance Manager). This structure needs to identify the scope and level of EA required by each position and the assessment criteria applied in assigning that EA, and should include not only DEs but all personnel performing engineering activities. This requirement assures the TAR that the AEO is employing sufficient competent and authorised personnel to carry out the full scope of engineering activities to be undertaken by the AEO.

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21. The minimum qualifications, experience and attributes required for the SDE, DSDEs and DEs are prescribed in Annexes A and B to Regulation 3. The SDE may choose to add to these requirements in accordance with the role and nature of the AEOs activities (eg. specific weapon system or technology experience). These additional requirements should be documented within the EMP. In selecting personnel to fill these positions, should applicants fail to meet any of the criteria for the position, then an exemption must be sought. The AEO must apply to the TAR for an exemption for personnel failing to meet the EMP requirements for SDE or DSDE, as well as DE positions where the Regulation 3 Annex B requirements have not been met. Should a DE applicant meet the requirements of Regulation 3 Annex B but not the additional DE requirements prescribed within the AEOs EMP, then the SDE of the AEO is able to issue a local exemption. For further information regarding exemptions see paragraph 28. 22. The minimum qualifications required for a DE at Annex B to Regulation 3 are presented as two options. The option at para 1.a.(ii) requires sufficient qualifications for membership to the Institution of Engineers, Malaysia (IEM) as an Officer Member (OMIEM). While IEM accepts applications for OMIEM based solely on experiential-based qualifications (such as a Certificate in Frontline Management), the TAR requires that DE applicants have academic-based qualifications. These are qualifications gained through attendance at a formal course conducted by a recognised tertiary institution. This requirement of the TAR, while additional to the general IEM minimum, is flexible in application. That is the TAR does not specify any minimum standard for the qualification (eg Diploma), the requirement simply being that the qualification is suitable and relevant to the scope and level of EA to be assigned to the DE. If there is any doubt, SDEs are encouraged to refer to DGTA for advice. Processes 23. Regulation 3.2.4 requires AEOs to maintain and follow documented, controlled and approved procedures for all their engineering activities. AEOs should already have a rigorous documentation control procedure, as this is a prerequisite for QMS certification. The TAR further specifies a number of essential processes, such as internal assignment of authority, Design Support Networks, and the Design Control system. Additional requirements are specified for those AEOs that undertake CI management activities. 24. The need for the TAR to mandate processes and procedures above those required by ISO 9001 is sometimes questioned. The reality is that ISO 9001 is a generic standard, which is to be adapted to meet specific industry requirements (a point which is often overlooked). In Regulation 3 the TAR has defined the level of adaptation required to meet the specific needs of the State technical airworthiness regulatory framework. This approach is in fact very similar to that taken by all recognised National Airworthiness Authorities, such as CASA and the FAA, which prescribe specific requirements for design and management of aircraft and aircraft-related equipment. 25. AEOs, depending on the scope and level of EA assigned to them, are also expected to maintain a number of plans subordinate to their EMP, some of which are prescribed by regulations. Such plans include the Engine Structural Integrity Management Plan (ESIMP) and Aircraft Structural Integrity Management Plan (ASIMP). A listing of plans and key procedures required by AEOs is provided at Annex B. Data 26. As a quality certified organisation, every AEO will already have identified a set of quality records for retention. Regulation 3.3.6 complements and reinforces this requirement of the quality standard by requiring AEOs to maintain access to data that relates specifically to the engineering being performed, particularly for design control activities and related decisions. For AEOs that manage whole aircraft types, Regulation 3.3.6 also covers the most important data set of all; that is, the aircraft Type Design data. The regulations aim to ensure that all data used by the AEO to make engineering decisions is available, relevant, www.dgta.gov.my 3.1 - 8 of 23 TERHAD

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authoritative and approved for use. For further information concerning data, refer to Section 3 Chapter 9. APPLICATION OF THE REGULATIONS 27. Compliance Assurance. Initial and ongoing compliance with TAR regulations by SAO AEOs will be assessed by DGTA through compliance assurance activities, as prescribed by Regulations 3.2.5 and 3.6.3. SAO AEOs will, in turn, perform compliance assurance monitoring of commercial AEOs they sponsor within their DSNs (with the assistance of DGTA as required). Section 1 Chapter 6 describes the process used by the TAR to evaluate AEO applicants and to monitor ongoing compliance through surveillance and audit. Section 3 Chapter 4 provides additional guidance on SAO sponsor AEO responsibilities, while Section 3 Chapter 3 provides specific guidance on the conduct of commercial AEO audits. 28. Exemptions to Regulations. In exceptional circumstances, an AEO (or AEO applicant) may seek exemption from one or more of the regulatory requirements, as provided by Regulation 3.1.2. Regulations that are clearly not applicable to the scope of work to be performed by the AEO should be indicated as Not Applicable within the EMP compliance matrix, and do not require exemption. Exemptions are for regulations that ordinarily should apply, but for some reason cannot be complied with. Such instances are to be fully justified and dealt with on a case-by-case basis through negotiation between SDEs and DGTA acting on behalf of the TAA. Application for, and approval of, such exemptions must always be confirmed in writing. Approved exemptions will also stipulate the timeframe for which the exemption is valid. 29. Application to Designs not Affecting Airworthiness. Section 1 Chapter 5 describes how the regulations apply to RMAF aircraft and aircraft-related equipment, and to other aviation system engineering activities in the SAO. Note
The regulations promulgated in TAMM are primarily focussed on ensuring technical airworthiness. They are not intended to address broader OH&S implications.

PRODUCTION Scope 30. Regulation 3.5.19 covers new aircraft, CIs and any aeronautical product produced specifically for that CI, such as cabling harnesses, mounting brackets, etc. It is not intended to apply to production of lower-level aeronautical product, such as wiring, connectors and fasteners. It is also not to be applied to existing non-AEO OEM suppliers of CIs for inservice use where the OEM is not involved in any integration or installation design activity for an existing Type Design. In other words, regulation 3.5.19 applies where a requirement exists to establish a commercial AEO to produce (as well as design) a new aircraft, or design a change (requiring some degree of production) to an existing Type Design. 31. Rather than regulating Authorised Production Organisations, Production (as defined) may be authorized under an organisations AEO certification, providing the EAC applicant can demonstrate appropriate production control and management systems as specified in regulation 3.5.19. In particular, please note the following: 32. 3.5.19.c(3). Procedures defining the manner of production address the interface issues between the production and design organisations. Such interfaces are essential to ensure that in the event of problems with production, adequate documented procedures are in place to cover part or material substitutions as well as deviations from the approved www.dgta.gov.my 3.1 - 9 of 23 TERHAD

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design, as required. Further, appropriate engineering staff must be involved in the decision making process, and appropriate records are generated from such actions. 33. 3.5.19.c(7)(iii). An essential aspect of production is the certification by the production organization that the product conforms to all specified requirements. Note that this may be in the form of a Certificate of Conformance. MODIFICATION INSTALLATION Significant aircraft maintenance activity 34. A significant aircraft maintenance activity is the determinant as to whether an organisation performing modification installation to an existing Type Design aircraft requires certification as an AMO in accordance with Regulation 4. Significant aircraft maintenance activities are defined at Regulation 3.5.20.a(2). The AEO applicant should make a determination as to whether significant aircraft maintenance activity is likely to occur during the modification installation, and therefore either submit an application for AMO certification, or adjust the level and scope of proposed AEO certification to suit. The following paragraphs amplify arrangements once this determination has been made. 35. Fleet-wide Modification Installation WITH significant aircraft maintenance activity. For any modification installation to an existing Type Design that is conducted concurrently with, or requires substantial maintenance activity, the organisation conducting the fleet-wide installation must be authorised as an AMO, holding a valid MAC for the applicable scope and level of work required. Regulation 3.5.19 refers. 36. Fleet-wide Modification Installation WITHOUT significant aircraft maintenance activity. The TAR acknowledges that there may be instances where a commercial organisation is contracted to design, develop, produce and install modifications to an existing Type Design, and the organisation will be required to achieve and maintain AEO certification. For those instances when fleet-wide installation will not involve substantial maintenance activity, the TAR does not require the organisation conducting the installation to become an authorised AMO. Rather, the organisation will have to demonstrate that the applicable Aircraft Maintenance Regulations (AMRs) have been adequately addressed and processes documented, refer to Regulation 3.5.20. 37. Certification as an AEO including modification installation can be achieved by including the additional AMR requirements within the AEO submission, and the EA scope will be assessed and assigned to reflect the modification installation requirements. Note that this option is made available by the TAR to recognise that the management overheads associated with obtaining full AMO certification, in addition to AEO certification, may be excessive if the modification installation activity is relatively simple. This option does not preclude the commercial organisation from obtaining AMO certification. Further, for organisations with existing procedures compliant with other regulatory systems, compliance of these procedures with the intent of regulation 3.5.20 will need to be demonstrated (as an alternative to the development of new procedures). 38. Trial modifications. The installation of a modification for the purposes of design development, prototyping and trial may be undertaken by the AEO that is developing the modification. The AEO must be able to demonstrate adequate controls over the installation process, to ensure that the technical airworthiness of the trial aircraft is not compromised. Regulation 3.5.6.b details the minimum requirements for trial modifications. Annexes: A. B. Guidelines on the Content of an EMP Examples of Plans and Procedures Required by AEOs 3.1 - 10 of 23 TERHAD

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UNCONTROLLED IF PRINTED TERHAD C. Alternative Means of Compliance SAE AS9100 Revision A

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PU 2103 Annex A to.. Sect 3 Chap 1

GUIDELINES ON THE CONTENT OF AN EMP 1. These guidelines are intended to assist EAC applicants to prepare an Engineering Management Plan (EMP). The purpose of an EMP is to provide a roadmap to an organisations Engineering Management System (EMS), that is, the organisational structure, responsibilities, procedures, processes and resources that an organisation applies to its conduct and management of engineering. Accordingly, an EMP builds upon an organisations Quality System and focuses the principles of quality management upon engineering (an EMP may be considered as a Quality Manual for engineering in the aerospace environment). The EMP may be focussed on engineering applied by the organisation to manage an existing aircraft weapon system (for example, a SPO), a project (for example, an aircraft acquisition project), or specialist engineering services provided (for example, Non Destructive Testing). 2. The EMP provides a documented baseline for evaluation and audit of the engineering system to verify its effectiveness. As such, the EMP is the key document supporting the assignment of EA to an organisation. Note that many organisations have established a system that supports design activity on aircraft and aircraft-related equipment that has been developed over time to comply with other regulatory environments (for example CASA, JAA, FAA, US DoD, UK MoD). The EMP is the document that discloses how these established processes and procedures meet the State technical airworthiness regulatory requirements, as the TAR does not necessarily expect that organisations will develop a unique range of processes and procedures in support of the SAO. In such cases, the EMP could simply be an interface document pointing to existing established processes to meet State regulatory requirements. The guidance below covers the minimum content requirements of an EMP prescribed by Regulation 3.2.8. GUIDANCE ON REGULATION 3.2.8 Introduction 3. The EMP should begin with an introduction describing the role of the organisation in broad terms along the lines of a mission statement. Following on from this statement of purpose should be a description of the strategy being adopted for overall management of the supported aircraft weapon system/s. This description should indicate the balance between the AEO and external agencies (including contractors) in the long-term management of the weapon system/s. By identifying the existence of relationships between these organisations, the introduction prepares the reader for explanation of the details of those relationships in the body of the EMP. Statement by Senior Executive 4. The Senior Executive is the person in overall charge or command of the organisation, thus this position has control of resource and schedule issues which impact upon engineering processes. The statement by the Senior Executive provides the top-level commitment by the organisation to meet its regulatory requirements as an AEO. The Senior Executive is required to confirm that the EMP and all referenced plans, procedures and instructions accurately reflect the engineering organisation. The Senior Executive is also required to give an undertaking that the necessary resources are available for the AEO to carry out its engineering activities. Regulation Compliance Table 5. The EMP is to include a table, or matrix, cross-referencing each regulation requirement to the specific plans, procedures and instructions used to demonstrate www.dgta.gov.my 3.1 - 12 of 23 TERHAD

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compliance with the requirement. The compliance matrix serves multiple purposes, as follows: 6. It provides the AEO applicant with a systematic approach to developing the EMS to satisfy all the relevant regulatory requirements. The process will highlight areas where an organisations existing management system requires further definition to address all of the TARs procedural requirements. 7. It allows the organisation to identify which regulations are relevant to the scope of work sought as an AEO and also those that should be highlighted as not applicable. For those regulations deemed to be not-applicable, a brief justification should be included in the compliance matrix. Regulations that are applicable but require no direct action or documented process should be annotated as noted. 8. A properly completed compliance matrix greatly assists the TARs review of the overall applicability and compliance of the applicants EMS in the evaluation phase leading to AEO certification. The compliance matrix allows the TARs staff to verify by desktop review that the applicants documented system meets the regulatory requirements. This gives confidence that the organisation understands the regulatory requirements and generally results in a smoother compliance (on-site) evaluation. 9. The compliance matrix should be structured to show compliance of the applicants EMS against all regulations, down to sub-numbered level, from Regulation 1 through Regulation 3. An example compliance matrix for the fictitious XXSPO organisation is shown at Appendix 1. Scope of Engineering Activities 10. The scope statement, together with the level statement described below, puts the remainder of the EMP into context by establishing the bounds of the activities to be performed by the organisation and its need for authority from the TAR to perform those activities. 11. The scope of engineering activities is to be described by some combination of systems and design services. System scope is to be defined in terms of aircraft typespecific systems, sub-systems or major assemblies, further refined as necessary by system classification (for example primary, secondary or tertiary structure) or system criticality. There is no need to include in the EMP an exhaustive list of all CIs to be managed by the AEO; this information should be visible through other configuration management documents. Design service scope is to include provision of one or more processes, technologies or disciplines. Where necessary, the design services being provided may be further defined in terms of design change significance. 12. The scope of engineering authority sought by an applicant must be consistent with organisational structure, competence and extent of external support networks. For commercial AEOs the scope of EA awarded by the TAR cannot exceed that defined in the formal instrument with the SAO sponsor AEO. Commercial AEOs should therefore carefully review the engineering requirements of their contract or other formal instrument to ensure that all relevant activities which require EA are included in the EMP. Equally, the EMP should not seek EA for activities outside the scope of work of the formal instrument. Level of Engineering Activities 13. Level relates to the highest level of engineering authority exercised for the scope of activity. The highest level exercisable by a commercial AEO is Design Approval certification, as defined by Regulation 3.4.3. Design Acceptance certification is a Malaysia corporate governance function, therefore only a SAO AEO with a resident Design Acceptance Representative (DAR) can be awarded organisational EA for Design www.dgta.gov.my 3.1 - 13 of 23 TERHAD

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Acceptance certification. In this case the EA awarded to the organisation complements the personal delegation given to the DAR. 14. Where the highest level of EA varies for different activities within the scope, the level of EA for each activity or group of activities should be identified. Similarly, if the highest level of EA does not incorporate lower levels of EA then this should also be highlighted. For example, a SAO AEO may require authority for Design Acceptance certification for all aspects of the aircraft weapon system design, but may only be able to perform Design Approval certification for a limited scope commensurate with the internal competence and capability of the organisation. 15. The description of scope and level, or levels, of activity in the applicants EMP combines to define the statement of organisationl EA being sought from the TAR. This determines the bounds for assessing the organization against all elements of the OPPD model described earlier. The rest of the EMP should explain how the organisation is structured to perform the full scope and level of engineering activities. Organisational Certifications 16. Regulation 3.2.6 requires the applicant to hold ISO 9001 or equivalent quality certification relevant to the scope of work to be performed as an AEO. The importance of quality certification is discussed in the main body of this chapter. The EMP is required to provide evidence of quality certification and should fully define the scope of activities covered by the certification, which must include the complete scope of work to be perfromed as an AEO. The EMP should also specify any other relevant engineering or airworthiness certifications (such as those awarded by CASA, JAA, FAA, UK MoD, US DoD etc) that would aid the TARs overall assessment of the competence and capability of the organisation. This includes any previous or current EACs awarded by the TAR. If the applicant has an existing EAC the EMP should clearly identify the new scope and level of EA being sought and demonstrate how the organisation has extended its EMS to cover the new or expanded scope of work. Organisation Chart 17. The purpose of the organisation chart is to identify all those appointments within the AEO that will exercise EA, in accordance with Regulation 3.3.2. This allows the TAR to determine whether the staffing structure is appropriate to support the whole scope of engineering activities. It also highlights the lines of responsibility and access requirements between key personnel, for example, between the Senior Executive and SDE as required by Regulation 3.3.2. The organisation chart should list position titles rather than individual names. 18. The organisation chart should identify the positions of: a. b. c. d. e. the Senior Executive; the Senior Design Engineer (SDE); any Deputy SDEs (DSDEs); Design Engineers (DEs); and other positions requiring EA (including positions external to the organisation).

19. Accompanying the organisation chart should be a brief narrative of the scope and level of engineering responsibilities associated with each position or type of position. Note that positions requiring EA at a level lower than DE may be disclosed in general terms, that is not every individual position is required to be shown. www.dgta.gov.my 3.1 - 14 of 23 TERHAD

UNCONTROLLED IF PRINTED TERHAD SDE and DSDE details

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20. Having identified in the organisation chart all positions requiring EA, the EMP must then include detailed curriculum vitae for the actual persons nominated for the SDE position and any DSDE positions. The qualifications, training and experience of the SDE and DSDEs (if nominated) are required because the TAR personally assesses the suitability of these individuals against the criteria in Regulation 3 Annex A. The TAR accepts the SDE and any DSDE appointments as part of acceptance of the EMP as the basis for the AEO. Unless otherwise specified the TAR allows the SDE appointment to exercise EA for the whole scope of organisational engineering activity. Additionally, DSDEs may be granted EA for the full scope of engineering activity (equal to that of the SDE) if the person demonstrates the necessary competence. However, the SDE remains the sole person responsible for management of the AEOs EMS. Design Support Network (DSN) 21. The DSN description collates a number of regulatory requirements on the AEO to establish relationships with external support agencies. There are certain types of organisations that must be included in the applicants DSN, as listed in Regulation 3.3.3. Applicants should first read Regulation 3.3.3 and Section 3 Chapter 4, Getting Help Design Support Networks, for a thorough understanding of DSN requirements before completing this section. 22. The EMP should provide, through its description of DSN members and services, a rationale of how the DSN is structured to enable the AEO to achieve its full scope of engineering responsibilities. Applicants who intend to rely substantially on subcontractors to provide engineering activities will need to clearly demonstrate how the subcontractors will be evaluated, selected and monitored (which includes audit) to ensure that the subcontractors meet both the TARs regulatory requirements and the technical requirements of the AEO. 23. A crucial element of support provided by external agencies is the provision or management of data related to CIs managed by the AEO. For this reason, the DSN section in the EMP must also include: 24. A list of all sources of technical information (TI). This listing allows cross-reference to the DSN to ensure that the AEO has established links with all external sources of technical information that could affect the AEOs airworthiness management of a CI or CIs (for those AEOs that manage CIs). 25. An explanation of any data access agreements and associated intellectual property rights, as prescribed by Regulation 3.3.6. Such agreements with the data provider (an original equipment manufacturer for instance) should address not only the direct access needs of the AEO, but also the possibility of third party access requirements for subcontractors assisting the AEO. 26. Interface arrangements with DSN members for management of Type Design data, to ensure that only relevant and authoritative data is used. These arrangements may cover, for example, the provision of Type Design data held by the AEO (as CI manager) to DSN members to assist in a specific task, or the provision of Type Design data from an OEM to the AEO on an as-needed basis. As previously mentioned these arrangements along with the other data-related requirements complement the overall description of DSN relationships in the EMP. 27. The TAR acknowledges that it can take some time to establish mature relationships with all DSN members. Hence, the emphasis during an initial AEO evaluation is to ensure that the AEO applicant has identified all the relevant external organisations and has evaluated those organisations for their suitability to provide competent engineering www.dgta.gov.my 3.1 - 15 of 23 TERHAD

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services. The EMP, at the time of submission to the TAR, should clearly reflect the current status of each DSN member, as well as the proposed mature relationship and the plan for achieving the mature arrangement (for example, subcontract, Memorandum of Understanding or other formal agreement). Locations of Engineering Activities 28. This section helps to define the overall organisation that comprises the AEO, especially where the organisation performs work under its AEO scope at multiple sites. The EMP should also identify those elements of engineering activity that are carried out at DSN member locations, particularly for major subcontractors. This is cross referenced against the preceding information on DSN relationships and organisational interface requirements. 29. The EMP should provide sufficient information to demonstrate that each of the Organisation, People, Processes and Data (OPPD) elements are in place at each location where work will be undertaken by the AEO. The TAR will determine which locations of the applicants organisation, and subcontractors where applicable, require onsite audit as part of the initial AEO evaluation process, per Regulation 3.2.5. Equipment, Tools and Facilities 30. Once the locations of all engineering activities within the scope of the AEO are identified, the EMP should then describe the necessary equipment, tools and facilities (ETF) at these locations to support these engineering activities. For example, the AEO may need access to specialist ETF in order to develop and test a design before Design Approval certification can be made. The ETF could be both software (for example, a finite element modeling package) and hardware (for example, an ultimate tensile strength testing machine). Arrangements for access to ETF not possessed by the applicant are also to be described. EMP Amendment Process 31. The SDE approves all changes to the EMP, however prior acceptance from the TAR is required before issuing an amendment that would alter the basis of AEO certification. These specific instances are prescribed in Regulation 3.6.2 and cover changes to the key personnel, scope or location of engineering work. The EMP should acknowledge the requirement for such proposed changes to be sent to the TAR, either directly, in the case of a SAO AEO, or through the sponsor AEO in the case of a commercial AEO. The TAR will determine if any additional compliance assurance activity is required prior to accepting an organisational change. A change to the engineering scope will trigger, at a minimum, reissue of the Letter of Engineering Authority. In general minor changes to an EMP (such as correction of typographical errors, references to updated procedures etc) do not require prior acceptance by the TAR. Contacting TAR Staff 32. Airworthiness Regulation Section is the regulatory arm of DGTA, responsible for managing the evaluation of new AEO applicants on behalf of the TAA. SAO organisations seeking further advice on the preparation of an EMP should contact ARS-DTA staff directly. Commercial AEO applicants should contact their SAO sponsor AEO in the first instance, although DGTA may provide further guidance if required. The AEO compliance assurance activities conducted by ARS-DGTA are detailed in PU 2103 (TAMM), Design and Technology Services Support Manual, Section 2 Chapter 1. Appendix: www.dgta.gov.my 3.1 - 16 of 23 TERHAD

UNCONTROLLED IF PRINTED TERHAD 1. Example Regulation Compliance Matrix XXSPO

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EXAMPLE REGULATION COMPLIANCE MATRIX XXSPO Table 1A11 Example Regulation Compliance Matrix XXSPO Regulation 1.1 1.1.5 1.2 Title General Authoritative Airworthiness Advice Design Acceptance Representatives Delegation of DAR Responsibilities Airworthiness Standards Representatives General Issue of a Type Certification Recommendation Issue of a Design Acceptance certificate for new aircraft or major changes RMAF SOR, Airworthiness standards for new aircraft or major changes Statement of Operating Intent Recognition of prior acceptance Type Design, Type Record Reserved Compliance Findings Special Flight Permits Service Release Applicability, Design Acceptance system for changes to a Type Design Classification of changes in Type Design Changes requiring a new MSTC, Supplemental Type Certification Design Acceptance for minor changes to the Type Design RMAF Statement of Requirements for minor changes 3.1 - 18 of 23 TERHAD Refer ASD QMS procedure 3-2-1-6 PDAS Development Refer ASD QMS procedure 3-5-1-1 Refer ASD QMS procedure 3-5-1-1 (Minor) XXSPO SI(LOG) 2-28 Design Acceptance Process (Major) Refer ASD QMS procedure 3-2-1-10 Refer ASD QMS procedure 3-2-1-6 PDAS Development Refer ASD QMS procedure 3-5-1-1 Compliance Noted XXSPO SI(LOG) 2-26 Technical Information WGCDR Barnes Wallace appointed XXSPO DAR vide certificate no. DTA666 XXSPO SI(LOG) 2-18 Assignment of internal EA Not Applicable Noted Refer ASD QMS procedure 3-5-1-1 Type Certification Plan Development Refer ASD QMS procedure 3-2-1-10 Design Acceptance Refer ASD QMS procedures 3-3-3-1 (Specification Development) and 33-3-2 (Statement of Work Development) Refer ASD QMS procedure 3-3-1-1 Refer ASD QMS procedure 3-5-1-1 Refer ASD QMS procedure 3-5-1-1

1.2.7 1.3 2.1 2.2.2 2.2.3

2.2.4, 2.2.5

2.2.6 2.2.7 2.2.8, 2.2.9 2.2.10 2.2.11 2.3 2.4 2.5.1, 2.5.2

2.5.3 2.5.4, 2.5.5 2.5.6 2.5.7

XXSPO SI(LOG) 2-28 Design Acceptance Process XXSPO SI(LOG) 2-28 Design Acceptance Process

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UNCONTROLLED IF PRINTED TERHAD 2.5.8 2.5.9 2.6.12.6.2 2.6.3 2.6.4 2.6.5 2.7 3.1 3.2.13.2.7 3.2.8 3.3.1 3.3.2 Airworthiness standards for minor design changes Assumption of Design Acceptance certification Changes to PWD/SOI Issue of Certificates of Airworthiness Reserved Notification of unairworthy conditions Civil Leased Aircraft General Engineering Authority Certificates Engineering Management Plan Definitions Personnel Noted Not Applicable Noted

PU 2103

XXSPO SI(LOG) 2-28 Design Acceptance Process XXSPO SI(LOG) 2-28 Design Acceptance Process Noted XXSPO SI(LOG) 2-35 Certificates of Airworthiness

Noted, Sponsor AEO / Commercial AEO aspects refer to XXSPO SI(LOG) 2-4 DSN XXSPO SI(LOG) 2-1 to 2-8 EMP Noted XXSPO SI(LOG) 2-2 Organisation XXSPO SI(LOG) 2-18 Assignment of internal EA XXSPO SI(LOG) 2-17 Professional Development and Training XXSPO SI(LOG) 2-4 Design Support Network Noted XXSPO SI(LOG) 2-32 Management of Data XXSPO SI(LOG) 2-6 Equipment, tools and facilities XXSPO SI(LOG) 2-19 Engineering Records XXSPO SI(LOG) 2-21 Internal Engineering audits XXSPO Quality Manual XXSPO SI(ADMIN) 1-3 Control of Documentation XXSPO SI(LOG) 2-28 Design Acceptance Process XXSPO SI(LOG) 2-11 Data Management XXSPO SI(LOG) 2-28 Design Acceptance Process XXSPO SI(LOG) 2-27 Judgement of Significance XXSPO SI(LOG) 2-28 Design Acceptance Process Noted

3.3.3 3.3.4, 3.3.5 3.3.6 3.3.7 3.3.8 3.3.9

Design Support Networks Design Control, CI Management Data Equipment, tools and facilities Records EMS Internal Evaluation System Documentation Control Design Control System Data Management Issue of Design Approval Certification Judgement of Significance Design Acceptance Applicability 3.1 - 19 of 23 TERHAD

3.3.10 3.4.1 3.4.2 3.4.3, 3.4.4 3.4.5 3.4.6 3.5.1 www.dgta.gov.my

UNCONTROLLED IF PRINTED TERHAD 3.5.2 3.5.3 3.5.4 Technical Information Review Maintenance Engineering Analysis Aircraft Structural Integrity Management Engine Structural Integrity Management Modifications Substitutions Deviations Aircraft stores clearance and certification Aerial delivery clearances Special Technical Instructions (STIs) Incorporation Approval Service Release Management of type design data Instructions for continuing airworthiness Flight manuals and aircraft operating instructions Weight and Balance Non Destructive Testing Operating Requirements Approved Maintenance Organisations Aircraft Maintenance and Management Procedures Not Applicable

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XXSPO SI(LOG) 2-26 Technical Information XXSPO SI(LOG) 2-33 Maintenance Requirements Determination F-XX ASIMP XXSPO SI(LOG) 2-36 Management of Aircraft Structural Integrity F-XX ESIMP XXSPO SI(LOG) 2-37 Management of Engine Structural Integrity XXSPO SI(LOG) 2-29 Modification Orders XXSPO SI(LOG) 2-30 Technical Substitutions XXSPO SI(LOG) 2-31 Deviations XXSPO SI(LOG) 2-38 Aircraft stores clearances Not Applicable to fighter aircraft XXSPO SI(LOG) 2-39 Special Technical Instructions XXSPO SI(LOG) 2-40 Configuration Control Boards XXSPO SI(LOG) 2-40 Configuration Control Boards XXSPO SI(LOG) 2-11 Data Management XXSPO SI(LOG) 2-12 Technical Publications XXSPO SI(LOG) 2-12 Technical Publications XXSPO SI(LOG) 2-41 Management of aircraft weight and balance XXSPO SI(LOG) 2-42 Non Destructive Testing Noted Not Applicable

3.5.5

3.5.6 3.5.7 3.5.8 3.5.9 3.5.10 3.5.11 3.5.12 3.5.13 3.5.14 3.5.15 3.5.16 3.5.17 3.5.18 3.6 4 5

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EXAMPLE OF PLANS AND PROCEDURES REQUIRED BY AEOS


33. The following list of plans represent those normally required by AEOs, which are usually contained or referred to within the Engineering Management Plan, and the regulations that they will satisfy: Type of Plan Quality Plan Configuration Management Plan (CMP) Integrated Logistics Support Plan (ILSP) Maintenance Engineering Analysis Plan (MEAP) Aircraft Structural Integrity Management Plan (ASIMP) Engine Structural Integrity Management Plan (ESIMP) Regulatory or Publication Reference Regulation 3.2.6 Not a TAR requirement Not a TAR requirement Regulation 3.5.3 Regulation 3.5.4 Regulation 3.5.5

34. The following list of required procedures is not exhaustive, but indicates some of the key processes that AEOs are normally required to document: Process Assignment of internal EA procedures including those for: Assessment of engineering staff for assignment of EA; Method of documenting authorisations; Ongoing competency development; and Appointment of staff to hold EA on a temporary basis. Design Support Network procedures (refer Section 3 Chapter 4): Identify each member of DSN and services provided; Define how the services provided are to be treated; Ongoing evaluation of DSN effectiveness; Assessment of new organisations for DSN; and Compliance assurance procedures (where applicable) Data management and record control procedures: Clearly identify all design reference data; Full disclosure of all intellectual property rights; Control of design reference data; and Retention and control of all engineering records Internal evaluation procedures: Describe relationship with Quality System internal review; SDE review of engineering outputs; Internal audit program of engineering staff and procedures; and Method for undertaking corrective action. Regulation 3.4.2 Regulation 3.3.8 Regulation 3.3.9 Regulation 3.3.6 Regulation 3.2.3 Regulation 3.3.3 Regulatory or Publication Reference Regulation 3.3.2

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UNCONTROLLED IF PRINTED TERHAD Procedures relating to the design control system Specification development and approval; Design development plans and drawing control; Judgement of Significance; Design Review and Design Approval (including certification); Design Acceptance certification (where applicable); Assumption of Design Acceptance certification (where applicable); Test, evaluation, verification; and Configuration management. Technical Information Review procedures (refer Section 3 Chapter 5): Clear identification of TI to be collected; Method for registering and sequence checking TI; Priority exchange of TAAI; Recording TI applicability and action taken; and Authorisation of personnel to undertake TIR activity. CI management procedures (where applicable): MEA; ASIM; ESIM; Modifications; TSUBs; Deviations; Stores clearance; Aerial delivery; STIs; Incorporation Approval; Service Release; Control of Type Design data; Management of instructions for continuing airworthiness; Management of flight manuals and operating instructions; Weight and balance; and Non destructive testing. Regulation 3.5.3 Regulation 3.5.4 Regulation 3.5.5 Regulation 3.5.6 Regulation 3.5.7 Regulation 3.5.8 Regulation 3.5.9 Regulation 3.4

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Regulation 3.5.2

Regulation 3.5.10 Regulation 3.5.11 Regulation 3.5.12 Regulation 3.5.13 Regulation 3.5.14 Regulation 3.5.15 Regulation 3.5.16 Regulation 3.5.17 Regulation 3.5.18

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ALTERNATIVE MEANS OF COMPLIANCE SAE AS9100 REVISION A 35. AS9100 - Quality Systems Aerospace Model for Quality Assurance in Design, Development, Production, Installation and Servicing is a standard published by the Society of Automotive Engineers. It is based on ISO 9001 and adds aerospace-specific requirements to provide a harmonised standard for aerospace companies worldwide. The standard is gaining wide acceptance. 36. For acquisition of new aircraft types, due to the inherent confidence that may be placed in the design capabilities of an OEM certified to AS9100, the process of such an organisation becoming an AEO can be considerably abbreviated, as: (1) it would be anticipated that many of the procedures required to be in place to achieve AS9100 certification would satisfy the design-related regulations of the TAMM; and (2) there is no need for the organisation to satisfy many of the CI managementrelated regulations. AEO Application 37. A submission for such an AEO applicant certified to AS9100 is to consist of: (1) evidence of the organisations AS9100 certification, with scope applicable to the design activity to be undertaken for the SAO; (2) evidence of ongoing surveillance of the OEM by the AS9100-certifying agency that is relevant to the SAO scope of work and of satisfactory quality; (3) a compliance matrix showing how the OEMs procedures meet the intent of relevant TAMM regulations; and (4) a Senior Executive statement declaring that the organisation will comply with their suite of procedures referred by the cross-reference matrix. Sponsor AEO assessment 38. The sponsor AEOs assessment of the candidate OEM for certification as a commercial AEO is to consist of the following minimum requirements: (1) a desktop assessment of the procedures (with the aid of the cross-reference matrix); and (2) assessment of the organisations AS9100 certification and ongoing surveillance for adequacy and relevance to the RMAF scope of work. 39. On-site initial compliance or ongoing compliance / surveillance audit activities are not mandatory, but may be included at the discretion of the sponsor AEO SDE. 40. Potential sponsor AEOs intending to follow this alternative means of compliance to certify an OEM as an AEO for a new aircraft type acquisition must document this intention within an initial evaluation plan for DGTA endorsement in accordance with Section 3 Chapter 4. Please contact DGTA as early as possible for advice.

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