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TECHNICAL AIRWORTHINESS MANAGEMENT MANUAL

SECTION 1 LEAFLET 2

OVERVIEW OF THE STATE TECHNICAL AIRWORTHINESS REGULATORY FOR DESIGN-RELATED ENGINEERING

INTRODUCTION 1. Upon first sight the regulations in Section 2 can appear intimidating and confusing. Since the individual regulations only define the necessary outcomes it is difficult to grasp the broader requirements. Whilst this difficulty is undesirable, it is also unavoidable if the regulations are to serve their primary purpose. PURPOSE 2. The purpose of this chapter is to provide an overview of the regulatory for designrelated engineering. In particular, this chapter will identify the major classes of organisations and persons mentioned in the regulations and describe the relationships between them. This chapter also provides a brief philosophical overview of the principal regulations relevant to design engineering, noting that further detailed guidance concerning specific regulations is contained in Section 3. DEFINITIONS 3. Definitions relevant to Section 1 are contained in the glossary. All definitions pertaining to the terms used in Section 2 are to be considered as regulatory in nature.

ORGANISATIONS AND PERSONNEL IN THE REGULATORY FRAMEWORK The Technical Airworthiness Regulator and Service Authorised Engineering Organisations 4. The TAR has three distinct roles within the State Technical Airworthiness Regulatory. These roles are to: a. establish a regulatory framework to control who may undertake engineering activities with respect to State aircraft and related equipment, and to establish the requirements those organisations must satisfy, b. define the standards to be applied to the design of aircraft and related equipment, and c. assign authority to organisations or to delegate it to individuals to perform engineering activities on behalf of the SAO, and to ensure those authorities and delegations are exercised in accordance with the relevant regulations. www.dgta.gov.my 1.2 - 1 of 11 TERHAD Rev 1 July 2013

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5. The TAR does not personally conduct all these activities, rather he or she has an extensive staff to provide support where required. Further, to provide flexibility for any future organisational change, the regulations refer to the TAR, not the TARs appointme nt, and not to appointments within the TARs staff. Authorised members of the TARs staff may act on behalf of the TAR; of these, formal actions are classified as Authoritative Airworthiness Advice (refer regulation 1.1.5 and Section 3 Leaflet 5). 6. Most engineering work carried out on State aircraft and related equipment is performed by organizations separate from the TAR and their staff. These organisations are awarded Engineering Authority (EA) to undertake this work, and are referred to as Authorised Engineering Organisations (AEOs). Their authority is generally recorded and promulgated via an Engineering Authority Certificate (EAC) issued from the TAR to the AEO. This arrangement is illustrated in Figure 21. 7. AEOs perform a wide variety of engineering tasks. Some AEOs, such as RMAF Engineering Department, RMAF Air Logistic HQ (MLU), RMN Engineering Department, PUTD, CAESE, UUBPM Engineering and MMEA Air Engineering are responsible for the management of entire aircraft systems. Other AEOs may only be responsible for providing design and/or configuration item management services with respect to particular components or technologies. The regulations make no distinction between these organisations and refer to all as simply AEOs.

TAR
AEOs
AEC AEC AEC

CI Manager of whole aircraft

CI Management of design service provider

CI Management of design service provider

Figure 21 Assignment of Organisational Engineering Authority 8. The TAMM is largely silent on the kind of person to be found within AEOs, generally referring only to competent and authorised persons. Thus AEOs have considerable freedom to determine what organisational structure best suits their situation. The regulations refer to only two distinct positions, a senior executive and a Senior Design Engineer (SDE), and one general class of persons, Design Engineers (DEs). The senior executive is the individual in overall charge or command of the organisation, and therefore has control of resource and schedule issues which impact upon engineering processes. The SDE is the engineer who has overall responsibility for ensuring the quality of the engineering system and its outputs. DEs are engineers with sufficient qualifications and experience to exercise professional judgement in cases where the design requires such judgement, or where the implications of the design may not be readily apparent. www.dgta.gov.my 1.2 - 2 of 11 TERHAD Rev 1 July 2013

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9. Some AEOs may establish Deputy Senior Design Engineers (DSDEs) should circumstances require them. Particularly for larger organisations, the intent is to allow for persons other than the SDE to be able to perform Design Approval of Significant designs without subsequent review of decisions by the SDE, as well as the ability to assign internal EA to subordinate personnel within the scope and level of the DSDEs EA. Use of DSDEs is not mandatory, and overall responsibility for the Engineering Management System (EMS) remains the responsibility of the SDE. Further guidance concerning DSDEs can be found in Section 3 Chapters 1 and 6. Design Acceptance Representatives and Airworthiness Standards Representatives 10. Under the system illustrated at Figure 21, all designs and design changes would need to be forwarded to the TAR for Design Acceptance certification prior to their incorporation. This situation is clearly unworkable, and the TAR has therefore delegated authority to individuals to act as his representative to manage the Design Acceptance process on behalf of the RMAF. These individuals are referred to by the regulations as Design Acceptance Representatives (DARs), and this structure is illustrated at Figure 2-2. 11. DARs are only appointed within those AEOs responsible for the Configuration Item (CI) management of whole aircraft or aircraft related equipment. In effect for in-service aircraft and aeronautical product, this means that only the MLU, RMN Engineering Department, PUTD, UUBPM Engineering and MMEA Air Engineering have DARs. Meanwhile for acquisition of aircraft and aeronautical product RMAF Engineering HQ, Jabatan Arah Tentera Darat, RMN Engineering Department, UUBPM HQ and MMEA HQ have DARs. Where the SDE is not a SAO employee, Design Acceptance certification must be either passed directly to the DAR of the parent aircraft or system, or an Assumption of Design Acceptance agreement must be established between the DAR and the AEO in accordance with Regulation 2.5.9. This agreement allows the AEO to assume Design Acceptance certification normally provided by the DAR for certain types of designs. 12. As stated at paragraph 5, the TAR and his or her staff would normally be responsible for the definition of the standards to be applied to aircraft and related equipment designs and the interpretation of those standards. However, in a number of areas, such as aerial delivery and aircraft stores clearance, there are other organisations having sufficient expertise to identify and interpret these standards. These organisations have been identified in the regulations and are collectively referred to as Centres of Expertise (COEs), thus at this particular time CAESE is the most proficient organisation to perform ASR tasks. The engineering element of these organisations is headed by an Airworthiness Standards Representative (ASR) who, like a DAR, exercises a personal delegation from the TAR to perform the design standard definition role of the regulator (refer Figure 22).

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13. As both the DAR and ASR are performing roles of the TAR under a personal delegation, these positions can only be filled by SAO employees. Also, neither the DAR nor ASR delegations may be further delegated without the explicit and written permission of the TAR.

TAR
AEOs Delegation AEC AEC CI Management of design service provider AEC Delegation

DAR CI Manager of whole aircraft

ASR CI Management of design service provider

Figure 22 Delegation of Engineering Authority to DARs/ASRs Commercial Authorised Engineering Organisations 14. SAO relies heavily upon commercial organisations to provide engineering services in the initial design, construction and maintenance of aircraft and related equipment. Commercial organisations also provide design support for in-service aircraft and related equipment. The State technical airworthiness regulatory applies equally to these commercial organisations as it does to SAO organisations (refer Figure 23). The regulations require that all commercial AEOs: a. b. c. be required to comply with the regulations by an enforceable legal instrument, comply with all applicable regulations, and be sponsored by a Service AEO.

15. The regulations differentiate between Service and commercial AEOs only when necessary; at all other times, they are treated as equally as possible. Where there are differences in treatment, these have arisen because of one of two reasons: a. Firstly, Service and commercial AEOs are bound to follow the regulations via very different mechanisms. Service AEOs are bound by Defence administrative and disciplinary procedures whereas commercial AEOs are bound only via a legal instrument. b. Secondly, the vast majority of commercial AEOs will be contracted by other Service AEOs to perform design services on their behalf, ie virtually all commercial AEOs will form part of a Service AEOs Design Support Network (DSN). Service www.dgta.gov.my 1.2 - 4 of 11 Rev 1 TERHAD July 2013

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AEOs are therefore required to adopt a sponsorship role of the commercial AEOs forming part of their DSN.

TAR
AEOs Delegation DAR CI Manager of whole aircraft AEC AEC AEC Delegation

ASR CI Management of design service provider

CI Management of design service provider

Commercial AECs

Sponsorship CI Management of design service provider

AEC

AEC CI Management of design service provider

Figure 23 Assignment of Engineering Authority to Service and Commercial AEOs How to Enter This Environment 16. Unlike the civil regulatory environment, entry into the State technical airworthiness regulatory framework is not discretionary. If a person or organisation is performing any of the activities covered by these regulations on any State aircraft or related equipment, that person or organisation must apply for and receive the appropriate authority first. Also, no person or organisation will be awarded any authority unless they have a role in designrelated engineering. Entry to the States regulatory is strictly limited to those who are, or will be in the immediate future, actually performing design-related engineering with respect to State aircraft or related equipment. 17. In contrast, the civil regulatory environment is open to anyone who would care to enter and who meets the relevant requirements. Therefore, a person or organisation planning (or hoping) to do work but with no actual tasking at that time can apply for and receive authority to undertake engineering activities at some point in the future. 18. SAO employees seeking personal TAR delegations as a DAR or ASR are to apply via minute, providing suitable evidence of their compliance against the respective requirements of Regulation 1 and Annex A to Regulation 3. www.dgta.gov.my 1.2 - 5 of 11 TERHAD Rev 1 July 2013

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19. Organisations seeking an EAC from the TAR are required to submit an application accompanied by an Engineering Management Plan (EMP) and a copy of all procedures, plans or instructions referenced in the EMP. Such application is to be made directly to the TAR for a Service organisation, and via the identified sponsor AEO for a commercial organisation. Further details of the requirements for an EMP are contained in Section 3 Chapter 1. This application will be reviewed and the applicant organisation evaluated as described in Section 1 Chapter 6 of this manual. 20. The regulations describe a number of processes, and it can be difficult to see how they all fit together. The following paragraphs provide a brief overview of some of the concepts. Regulation areas such as stores clearances and special flight permits are not discussed, as they are applicable to only a relatively small number of organisations. Other areas of the regulations, such as record keeping, have been omitted, as they are general requirements. The regulations can be considered in four broad conceptual areas: Design Acceptance, Type Certification, Design Control and Configuration Item (CI) management. Design Acceptance 21. Design Acceptance is the determination of the technical acceptability of a design to the SAO and by extension, the SAO. Design Acceptance is therefore the cornerstone of the State Technical Airworthiness Regulatory framework and the fundamental reason for the DARs existence. 22. Design Acceptance is a quality management process, not an act. The Design Acceptance process comprises four phases: a. Specification of Requirement. The State technical airworthiness requirements must be articulated via a specification document providing a suitable basis for Design Acceptance in that the requirements are sufficiently complete, verifiable and attainable. The specification document is referred to within the regulations as forming part of the State Technical Airworthiness Regulation Statement of Requirements (SOR), see regulations 2.2.4 and 2.5.7. b. Determination of Competency. The organisation performing the design must be assessed as having, and must be judged to have applied, the necessary quality systems and competence to complete the design and development with acceptable levels of technical risk. The TARs method of recognizing organisational competence is through certification as an AEO to an appropriate level and scope. c. Verification of Requirement Satisfaction. DGTA must ensure that its requirements are satisfied prior to accepting a product. Therefore Design Acceptance requires the verification that the test and evaluation results produced by, or presented to, the DGTA provide adequate evidence that the design complies with the specification. d. Certification of Requirement Satisfaction. Design certification is required from the design agency stating that the design meets the specification. The regulations refer to this as Design Approval certification, see regulation 3.4.3. www.dgta.gov.my 1.2 - 6 of 11 TERHAD Rev 1 July 2013

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23. The Design Acceptance process is the responsibility of the DAR to manage, although certain activities within the process may be delegated to staff or commercial organisations. For example, DARs may delegate review of test reports or design certificates to their staff, or to organisations forming part of their DSN. 24. Despite this, the DAR may not delegate the final act of Design Acceptance certification. This certification is required prior to incorporation of the design in the case of changes to existing equipment, and prior to issue of a MSTC or STC for aircraft acquisitions. While the DAR may not delegate this authority without TAR approval, for designs classified as Minor in accordance with regulation 2.5.3, the DAR may choose to establish an Assumption of Design Acceptance arrangement (see regulation 2.5.9 and Section 3 Chapter 7). Such an arrangement allows specific individuals the ability to assume that the DAR would have provided Design Acceptance certification. Type Certification 25. Type certification is concerned with the issue of a Malaysian State Type Certificate (MSTC) or a Supplemental Type Certificate (STC), based upon the review and acceptance of sufficient evidence that assures the Type Designs compliance with airworthiness requirements. The TAR does not grant MSTCs or STCs, however the TAR is required to make a recommendation to the Airworthiness Board on the technical airworthiness aspects of a Type Design. The MSTC or STC is issued by the SAA based on advice from an Airworthiness Board. The issues of most concern to the TAR in giving his recommendation are as follows: a. compilation and approval of the Design Acceptance strategy (including the provision of evidence that the Design Acceptance strategy has been achieved see Annex A to Regulation 2 and Section 3 Chapter 7); b. c. d. issue of a Design Acceptance certificate; compilation of the Type Record; and compilation of the certification basis description (CBD).

Design Control 26. The regulations require a relatively simple design control process be implemented to reduce the risk of errors. Given that Design Acceptance is the cornerstone of the regulations, the design control process has been regulated from the point of view of what must be done to achieve Design Acceptance certification. Thus it may appear to be presented in reverse order. 27. Design Approval and Design Review. The regulations require that only designs properly approved, via the issue of Design Approval certification, may receive Design Acceptance certification. Requirements for Design Approval and Design Review are prescribed at regulations 3.4.3 and 3.4.4, and guidance is provided at Section 3 Chapter 6.

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28. The TAR considers that Design Review is a critical step in the design control process and essential to ensuring the airworthiness of all designs to be implemented on aircraft or aircraft-related equipment. Thus the regulations require that: a. All designs and design outputs are subject to Design Review (no matter how simple or limited in scope); b. Design Review must be independent (ie. design reviewers must not have participated in the development of the design or design output); and c. for designs judged as Significant, two professional engineers are involved in the development or review of the design. 29. For Significant designs, when a person other than an authorised DE develops a design judged as Significant, the person providing the Design Approval certification (ie. SDE, DSDE or specifically authorised DE) must not have participated in either Design Development or Review, and shall provide a second level of review as part of the Design Approval process. 30. Judgement of Significance. All designs are required to be subject to a judgement of significance. This judgement is an assessment of the technical risk introduced by the implementation of the design and must consider both the probability and consequence of partial performance or failure of a design. Following this judgement, all designs shall be classed as either significant or non-significant. Designs judged as Significant are subject to a more rigorous Design Review and Approval process. For further information, refer to regulation 3.4.5 and Section 3 Chapter 6. 31. Performance of Design and Design Planning. The TAR recognises that designs and design changes originate from many sources and differ markedly in scope and complexity. The regulations therefore have not attempted to control who may perform design. The regulations instead require organisations to conduct design in accordance with a design plan. The design plan is intended to ensure that the design process is adequately guided in accordance with the specification, in terms of its development, review, and approval. For further information concerning design planning, refer to annex A to regulation 2 (TAR Requirements for Design Acceptance Strategies a suitable design plan for Major changes to a Type Design), regulation 3.4.1, and Section 3 Chapter 6. 32. The regulations also require that organisational and technical interfaces are well defined and documented, in recognition of common partnerships between DAR and ASR and other AEOs during design development. Configuration Item Management 33. Regulation 3.5 refers to Configuration Item (CI) management, not simply configuration management. This regulation contains the requirements for AEOs responsible for the management of CIs, as opposed to AEOs who simply perform design on CIs managed by others. Not all of regulation 3.5 will apply to all CI managers, eg. regulations 3.5.4 and 3.5.5 pertaining to aircraft/engine structural management are only applicable to organizations managing whole airframes and engines. www.dgta.gov.my 1.2 - 8 of 11 TERHAD Rev 1 July 2013

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34. Technical Information Review. Organisations managing CIs usually receive large quantities of Technical Information (TI) which may be of use in managing the equipment for which they are responsible. Often such TI will be received as part of an even broader selection of general correspondence, much of which may not be technical in nature. To remain fully informed and capable of discharging their responsibilities, organisations need a process of Technical Information Review (TIR) in accordance with regulation 3.5.2 to collect, record and analyse TI, and decide on the appropriate action to take. For further guidance, refer to Section 3 Chapter 5. 35. Maintenance Engineering Analysis. Regulation 3.5.3 requires that all organisations responsible for CI management put in place a Maintenance Engineering Analysis (MEA) system. The purpose of this system is to: a. CI, b. and identify those maintenance requirements essential to the airworthiness of the

identify the data and analyses underpinning those maintenance requirements,

c. regularly review all aircraft maintenance requirements as a result of relevant TIR received. 36. The MEA system is to be pro-active, constantly monitoring the effectiveness of the maintenance regime already in place as well as providing ad hoc analyses of changes to the CIs maintenance requirements. Therefore, all organisations are to have an MEA Plan (MEAP) which is to be updated at least every two years. 37. Aircraft and Engine Structural Integrity. The SAOs experience with operating and maintaining aircraft has made it clear that airframe lives must be managed very carefully if the aircraft is to remain airworthy, without shortening its life through overly conservative usage and damage assumptions. Thus regulation 3.5.4 requires that airframes receive such management via an Aircraft Structural Integrity Management (ASIM) system. The regulation is very similar to that applied to the more general MEA, however it is more rigorous in that it calls for audits of maintenance requirements against the Aircraft Structural Integrity Management Plan (ASIMP) and other specialized processes. It also requires that ASIMPs be reviewed at least every year (as opposed to two years for MEAPs). 38. Recent trends in aircraft engine design and SAO experience in aircraft engines has shown that engine and engine component lives are best managed using specialised processes similar to those traditionally applied to aircraft structures. Regulation 3.5.5 therefore also requires organisations responsible for the CI management of engines to put an Engine Structural Integrity Management (ESIM) system in place in accordance with an ESIM Plan (ESIMP). 39. Modifications, Substitutions and Deviations. Regulation 3.5 allows three distinct ways of changing the configuration of a CI: these are modifications, substitutions and deviations. The distinction between these classes of change is best illustrated by considering them in the reverse to their listing above. 40. A configuration change to a CI is to be managed as a deviation where: 1.2 - 9 of 11 TERHAD Rev 1 July 2013

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a. one, or a limited number, of CIs within a population will depart from the current approved type design; or b. where the entire population of a CI will depart from the current approved type design for a limited time. 41. Deviations will normally be raised to deal with accidental damage, production errors, deterioration or unavailability of material or parts, or any other occurrence generally limited in duration. 42. A configuration change is to be managed as a substitution where: a. a new part is to be authorised for use in a CI as an alternative to, or replacement for, a currently approved part; and b. the configuration change has no other effect on the functionality, interface characteristics or logistics support requirements of the affected CI or CIs. 43. All other changes are to be managed as a modification. In effect, a modification is a configuration change that effects the whole population of a CI permanently and also affects the form, fit or function of either the CI being changed or other CIs in the relevant system. It must be noted that these classes of configuration change are not absolute and rely upon the judgement of the engineers and technical personnel involved in the process. 44. Incorporation Approval and Service Release. Incorporation Approval of a design change is the formal process of permitting a design change to proceed from the design to the incorporation phase and has the effect of committing whatever resources are required for implementation. Service Release is the process of permitting the actual in-service use of the design change. Each of these processes need to address a wide range of engineering, support, contract, cost and schedule considerations, however, the regulations are limited to engineering issues. Refer to regulations 3.5.12 and 3.5.13, as well as Section 3 Chapter 10 for further detail. 45. The distinction between Incorporation Approval and Service Release regulations lies in the difference between the word draft and all. The documentation set required to fully implement a design will probably still be incomplete for the grant of Incorporation Approval. For example, a design change to an item in the cockpit of an aircraft may receive Incorporation Approval prior to the completion, or even drafting, of any amendments to the flight manual required by that change. Service Release may only be granted in the above example when those hypothetical flight manual amendments and any other documentation amendments are complete and issued. 46. Management of Type Design Data. It was noted earlier that this area of both this chapter and the associated regulations was generally concerned with CI management rather than the rather more restricted configuration management. Regulations 2.2.8, 2.2.9, and 3.5.14 concerning the management of type design data however, are intended to capture the essential outcomes required by the TAR of the discipline commonly known as configuration management.

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47. The primary outcome required of an organisation managing type design data is that only relevant data is used for design activities. For further information refer to TAMM Section 1 Chapter 4.

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