FAA/JAA

Changed Product Rule Aircraft Certification Workshop

John McColl

19th Annual FAA/JAA International Conference

Topics
Conference Objectives

FAA/JAA

Background (including TOR, Schedule & Status) Issues/Debate/Progress & Agreements to date Proposed Changes to AC(J) & Examples Training & Implementation

19th Annual FAA/JAA International Conference

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FAA/JAA
Conference Objectives for CPR
To explain the current direction of CPR activity. Clear Understanding of CPR within Authorities & Industry. Unambiguous Advisory Text. Agree Upon Implementation & Training.
19th Annual FAA/JAA International Conference Page 2

Background General

FAA/JAA

Lack of Adequate Guidance and harmonisation (level playing field for old and new products) on change aspects of aeronautical products. Task Force Established 1990 , International Certification Procedures Task Force (ICPTF)). Report issued May 1990 proposing changes to JAR/FAR21 (21.19 & 21.101) to move from a bottom up to a top down approach to certification of changes. JAAC Adopted NPA 21-7 (rule) on 30 May 1999 NPA 21-7 Published in Amendment 2 of JAR-21, 1st March 2001. FAA Published rule in amendment 21-77 on 7th June 2000.
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Background

FAA/JAA

Advisory material prepared by JAA/FAA/TCCA This addressed the process and examples for transport category aeroplanes only. JAA Circulated NPA21-28 on 1st September 2000. Adopted by JAAC (after some revisions in March 2001). NPA 21-28 Published in amendment 3 to JAR-21 on 1st November 2001. FAA Similarly published AC 21.101 August 2001 TCCA will publish their advisory material based on the harmonized AC(J).
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Background

FAA/JAA

Effectivity Dates; 10 December 2001 for transport category aeroplanes 9 December 2002 for all other products Ad Hoc Groups & Steering Committee formed to develop examples for other products. Autumn 2001 Industry & Authority concerns raised regarding implementation & interpretation of significant change. JAA/FAA & TCCA agreed to delay implementation of CPR on all products and continue the revision activity on the advisory material.
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Background
Revised Effectivity Date;

FAA/JAA

10 June 2003 for all products

JAA CST in consultation with FAA / TCCA & Industry created another Ad Hoc Group with Specific Terms of Reference.

19th Annual FAA/JAA International Conference

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FAA/JAA
TOR CPR All Products
TOR Agreed @ CST Meeting January 2002 Pre-TOR Discussion CST & CMT wrt Rule change TOR only Address ACJ Objective Implement CPR (Efficiently & Practically) + Harmonise ACJ Tight Timescale to coincide with 18 month delay (allows for 6 month training and brings all products together)
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FAA/JAA
TOR Deliverable
Harmonise Red/Blue/Green text Add Rotorcraft Examples Identify Discriminators (criteria/fast track) Also:- Develop guidance on extent of change cumulative effects Other Issues:Assumptions Service Experience Big Regs
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TOR 2002 Schedule

Jan 2002 25 February 1st Meeting @ CJAA 5 March 29 March April

FAA/JAA

TOR Agreed & Ad Hoc Group Formed

CMT (Open & Closed Presentation) Draft ACJ circ to Ad Hoc Group CST & RST CST & RST Agreement Required (RST presentation 17/18 April) (CST presentation 23/25 April)
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FAA/JAA
End May Issue Draft NPA (2 month comment period for ACJ) Consultation closed for draft NPA (Reg Div pass comments to Ad Hoc Group) Ad Hoc Review late August (meeting 27 to 29 August) Presentation of the draft AC(J) to RST (12 September)
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Beg Aug

End Aug

Mid Sep

FAA/JAA
End Sept Presentation of draft AC(J) to CST (25/26 Sept) Final NPA & Support Material to CST & RST for final agreement NPA and support material sent to JAAC for adoption by 30 October 2002. JAAC Agreement & Adopt NPA 21-32

End Sept

End Oct

End Nov

19th Annual FAA/JAA International Conference

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FAA/JAA
FAA Status
Draft AC Change 1 now on Public Display AC Published 23 April + FAA Web Site Industry & ACO comments by 5 June Chartered Team meeting 11-13 June Comments to JAA early August Review with Ad Hoc Group late August Publish Dec 2002

19th Annual FAA/JAA International Conference

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FAA/JAA
TCCA Status
TCCA advisory material will be based on the harmonized ACJ/AC Change 1. Canadian industry invited to participate in the public comment process of FAA/JAA on draft Change 1 pending issuance of Canadian CPR final rule. TCCA to remain involved with the FAA and JAA in finalizing ACJ/AC Change 1 TCCA expects to publish their CPR final rule and advisory material by 1st quarter of 2003.

19th Annual FAA/JAA International Conference

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Ad Hoc Gp Mtg

FAA/JAA

28 Participants (Chairman as opposed to St Com) 3 1/2 Days (JAA/FAA/TCCA/CTA/AECMA/AIA) Several original ICPTF members JAA/FAA/TCCA Presentations AIA Presentation 1 Days debate on Philosophy and issues Criteria & Examples agreed Consensus Consensus on Major Issues Agreements

Post Meeting Note; Approx 6 additional conference calls & final draft @ issue 20.
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Issues

FAA/JAA

Industry recommended rule re-write because flawed, stop ACJ, not agreed, outside TOR Rule is not clear on change (TC amendments or everything) Perception of Added Cost, Time & Bureaucracy Significant Criteria Set Too Low Significant = Amended TC was intent of ICPTF If threshold too low: Considerable Number of Significant Changes Configuration Issues make it unworkable Configuration Issues could add risk
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Issues

FAA/JAA

Setting Criteria too low 95% added effort for 5% benefit Industry already complying with 21-7 (21.101) for derivatives Industry / Authorities could not cope with paperwork Rule / ACJ is transferring work from FAA to Industry Large Number of Major Changes Production line changes should be excluded DER Delegation may not work (inconsistent interpretation)
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Issues

FAA/JAA

Examples/Tables; Set Too Low and therefore distort intent Cannot capture all changes Conditional is of no use Too much wiggle room Regulations column is retroactive application Declaration of Not Significant is not value added Flow chart is not helpful or logical DOA Classification of Not Significant required If Criteria is required, the rule Criteria are not appropriate
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Debate

FAA/JAA

TOR is for ACJ only ACJ & training can accommodate issues with the rule ACJ needs to clarify CPR wrt TC & Type Design Review of FAA data suggests actual unique major changes are relatively low; Part 25, ~ 300 (from 3,000 in a 2 year period) Part 23, ~ 80 Part 27/29 ~ 60 Part 33/35,~ 60 Total ~ 500 Number of Significant Changes very small If threshold correct additional effort and paperwork is negligible.
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Debate

FAA/JAA

The design change should drive Significant, not the rule Significant should be based on Criteria and not driven by amended TC Production line changes would normally be not Significant Examples / Tables approximate to amended TC in most cases Setting the threshold too high adds risk of getting it wrong Classification of not Significant would normally be obvious Additional admin burden would be minimal
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FAA/JAA
CPR Cert B
Substantial (New TC) Derivative Models, Extensive Modifications

Process
Minor (N/A)

Major Change

(Significant) Latest Cert Basis Unless; Not ected rea Not materially contributing to afety Im ractical SCs as normal

(Not Significant) Existing Cert Basis Elect to Com ly Special Conditions ay be appropriate (as normal)

19th Annual FAA/JAA International Conference

Production Line Changes

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FAA/JAA
Progress
Criteria set at Product Level Assumptions, examples added to help understanding Cumulative Effect, examples added, weight & thrust Agreed to delete requirements column Agreed that Examples / Tables are required to supplement Criteria Particular debate on assumptions Product Group Consensus Excluded examples will be used for training database
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FAA/JAA
Agree ents - Consensus
The design change should drive Significant, not the rule The change should be at Product level (not component) Automatic Criteria for Significant Tables of Examples that validate Criteria Attempt to have Not Sig examples set at high level Classification / Delegation of Not Significant Threshold approximates to Amended TC / Derivative AC(J) to be drafted reflecting the above
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Changes to AC J)

FAA/JAA

Major re-write & Includes all Products Minimise confusion (Added an applicability, define) Minor, Major, STCs, TC, Type Design Added a General Overview Updated flowchart with steps that relate to text Concentrates on the determination of Significant Addresses classification of changes - Delegation Clearly stated that threshold normally approximates to derivative (Product Level) 3 Automatic Criteria defined Fast Track replaced with more obvious classification
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S te p 1 . I e n tif th e P ro o s e C h a n g e to a n A e r o n a u tic a l P r o u c t

FAA/JAA
o t

S te p 2 . Is th e C h a n g e s ta n tia l? ( 2 1 .1 9 )

2 1 .1

1 (a ) S te p 4 . Is th e P r o o s e C h a n g e c o n s i e re to e ig n ific a n t? 2 1 .1 1 ( ) ( 1 ) Y

Y es Y es

re Y

u ire

n a ffe c te

S te p 6 . A r e th e e e u ire e n ts r a c tic a l a n o th e c o n tr i u te a t e r i a ll t o t h e l e e l o f a fe t ? 2 1 .1 1 ( ) ( )

I r a c tic a l o r o t C o n tr i u tin g a te r ia ll to t h e L e e l o f a fe t

X I

T I

C E R T IF IC A T I O N

B A S IS

19th Annual FAA/JAA International Conference

 

T Y P T IF IC A T 2 1 .1

L A T I

A L I T P I T IF IC A T I

Q T B A

      

         

   

S te p 5 . F o r e e r a r e a , is th e a r e a a f fe c te t h g BB t hhee P r o t ho es e C h ar n e e ? t h e 2 1 .1 1 ( ) ( 2 )

ill t h e l a t e s t e n ts e u s e

    

"!

S te p 3 . i ll t h e la te s t re u ire e n ts e u s e ?

    

ig n ific a n t

A re a s

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Changes

FAA/JAA

Appendix 1, changed from Process to Examples

Criteria Supplemented by Examples; 168 Part 23, 25 Significant, 43 Not Significant Part 25, 17 Significant, 13 Not Significant Parts, 27&29 14 Significant, 9 Not Significant Parts, E&P 14 Significant, 33 Not Significant 70 98

Appendix 2, Impracticality (minimum change (23&25) examples) Appendix 3, Service Experience (minimum change (25 & 29 examples))
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FAA/JAA
Exa ples Significant Changes
Part nly

The following are examples for significant changes:

Description of Product Level hange 21.101(b)(1)(i) Is there a hange to the General onfigu-ration? 21.101(b)(1)(i)Is there a hange to the Principles of onstruction? 21.101(b)(1(ii) Have the assumptions used for ertification been invalidated? otes

Conventional tail to T-tail or Y-tail, or vice versa

Yes

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FAA/JAA
Typical Exa ples of Significant Changes
Large Aircraft
Conf. Const. Assu.
Derivative model, e.g. Increased passenger payload, Freighter version, or Complete update of a certified aeroplane. Modify for flight in known icing conditions by adding ice detection systems. Yes No Yes Updated aeroplane would change principles of construction. Yes Yes Yes Multiple changes packaged into a new model. Increased payload new freighter would change the general configuration and assumptions.

New A/C operating Envelope Requires installation of major new systems & evaluation
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19th Annual FAA/JAA International Conference

Typical Exa ples of Significant Changes

Small Aircraft
Conf. Const. Assu.
Conventional tail to T-tail or Y-tail, or vice versa Yes Yes Yes Change in general configuration. Likely changes in principles of construction & certification assumptions.

FAA/JAA

Addition of cabin pressurisation

No

Yes

Yes

Change in cert Assumptions Requires extensive construction re-assessment.

19th Annual FAA/JAA International Conference

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Typical Exa ples of Significant Changes

Rotorcraft
Conf. Const. Assu.
No Extensive changes to equipment, systems, and installations required to support an upgrade to CATA certification approval Certification for flight into known icing conditions. No No Yes Engine and drive systems rating changes appropriate for CATA and rotorcraft performance requirements, and change in design requirements specific to CATA

FAA/JAA

No

Yes

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Typical Exa ples of Significant Changes Engines

Conf. Const. Assu.
Hydro-Mechanical to FADEC/EEC without backup Yes Yes Yes

FAA/JAA

Change in engine control configuration. Likely change in model designation. Not interchangeable. Assumptions used for certification may no longer be valid Change in methods of construction that can affect inherent strength

A change in the containment case from hard-wall to composite or vice-versa, that is not retrofittable

No

Yes

No

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Typical Exa ples of Non Significant Changes

Large Aeroplanes
Conf. Const. Assu.
Change in type or number of emergency exits. No No No

FAA/JAA

So long as the product change does not require an increase in the number of passengers normally allowed per exit, this is not a significant product level change. This is not a product level change it is a component level change since the basic functionality of the systems are unchanged.

Integrated modular avionics

No

No

No

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Typical Exa ples of Non Significant Changes

Small Aeroplanes
Conf. Const. Assu.
Addition of wingtip modifications (not winglets) No No No

FAA/JAA

Structural strength increases

No

No

No

No change in general configuration, principles of construction & certification assumptions.

19th Annual FAA/JAA International Conference

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Typical Exa ples of Non Significant Changes

Rotorcraft
Conf. Const. Assu.
FLIR or surveillance camera installation No No No

FAA/JAA

Additional flight or structural evaluation may be necessary but the change does not alter the basic rotorcraft certification Certified per rotorcraft HTAWS AC guidance material

Helicopter Terrain Awareness Warning System (HTAWS) for operational credit

No

No

No

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Typical Exa ples of Non Significant Changes

Engines
Conf. Const. Assu.
Increase/decrease in the number of compressor/turbine stages without resultant change in performance envelope Changes to limits on exhaust gas temperature No No No

FAA/JAA

No change in performance. Model designation may or may not change. Assumptions are still valid

No

No

No

No controversy-No comments

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Making the Classification

FAA/JAA

The applicant for a change to type certificate makes a classification of significant/non-significant (the application of 21.101(b)(1)) in one of two ways; 1. By the authority agreeing to appropriate controls and procedures that enable the applicant to make a declaration of not-significant. In all cases the authority retains the option to become involved. An appropriate declaration by the applicant to the authority would be acceptable for this purpose. 2. By the authority accepting the determination of significance relevant to a major modification based on the applicants submission. Note for FAA & TCCA: 2. is replaced by .. 2. By delegation, where appropriate guidelines are in place to support a
classification of not significant by the applicant. The Authority may accept the not significant determination without further showing and rely on the applicants design control system and the authoritys oversight system to monitor and validate decisions.
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Training

FAA/JAA

Training Material (some already available)

(FAA Internal Awareness training was done & TCCA training inc Industry), Do not repeat, Go to Detailed. Agree common material Use draft AC(J) examples as a database for training

Training of Trainers ; Use Ad Hoc Gp

Authority & Industry Members

Training of Authority & Industry Staff

(Joint, if possible)
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FAA/JAA
FAA Training
3 Meetings to update material to include all products and policy changes regarding the AC. Lesson development meetings (July, Oct & Nov 02) Walkthrough meeting in Jan 03 Prototype class Feb 03

19th Annual FAA/JAA International Conference

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TCCA Training

FAA/JAA

Training Lesson development: Oct 02 Jan 03 Awareness Level training: Satellite Broadcast
2 sessions (Jan/Feb 03) 1 day each

Specialist Level training; Classroom Delivery

12 sessions (Feb through May 03) 3 days each Different locations across Canada Canadian industry is an integral part of CPR training 19th Page 38 development and deliveryAnnual FAA/JAA International Conference

FAA/JAA
JAA Training
Population to be trained:
Authority (cert/val JAA teams) Authority (NAAs) Industry 250 (estimated)

Training sessions (only for the cert/val teams):

10 sessions (25 participants)

Trainers: 5 (JAA)
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FAA/JAA
JAA Training
Training for JAA trainers:
Duration: 3 days (including preparation) Location: CJAA Dates: tbd Material: From jointly developed with FAA & TCCA.

19th Annual FAA/JAA International Conference

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FAA/JAA
JAA Training
Training for JAA cert/val specialists
Duration: 3 days (including preparation) Location: CJAA and NAAs (most suitable for each case) Dates: Not yet available Material: From jointly developed with FAA & TCCA.

Training for Authorities (NAA)

(not yet defined)

Training for Industry

(not yet defined)
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FAA/JAA
Implementation
Identify internal procedure changes (JAA/FAA/TCCA) Process for PCMs, Teams & Authorities to submit data to JAA (EASA) on CPR change applications / determinations (Sig & Controversial Not Sig changes) Monitor Progress (Consistency) JAA/FAA/TCCA update & review (initially every 6 months)
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FAA/JAA
Reviewing Objectives
Have we set the bar at the correct level for a Significant Change Clear Understanding of CPR (Authorities & Industry) Training (Timescales & Participation) Implementation

19th Annual FAA/JAA International Conference

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