New Manufacturing Rules: A Briefing on the Most Significant FAA Manufacturing Rule Change in 50 Years

Transcription

1 New Manufacturing Rules: A Briefing on the Most Significant FAA Manufacturing Rule Change in 50 Years FAA Part 21/SMS Aviation Rulemaking Committee (ARC) Presented by: Walter Desrosier General Aviation Manufacturers Association (GAMA) and Part 21/SMS ARC Industry Co-Chair

2 FAA Type Certification Process: Evolution of Continuous Improvement Part 21 Certification Procedures : Amendments 21-0 Through (and Part 183) Applicant Must Show Compliance to All Standards FAA Finds Compliance by Making any Tests, Inspections Necessary Expansion of Delegation Programs Applicant Must Provide Certifying Statement Recommendations From Independent Studies Challenge 2000: Recommendations for Future Aviation Safety Regulation National Civil Aviation Review Commission National Research Council, Improving the Continued Airworthiness of Aircraft RTCA Task Force 4 - Certification

3 FAA Type Certification Process: Evolution of Continuous Improvement (Cont.) Industry Best Practices FAA and Industry Guide to Type Certification, 1999, 2001, 2004 MARPA 1100 Streamline Program for PMA Applications, 2012

4 FAA Type Certification Process: Evolution of Continuous Improvement (Cont.) Common Theme for Nearly All Certification Process Improvements Delegation Improves Safety, Effectiveness and Efficiency Utilize Technical Expertise and Experience Available in Industry Allows FAA to Focus Resources on Safety Critical Activities Increase Industry Role and Responsibility for Compliance Recognize Robust Industry Processes for Showing and Verification Shift to a Systems Safety Approach for Certification & Oversight Allows FAA to Focus Resources on Safety Activities

5 Drivers for a Part 21 Change Efficiency - Current FAA Certification Capacity Does Not Meet Industry Needs Routine Delays & Uncertainty in Support for Ongoing Projects Significant Public/Congressional Pressure to Reduce Deficits/Budgets Effectiveness Ensure Safety in Dynamic Environment Focus FAA Resources on Safety Risk Activities Strengthen FAA Surveillance & Oversight Integrate SMS Principles

6 Part 21/SMS ARC Chartered by FAA Administrator in October 2012 Objective Improvements to Part 21 that Reflect a Systems Approach for Safety that Will Promote an Effective and Efficient Certification Process Membership DAHs Representing All Sectors (U.S. and Intl) and FAA Observers from EASA, TCCA, and ANAC to Ensure Harmonization ARC Working Groups Addressing Key Issues Greater Participation by Subject Matter Experts

7 Part 21/SMS ARC: Key Deliverables Establishment of an FAA Systems Oversight Approach to Certification Processes and Continued Airworthiness Design Organization Requirements, Responsibilities and Privileges Implementation of SMS Requirements for Design and Production Organizations Based on Part 5 with Appropriate Applicability FAA Oversight Methodology Integrated Oversight/Surveillance/Enforcement Approach for Production and Design Organizations

8 Current ARC Status: Design Organization Requirement Main Responsibilities Establish and Follow DO Procedures Manual Design Assurance, Quality Management & Safety Management Systems Identify and Qualify Minimum Management and Technical Staff All Activities Within Scope of DO Must be Accomplished Under DO Main Privileges Make All (100%) Determinations of Compliance Within Scope of Certificate Determination = Showing + Verification Verification/Design Assurance Not All via Independent Second Person No FAA Retained Findings - No Use of Delegation FAA Level of Project Involvement (LOPI) Based on Defined Criteria Create Approved/Acceptable Data Necessary for COS

9 Single Finding Current ARC Status : Design Organization Requirement (Cont.) ODA Show Compliance ODA INDUSTRY System Oversight FAA Find Compliance Transition Establish LOPI Policy Full Use of All Authorized Delegation Acceptance of Design Organization Statements Procedures Manual Design Assurance System Design Organization (DO) Discreet Determinations of Compliance FAA System Oversight Project LOPI Discreet Find Compliance and LOPI System Oversight

10 Current ARC Status : Design Organization Requirement (Cont.) FAA Certificated Design Organization New Part 21 Subpart (consideration of EASA DOA) DO (or application for DO) Required to Make Application for and to Hold Design Approval (based on applicability) Key Challenge for Mandate Number of Applicants/Holders and Burden on FAA Small Businesses and Burden on Industry Applicability Approaches Considered Scalable to All Applicants/Holders (similar to PAH model) To Certain Applicants/Holders Based on Threshold

11 Current ARC Status : Design Organization Requirement (Cont.) Applicability Decision Mandatory Certified Design Organization Based on Threshold TCH Based on Type of Product and Operation STC, PMA Based on Safety Risk TSO Not Applicable (Does Not Perform Compliance to Regulatory Standards) For Manufacturers Below the DO Threshold Voluntary Scaled Design Organization Concept to be Explored Industry Standard for Design Assurance Process Handbook Industry 3 rd Party Audit/Accreditation of Implementation FAA Review and Acceptance of Manufacturer Handbook Facilitate Acceptance of Company Showings of Non-Critical, Routine, Specialty Service Activities IAW Well Known MOC New Minimum Applicant & Holder Requirements

12 Current ARC Status : Applicant & Holder Requirements New Minimum Applicant Qualification such as PAH Organization (21.135/305/605) Provide a document describing how organization will ensure compliance with the provisions of this subpart/part Includes design and certification experience Enhanced Application such as Detailed description of design features, proposed certification basis, proposed certification plan (with planned delegation), etc Holder Responsibilities Maintain Document Describing How Organization Will Ensure Compliance i.e. Modeled after PAH responsibilities , , Enhanced Continued Operational Safety

13 Current ARC Status : PAH Requirements Implementation of SMS Requirements Reference to Part 5 Develop Guidance and Policy for Part 21 Application Applicability Same as Design Organization Requirement Consideration of Certain TSOA Holders

14 Part 21/SMS ARC Next Steps Significant Change and Significant Scope Strategic Shift to Regulate Design Organizations How to Ensure Intended Benefits/Improvements are Realized? What is Delta Between Fully Utilized ODA and DO concept? Potential Political and Workforce Issues/Concerns Cost/Benefit and Small Business Impact Need Industry Input from Every Sector of DAH Manufacturers Opportunity to Shape Direction of Future FAA Certification Process Best Approach to Improve Effectiveness & Efficiency Provide Information/Comments Through MARPA

15 QUESTIONS?