Information for Delegation Holders

Peter GillAirworthiness Engineer

Topics to be covered: Delegation Changes since 2009 Major Design Change Authorisation

Process Manufacturing Considerations STC’s AC’s Other Miscellaneous Topics

Delegation Changes since 2009

No approval of modification classified as “major design change” (schedule One) without CAA authorisation

CAA undertook to give authorisation for appropriate “one-off” modifications where not contrary to CAA policy

All delegations which included modifications were re-issued August 2010

Authorisation Process

Authorisation Requests 2010 10 Yes 0 No 2011 54 Yes 5 No Reasons for No: 1 – Unusual design features

1 – HEC (CAA Policy – STC)1 – 21.303 (later authorised)1 – Operational Concern1 – TCDS Change

2012 10 Yes 0 No

Manufacturing Considerations

Part 146 organisations approve data – do not authorise manufacture

CAA expect part 146 organisations to promote compliance with Rules where possible

CAA has publicised compliance with 21.303 to industry (Vector magasine article Nov/Dec 2010)

Factor in authorisation process

Manufacturing Considerations Contd

CAR 21.303 – be manufactured “by a person performing maintenance on the product…” No subcontracting (can supervise) NOTE: “Subcontracting” term here is used in the

manufacturing sense where the manufacturer takes responsibility for the subcontractors work.

Where the “subcontractor” has an organisation certificate of its own and can issue a release certificate, that is acceptable (they are then a “supplier” rather than a ‘subcontractor”.)

Manufacturing Considerations Contd

How to approved “existing” equipment (where origin unknown)? Should be a document (Form One or

Two) identifying part and origin Part 21Q has always required part

marking

STC’s See later presentation from Beth Small number of “New” STC’s Large number started, stalled Time delays – CAA extra assessment Certification Basis – Determine iaw FAR

21.101 Changed Product Rule Requirement for any STC where FAA validation is likely to

be sought Should always specify why you can’t/don’t use the latest

requirements

Advisory Circulars Advisory Circulars to be revised or

written by ACU (we welcome comments or suggestions): AC 146-1 - Clarify CAA position on “one-

man-bands”; Clarify Delegation Issue Process; General Update

AC 148-1 – General Update; Remove Extraneous material; Clarify CAA position on Subcontractors, senior person qualifications, Critical Parts, Design Data.

Advisory Circulars Contd

AC 43-9 (Mods, Repairs, 337) – Complete re-write and update

AC 91-5 (PEDS) – General update New AC on aircraft Electrical Load Analysis - Probably an AC 91-X – detailing how the owner

should maintain an ELA for his aircraft

Miscellaneous Topics Where making a minor change to a

“major design change” – is this major? Original approver? Effect of change?

Continuation of Class A/B delegation classifications? Not yet determined

Miscellaneous Topics Contd

Delegation of Part 146 activities: Testing Data (eg Weight & Balance data)

Electrical/Mechanical demarcation 1309 training – Seen by CAA as

essential

Miscellaneous Topics Contd

Surveillance – effect of new policy Increased preparation More targeted audit No change to delegate monitoring

Questions?