Federal Aviation Administration TSO Process and Policy Revisions

Transcription

1 TSO Process and Policy Revisions Presented to:

2 Overview Background on TSO Authorization Order Proposed Changes to Order b TSO Oversight Technical Evaluations 2

3 What is a TSOA A TSO authorization (TSOA) is an FAA design and production approval issued to a US manufacturer of an article which has been found to meet a specific TSO performance standard An article manufactured under a TSOA is an approved part under 14 CFR A TSOA holder controls the design and quality of the article produced, including the sub-parts and any processes or services that are procured from an outside source 3

4 What is a TSOA An article with a TSO marking indicates: The design of the article has been found to meet the TSO performance standard The produced article conforms to the approved design A TSO authorization does not include installation approval Requires some other approval to be installed on the aircraft (e.g. included in TC, Repair/alteration approval, STC, etc.) 4

5 Order The TSO process is defined in CFR Part 21, Subpart O AIR-100 is responsible for Administering CFR Part 21 and controls the content of Order Order is an FAA document that provides direction to FAA offices on how to implement the TSO Program The Order is at revision b and currently being revised 5

6 Outline of Proposed Changes & Updates to Order b: Applicable to DER s: DER Use in TSO Process Incomplete System (Partial TSO) Major/Minor Changes TSO Approvals for Military Articles Non-TSO Function(s) Integrated in a TSO Article 6

7 Outline of Proposed Changes & Updates to Order b: Information Only: LODA Requirements for Evidence of Import Deviation Approvals Marking Conversion of TSOA to LODA and LODA to TSOA 7

8 DER Use in TSO Process A DER is NOT permitted to issue TSOA, sign a Statement of Conformance, or sign an in support of a TSOA. DER s can be used as a technical consultant, i.e. an employee of applicant/holder, but not as a delegated FAA representative. One Exception for is Software and Complex Electronic Hardware (CEH) Approvals (AIR-100 Policy Memo s 4/16/01, 12/20/07 and Order d) 8

9 DER Use in TSO Process Software, CEH Approvals Only: Appropriately delegated Software and CEH DER can make finding of compliance when required. DER must obtain approval from ACO before any TSO testing or data collection has begun. Use with statement in PURPOSE OF DATA block In support of TSO-CXXX application. 9

10 Incomplete System (Partial TSO) A partial TSO approval may be issued for any component or sub-system of a complete system when: Component/sub-system provides a major function or feature specified in TSO performance standard and must meet the conditions defined in the order. Deviation required if MPS are inadequate to define evaluation and testing. Applicant must address installation procedures and limitations to ensure that the incomplete system can be integrated into a complete system Incomplete systems must be clearly marked incomplete 10

11 Incomplete System (Partial TSO) DER s Must: Understand the extent of the TSO performance standard covered by the incomplete system approval Understand any limitations included in the incomplete system approval Evaluate the installation of the incomplete system at a Product level when finding compliance to the Airworthiness Regulations 11

12 Major/Minor Changes An article s design can be modified by the original TSOA/LODA holder Design change categorized as major or minor, per 14 CFR An article s design can also be modified by a manufacturer or a person other than a manufacturer Manufacturer is the person who controls the design and quality of the article, including any processes and parts procured from an outside supplier (Ref (b)(5)) If the design is modified by another manufacturer, they must apply for new TSOA/LODA 12

13 Major/Minor Changes If article s design is modified by a person other than a manufacturer, change is approved under airworthiness regulations (e.g. TC, STC) or under Part 43. To maintain the original TSO tag, must demonstrate the design of modified article still meets TSO standard. Otherwise the original TSO approval marking (e.g. Meets TSO-C22g) must be obliterated. Modified design must include mod placard on the article Considered a major alteration if under Part 43 13

14 Major/Minor Changes DER s Should Note: That a major/minor design change to the TSO article is evaluated relative to the TSO performance standard and only applies to the original manufacturer Any design change to the TSO article must also be evaluated at a Product (installation) level relative to the applicable airworthiness regulations A minor change relative to the TSO standard could result in a significant non-compliance to the airworthiness regulations at the Product level. 14

15 TSO Approvals for Military Articles Addresses civilian TSO articles that perform one or more military function that deviates from the MPS and would not be approved for civilian use. Upon applicant request, FAA will approve a TSOA/LODA for articles with a limitation for military functions where the article will be marked For Military Use Only. DER s should note that articles marked For Military Use Only may not be included in the type design of civilian Products. 15

16 Non TSO Function Definition of Non-TSO Function: Is a characteristic of the article that is not covered or evaluated by the TSO performance standards, Does not prevent the article from meeting the TSO performance standards. The non-tso function is declared by the manufacturer to the TSO approving office: If the manufacturer seeks credit for the non-tso function. Note: Some TSOs require the applicant to identify non-tso functions even when credit is not sought 16

17 Non TSO Function Data (testing or analysis) that supports the installation approval of a non-tso function may be accepted by the TSO issuing ACO. The accepted data is not approved under the TSO program (i.e. Part 21, Subpart O) The DER must consider the data valid when approving the installation of the article into the Product The DER verifies that the non-tso functions data is applicable to the installation. 17

18 Non TSO Function Summary: Acceptance of declared non-tso function data is not a design approval Acceptance of the data means the data is considered valid (i.e. it is good data). The applicability of the data is determined during installation approval at the Product level (i.e. is it the right data?) 18

19 TSO Oversight Technical Evaluations Overview: What have we been doing? Current oversight for TSOA holders Technical Evaluation for TSOA holders Expectations Evaluation criteria Proposed prototype TSOA holders 19

20 What We Have Been Doing TSOs were originally very simple articles, but over time they have become very complex and are often installation dependent DERs are being used in some ACOs for TSO approval activity This has been increasing with the complexity of TSOs This practice increases the DER oversight activity However, The intent of a TSO authorization is for self certification and doesn t support the use of DERs outside of TSO Software and CEH. New guidelines for overseeing TSOA holders are being considered 20

21 Current oversight for TSOA holders Aircraft Certification System Evaluation Program (ACSEP Audits) IAW Order Manufacturing process Quality System Review Focused on production holder s procedures - not design criteria 21

22 Technical Evaluation for TSOA holders Technical Data Substantiation Evaluations Evaluates methods, data, articles used to substantiate statement of conformance Evaluate whether products and data Technically acceptable Comply with regulations Produced using sound engineering judgment and practices 22

23 Technical Evaluation for TSOA holders These are the elements that have been identified for evaluation by the prototyping effort TSO MPS Compliance System requirements Software Compliance Complex Electronic Hardware Compliance Environmental Testing Results Change process/change impact analysis Continued operational safety review 23

24 Technical Evaluation for TSOA holders Prototype Goals Validate the processes and requirements in the TSO order Design of the appliance meets the TSO minimum performance standard Production System is capable of producing duplicate appliances that conform to the approved design Document the results of these reviews to establish trending information and policy needs Obtain industry/faa feedback prior to full implementation Identify any changes needed in the TSO order 24

25 Questions The TSO process is managed by AIR-120 in FAA Headquarters If you have any questions on the TSO process please contact: Carol Martineau, AIR-120 Manager Telephone: (202)