Role of DOA and AP-DOA Privileges for ICAs issuance and approval. ICA Workshop 19 January 2010

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1 Role of DOA and AP-DOA Privileges for ICAs issuance and approval ICA Workshop 19 January 2010

2 Role of DOA An approved Design Organisation should ensure through its Design Assurance System: Preparation and update of all maintenance instructions needed to maintain (continued) airworthiness see GM No.1 to 21A.239(a) a Establish the list of all documents it is producing to comply with CS , , Define procedures and organisation to produce and issue these documents (using when applicable and so elected 21A.263(c)(3) privilege) Providing these documents to all affected operators see GM No.1 to 21A.239(a) b 19 January 2010 ICA Workshop Slide 2

3 21A.263(c)(3) Privilege The privilege related to the issuance of information or instructions has been present in JAR 21 from very beginning (1 st Issue Jun 1994) Starting with Nov (Amdt. 3) the wording used is the current one With Amdt. 4 the Scope of the privilege is extended to different types of Manuals (see ACJ 21.A263(b)(3)) (before referring more to SB) In the current AMC & GM for Part 21 the wording is once again improved to better define the Scope of the privilege. Direct reference to ICA (21A.61, 21A.107, 21A.120 or 21A.449) is now introduced (see GM 21A.263(c)(3)) 19 January 2010 ICA Workshop Slide 3

4 21A.263(c)(3) Privilege According to the GM 21A.263(c)(3) the privilege to issue information and instructions covers: Embodiment instructions (for design changes or repairs); and Maintenance data for the performance of maintenance or inspection in accordance with 21A.61, (Instruction for Continued Airworthiness) 19 January 2010 ICA Workshop Slide 4

5 21A.263(c)(3) Privilege To obtain the privilege the DOA holder should have a procedure covering: Preparation of ICA Verification of technical consistency with approved data (change, repair, ) Verification of feasibility in practical applications Authorised signatories 19 January 2010 ICA Workshop Slide 5

6 21A.263(c)(3) Privilege If the privilege is granted and used, the information or instructions shall be issued with the following statement: The technical content of this document is approved under the authority of DOA nr. EASA.21J.xyz Note: Approval of the technical content means that: - the design data has been appropriately approved; - the instructions provide for practical and well defined inspection methods, and, when accomplished the product is in conformity with the approved data. (see GM 21A.263(c)(3)) 19 January 2010 ICA Workshop Slide 6

7 Role of Alternative Procedure to DOA (AP-DOA) AP-DOA holder should have a procedure for preparing ICA (see GM 21A.14(b) 4) in connection with the EASA approved design data, as relevant. The procedure should address same items (like the DOA procedure): preparation, verification of technical consistency, verification of feasibility and internal authorised signatories. AP-DOA has no privileges consequently, no approval statement can be inserted, but only an indication that the instructions have been produced in accordance with alternative procedures to DOA EASA.APxyz. 19 January 2010 ICA Workshop Slide 7

8 MDM.056 Questions raised What privileges are used today? What is an «instruction» and an «information»? Are DOA privileges adapted? What does the privilege to issue an instruction mean? Is it the controlled mechanism to issue non approved instructions? What can/should be the role of DOA in the issuance of ICA? Does the use of the privilege to issue instructions automatically lead to use the privilege on the statement of approval? What is the added value of the statement following issuance of the instructions? 19 January 2010 ICA Workshop Slide 8

9 Any thoughts? 19 January 2010 ICA Workshop Slide 9