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Airworthiness Roles & Responsibilities (As Civil As Possible… As Military as Necessary) Captain Steve Greenwood RN – AD Air Systems – CASD Mr John Allan - AD Air Systems – DMSD Themes Why “as civil as possible as military as necessary” International Procurement
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Airworthiness Roles & Responsibilities (As Civil As Possible… As Military as Necessary) Captain Steve Greenwood RN – AD Air Systems – CASD Mr John Allan - AD Air Systems – DMSD
Themes • Why “as civil as possible as military as necessary” • International Procurement • Different roles within an IPT • Principle Airworthiness Roles • Possible Models
Why? (As civil as possible…) • ICAO – “due regard” – Chicago Convention 1944 • EASA – “due regard as far as practicable to the objectives of this regulation” – 216/2008 • CAA & ANO • SofS – derogations from legislation • International Military Procurement “Where Defence can rely on exemptions or derogations from either domestic or international law, we introduce standards and management arrangements that are, so far as reasonably practicable, at least as good as those required by legislation”.
International Military Aviation Procurement Project specific arrangements are tailored for each multinational programme… This costs a huge amount of time and money! (& leads to tensions across partner nations and industry) Procedures Certification Competence Maintenance
EDA Initiative • Roadmap • Common Regulatory Framework; • Common Certification Processes; • Common approach to Organisational Approvals; • Common certification/design codes; • Common approach to preservation of airworthiness; • Arrangements for mutual recognition; • Formation of European Military Joint Airworthiness Authority.
Regulatory Structure – EDA Initiative Common Regulatory Framework Basic Regulation JSP553 Common approach to Preservation of Airworthiness with Organisation Approval Codes Common Certification Processes with Organisation Approval Codes Organisation Approval Codes Organisation Approval Codes Organisation Approval Codes Organisation Approval Codes 05 05 - - 123 123 - - Design Organisation Design Organisation 05 05 - - 130 Pt M (G) 130 Pt M (G) - - Continued Airworthiness Continued Airworthiness Management Management AS9110 AS9110 - - Production Organisation Production Organisation 05 05 - - 130 Pt 145 130 Pt 145 - - Maintenance Organisation Maintenance Organisation Common Certification Design codes Design Standards Design Standards 05 05 - - 130 Pt 147 130 Pt 147 - - Training Organisation Training Organisation 00 00 - - 970 970 – – Fixed Wing Aircraft, Fixed Wing Aircraft, Processes / Standards Processes / Standards Processes / Standards Helicopters, Helicopters, UAVs UAVs and Engines and Engines 05 05 - - 130 Part M (C) 130 Part M (C) - - Airworthiness Airworthiness Management Management Guidance Material Guidance Material Guidance Material Guidance Material Acceptable Means of Compliance Acceptable Means of Compliance Acceptable Means of Compliance Acceptable Means of Compliance JAP100A - 01
Conflict of interest? • Each safety management organisation is to demonstrate a level of independence such that its activities are not unreasonably constrained by operating or commercial pressures. JSP550 Reg 445.100.2
How many hats does an IPTL wear? TAA Customer Owner Supplier TCH Maintainer Buyer Duty Holder CAMO Team Leader
Principles • Structure of Airworthiness Roles in 3 Groups: • Regulation • Management • Delivery • Organised to: • Create clarity of responsibility • Avoid conflicts of interest within individual accountability
Certify Products Approve Organisation The Key Principles – Where We Want to Be Regulator Designer Operator Design Individual Aircraft Type Certificate Certificate of Airworthiness
Designer Operator Airworthiness Principles - Roles Regulator Sets the Rules; Establishes Competence (organisational approvals); Certifies Products Operates and Maintains Aircraft to the Designer’s Limits and Procedures Establishes and Maintains an Airworthy Design Design Individual Aircraft
Roles & Responsibilities - Civil • Regulator (EASA/CAA) – rules, design, operating & CA standards, approvals & survey; • TC Holder (OEM/Manufacturer) – through life design, continuous improvement; • AOC Holder (Airline) – operates within rules, preserve airworthiness; • CAMO – maintenance programmes & management, feedback, maintain airworthiness; • Maintenance Organisation – ‘garage’.
Basic Regulation Basic Regulation 216/2008. 1592/2002 Organisation Approval Codes Organisation Approval Codes Organisation Approval Codes Organisation Approval Codes Organisation Approval Codes Organisation Approval Codes Pt 21(J) Pt 21(J) Pt 21(J) - - - Design Organisation Design Organisation Design Organisation Pt M (G) Pt M (G) Pt M (G) - - - Continued Airworthiness Continued Airworthiness Continued Airworthiness Management Management Management Pt 21(G) Pt 21(G) Pt 21(G) - - - Production Organisation Production Organisation Production Organisation Pt 145 Pt 145 Pt 145 - - - Maintenance Organisation Maintenance Organisation Maintenance Organisation Certification Standards Certification Standards Certification Standards Pt 147 Pt 147 Pt 147 - - - Training Organisation Training Organisation Training Organisation CS25 CS25 CS25 - - - Aeroplanes Aeroplanes Aeroplanes Processes / Standards Processes / Standards Processes / Standards CS29 CS29 CS29 - - - Helicopters Helicopters Helicopters Pt M (C) Pt M (C) Pt M (C) - - - Airworthiness Airworthiness Airworthiness E E E - - - Engines Engines Engines Management Management Management Guidance Material Guidance Material Guidance Material Guidance Material Guidance Material Guidance Material Acceptable Means of Compliance Acceptable Means of Compliance Acceptable Means of Compliance Acceptable Means of Compliance Acceptable Means of Compliance Acceptable Means of Compliance Regulation Structure – Civil (EASA)
Regulation Structure - Military Basic Regulation Basic Regulation JSP553 JSP553 Organisation Approval Codes Organisation Approval Codes Organisation Approval Codes Organisation Approval Codes Organisation Approval Codes Organisation Approval Codes Design Organisation 05 05 05 - - - 123 123 123 - - - Design Organisation Design Organisation 05 05 05 - - - 130 Pt M (G) 130 Pt M (G) 130 Pt M (G) - - - Continued Airworthiness Continued Airworthiness Continued Airworthiness Management Management Management AS9100 AS9110 AS9110 - - - Production Organisation Production Organisation Production Organisation 05 05 05 - - - 130 Pt 145 130 Pt 145 130 Pt 145 - - - Maintenance Organisation Maintenance Organisation Maintenance Organisation Design Standards Design Standards Design Standards 05 05 05 - - - 130 Pt 147 130 Pt 147 130 Pt 147 - - - Training Organisation Training Organisation Training Organisation 00 00 00 - - - 970 970 970 – – – Fixed Wing Aircraft, Fixed Wing Aircraft, Fixed Wing Aircraft, Processes / Standards Processes / Standards Processes / Standards Helicopters, Helicopters, Helicopters, UAVs UAVs UAVs and Engines and Engines and Engines 05 05 05 - - - 130 Part M (C) 130 Part M (C) 130 Part M (C) - - - Airworthiness Airworthiness Airworthiness Management Management Management Guidance Material Guidance Material Guidance Material Guidance Material Acceptable Means of Compliance Acceptable Means of Compliance Acceptable Means of Compliance Acceptable Means of Compliance 01 JAP100A JAP100A - - 01
Roles & Responsibilities - Military • Regulator (MAFTR/TAA) – rules, design, operating & CA standards, approvals & survey; • TC Holder (MOD or OEM/Manufacturer) – through life design, continuous improvement; • AOA – operates within rules, preserve airworthiness; • CAMO – maintenance programmes & management, feedback, maintain airworthiness; • Maintenance Organisation – ‘garage’. If only it were so simple!
Roles & Responsibilities - MOD • Regulator (MAFTR) – rules, design, operating & CA standards, approvals; • Military TC Holder (OEM/Manufacturer/MOD?) – through life design, continuous improvement; • AOA FLC/Company – operates within rules, preserve airworthiness; • CAMO – maintenance programmes & management feedback, maintain airworthiness; • Maintenance Organisation – ‘garage’; But: • TAA – type & tail no specific regulation – (Crown Servant) – airworthiness responsibility; • RTSA • IPTL – Programme Manager/Line ManagerTAA? • MOD/Prime/Sub – what roles?
Regulatory Environment MoD Airworthiness & Flight Test Regulators Type Airworthiness Authority Management Organisations Release to Service Authority Integrated Project Team Leader Aircraft Operating Authority Continued Airworthiness Management Organisation Type Certificate Holder Design Approved Organisation Maintenance Approved Organisation Service Maintenance Organisations Training Approved Organisation Training Approved Organisation Delivery Organisations
Management Organisations Release to Service Authority Integrated Project Team Leader Aircraft Operating Authority Continued Airworthiness Management Organisation Type Certificate Holder Regulatory Environment MoD Airworthiness & Flight Test Regulators Type Airworthiness Authority Design Approved Organisation Maintenance Approved Organisation Service Maintenance Organisations Training Approved Organisation Training Approved Organisation Delivery Organisations
What Could We Give To Industry? • Project Specific! • Mil Type Certificate Holder? • AOA? • CAMO – Part M approval? • Mil Part 145 approval
Questions? www.maos.mod.uk