DASR Type Certification 216207 - Department of Defence · 3. Type Certification Overview 4. Define...

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DASR Type Certification – 216207Mr Mark WadeDirector of Initial Airworthiness (DIA)Directorate of Initial Airworthiness (DIA-DASA)DASA

Mr Darryl TaylorDeputy-Director Type Certification (DDTC)Directorate of Initial Airworthiness (DIA-DASA)DASA

Updated: 15 Aug 19

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Admin

• Bathroom

• Emergencies

• Breaks

• Attendance Sheet

• Course notes

• Feedback Sheets

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Scope

• This course will provide:

– Roles and responsibilities for safe aircraft design

• Designers, POs, SPOs, MTCH

• Command

• DASA

– An overview of key DASR instruments

• MTC, MSTC, MPTF, etc

– Type Certification requirements and processes

– Final points

• Lessons learned

• DASA diagram

• Role of PCM

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Scope

• This course will not:

– Provide an in-depth understanding of Type Certification under DASR;

– Cover knowledge delivered through the DASR 21 courses;

– Cover Non-Defence Registered Aircraft;

– Cover off on requirements external to Type Certification, such as the

ASAMP, MAOCMP, LSP etc

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Modules

1. WHS Background and Airworthiness Responsibilities

2. Aviation Safety Instruments

3. Type Certification Overview

4. Define Operating Intent

5. Authority Agreement (CPP) (includes tailoring the TCB, evidence relief, CRE, etc)

6. Compliance Demonstration

7. Submission

8. Authority Assessment and Approval

9. Lessons Learned

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WHS Background and Airworthiness Responsibilities

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Why ?

• WHS Legislation

– is applicable to Defence

• … apart from the few exemptions

– is the basis for DASRs

– provides essential role clarity for aircraft

design

• (WHS Legislation = Act + Regulations)

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Maximum Penalties under WHS Legislation

Type of offence Maximum penalty for

corporation

Maximum penalty for

officers

Maximum penalty for

workers

Category 1:

Breach of a health and safety duty

involving recklessness as to the risk of

death or serious injury or illness

without reasonable excuse

$3,000,000 $600,000

or

5 years’ imprisonment

$300,000

or

5 years’ imprisonment

Category 2:

Breach of a health and safety duty

which expose an individual to death or

serious injury or illness (without

recklessness)

$1,500,000 $300,000 $150,000

Category 3:

Other breaches of health and safety

duties

$500,000 $100,000 $50,000

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Essential Concepts

Ensure: ‘to make sure, certain or safe (implying a responsibility to make it happen)’

Assure:

‘to give confidence, to reassure (implying a monitoring and reporting role)’

Source: Sea King Board of Inquiry report

S17 Management of risks

‘A duty imposed on a person to ensure health and safety requires the person:

(a) to eliminate risks to health and safety, so far as is reasonably practicable; and

(b) if it is not reasonably practicable to eliminate risks to health and safety, to

minimise those risks so far as is reasonably practicable.

Source: WHS Act 2011

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Safety is a Command Responsibility (WHS, Section 20/21)

Explosives

Aviation

Radiation

Falling objects

Confined spaces

Noise

Lifting

Demolition

Diving

Electrical

Chemicals

Lead

Asbestos

Fire

Contaminated air

Heights

Maintenance of plant

Excavating

Poor training

Poor labels

Poor health monitoring

Poor reporting

WHS Section 22-25 WHS Section 20/21

Command must ensure that risk is treated SFARP

Section 16

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DefenceAA/DASA/DASP/DASR amplify WHS legislation

DefenceAA assures Defence aviation safety

No WHS obligations : specialist amplification of WHS provisions for Defence Aviation hazards

Explosives

Aviation

Radiation

Falling objects

Confined spaces

Noise

Lifting

Demolition

Diving

Electrical

Chemicals

Lead

Asbestos

Fire

Contaminated air

Heights

Maintenance of plant

Excavating

Poor training

Poor labels

Poor health monitoring

Poor reporting

WHS Section 22-25 WHS Section 20/21


Section 16

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DefenceAA

DASA

- DPEPS

- DIA

- DCA

- DAVENG

- ACPA

-DFSB

DASP

- Policy / regulation

- Promotion/education

- Initial Safety Case

- Ongoing Assurance

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CO/CENGR CO SQN

OC Wing

Clear safety accountabilities under Legislation / Common Law

DefenceAA assures Defence aviation safety

DefenceAA

DASA

DASR

CAF

ACAUST

FEGCDR

CASG

HASD

DG

OC SPO


No WHS obligations : specialist amplification of WHS provisions for Defence Aviation hazard

DASP

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sWHS Section 22-25 WHS Section 20/21

Section 16 Section 46 S1

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WHS Act 2011 – Who Has a Duty?

• Section 22: Duties of persons … that design plant/structures

– applies to a person (the designer) … who designs plant/structure

that is to be used as/at a workplace

– The designer must ensure, so far as is reasonably practicable,

that the plant/structure is designed to be without risks to the health

and safety of persons … who use the plant/structure for a purpose

for which it was designed

– The designer must carry out, or arrange the carrying out of, any

calculations, analysis, testing or examination that may be

necessary

– The designer must give adequate information to each person who

is provided with the design for the purpose of giving effect to it

Note: The text on this slide is extracted for the convenience of the reader and doesn’t represent the full wording from the legislation

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WHS Act 2011 – Who Has a Duty?

• Section 24: Duties of persons … that import plant/structures

– applies to a person (the importer) … who imports plant/structurethat is to be used as/at a workplace

– The importer must ensure, so far as is reasonably practicable, that the plant/structure is without risks to the health and safety of persons … who use the plant/structure for a purpose for which it was designed.

– The importer must:

• carry out, or arrange the carrying out of, any calculations, analysis, testing or examination that may be necessary … or

• ensure that the calculations, analysis, testing or examination have been carried out.

– The importer must give adequate information to each person to whom the importer provides the plant, substance or structure …

Note: The text on this slide is extracted for the convenience of the reader and doesn’t represent the full wording from the legislation

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• MDOA– Australian organisations: WHS Act 2011 applies + DASR through contract law.

• Ensure design is (SFARP) without risks to health/safety of persons who use it as intended

– International organisations: Host nation/union regulations + DASR through contract law.

• SPO contract managers, Defence PO– Many possible roles in which they take on an obligation to ensure risks are

eliminated/minimised SFARP

• (depends on contract, GFE/GFI, resource control, etc)

– Importer ?

– Supplier ?

– Designer ?

– Focal point for shared duty holders to consult, cooperate, coordinate activities

• MTCH (Senior SPO Engineer)– Management of the MTC, identify latent defects, etc

• CAM (Air Operator)– Advise on intended use of aircraft, ensure aircraft is operated within designer’s

conditions/limitations

– Advise MTCH on latent defects

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Responsibility for safe aircraft design ?

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Responsibility for safe aircraft design (continued)?

Authority ?

• Risk advice regarding defensible standards (ie good practice)

• Risk advice regarding non-compliance with standards

• Authority activities may contribute to Duty Holder ‘ensure’ functions:

– Partial - eg Type Certification, evidence inspections, etc

– Extensive - eg organisational approvals

– (Note: SME advice may contribute but is not an Authority role)

No responsibility to ensure safe aircraft design

• Responsible to Defence AA to assure effective management of aviation safety

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Aviation Safety Instruments and Certificates

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List of Aviation Safety Instruments and CertificatesInstruments

• MTC – Military Type Certificate

• MRTC – Military Restricted Type Certificate

• Type Certificate amendment

• MSTC – Military Supplemental Type Certificate

• MPTF – Military Permit to Fly

• UASOP – Unmanned Aircraft System Operating Permit

Certificates

• CoA – Certificate of Airworthiness

• MAOC – Military Air Operator Certificate

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MTC

“Certificate issued by the Authority … that certifies the aircraft type design complies

with the applicable Type Certification Basis when operated within the conditions and

limitations specified on the associated Type Certificate Data Sheet”

• Aircraft must be on Defence register

• Defence Registered Aircraft (DRA) must have a valid Type Certificate before being

authorised for flight operations (exception: ops under MPTF, some UAS)

• Aircraft must be operated in the roles authorised in OIP and TCDS (and defined in SOIU)

• Applicant is usually the acquisition PO

• An AwB is convened to provide a recommendation to issue (or not to issue) an MTC.

• Issued by DG DASA

• MTC is issued to a Defence organisation

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MTC

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Type Certificate Data Sheet (TCDS)

• The TCDS for a specific aircraft type or Certified category UAS complements the Type

Certificate by documenting the approved Instruments and summarising the basis of

certification.

• The TCDS identifies specific information contained in Defence approved records, or in

records approved by other recognised airworthiness authorities, and should identify or

reference:

• the TCB, including all approved MCRI

• the approved aircraft role(s) and environment(s)

• the aircraft configuration

• operating and maintenance instructions

• any limitations.

• Platform Instruments Webpage

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http://drnet/dasa/Pages/Instruments-Platforms.aspx

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TCDS

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MRTC

“Certificate issued by the Authority … that certifies the aircraft type design complies

with the applicable Restricted Type Certification Basis when operated within the

conditions and limitations specified on the associated Restricted Type Certificate Data

Sheet (RTCDS)”

• For an aircraft that does not meet the provisions of DASR 21.A.21(c)…

– Do not comply with all the TCB and environmental protection requirements;

– Have outstanding non-compliances (those which are not compensated for by factors

that provide an equivalent level of safety);

– Have features or characteristics which are not yet deemed airworthy.

• … however:

– At face value may not be useful in our Defence context

– EMAR users have different interpretations

– => Defence use TBA.

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Minor vs Major design change ?

• A Minor Change is a change that has no appreciable effect on the mass, balance,

structural strength, reliability, operational characteristics, or other characteristics affecting

the airworthiness of the product.

• A Major Change is any technical or configuration change to the Type Design that is not

deemed a Minor Change.

• Classification is the remit of the Authority, or MDOA holder with the appropriate privilege.

• Two approaches to major design change:

– Type Certificate amendment

– MSTC

• Major changes approved by DASA

• The requirement for an AwB will be determined based on:

– complexity of the modification

– complexity of effort to integrate the new capability into Defence

– complexity of MAOC considerations

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Type Certificate Amendment

• MTCH may request an amendment to the existing MTC/MRTC

– May or may not actually change the information on the MTC or TCDS

• Controlled through DASR 21 Subpart D, Changes to Military Type-Certificates

and Military Restricted Type Certificates

• Applicant is MTCH organisation (including supporting contractor).

• Approved by DG DASA (or DIA for non-complex mods)

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MSTC

“Certificate issued by the Authority … that certifies a change to the aircraft type

design by an organisation, other than the original design organisation, with DASR

Military Design Organisation Approval (MDOA). The design change may result from a

change in configuration, operational role, or specification of the aircraft type.”

• Controlled through DASR 21 Subpart E, Military Supplemental Type Certificates

• MSTC will have its own TCB

– Can include limitations

– Requires a CPP in most cases

• Any associated limitations and conditions are specified on the Supplemental Type

Certificate Data Sheet (STCDS).

• Applicant is usually other than the MTCH (or supporting organisations)

– But MTCH can request MSTC if desired

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MPTF

“Permit issued by the Authority or organisations and delegates granted such privilege

by the Authority when an aircraft does not meet, or has not been shown to meet,

applicable airworthiness requirements but is capable of safe flight under defined

conditions and for specified purposes. A Military Permit to Fly (MPTF) is also issued

for Flight Test activities”

• Examples of where a military permit to fly may be required include (DASR 21.A.701.a):

– Development;

– Demonstration of compliance with regulations or certification requirements;

– Production flight testing of new production aircraft;

– Flying the aircraft to a location where maintenance or airworthiness review are to be

performed, or to a place of storage;

– etc………

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MPTF (cont)

DASR 21.A.701.a(15): For individual aircraft or types for which a certificate of

airworthiness or restricted certificate of airworthiness is not appropriate.

cf

EASA 21.A.701.a(15): for non-commercial flying activity on individual non-complex

aircraft or types for which a certificate of airworthiness or restricted certificate of

airworthiness is not appropriate.

• At face value they’re similar, but AUS GM 21.A.727 states:

EASA implementation of permits to fly stipulates a single aircraft may only have

one valid permit allocated at one time, and that a permit may only be applicable

against a single aircraft. In order to accommodate the expected ADF usage, which

is focussed on providing in-service flexibility within a military environment, the

DASR unique AMC and GM allows for concurrent MPTF being valid against a

single aircraft, and for a single MPTF to be valid against more than one aircraft..

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MPTF (cont)

• Applicant is the MAO

– only organisation that can make the risk decision (Declaration of Safety) considering

all technical and operational aspects

– responsible for ensuring that all the conditions and limitations associated with the

MPTF are continuously satisfied

– the application should provide all the information provided to the MAO in support of

the risk decision - that all risks associated with the proposed MPTF have been

minimised SFARP

• Approval Authority is DASA

– Internal (DG, DIA, DAVENG)

– Flight Test DoSA (AWC, AMAFTU), limited scope

– Platform DoSA, limited scope

• AwB required for platform MPTFs

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Unmanned Aircraft Systems

• Present a hazard to:

– Other aircraft

– People on the ground

– (critical infrastructure)

• UAS often of lower design integrity

=> Rely extensively on operational risk controls

• Three ‘instrument’ options:

– MTC + MAOC

– Unmanned Aircraft System Operating Permit (UASOP)

– Nil

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Airspace: meet SOC

Ground: meet SOC

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OPEN

Micro (<100g): VLOS, <400’, day VMC, not in Rest or movt

areas (etc) without approval, RP trained

Very Small (<2kg): “Micro” limits, >30m from GP, not over

populous, <3nm from aerodrome requires approval, 1RP/UA

Small (<25kg): “Very Small” limits, operate over Defence

land/water, ops in controlled airspace require approval

SPECIFIC

Standard Scenario #2: <design>, <ops>, <RP training

INSTRUMENT

Standard Scenario #1: <design>, <ops>, <RP training>

Standard Scenario #x: <design>, <ops>, <RP training

LIMITATIONSCATEGORY

MTC MAOC

Airspace: unlimited*

Ground: unlimited

Airspace: risk assessment + treatment

Ground: risk assessment + treatmentUASOP

(nil)

(nil)

(nil)

(nil)

* With equipage

(further work needed)

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Certificate of Airworthiness

“A document, issued by the Authority or delegate, certifying that a particular

aircraft, at the date of issue, conformed to the Type Design recorded in the

Type Record.”

• Exists outside of the Type Certification process.

• Contingent on:

– the issue of the relevant Type Certificate

– provision of an Aircraft Statement of Conformity

– an appropriate level of inspection by the Authority.

• Usually issued by a DoSA

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MAOC and OpSpec

• Operation of all Defence Registered Aircraft must be conducted under the authority of a

Military Air Operator Certificate (MAOC).

• A MAOC is a single page certificate to authorise the MAO to perform military air

operations. A MAOC is granted when the Authority is satisfied the MAO can safely

conduct flight operations.

• Every MAOC has an accompanying Operations Specification (OpSpec), which includes a

separate annex for each aircraft type operated by the MAO. The OpSpec details:

– the key positions in the MAO (Accountable Manager (AM), Continuing Airworthiness

Manager, Hazard Tracking Authorities and UAS Manager);

– the aircraft types the MAO is authorised to operate, and the associated operating

provisions; and

– the roles and tasks, specific approvals, and any limitations or conditions for each

approved aircraft type operated by the MAO.

• Platform Instruments Webpage

http://drnet/dasa/Pages/Instruments-Platforms.aspx

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Type Certification Overview

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What is Type Certification ?

“The process through which compliance with the airworthiness design

requirements contained in the Type Certification Basis is established

through the development of the Type Design to meet the operating roles and

environment contained in the Statement of Operating Intent and Usage

(SOIU)”

• Outcome: A Type Certificate is issued when sufficient design, test and

certification activities necessary to establish compliance with specified

airworthiness standards, in order to operate safely within approved roles and

environments, have been completed.

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• Produce/update SOIU

• Identify Applicant and design organisations

• Agree TCB

Airworthiness codes/standards

Tailoring to standards (MCRIs)

Command safety/capability position

• Agree Means of Compliance (CCL)

Evidence requirements

Relief through extant certifications (CRE Δ)

• Agree Authority evidence inspections (LOI)

• Agree Declaration of Compliance

• Produce design

• Update CPP (if required)

• Produce evidence of compliance

Evaluations, inspections, ground tests, etc

Flight test

• Authority Inspections

• Declaration of Compliance

• Apply for certification or approval

• Confirm Continued Airworthiness responsibility

Maintain TC

Start

Define Operating Intent

Authority Agreement (CPP)

Design

Compliance Demonstration

Submission

•Authority assessment

(Project DoSA attestation, AwB, etc)

• Issue instrument or approve major change

Certification/Approval

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Type Certification vs Qualification ?

• Qualification is the process used by the contracting entity to establish compliance of a

product with a set of performance and contractual requirements.

• Generally, type-certification is a pre-requisite to qualification but these activities can be

conducted in parallel.

• Type-certification can occur as soon as all airworthiness requirements have been

adequately met. Type-certification may include some performance, availability, reliability

and maintainability requirements which are aviation safety related.

• To achieve acceptance by military services, it is usually necessary for the project to

demonstrate compliance with both safety and capability requirements.

• Therefore, capability criteria are usually addressed by product qualification.

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Type Certification vs Qualification

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• Agree TCB









• Produce design




Flight test





Maintain TC

Start



Design


Submission





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Purpose of the SOIU

• DASR ARO.50 – A SOIU must be issued for all Defence registered

aircraft types

• DASR 21.A.21(c)3 (or 21.A.103(a)2.iii) – No feature or characteristic

makes it unsafe for the uses for which certification is requested

• Provides the means of documenting the aircraft’s intended roles,

missions and operating environment

– May not highlight any current limitations to that intent

• Aircraft Orders, Instructions and Publications (OIP) are the authoritative

sources for limitations. Not the SOIU.

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Purpose of the SOIU

• Type Certification:

– Support definition of the Type Certification Basis (TCB)

– Inform design and compliance evidence development

– Used for Configuration, Role and Environment delta assessments

(if required)

• Continued Airworthiness:

– Ensure ongoing aircraft operations remain consistent with the TCB

• Includes both peacetime and war operations

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• SOIU describes:

– All intended aircraft roles and operational tasks

– For each role/operational task, the intended flight profiles including:

• description of sortie(s) associated with each task

• duration of sortie(s)

• aircraft speeds and altitudes

• operating mass and configurations

• ‘G’ envelope for each sortie

• mix of land and over sea operation

• landing and landing surfaces

• pressurisation cycles

• stores and other payloads

• delivery, attack and training manoeuvres

• mission mix, RoE and planned life

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SOIU Content

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• Physical operating environment, including:

– air physical environment

• dust, sand, rain, snow, icing, salt laden air, wind shear, bird

strike, electromagnetic environment, solar radiation, thermal

extremes, lightning, etc

– ground physical environment

• runway conditions, short/unprepared runway/landing sites,

rough surfaces, arrested landings, aircraft tie down and

anchoring, ground handling, ground running, etc

– operational role and task physical environment

• flight over water (ditching, life support equip), remote operations

(DLRO), ops close to terrain/obstacles, embarked ops,

aircraft/ship interface, ordnance loading/unloading, NBC

protection, threat environment and ECM, etc

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SOIU Content

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• Functional operating environment

– CNS/ATM, interoperability, night vision capability, frequency

spectrum, minimum crew for specified roles/tasks, units of

measurement, Due Regard ops, etc

• Applicable policies and procedures

– Australian legislation compliance, eg. Laser radiation safety

– ADF policy, eg. Crash protection, FDR

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SOIU Content

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• All SOIUs for new aircraft acquisitions require:

– Endorsement by the Authority (DG DASA)

– Approval by the relevant 2* operational commander (COMAUSFLT, COMD

FORCOMD, ACAUST)

• The MAO (and CAM) is responsible to ensure that roles, tasks and the

operating environment do not exceed those stipulated in the SOIU (and OIP).

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SOIU Approval and Ongoing Management

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• MTCH must review all proposed SOIU amendments

– Ensure proposed operations can be safely conducted within the

scope of the aircraft TCB

• Do the amendments require new TCB requirements?

• Does compliance with the TCB need to be re-established?

• Where proposed amendments are administrative or do not impact

approved roles, environments or usage (ie minor in nature):

– MTCH endorses and MAOC Holder approves

• For all other amendments – Authority must endorse and 2* operational

commander must approve

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SOIU Amendment

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Resources Available

• Type Certification webpage (SOIU Section)

• SOIU Template (DASA Templates Webpage)

• SOIU Principles Paper

http://www.defence.gov.au/DASP/DefenceAviationSafetyProgram/SafetyAuthority/InitialAirworthiness/TypeCertification.asp

http://www.defence.gov.au/DASP/Docs/DASR-Documents/DASR-Templates/DASRAROSOIUStatementofOperatingIntentandUsage.doc

http://www.defence.gov.au/DASP/DASR-Regulations/DASR-Templates.asp

http://www.defence.gov.au/DASP/DASR-Regulations/DASR-21/SOIU/SOIU.asp

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• Agree TCB









• Produce design




Flight test





Maintain TC

Start



Design


Submission





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What is a CPP

• All acquisitions and modifications need a Certification Program (DASR 21.A.20(b))

• All acquisitions will require the development of a Certification Program Plan (CPP)

• Most Major Changes to Type Design will also require a CPP

• The CPP is an agreement between the Applicant and the Authority on how to achieve

Type Certification. Level of detail is scalable.

• An agreed CPP provides confidence to both parties that the aircraft/change will be Type

Certified

• Flexibility in respect to breaking up large modifications:

• Cover under one CPP and one instrument, or

• Split into independent portions, each with their own CPP and own instrument.

• No regulated time requirement for development of a CPP. Pre-negotiation is highly

recommended.

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CPP Contents

• General information identifying the Applicant, Project Office, prime design organisation/s,

etc.

• Certification Project Description

– History of the certification activities to date, particularly certification by another

Authority.

– High level definition of the aircraft configuration including systems, equipment, any

limitations as well as unconventional and/or novel design features being introduced.

– Keep it brief!

• Type Certification Basis (TCB) and Compliance Check List (CCL)

• Means of Compliance (including use of previous certification)

• Authority Level of Involvement (LOI)

• Project schedule:

– Major milestones

– Data and test plan submittal

– Authority inspections/witnessing

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CPP Contents – What is not included

• Type Certification does not cover aspects such as:

– Production

– Certificate of Airworthiness

– Sustainment arrangements

– Logistics

– Training

– Facilities

– Incorporation Approval

• Certification can be provided if there are issues with the above

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When do you need a CPP?

• There are four options:

1. Full CPP

– Acquisitions: AMC 21.A.20(b) requires a CPP

– Major Changes: Regulations refer back to 21.A.20 but other regulations permit some

flexibility

2. Simplified CPP;

– AMC 21.A.97 allows changes not requiring long and complex compliance

demonstration activities to have a simplified CPP, containing (as a minimum):

• General information

• Description of change

• TCB / CCL including special conditions, equivalent safety findings and

environmental protection requirements.

• Means of Compliance

• Schedule including delivery schedule of compliance documents

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When do you need a CPP?

3. Standing CPP;

– A standing agreement between the Applicant and DASA to support numerous

common Major changes to Type Design (eg. rolling software upgrades)

4. No CPP (Form 31a/b and data pack);

– There are no long and complex compliance demonstration activities (eg. full relief

from presenting compliance demonstration evidence due to prior certification) and

the applicant reasonably expects that the Authority will not conduct any inspections.

– Completion of the Form 31a/b is equivalent to a simplified CPP

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Applicant / Authority Interaction

• Use the Type Certification mailbox

• For larger and more complex certification programs, face-to-face discussions/workshops

are preferred to derive the approach and generate an initial draft of the CPP.

• Submit a mature draft of the CPP to the DIA-DASA Project Certification Manager (PCM)

for comments and feedback

• Seek advice early in the process to avoid rework, e.g.:

– presenting a Form 31a only when some Authority inspection is required

– submitting a simplified CPP when a full CPP would be more appropriate.

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• Agree TCB









• Produce design




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Applicant

• The applicant may be any entity which meets 21.A.14 or 21.A.112B eligibility.

– A DASR MDOA;

– A government organisation who has an agreement in place with a design

organisation which has access to the type design data.

• SPO supported by a DASR MDOA;

• PO supported by a DASR MDOA or design organisation approved

under a recognised N/MAA.

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Applicant

• Typical applicants for:

– MTC/MRTC:

• Acquisition PO

– MSTC:

• SPO

• PO

• DASR MDOA

– MTC Amendment:

• MTCH

• DASR MDOA that performs holder functions for the MTCH

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* Ref: AC 002/2018 – Application For Military Type Certificates and Major Design Changes

Designer

• The Designer is the organisation that carries out design activities for a

part or appliance.

• AC 002/2018 describes three candidate scenarios:

– Scenario 1 - Designer is a DASR MDOA

– Scenario 2 - Designer is not a DASR MDOA, but the design is certified by

a DASA-recognised N/MAA

– Scenario 3 - Designer is not a DASR MDOA and the design is not certified,

but the design is created using the same

organisation/people/processes/data/tools as would be used for designs

approved by a DASA-recognised N/MAA

… each scenario covered on next slides

60

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Designer (Scenario 1): Design by DASR MDOA

• DASR MDOA creates design:

– May create design themselves

– May leverage off design produced by subcontractor

– May leverage off previously certified design (Scenario 2)

– … or may be a combination of all three

• CPP may need to cover:

– Subcontractor structure and responsibilities, along with any DOA as appropriate.

• Examples:

– Boeing Defence Australia

– Airbus Australia Pacific

– BAE Systems LIFLMO

– NASPO

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Designer (Scenario 2): Design certified by recognised N/MAA

• Use of prior certified designs discussed at length later

in the course

• If essential prerequisites are met, the design can be

DASA certified with no DASR MDOA involvement (full

relief)

• If certain conditions are only partially met, additional

DASR MDOA involvement may be necessary to

(partial relief):

– create additional design, and/or

– create additional compliance demonstration evidence

– i.e. becomes a Scenario 1 activity

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Designer (Scenario 2): Design certified by recognised N/MAA

• CPP to assess how the essential prerequisites are /

will be met (per DASR 21.A.20) – more detail later

• Examples:

– ACEASPO using a USN certified design for F/A-18F

– DASSPA using a FAA certified design for the BBJ

– NASPO using a USN certified design for the MH-60R

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Designer (Scenario 3): Not MDOA, design not N/MAA certified

• Examples:

– ALSPO - RAAF unique C-130J modification that will be designed by

Lockheed Martin

– ATACSPO - Pilatus designed Tactical Terrain Avoidance and Warning

System (TAWS)

– BAE Systems - Hawk Mk127 design developed by BAE Systems UK

• Although the design organisation doesn’t have to be a DASR MDOA,

the applicant must demonstrate that the arrangement provides an

acceptable equivalence to the DASR 21J requirements

• CPP to outline how the applicant will demonstrate the equivalence

• Applicant (MTCH or PO) to subsequently attest to satisfactory

execution

=> Substantially expanded role for CASG (as Applicant)

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Designer (Scenario 3): Not MDOA, design not N/MAA certified

• Demonstrating equivalence:

– Design organisation (DO) is normally oversighted by recognised N/MAA

– DO has appropriate scope and expertise for the intended design(s),

– systems, processes and personnel used in developing other major designs

for certification by the parent NAA/MAA will be used in the design

development or holder activities associated with the ADF design,

– DO is able to provide an attestation of compliance against Defence TCB

– Any expected oversight by the DO’s parent NAA/MAA is appropriate,

– Where applicable, arrangements for DASA oversight are in place, and

– Articulate how above arrangements will be monitored and ensured during

the design development and submission process.

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66



• Agree TCB









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What is a TCB?

• DASR 21.A.17A(a) states that the TCB consists of:

– 1. The applicable airworthiness codes established according to DASR 21.A.16A

(Airworthiness Codes) unless:

• i. Otherwise specified by the Authority; or

• ii. Compliance with later effective amendments is elected by the applicant or

required under paragraph (d) (others the Authority finds directly related).

– 2. Any special condition prescribed in accordance with DASR 21.A.16B (Special

Conditions). (Also DASR 21.A.17(e) that states special conditions may be required to

take into account the intended military use of the aircraft.)

– 3. The tailoring of the criteria in European Military Airworthiness Certification Criteria

(EMACC) based on the military use of the product, when appropriate airworthiness

codes are not available.

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What is a TCB continued

• The TCB is “an agreed set of airworthiness requirements a product must be compliant with in order to

obtain a Type Certificate”.

• TCB:

– Comprehensive set of airworthiness design requirements

• Consists of an airworthiness code plus additional standards as required

– Fully account for intended role and usage (i.e. cater for the SOIU)

– Scope should be limited to the scope of airworthiness certification criteria in the European Military

Airworthiness Certification Criteria (i.e. no capability performance requirements, no long-term

WHS issues etc)

• Reflective of the design requirements actually met by the design:

– Airworthiness Requirements tailored via Military Certification Review Items (MCRIs)

• TCBs are first proposed by the applicant in the CPP

• Approved by the Authority via approval of the CPP

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Airworthiness Codes / Standards

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Airworthiness Codes

• An Airworthiness Code is a complete and consistent set of airworthiness

design requirements that define those attributes of aircraft systems or equipment

that underpin safe flight.

– ADF does not prescribe its own Airworthiness Code

• For an Airworthiness Code to be recognised by the ADF it must:

– be prescribed by a recognised N/MAA;

– have demonstrated a sound safety record;

– prescribe a complete and consistent suite of airworthiness design requirements;

– be supported by associated guidance on how to achieve compliance; and

– be accessible (ie published by the N/MAA in a consolidated/accessible format).

• Recognised codes are presented in Section 1 Chapter 3 of AAP 7001.054.

– Civil: FAR/CS Part 23, 25, 33 etc

– Military: MIL-HDBK-516C; DEF-STAN 00-970 Part 1, 3, 5, 7, 11; etc.

– NOT EMACC

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European Military Airworthiness Certification Criteria (EMACC)

• The EMACC was created by the European Defence Agency (EDA) to help

harmonise the airworthiness requirements and processes.

– based off MIL-HDBK-516B

• The purpose of the EMACC Handbook is to enable the systematic selection of

appropriate certification criteria to form a TCB for Military aircraft.

• The Handbook is not a set of certification requirements, rather it cross-

references existing airworthiness codes broken into systems (Structures,

Propulsions etc).

• Although different codes are referenced within a standardised structure, no

level of equivalence is inferred.

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European Military Airworthiness Certification Criteria (EMACC)

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Airworthiness Standards

• A standard is a document relating to the procedures, guidelines and

specification of many types of merchandise, services and systems

• Aerospace domain is served well by Standards

– Repository for accumulated knowledge on aircraft design failures

– Published by civil or military standards bodies

– Often used to demonstrate compliance with Airworthiness Code

• Provides design requirement/s, often including MoC, for the

purposes of establishing adequate levels of safety for particular

design features.

– More detailed

– Cover only a limited part of the aircraft design

– Often used to demonstrate compliance with Airworthiness Code

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Role of ‘System Safety’

• Aircraft design hazards are largely managed by employing aerospace design standards

• Individual sub-system components are required meet relevant reliability, safety or performance

benchmarks.

• But, the integration of sub-systems can give rise to hazards at the system level

• System Safety employs tools and techniques to identify aircraft hazards, and eliminate or minimise

associated safety risks, during the design process.

• The application of these tools and techniques is an essential adjunct to a standards based approach to

design, noting that design standards may:

– not apply to a whole system, merely elements of the system;

– not be relevant for novel applications, which can pose novel hazards;

– not keep up with technology advances, since standards often have review and update cycles that

span many years; and

– allow different options depending on the system’s criticality.

• Airworthiness Codes therefore include System Safety

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Role of System Safety

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AAP7001.054 – Airworthiness Design Requirements Manual

“AAP 7001.054 prescribes design requirements for aircraft systems

and functions that are necessary to achieve safe flight in Defence’s

proposed configuration, role and operating environment”

• Three foundational principles:

– airworthiness design requirements prescribed by several N/MAAs provide a sound

foundation for the safe design of Defence aircraft;

– supplementation may be required where an aspect of a requirement is judged

deficient or to support application to Defence’s unique role and environment; and

– a System Safety Program must be conducted to provide a robust means for

identifying and analysing aircraft hazards during the design process, and for

eliminating or minimising the resultant risks so far as is reasonably practicable.

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AAP7001.054 (continued)

• ‘Essential requirements ’: Design requirements for aircraft systems and

functions that are necessary to achieve safe flight in Defence’s proposed CRE)

• May include separate approaches for acquisitions and modifications

• ‘Recommend requirements’: Additional design requirements that may further

improve the level of safety, and that should be implemented where reasonably

practicable.

• Where an aircraft design fails to meet the design requirement, the ADRM

identifies the hazard(s) that the design requirement is intended to treat, to

provide a basis for informed risk management.

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AAP7001.054 (continued)

• Section 1: Application of Airworthiness Design Requirements

– Airworthiness Codes

– Contribution to satisfying WHS legislation

– Design requirements for capability and interoperability

• Section 2: Integrated Design Requirements

– System safety, E3, Human Factors, Crash Protection, etc

• Section 3: Aircraft System Design Requirements

– Nav systems, oxygen systems, electrical systems, FDRs, etc

– Only covers systems where Airworthiness Codes may require supplementation

• Section 4: Unmanned Aircraft Design Requirements

– (under review)

• Section 5: Aircraft Support Systems

– MPS, Aerial delivery, POL, Aerodromes, etc

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‘SFARP’ Contribution ?

• Airworthiness Codes and Standards can provide an excellent source of

‘reasonable knowledge’

– AAP 7001.054 Sect 1 Chap 2 Annex A (Exercising Reasonable Knowledge

in Aircraft Design) provides insight

• Can make a substantial contribution to an ‘SFARP’ argument provided:

– they are ‘recognised’

– essential supplementation in AAP 7001.054 is applied

– their context of use is appropriate

– they are intelligently applied

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Establishing an Agreed TCB

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Establishing an Agreed TCB

• The objective of the tailoring process is to set appropriate airworthiness standards for

certification according to the air system’s general design, role(s) and mission(s).

• Selection of a PCC

– Select the most appropriate given the configuration, role(s) and missions(s).

– Identify those sections of the PCC that are not relevant and justify why they can be

excluded.

– PCC used for prior certification will be the basis of the Defence TCB

• Supplementation

– Apply the EMACC and ADRM to identify where the PCC needs to be supplemented:

• to cover systems not considered by the PCC (civil vs military)

• to revise PCC requirements to consider the Defence CRE

– Develop additional criteria, as appropriate, for any capabilities or systems not

covered by the EMACC or ADRM (eg. new technologies).

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TCB Structure

• Overall Basis of Certification. Description of the Primary Certification Code (PCC)

(including version number) against which the whole aircraft is certified. This forms the

default certification code for all systems, sub-systems and elements not specifically

covered in the later sections.

• Note that a PCC must an acceptable Airworthiness Code that forms the basis of the TCB.

Cannot develop a PCC by picking parts from different Codes.

• Additional Airworthiness Requirements. Description of additional standards that are

required to account for scope shortfalls of the PCC and/or supplementation required due

to the proposed usage. (ADRM requirements included here.)

• Tailoring. Listing of the Military Certification Review Items (MCRIs):

– Exceptions

– Special Conditions

– Elect to Comply Items

– Equivalent Safety Findings

– Interpretive Material / Means of Compliance / Acceptable Means of Compliance

• Further discussion in the MCRI module.

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TCB Example

PCC

Supplementation

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TCB Example

Tailoring

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TCB vs CCL

TCB: Type Certification Basis. Word picture describing the Primary Certification Code

(Overall Basis of Certification); additional design requirements (including those required by

the ADRM); and any tailoring (Exceptions, Special Conditions, Elect to Comply Items,

Equivalent Safety Findings).

CCL: Compliance Checklist. A list of all design requirements stipulated by the TCB in order

for the recording of the MoC and reference to compliance evidence for each design reqt.

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CCL Extract

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Establishing a TCB for Major Changes• The baseline is the existing aircraft TCB.

• The applicant shall identify the applicable airworthiness requirements affected by the

Major change to Type Design.

– For MSTC this means a separate TCB and CCL

– For MTC amendment the existing aircraft TCB and CCL will be updated (where

required)

• The applicant needs to propose whether the Major change is Substantial/Non-Substantial

or Significant/Non-Significant. This will determine whether more recent amendments of

the PCC/design requirements are required.

– Authority makes the determination.

• Could be overtaken by Defence Policy (e.g. Crash Protection) or DASA mandate.

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Design Significance

• Significant change – A change to

the type-certificate significant to the

extent that it changes at the product

level one or more of the following:

general configuration, principles of

construction, or the assumptions

used for certification, but not to the

extent to be considered a substantial

change.

• Substantial change – A change

which is so extensive that a

substantially complete investigation

of compliance with the applicable

type-certification basis is required,

and consequently a new military type

certificate, in accordance with DASR

21.A.19.

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Tailoring Standards - Military Certification Review Items (MCRIs)

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Military Certification Review Items (MCRIs)

• Military Certification Review Item:

– “Where a design standard in the TCB is to be tailored (or has been tailored), a

Military Certification Review Item (MCRI) shall be raised and approved by the

Authority unless the tailoring applies to non-safety elements of the standard, or has a

trivial effect on safety.”

– Included as part of the TCB

• MCRIs are used to tailor the requirements when it is considered that the

requirements do not adequately address consideration of the system or product

complexity, type, data, and intended use.

• The MCRI documents and communicates the rationale to the Authority for

approval.

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MCRI – ADF Approach

• Specific ADF MCRI requirements are detailed in:

– DASR 21.A.16B - ‘Special Conditions’

– DASR 21.A.21(c)(2) – ‘Issue of a Type Certificate’ equivalent level of safety

requirements; and

– DASR 21.A.103(a)(2)(ii) – ‘Issue of Approval’ equivalent level of safety requirements

• The AMC/GM related to these requirements are essential reading before MCRI

submission.

• In addition, Section 4.3 of the EMACC Guidebook provides closely aligned detail of the

required approach to defining certification requirements.

• Guidance and templates are available on the website.

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MCRI – Categorisation – Special Conditions

• A Special Condition MCRI details those elements of the design for which a bespoke

certification specification has been developed.

• DASR 21.A.16B:

– The Authority shall approve any special detailed technical specifications…….. if the

related airworthiness codes do not contain adequate or appropriate safety standards

for the product, because:

• The product has novel or unusual design features………; or

• The intended use of the product is unconventional; or

• Experience……….. has shown that unsafe conditions may develop; or

• Airworthiness codes do not exist for the concerned product function.

– The special conditions contain such safety standards as the Authority finds

necessary to establish a level of safety equivalent to that established in the

applicable airworthiness codes or a level of safety acceptable if airworthiness codes

do not exist for the concerned product.

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MCRI – Categorisation – Special Conditions

• Examples:

– Increased High Intensity Radiated Fields (HIRF) requirements

– Tactical Terrain Avoidance and Warning System (TAWS)

– F/A-18F, remote control of the aircraft prior to landing

– Enhanced vision systems

– Composite fuel tanks

– FAR29 Fly by Wire requirements

• DASA Approves (with MAO consultation if required)

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MCRI – Categorisation – Equivalent Safety Finding

• An Equivalent Safety Finding MCRI specifies where it is not possible to certify against an

accepted standard, and agreement has been reached to provide a safety argument to

demonstrate an equivalent level of safety has been achieved.

• Examples:

– Use of military Performance Based Navigation standard

– Use of operating limitations to address design shortfalls


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MCRI – Categorisation – Elect to Comply

• An Elect to Comply MCRI details those elements where a later version of the Primary

Certification Code (PCC) or alternative standard has been approved for use.

• Predominantly used in the civilian context.

• Examples:

– Large airplane: Expansion of the certification basis to include CS 25.562 (includes

non-aircrew dynamic seat emergency landing conditions, thereby allowing

passengers to be carried).

• If an applicant elects to comply with a later amendment of an airworthiness code, the

applicant shall also comply with any other amendments that the Authority finds is directly

related.


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MCRI – Categorisation – Interpretive Material / Means of Compliance / Acceptable Means of Compliance• An IM/MOC/AMC MCRI is used where the applicant wants to use an extant

IM/MOC/AMC, but only in parts or with some basic changes to the content, or if there

was a discussion about the application of such documents which needs to be recorded.

• Examples:

– Use of Modelling where standard requires test

– Novel system/implementation of a system where the existing AMC is deficient

• DASA Approves but may require MAO consultation

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MCRI – Categorisation - Exception

• Exception. An exception MCRI details agreed tailoring to an Airworthiness Code or

design standard, where requiring compliance would adversely affect Defence capability.

• Examples:

– Crash Protection

– Reduced Flight Data Recorder parameters

– Fire safety (from fire-rated systems)

• DASA Approves on the basis of a Command Safety Position (next module)

• There are some that DASA cannot approve regardless of Command Safety Position.

RNP/RNAV Approvals can use MCRIs but they can only be Equivalent Safety Findings.

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Command Safety Position

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What if a design doesn’t meet the required level of safety?

• Meeting a prescribed standard may have an adverse impact on Defence capability

• The Authority may, in consultation with command, agree to an alternative requirement

that does not satisfy the Authority agreed safety criteria (ie the level of safety inherent in

the recognised Codes and Authority prescribed supplementation) – Exception MCRI

• A tailored standard will contextualise the level of safety afforded by the design for the

military role and operating environment

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What if a design doesn’t meet the required level of safety?

• Proposals to meet such tailored standards must be supported by documented rationale

that includes:

– Confirmation that the commander has a well-defined capability imperative;

– Confirmation, by the applicant, that meeting the prescribed standards impedes

achievement of the capability imperative;

– The applicant has defined the delta between the prescribed and tailored standards;

– Confirmation of appropriate consultation, cooperation and coordination by the

applicant and the commander;

– The applicant, with assistance from the commander, has clearly characterised the

risk due to this delta; and

– All possible controls have been assessed using the Hierarchy of Controls

• The agreed tailoring, including any risk controls (eg. Limitations, AFM amendment) that

are necessary to achieve the level of safety afforded by the tailored standard, will be

documented in an Exception MCRI.

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AwIPs

• AwIPs are used to communicate and record the risk decisions by Command related to an Exception

MCRI or to inform the Authority of, and provide a record of, issues of concern for a platform.

• AwIPs must provide a joint technical/operational assessment of the issue, and the proposed

treatments.

– It is the responsibility of applicants to engage operators WRT proposed treatments

• DGDASA will provide an Authority position on the AwIP, assessing whether:

– Risk treatments appear appropriate, and

– Risk characterisation appears robust.

Provides risk advice to command.

• Command makes a decision whether risks have been eliminated or otherwise minimised SFARP

Provides risk decision for way ahead.

• AwIPs can remain open for many years. The related MCRI remains in place until the issue is resolved.

• AwIP template and Factsheet available on DASA Website.

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Defence - TRADITIONAL Approach to Risk Management

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Defence - Modified Approach to Risk Management

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Hierarchy of Controls

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AwIP Structure

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107



• Agree TCB









• Produce design




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Submission





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MoC Codes

• Designers produce evidence

to demonstrate compliance

with the TCB.

• Airworthiness Standards may

specify what MoC are

required to demonstrate

compliance.

• DASR acceptable means of

compliance codes are

specified in Figure 1 to

Appendix 1 to AMC

21.A.20(b).

• (Note: equipment qualification

is mostly the use of TSO etc)

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109



• Agree TCB









• Produce design




Flight test





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Start



Design


Submission





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Relief through Prior Certification

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Relief through Prior Certification

• Where another recognised NAA/NMAA has conducted Type Certification

activities, applicants may seek relief from the need to generate Compliance

Demonstration evidence.

• The Authority may grant part or full relief against the requirement to present

evidence to the Authority for inspection.

– … provided essential prerequisites are met

• Application for full/partial relief is made through the CPP.

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Relief through Prior Certification (cont)

• Full Relief from presenting evidence can be granted where certification covers

the full scope of the aircraft Type Design by a recognised NAA/NMAA;

• Partial Relief from presenting evidence can be granted where certification

documentation does not cover the full scope of the aircraft Type Design by a

recognised NAA/NMAA, i.e:– Certification can not be shown for the whole TCB

– Certification was not completed in the context of the ADF CRE

– NAA/NMAA risk treatments require reassessment in the ADF SFARP context

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Recognised N/MAAs

• NAA:

• Australia

• EASA

• United Kingdom

• Switzerland

• Canada

• New Zealand

• United States of America

• … + any recent additions

• any other country for which the

Authority provides specific approval.

• NMAA:

• Canada

• French Republic

• United Kingdom

• Kingdom of Spain

• United States of America

• Germany

• Netherlands

• … + any recent additions

• any other country for which the

Authority provides specific approval.

NOTE: DASA places caveats on certain N/MAAs. If the caveat is unclear, refer to limited-circulation report on the N/MAA.

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Essential Prerequisites

• Essential prerequisites to seek relief (AMC DASR 21.A.20):

– Defence fully understands the certification requirements employed by the

N/MAA;• Including what the N/MAA certification covers and does not cover

• Are those requirements in accordance with their normal processes?

– The context is appropriate for the Defence CRE;

• If not, Defence understands the CRE used by the N/MAA

– The N/MAA has disclosed all safety risk treatment decisions;• limitations, risk retention, additional inspections, etc

– The N/MAA is sufficiently experienced in certification of the particular design

activity; and

– The certification is within the scope, conditions and caveats specific to DASA

Recognition of the certifying N/MAA.

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What Relief through Prior Certification is not

• ‘Auto-Embodiment’: My MTC = EASA TC+STC, therefore any change to EASAs

instruments automatically update or apply to my MTC

– The Australian MTC solely represents certification of the Australian Type Design.

Recognition of Prior Certification only allows relief from providing Compliance

Demonstration evidence when applying for a Major Change to Type Design. It does

not excuse the applicant from the Type Certification process.

• Exclusion from WHS Act 2011 Importer responsibilities.

• IMPORTANT: If during the course of the project, Defence learns of some breakdown or

deficiency in the application of the NAA/NMAA’s usual processes, those cannot be

ignored (AMC DASR 21.A.20)

=> Prior certification is not a replacement for good engineering/thinking

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• Prerequisites:

– N/MAA must be ‘recognised’

– address any caveats on the recognition

– address five criteria in DASR AMC 21.A.20

• Identify CRE deltas

• Address CRE deltas.

– (later slide)

116

Application #1: Relief through COTS Prior Certification

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• Prerequisites:

– N/MAA must be ‘recognised’

– address any caveats on the recognition

– assess the extent to which five criteria in DASR AMC 21.A.20 will be

satisfied

• Endeavour to have N/MAA to certify for Defence’s CRE

– If not, then only partial relief for providing evidence is available, and

Applicant will need address the delta (per previous slide)

• Refer to AC 002/2018 (Scenario 2) for further information

117

Application #2: Engage N/MAA to Certify New Design

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Relief through Prior Certification - Example

Boeing 737-700 IGW+ ADF Mods

FAA TC and STC

ADF Military Type Certificate

ADF Effort - extra evidence

- risk treatment- etc

Evidence Evidence

Full relief (some TCB elements)

Partial relief (some TCB elements)

No relief (some TCB elements)

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Configuration, Role and (Operating) Environment(CRE)

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Why is CRE important?

• “CRE” is a pivotal concept for aircraft Type Certification.

• Application:

– Leverage off Prior certification – CRE delta assessment used to confirm the

aircraft is safe for ADF intended use

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• The ‘technical description of the functional and physical characteristics

of an aircraft’

– Limited to those systems/functions that have direct airworthiness

implications

– Disclosed in the type design data

• Defence ‘green’ aircraft same configuration as other users – no delta

configuration exists

• Delta assessment required whenever Defence wants to employ

systems/equipment previously certified by another NAA/MAA

=> deltas affect the extent of ‘relief’ from providing evidence

121

Configuration

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• Aircraft roles are identified in the SOIU

• Roles include:

– offensive counter air, defensive counter air, strategic attack, close

air support, air interdiction, anti-submarine warfare, etc

• A key Type Certification issue is how these roles are executed:

– Mission mix;

– Flight manoeuvres;

– Flight duration;

– Cycles; etc

• Also a good signpost for the operating environment

122

Role

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Airborne physical

• physical flight conditions (dust, sand, salt, rain, snow, icing, volcanic ash, wind shear, humidity,

lightning, solar conditions (radiation and UV) etc

• impact with objects (hail, bird strike, foreign object debris/damage)

• electromagnetic environment (high intensity radiated fields, both benign and hostile)

• threat environment (eg exposure to small arms fire, missiles and so on), etc

Ground physical

• short runway landing and approach profiles, unprepared airfields/landing sites

• tie-down and lashings (land-based – expected wind conditions, ship based – expected sea conditions)

• corrosive/salt laden atmospheric conditions whilst on the ground, such as those experienced during

embarked operations, etc

Functional

• performance based navigation (RNP/RNAV/NPA, vertical navigation, navigation sensors (GNSS/INS))

• frequent operations close to the ground (need for TAWS/GPWS)

• flight over water (extended flight over water operations, ditching capabilities and need for life support

• Defence Long Range Operations, crash protection, etc

123

Operating Environment

UNCLASSIFIED

UNCLASSIFIED

• Delta assessment – process of identifying differences between the

aircraft’s as-designed CRE and the ADF’s proposed CRE

– Engineers, operators, AWC, etc

• Possible outcomes:

– confirmation the aircraft design is compatible with ADF intended use

– change to intended use (ie SOIU) to align with aircraft design

– impose operational limitations

– modify the aircraft to be safe for the proposed ADF use

– change ICA (eg add maintenance requirements) so design remains

safe for the proposed ADF use

– … or other risk treatment

124

CRE ‘delta assessment’

UNCLASSIFIED

UNCLASSIFIED

• CRE assessments useful to analyse issues outside the Type Design

that affect safe aircraft operation, for example:

– aeronautical data, electronic flight bags, mission planning systems

– compatibility of aircraft operating/maintenance procedures (not AFM or ICA) and

publications with ADF standard training and doctrine

– NVG and external (ground or other aircraft) lighting systems

– Wider WHS issues (eg health effects due to RADHAZ, HAZCHEM, etc)

• CRE assessments useful to analyse issues outside the Type Design

that affect aircraft capability, for example:

– airfield limitations, compatibility with ADF common GSE, frequency spectrum use

and access, extended operation of aircraft systems on the ground, crew action to

disable aircraft systems (eg TEMPEST), etc

=> Defence needs to confirm these issues are fully addressed. BUT NOT

ACHIEVED THROUGH TYPE CERTIFICATION

125

CRE delta assessment - other uses (not Type Certification)

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126



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Level of Involvement (LOI)

• Roles in design:

– Designer produces evidence (‘ensure’ function)

– (PO may collate evidence for overseas OEMs)

– Authority inspects evidence on a non-exhaustive basis (‘assure’ function)

• Extent of Authority involvement is known as ‘level of involvement’ LOI

• LOI first proposed by Applicant in CPP draft, then agreed with CPP

approval.

– Sometimes appropriate to make it broad at first and refine it later.

– Authority may change LOI as the project matures.

• (Note: LOI Execution discussed later)

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LOI Drivers

• Likelihood of an unidentified non-compliance:

– Novelty

– Complexity

– MDOA performance

+

• Potential impact of a non-compliance

=> Authority LOI

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Who can perform Inspections?

• Could be:

– Authority staff

• (eg SMEs for software, structures, E3, system safety, crash protection, etc)

– Authority-agreed Defence SMEs

• (eg AWC for HF, P&H, stores clearance, etc)

– Authority-agreed individual

• (eg CASG member with requisite QTE)

– Authority-agreed Contractor

• (local or overseas)

• Requirements

– QTE

– Independence

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130



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Declaration of Compliance (MDOA)

• A declaration by the applicant that they have demonstrated compliance with the

applicable TCB, according to the certification programme.

• The applicant might propose in the CPP a variation in the scope of the

‘Declaration of Compliance’, for Authority approval such as:

– will not directly demonstrate compliance but sub-contractors will

– will use prior certification to provide relief from demonstrating compliance

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Produce design

• Designer produces the design

• Could involve years of effort, but little Authority involvement unless

• it exceeds the bounds of the CPP, or

• Authority inspections are required

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Updating the CPP

• CPP is a living document, keep it updated to inform the Authority of any changes to the

certification programme.

– Organisational changes (subcontractors for example)

– Advise Authority first to determine if CPP is affected

• If you can no longer meet the CPP you are obligated to inform the Authority

• Note, the Authority may require changes to the CPP as well.

– May become aware of issues / difficulties through inspections

• Raise MCRIs as you become aware of design shortfalls – won’t affect the CPP but needs

to be dealt with at the earliest opportunity.

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• Compliance demonstration is the “Activities to demonstrate that the product, part or

appliance complies with the requirements in the Certification Basis according to the

relevant Acceptable Means of Compliance.”

• Compliance Demonstration Steps:

– Designer produces compliance demonstration evidence

• Authority inspects selected evidence (IAW LOI established in the CPP)

– PO (if Applicant) collates and presents evidence to Authority

– Declaration of compliance: Declaration signed by the applicant stating the aircraft

is airworthy within the specific design limitations.

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Evaluations, Inspections, Ground Tests

• As defined by the agreed MoC and/or applicable design standards

• Any certification issues that arise during development of evidence should be

communicated to the Authority as soon as practical (i.e. don’t wait until the submission)

• Authority LOI may dictate involvement during the development of evidence, eg.

witnessing tests

• As the regulator, the Authority has limited scope to provide applicants with SME guidance

on work within scope of their MDOA

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Flight Test - MPTF

• Military permits to fly shall be issued to aircraft that do not meet, or have not been shown

to meet, applicable airworthiness requirements but are capable of safe flight under

defined conditions.

• Examples of where a military permit to fly may be required are:

– Development;

– Demonstration of compliance with regulations or certification requirements;

– Design organisations or production organisations crew training;

– Production flight testing of new production aircraft;

– Flying the aircraft for Authority acceptance;

– Exhibition and air show;

– Flying the aircraft to a location where maintenance or airworthiness review are to be

performed, or to a place of storage;

– For individual aircraft or types for which a certificate of airworthiness or restricted

certificate of airworthiness is not appropriate

– And many more…

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Authority Inspections

• Inspections executed per CPP

– Additional inspections may be required at the discretion of the Authority

• Inspections of Compliance Demonstration Evidence (CDE) do not ensure the quality of

the design, nor its compatibility with Defence’s proposed Role and Environment.

– This responsibility is left with the designer and the importer.

• The Authority’s role is to check the validity of the CDE submitted by the Applicant

– in other words, inspections of CDE by the Authority assure safety.

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• The main outcomes sought through Authority inspection of CDE:

– assurance that CDE produced by the MDOA holder (or Authority-accepted

equivalent) is of adequate coverage and quality;

– assurance that design of novel or unusual features of the certification project has

been executed competently; and

– assurance that particularly critical elements of the design have been subject to

appropriate engineering rigour.

• In addition:

– building Authority confidence in MDOA holder skills (with a particular emphasis on

CVEs) for complex technical disciplines (eg software, structures);

• This can impact future acquisition/modification LOI

– contributing to the Authority’s ongoing compliance assurance of the MDOA holder (or

Authority-accepted equivalent).

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• Examples:

– engineering evaluation of design and compliance documents (type design definition

documents, calculations/analyses, safety assessments, manuals, test plans

(laboratory/ground/ flight) and test reports, inspection reports/records etc.);

– a review and engineering evaluation of the MDOA holder’s test article conformity

documents, including an evaluation of non-conformances of test articles/specimens;

– participating in reviews, inspection of products, auditing processes and procedures;

– witnessing or participating in the MDOA holder’s tests or inspections; and/or

– performing the Authority’s own inspections/tests, including flight tests.

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Declaration of Compliance

• A DoC has to be made by the applicant IAW 21.A.20(d).

– It declares that the aircraft is airworthy within the specific design limitations.

• Regardless, the compliance with the TCB must be shown:

– Use MCRIs to tailor the TCB

• DoC can only be completed:

– After DASA approval of all MCRIs; and

– after all Authority inspections have taken place.

– If so agreed by the Authority, some compliance documentation may be produced

after issuance of the DoC (eg. ICA for maintenance first occurring well after

certification such as a 10YR interval inspection).

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Submission

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MTC / MRTC

• There are forms under development, however given the limited number of applications

expected for MTC / MRTC, the Authority is currently waiving the requirement to use the

form.

• Currently, the application for MTC / MRTC is the Accomplishment Summary.

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Form 31 – Major Change/Repair to Type Design and MSTC• The DASR Form 31 is used to apply for approval of a Major Change or Major Repair to

Type Design and MSTC. Comes in three variations:

– Form 31 may be submitted at the start of the project. It signals to the Authority your

intent to undertake the activity. (But there are other ways to achieve this.)

– Form 31a (Major changes and MSTC): Submitted at the end along with all necessary

substantiation documentation.

– Form 31b (Major repairs): As above.

• Found on the DASR Forms webpage – use as the source, not locally stored versions

• Form 31a submitted to the PCM with the Type Certification mailbox cc’d

• Form 31b to the DAVENG-DASA desk officer

• In the case of Major changes, the Authority will determine whether MTC amendment or

MSTC is appropriate.

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Form 20a/18a/21 – MPTF

• Form 18a - Approval of Flight Conditions for a Military Permit To Fly (Authority)

– Submitted first in the process.

– Contains the substantiation documentation.

– Requires Declaration of Safety – by an appropriate MAO delegate

• Form 21 - Application for Military Permit to Fly

– Submitted second in the sequence once flight conditions have been approved.

– Summarises the application.

• Form 20a - Military Permit To Fly (Authority)

– The actual permit which will be signed by the Authority or delegate.

• Further information in AC 003/2017 - DASR Implementation of Military Permits to Fly.

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Confirming Continued Airworthiness

• The MTCH is required to make a holder attestation which:

– agrees to proceed with the change to the Type Design (i.e. it does not invalidate the

existing Type Design); and

– confirming suitable arrangements for the holder obligations are in place for

maintaining the Type Design.

o Namely, a suitable design organisation is contracted to provide support for the

life of the design.

• Included on Form 31a if that approach is taken

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156



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157



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Authority Assessment - Upon Formal Submission

• Separate to LOI

• PCM identifies any SME assessment required

– Typically DTS-DIA, DAVENG

– May be AWC, ASCENG, etc

• PCM completes their own assessment

– Confirm certification activities are congruent with agreed CPP.

• Brief drafted for Approval Authority

– Recommendation for approval of instrument, or

– Recommendation to AwB

• Airworthiness Board ?

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Project DoSA

• No delegated authority

• Two broad roles:

1. Assist DASA with local expertise

… conceptually similar to a DASA staff member

2. “Provide Director General DASA (DG-DASA) with a declaration that

there is no issue to the DoSA-Project’s knowledge that might preclude

the Authority from issuing the requested certification.”

… DoSA always executes, but DASA doesn’t always request declaration

UNCLASSIFIED

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Airworthiness Board (AwB)• Not directly a part of Type Certification process

• Provide independent assurance to DefAA that aviation safety is being

effectively managed

• Convened at the discretion of the Authority, typically for:

– Acquisitions;

– Some Major changes; and

– any other reason as directed by the Authority.

• For Major changes, the Authority decision to convene an AwB may consider:

– complexity of the design

– complexity of introducing new arrangements for operations, design, continuing

airworthiness, logistics, safety management, etc.

– the significance of any identified design deficiencies and, in particular, how these are

proposed to be managed

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AwB Outcomes

• ‘No objection’ conclusion to the Authority that the aircraft/Major change be

approved for operations, where:

– any recommendations offered by the appropriate two star commander have been

considered

– the appropriate MAO-AM and the Defence Aviation Safety Authority (DASA) have

recommended (to AwB) issue or amendment of the MAOC

– the AwB is satisfied that the Aircraft can be safely operated and its airworthiness

maintained, in the intended roles and environment, subject to any prescribed

conditions and limitations.

• AwB submits a report to the DefAA, recommending the appropriate Aviation

Safety Instruments be issued by the Authority.

– Instruments are issued once DefAA signs the report.

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Instrument Issue and Approval

• DGDASA is the issuing Authority for MTC/MRTC/MSTC

• Major change approvals

– Signed Form 31a + minute => DG DASA or DIA

– Signed Form 31b => Authorised DAVENG staff member.

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Maintain Type Certificate

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MTCH Obligations

• The MTCH has ongoing obligations to ensure the validity of the Aviation Safety

Instrument.

– System for collection, investigation and analysis failures, malfunctions and defects

– Implement Airworthiness Directives

– Ensure collaboration between design and production organisations as necessary to

achieve continued airworthiness

– Record keeping, maintain and update manuals, furnishing ICA to operators and the

Authority

– Periodic ASI and ESI integrity assessments

• It is the responsibility of applicants to engage the MTCH.

• The Authority controls the TCB and TCDS. The MTCH is custodian of the CCL.

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Final Points

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Common Type Certification Issues• Confusion over the role of the applicant.

– The designer, regardless of MDOA, may not necessarily be the applicant (e.g. if the interface is

managed by a PO).

– Non-MDOA applicants (POs) cannot create compliance demonstration evidence.

– Any competent individual can conduct a CREA, however the outcomes often lead to work

requiring MDOA (i.e. additional evidence, analysis etc).

– Understanding of AC 002/2018

• Some external contractors don’t fully understand the Defence context.

– Defence often uses its aircraft in unique roles and operating environments and this needs to be

taken into account in their design.

– Some are familiar with civilian process, but less familiar with the military aspects of the DASRs.

– Many have difficulties with risk communication.

• Several applications propose unrealistic DASR certification timelines.

– Failing to create a timely CPP can result in different certification expectations between the

applicant and the Authority (usually realised very late in the design process)

– Late or no engagement doesn’t help either the applicant or the DASA if the application is

presented with shortfalls and issues

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Common Type Certification Issues (continued)

• Some POs may not be timely/effective in characterising/disclosing risks to operators that are due to

design deficiencies discovered during the certification program.

– The 7-step approach is essential if there is a shortfall. Certification cannot proceed without it.

• CPP vs contractual/capability outcomes.

– Avoid using CPPs to achieve a desired capability outcome.

– Avoid (where possible) using approval of CPPs as contractual milestones.

• Projects that establish an initial CRE assessment early, and regularly update it as new information

emerges, are much less likely to encounter unpleasant surprises late in the project lifecycle. The CPP

should summarise and reference out to the CRE assessment.

• If an element of certification will impose a huge burden on a project without a commensurate safety

benefit, then by all means argue your case. However, spending five times the effort to argue against a

requirement than simply complying will delay certification.

• Act firmly on all feedback received from DASA. Either comply with the feedback or argue against it

(noting above), but never ignore it. Ignoring feedback will delay certification.

UNCLASSIFIED

UNCLASSIFIED

Directorate of Aviation

Engineering

DAVENG

GPCAPT Gregory Lamb

Director General

Defence Aviation Safety

Authority

DGDASA

AIRCDRE Jason Agius (O7)

Directorate of Continuing

Airworthiness

DCA

GPCAPT Gavin Jenkinson

Directorate of Initial

Airworthiness

DIA

Mr Mark Wade (EL2)

Airworthiness Coordination

and Policy Agency

ACPA

GPCAPT Terence Deeth

Directorate of Policy,

Engagement, Promotions &

Safety Management Systems

DPEPS

Dr Sonja Jenkinson (EL2)

Chief of Staff Directorate

COSD

Mr Campbell Smith (EL2)

Defence Flight Safety Bureau

DFSB

GPCAPT Nigel Ward

171

DASA Organisation

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Role of DIA Project Certification Manager (PCM)• Initial contact to be made through [email protected] mailbox. Once a PCM

is assigned they act as a centralised DASA POC to improves the timeliness and

consistency of DASA input to Projects

• Roles of the PCM:

– Authority POC

– Certification guidance to applicant

– Conduct/coordinate SOIU, CPP, MCRI. TCB, AwIP endorsement/approval

– Assess whether instruments warranted, provide recommendation

mailto:[email protected]

UNCLASSIFIED

UNCLASSIFIED 173

Further Information

1. DASA Webpage

i. TC Webpage

ii. Advisory Circulars (ACs)

2. PCM

3. TC Mailbox ([email protected])

http://www.defence.gov.au/DASP/DefenceAviationSafetyProgram/SafetyAuthority/InitialAirworthiness/TypeCertification.asp

http://www.defence.gov.au/DASP/DASR-Regulations/AdvisoryCirculars.asp

mailto:[email protected]

QUESTIONS

UNCLASSIFIED

UNCLASSIFIED

DASR Type Certification 216207 - Department of Defence · 3. Type Certification Overview 4. Define...

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