General Session LA 2018 - faa.gov · Tb.t furu,e orAmntl Ctttwuuon : IDtttoauooal Upclaie (opllOIW)...
Transcript of General Session LA 2018 - faa.gov · Tb.t furu,e orAmntl Ctttwuuon : IDtttoauooal Upclaie (opllOIW)...
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Aircraft Certification Designee Management
May 8, 2018 Long Beach, CA
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Delegation and Organization Procedures Branch AIR-6F0
General Session Presentation Printout Section 508 Compliant
Section 508 requires that when federal agencies develop, procure, maintain, or use electronic and information technology (EIT), individuals with disabilities have access to and use of information and data that is comparable to the access and use by individuals without disabilities. For more information visit: Section508.gov.
Use of the information provided in this document is for general reference only. This document can be superseded at any time by the next revision or expiration of the referenced information.
Renewal Requirements
FAA22000002 DER Recurrent General Session
FAA Order 8100.8D paragraph 803.g. states: "DERs must attend a recurrent seminar every 2 calendar years to maintain their knowledge of the regulations and policies and as a condition for renewal. DERs may satisfy the 2 year requirement by attending a DER seminar in the calendar year it is due.
Contact EDR Training
If you have any questions or comments concerning the content of this document, send an email to the Engineering Designee Recurrent Training Branch.
For Program Information visit our website: Engineering Designee Recurrent Training Information
http://www.section508.gov/mailto:[email protected]://www.faa.gov/other_visit/aviation_industry/designees_delegations/training/der_recurrent/ -
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AIR-6F0 Engineering Designee Recurrent Seminar List of Acronyms
Acronym/Symbol 14 CFR AC ACE ACO AD ADO AEG AIA AIR AIR-1 AIR-100 AIR-6A0 AIR-6B0 AIR-6C0 AIR-6D0 AIR-6E0 AIR-6F0 ASTC ASW ATC ASTM AVS
C of A CA CBT CDO CDPO CFR CLOA CMACO COA COS CP CPN
DAH DAR DBR DER DIN DMS DOT DRS
Definition Section Title 14 of the Code of Federal Regulations Advisory Circular Small Airplane Directorate (SAD) Aircraft Certification Office Airworthiness Directive Approved Design Organization Aircraft Evaluation Group Aerospace Industries Association Aircraft Certification Service Director, Aircraft Certification Service Design, Manufacturing & Airworthiness Division Certification Procedures Branch Technical & Administrative Support Staff Branch Systems & Equipment Standards Branch Operational Oversight Policy Branch System Performance and Development Branch Delegation and Organization Procedures Branch Amended Supplemental Type Certificate Rotorcraft Directorate Amended Type Certificate American Society for Testing and Materials Aviation Safety
Certificate of Airworthiness Certificating Authority (a.k.a. exporting authority) Computer Based Training Certified Design Organization Certified Design Production Organization Code of Federal Regulations Certificate Letter of Authorization Certificate Management ACO Certificate of Authority Continued Operational Safety Certification Plan Certification Project Notification
Design Approval Holder Designated Airworthiness Representative Delegation by Regulation Designated Engineering Representative Designee Information Network Designee Management System Department of Transportation Designee Registration System
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AIR-6F0 Engineering Designee Recurrent Seminar List of Acronyms
E&PD Engine and Propeller Directorate ECO Engine Certification Office EDR Engineering Designee Recurrent EMI Electro-Magnetic Interference
F Fahrenheit F&R Function and Reliability F/A Flight Attendant FAA Federal Aviation Administration FAATC Federal Aviation Administration Technical Center FADEC Full Authority Digital Engine Control FANS Future Aeronautical Navigation System FAQ Frequently Asked Questions FAR Federal Aviation Regulation FCAA Foreign Certification Airworthiness Authority FSDO Flight Standards District Office
GA General Aviation GAMA General Aviation Manufacturers Association GAO General Accounting Office
HQ Headquarters
ICA Instructions for Continued Airworthiness
LOPI Level of Project Involvement
MARPA Modification and Replacement Parts Association MOC Method of Compliance MOU Memorandum of Understanding
NACIP National Automated Conformity Inspection Process NAS National Airspace System NPRM Notice of Proposed Rulemaking NTSB National Transportation Safety Board
ODA Organization Designation Authorization ODAR Organizational Designated Airworthiness Representative OIG Office of the Inspector General OMT Organization Management Team
PACO Project Aircraft Certification Office PMA Parts Manufacturer Approval PNL Program Notification Letter POA Production Organization Approval POC Point of Contact PSCP Project Specific Certification Plan PSP Partnership for Safety Plan
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AIR-6F0 Engineering Designee Recurrent Seminar List of Acronyms
PTRS Program Tracking and Reporting Subsystem
R&A Repairs and Alterations RBDM Risk Based Decision Making RBRT Risk Based Resource Targeting RFC Request for Conformity RGL Regulatory and Guidance Library
SAD Small Airplane Directorate SAIB Special Airworthiness Information Bulletin SAR Selection, Appointment, and Renewal SFAR Special Federal Aviation Regulation SME Subject Matter Experts SMS Safety Management System SOP Standard Operating Procedure SRM Safety Risk Management STC Supplemental Type Certificate
TAD Transport Airplane Directorate TBD To Be Determined TC Type Certificate TCDS Type Certificate Data sheet TSO Technical Standard Order TSOA Technical Standard Order Authorization
UM Unit Member
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Federal Aviation Administration
WELCOME 2018
Engineering Designee Recurrent Seminar
General Session
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Logistics
Cellular Phones
Exits
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Logistics
Restrooms
Food
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Logistics
Microphones
Security
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Logistics
Sign-In Sheets
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New Format
Morning Session ContainsRequired Material
Afternoon session attendance is optional
Tests will be given after the last speaker of the morning
session.
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Logistics
Please return on time from breaks and lunch
Tests will be given at the end of the morning session, tests
will not be given early.
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Test Today
Test Today AVS Order 1100.2 requires learning
assessment We need to have a test paper to match
every signature on the sign-in roster It is not necessary to sign the test, please
write your name legibly on the test sothat it can be matched to the name on the sign in sheet.
Test forms given out at the end of the morning session
Tests will be given out after the last speaker of the morning session has finished. No tests can be given early.
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Test Today
Test Today VERY IMPORTANT!
1. If you do not complete and submit the test today, you will not receivecredit for this seminar.
2. You must take the test in the session where you are registered.
3. You must pass the test with 70% orgreater to get credit
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Evaluations/Certificates Following the seminar: AIR-6F0 will verify attendance of all participants in the
registration system. You will receive email notification with a link to the course evaluation.
After you have completed the evaluation, you will be able to print the course completion certificate.
AIR-6F0 will retain records of your course completion. AIR-6F0 will update your training records in our designee database.
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Comment Sheets Are Included inParticipant Guides Comment Sheets
Are Included in Participant Guides
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Federal Aviation Administration
WELCOME 2018
Engineering Designee Recurrent Seminar
General Session
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Federal Aviation Administration Engineering
Designee Training Overview
Presented to: 2018 DER Recurrent Seminar General Session
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Seminar Program Overview Designee Training Program Website Course Fees Policy Memo Recurrent General Session Seminar Locations Course Certificate Feedback Contact Us
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Designee Training Program Website
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Course Fees Course fees are being updated on an annual basis as necessary to ensure the solvency of the training program
The FAA no longer subsidizes Engineering Designee training Fees will be adjust periodically to cover program expenses All monies collected from training course fees will be used for engineering designee program
Technical training will have a flat fee
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Policy Memorandum AIR100-17-160-PM02
Revises the recurrent training requirements contained in FAA Order 8100.8D paragraphs 803g and 201b
Changes the technical training requirement to an annual requirement for DERs, ODA UMs, DER advisors and OMT members
General Session training requirements will remain unchanged for DERs
General Session training requirements for DER Advisors being changed to every 2 years to align with the DER requirement
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Training Program Engineering Designees have access to complete required training at any time during the training year
Technical training courses are being developed on an ongoing basis and will be released individually as they are completed
Technical training course curriculum will include required courses and electives Required courses will be any courses selected by the FAA to be completed by all designees within a particular discipline
Elective courses will be within the designees discipline Designees will select a minimum number of elective courses
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New Training Program (cont.) Access to the technical training will be based on a flat annual fee Once paid designees will have access to the entire training library for the duration of the calendar year
Designees will then be able to register for and complete their required training by the end of the training year as required
The FAA will be issuing a required Introductory course which will include: Details on the changes to the technical training program Instructions on how to access and navigate DRS and Blackboard Details on required versus elective courses Instructions for the selection and completion of elective courses
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Recurrent Seminar General Session
Recurrent General Session will now have a mandatory morning session and an optional afternoon session
There is an online option for the Recurrent General Session The fee will be the same between the face to face and online versions
Online version will include the required morning session but will not include the material covered in the optional afternoon session (although the presentations from the afternoon will be made available)
General Sessions will be offered in same locations but less frequently (next slide)
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Seminar Locations
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Course Certificate
Course Certificate: Issued after up to 4 hours after successful completion. If you do not receive a course certificate:
Make sure the course requirements are met. Contact the help desk for assistance
Do not wait until the end of the training year to figure out you did not get a course certificate.
You may retrieve your current and past certificates from DRS (see FAQ webpage)
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We Need Your Help!
Feedback: Engineering Designee Seminar Program is YOUR program
Most topics come from field suggestions (Designees, ACOs, Directorates, etc.)
Future changes/improvements will include input from our designees
There are many ways YOU can provide input End of course Survey Website: Contact us Email: [email protected] Contact Us button found in each course
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Contact Us Please allow time to look into your problem and respond. The program is growing and we are doing our best to respond to all inquiries in a timely manner.
1. For content specific questions each course will now have contact information for the Subject Matter Expert (SME) for that course. Please contact the SME for content related questions.
2. Preferred Method: Email: 9-AMC-EDR [email protected]. Each course has a Contact Us Menu Item. Provide as much information as possible, but at a minimum be sure to include: Your full name as it appears in DRS not a nickname Course Number and title for example: (27200106) Electrical: Electronic Flight Bag Page Number: Page 5 of 25 Explain the error found Provide a screen shot if possible
3. If you decide to call and leave a Message: a. Clearly Provide your full name as it appears in DRS not a nickname b. Course #, Lesson and problem: We can troubleshoot and perhaps correct the issue if we have the
details before we contact you by email or returning your call.
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Questions
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Stump the Regulator
Presented to: 2018 Engineering Recurrent Seminar
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Stump the Regulator
Open Q&A session with everyone from FAA Headquarters on stage
We reserve the right to tap into local FAA knowledge
Any question relating to delegation of any kind is fair game
Prize to those who manage to stump us Note: not liking our answer is not stumping us
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Sample questions
Question: As a DER I last took the General Session training in Sept of 2016. My renewal is in Aug of 2018. Can I be renewed or do I have to take the training before?
Answer: Yes, you can. The General Session training requirement is once every 2 calendar years, which means you have until Dec 31st of 2018 to take the training in this scenario.
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Sample questions
Question: Can a Repair Specification be created for minor repairs?
Answer: No, Repair Specification approvals are for major repairs ONLY. Minor repairs only require acceptable data, not approved data, and therefore no 8110-3 or 8100-9 is required.
Ref 8110.37F and 14CFR 43
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Sample questions
Question: I see there is something called a vintage DER Do I have to have that before I can work on Vintage Airplanes?
Answer: No, a vintage DER is a DER who did not meet all the qualifications of a DER but who has demonstrated expertise in a certain type of vintage aircraft.
Ref 8110.37F
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Questions before we begin?
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Ok, then lets see if you can STUMP THE REGULATORS
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New Policy
Presented to: 2018 Engineering Recurrent Seminar
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New Regulations/Policy of Note
8110.37F 14 CFR 23 AMOC Order 8110.103B PMA for minor modification articles Lithium Battery policy memo New DER landing page website
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Recent Policies
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Order 8110.37 Revision F 8100.37F was released in August of 2017 Here are some of the changes incorporated in Revision F
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Whats in 8110.37F No more DER Candidates Anyone who would have been identified as a Candidate DER may now be appointed as a DER with authority limited to Recommend Approval
Existing Candidates may either be appointed or terminated
A note was added to require the removal of Administrative DERs
A new section on rescinding an 8110-3 after its been issued
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Whats in 8110.37F
Added a section on repair of TSO products Cannot just repair a part that was produced under a TSOA to the TSO
Must address the certification basis of the product upon which the repaired part will be installed on
Added instructions in Appendix B on how to document new part 23 findings on the 8110-3 form Now required to list the means of compliance accepted under 14 CFR 23.2010 in addition to the regulations
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Questions?
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14 CFR Part 23 rewrite
The entire part 23 has been rewritten Final rule was out in December 2016 It becomes effective on August 30th 2017 The philosophy is to have the WHAT we want to happen in the rule (e.g. keep occupants from severe injury during a crash) and put the HOW into Method Of Compliance (MOC) documents
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14 CFR Part 23 rewrite The rule and the MOC documents will be used together to show compliance
Initially the new form (Rule and MOC documents) will look very similar to the current 14 CFR Part 23 at amendment 62 because that was the starting point for the ASTM documents
As time goes by changes to the ASTM MOCs and other accepted MOC documents will result in a more streamlined process for applicants
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14 CFR Part 23 rewrite
How does this affect DERs? Actually very little impact If you currently have a delegation for part 23 you may, when delegated, find compliance to the new part 23
The compliance finding will be to the new performance based regulation (all new numbering system!)
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14 CFR Part 23 rewrite
The DER will list the new regulation in block 9 applicable requirements.
The DER will also be required to list the MOC in block 7 in the list of data block
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14 CFR Part 23 rewrite
If you will be finding compliance to the new part 23, youll most likely need to subscribe to ASTM to get access to the MOCs. $75/year.
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Questions?
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AMOC Order 8110.103B
The AMOC order has been rewritten. It allows for the FAA to delegate AMOC authority in certain cases
Still limited to company DERs and ODAs and only certain ADs.
It can be found at http://rgl.faa.gov/Regulatory_and_Guidance _Library/rgOrders.nsf/0/9EB2E3C417522B5E 86258030005AD1FC?OpenDocument
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PMA for minor modification articles PS-AIR-21-1601
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Lithium Battery policy memo AIR100-15-140-GM50
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Questions?
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The New DER Landing Page
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How to find it?
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Screenshot
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The New DER Landing Page
Serves as a place for DERs to start looking for FAA information Goal is for any information useful to a DER is only one or two clicks away
It has a newsfeed for updated topics It has a library of useful information such as links to forms etc.
Please put on your comment form any information you think would be useful to have on the site
A link for user feedback and suggestions is on each page
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Questions?
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Title Page
Designee Management System (DMS)
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Presented to: 2018 Engineering Recurrent Seminar
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What is DMS?
DMS is a web based tool for the FAA to use in managing its designees
Created in Response to a Government Accountability Office (GAO) audit of the FAA
Replaces the individual systems that each line of business was using
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What will DMS do? It will roll up Appointment Renewal Terminate as well as provide for the management of the delegation
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Current Deployment Schedule
DMS is up and running for Manufacturing, Aeromedical and AFS Designees
DERs are next We will be working on the requirements document through this fiscal year (Oct)
DERs should not expect to have to do anything until early 2019.
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DMS
When we do transfer your data over from our existing system we will need you to verify that the data we have is correct
We may do that before or after the transfer depending on what is easiest
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Questions?
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Title Page
DER: Roles and Responsibilities
Federal Aviation Administration
Presented to: 2018 Engineering Recurrent Seminar
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Roles and Responsibilities
This is a refresher of some information presented in the initial DER training
Well remind you of: Use of DER Numbers Proper Use of Form 8110-3 DERs and Conformity Certification Plans
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Use of DER Numbers There are limited instances where it is appropriate for DERs to use their DER identification number.
DERs have used their DER numbers inappropriately. We DO NOT permit DERs to use their DER identification number when signing: Company or personal reports Drawings Service documents Letters
DERs signature on these types of documents does not constitute FAA approval.
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Use of DER Numbers
DERs may use their DER identification numbers in five places: FAA Form 8110-3 - Statement of Compliance with Airworthiness Standards DERs find compliance to airworthiness standards.
FAA Form 8100-1 - Conformity Inspection Record DERs may be authorized to disposition items found to be unsatisfactory during the conformity inspection process.
FAA Form 8120-10 - Request for Conformity DERs may be authorized to initiate a request for conformity.
Repair Specifications DERs with a special delegation are authorized to approve repair specifications
Certification Plans DERs are encouraged to review the applicants certification plan prior to review and acceptance by the FAA.
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Questions?
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Proper Use of Form 8110-3
Even though it is referred to as a data approval, except for major repairs or alterations, the Form 8110-3 signifies only that the data complies with the airworthiness standard
In general, Form 8110-3 is not an FAA approval to produce parts or otherwise use the data
Form 8110-3 signifies that the DER has verified compliance on behalf of the FAA, or has reviewed the data and recommends that the FAA concur with this recommendation
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Proper Use of Form 8110-3
A DER authorized to approve technical data may decline to approve any or all portions of the data. The DER must NOT submit a 8110-3 Form (ref 8110.37F Chapter 3 paragraph 1(e) )
The DER must discuss the reasons for not approving the data with the project office.
For major repairs or major alterations Approval of the engineering design data is required before the repair or alteration may be returned to service.
Form 8110-3 serves as: Finding of compliance Approval to accomplish the repair or alteration
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Proper Use of Form 8110-3
Form 8110-3 is used to document a finding of compliance with airworthiness standards.
Form 8110-3 is NOT used to document a DERs participation in or review of any other part of a certification project, such as: Certification plans Compliance checklists Conformity plans Project schedules Proposed certification basis
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Questions?
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DERs and Conformity
Conformity is verification that aircraft and parts were manufactured according to the approved engineering drawings.
Form 8100-1, Conformity Inspection Record, is used to document conformity inspections during type, production, and airworthiness certification programs. Lists all discrepancies and nonconformities identified during a conformity inspection of a part, installation, or entire product.
Records corrective actions taken to resolve discrepancies and nonconformities.
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DERs and Conformity
Items identified on the Conformity Inspection Record as unsatisfactory are referred to as UNSATs, and must be cleared before the part, installation, or product can be issued an approval or certificate
A DER may be authorized to participate in the conformity process when corrective action to resolve any UNSATs involves the engineering design
All inspections conducted by an ASI or designee to determine conformity to an approved type design before an airworthiness certificate is issued must be recorded on FAA Form 8100-1
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DERs and Conformity
DERs authorized to disposition UNSATs on a Form 8100-1 must be identified by the ACO requesting the inspection
DERs are specified by name and DER identification number on the Request for Conformity, Form 8120-10
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DERs and Conformity
An authorized DER can determine, from an engineering standpoint, if the nonconformance is acceptable, if the part must be reworked, or if it must be scrapped. If the discrepancy allows the part, installation, or product to comply with the airworthiness standard, the DER may approve a drawing revision to clear the UNSAT
Form 8110-3 only approves the drawing revision, and does not reference Form 8100-1
DERs entry on Form 8100-1 to clear the UNSAT should reference the new Form 8110-3
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DERs and Conformity
DERs authorized to clear unsatisfactory conditions/nonconformities will enter the nonconformity in block 9, and describe the corrective action in block 13
May also transmit this information to the inspector or DMIR/DAR-f to be recorded on the 8100-1
When corrective action is completed, the DER will: Line through and initial the UNSAT in block 12 Sign the corrective action in block 13 with his/her DER identification number
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Request for Conformity
The Project ACO may designate a Management DER to initiate this request on their behalf
The DER completes a Form 8120-10, Request for Conformity (RFC)
The completed RFC is sent to the MIDO to request the inspection, whether by a MIDO inspector or by one of their designees, a DMIR or DAR-F
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Request for Conformity
Instructions for completing the RFC are found as a separate instruction sheet attached to the printed version of the form, or as the first two pages of the electronic version of the form
DERs initiating the RFC on behalf of the ACO should record their name and DER identification number on the line identified for the FAA project manager
The completed RFC must be reviewed and signed by the FAA project engineer
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Questions?
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Certification Plans
We encourage DERs to review and coordinate on certification documents submitted to the FAA, such as certification plans
DERs may use their DER number and title on the certification plan cover sheet to indicate that they reviewed the documents
A DERs signature on a certification plan does not constitute FAA approval
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Questions?
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Aircraft Certification Transformation
Federal Aviation Administration
Presented to: 2018 Engineering Recurrent Seminar
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Introduction
Aircraft Certification Service (AIR) Transformation Responsive to
Congressional Direction (FAA Modernization and Reform Act of 2012)
Industry requests for more efficient certification processes
Discuss evolution of FAA/Industry roles and responsibilities Expectations are changing as we strive for efficiency
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AIR Transformation is our holistic approach to becoming more efficient and effective
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Refresh Certification Strategy AIRs future state model will streamline compliance activities and promotes early and iterative actions between industry partners and AIR.
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Improve Our Organization The future state AIR organization is aligned by function (key capabilities of each Division below).
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Next Steps for Implementation
Realignment was the first visible step of a phased implementation of the functional organization
AIR realigned the organization in July 2017 allowing us to institutionalize process improvements (currently in progress).
Realignment changed management structure of AIRs existing local offices (ACOs, MIDOs, etc.) to align with AIRs functional divisions. ACOs are currently part of the Compliance and Airworthiness Division, AIR-700.
Industry POCs have been retained to ensure seamless relationship management and to facilitate contact with the appropriate AIR employees.
AIR will continue to brief industry on implementation status and to solicit feedback.
As an outcome of realignment, AIRs Four-Directorate structure ceased to exist. Directorate standards functions now reside in the Policy and Innovation Division AIR-600
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Evolution of FAA/Industry roles and responsibilities Goals: Provide ability to better manage workload and be more responsive
Define involvement based on compliance risk Maximize applicants capability to show compliance Develop an applicant base fully capable and competent in showing compliance so that the FAA can focus its resources on risk based oversight
Expand FAA recognition of applicant showing only (ASO) for compliance
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Evolution of FAA/Industry roles and responsibilities Strategic Objectives:
Support an empowered FAA workforce who embrace risk based oversight for applicants that demonstrate a compliance culture.
Utilize ASO policy memo on targeted certification activities
Build/Enhance a systems approach to certification within the applicants organization
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Summary FAA Transformation is responsive to:
Congressional Direction (FAA Modernization and Reform Act of 2012) Industry requests for more efficient certification processes
Implementation of FAA initiatives that support the transformation have already begun: Risk Based Level of Project Involvement Tools (RBRTa/RBRTo) Certification Process Improvement (CPI) Guide Revision Recognition of ASO
Next step is to continue to refine the organization and promote early and iterative actions between industry partners and AIR
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Questions?
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Federal Aviation Administration
Presented to:
Engineering Designee Recurrent Seminar
International Update
2018 Engineering Designee Recurrent Seminar
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Overview FAAs Global Leadership International Policy Division ( AIR-400) Bilateral Agreements Overview
Implementation Procedures Current Agreements
FAA and EASA (TIP) DERs and International Policy DER Dos and Donts Helpful Links Questions???
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FAAs Global Leadership Certification Management Team (CMT)
Represents the key authorities for global aviation FAA, EASA, TCCA, and ANAC Leadership for FAA is AIR-1 (Dorenda Baker)
CMT Collaboration Strategy (May 2016): Partnership leveraging Continued confidence building Global leadership Certification policy alignment
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FAAs Global Leadership, Contd
CMT Goals for 2018 Develop bilateral validation improvement roadmaps with each CMT partner FAA and EASA signed a Validation Improvement Roadmap (VIR) in August 2016
FAA is working with TCCA and ANAC on specific roadmaps
Integrate key areas into FAA policy and our bilateral agreements EASA: TIP Rev 6 Active on March 22nd, 2018 TCCA: IPA Rev 2 was signed in Nov 2016, Rev 3 is underway
ANAC: IPA Rev 2 on target for Mid FY18
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International Policy Division (AIR-400) Advocate in worldwide Aircraft Certification activities Promote strategic and effective international partnerships
Lead international conferences and meetings Promote U.S. priorities at International Civil Aviation Organization (ICAO) and other international forums Representative on ICAO Airworthiness Panel
Policy holder for FAA Order 8110.52, Type Validation Procedures (TVP) Rev. B Signed on September 29th, 2017
Foundational Policy for all Bilateral IPAs
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International Policy Division (AIR-400) Bilateral Agreement Development and Management Assessment, negotiation, development, and management of bilateral agreements
Address issues faced by AIR offices and U.S. industry in foreign certification activities
Special Arrangements and Management plans Supplemental IPA language; provides additional authority and provisions
Detailed how to information describing a technical situation (design, production, or airworthiness)
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Bilateral Agreement Overview
Bilateral Aviation Safety Agreement (BASA)
Promote aviation safety and environmental quality and enhance cooperation and increase efficiency in matters relating to civil aviation.
Provide for bilateral cooperation in a variety of aviation areas: airworthiness certification, maintenance, flight operations, and environmental certification.
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Bilateral Agreement Overview, Contd
IPs provide guidance for use of FAA designees in the validation process
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Bilateral Agreement Overview, Contd
Implementation Procedures Implementation Procedures for Airworthiness (IPA)
Represents the majority of IPs between the FAA and our FCAA partners
TCCA, ANAC, CAAC (new), JCAB, Indias DGAC, etc
Technical Implementation Procedures (TIP) ONLY between the FAA and EASA Unique in its specifics and breadth
Schedule of Implementation Procedures (SIP) Older version no longer utilized moving forward Indonesias DGAC, Mexico, etc
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Bilateral Agreement Overview, Contd CURRENT AGREEMENTS
* Executive agreement only at this time
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FAA and EASA TIP EASA Represents
* These countries chose to adopt EC legislation for aviation safety
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FAA and EASA (TIP), Contd Overview of the agreement Currently at Revision 6, signed Sept. 22th, 2017
Rev. 6 went live on March 22nd, 2018
Emphasis on more efficient validation processes via either Acceptance or Streamline or Technical Full TSO/ETSO reciprocal acceptance Reciprocal acceptance of most major and minor repair data
Streamlined Validation for Basic STCs and some TCs Limited Technical Validation for everything else
AIR-400 online training course will be available via DRS after March 22nd, 2018 Course number and release date are TBD
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DERs and International Policy A DER can be used in international work: To make findings on behalf of the FAA for
U.S. State-of-Design (SoD) products U.S. State-of-Registry (SoR) aircraft
TCCA SoR is allowed under exception Other activities as authorized by the appointing ACO and per FAA policy e.g. technical assistance (witness a test for another civil aviation authority)
A DER can NOT be used: To make compliance determinations directly for a FCAA
In FAA Shadow Programs of FCAAs (typically)
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DERs and International Policy, Contd
ICAO places responsibility for an aircrafts airworthiness with the State of Registry N-registered aircraft are FAAs responsibility Non-N registered aircraft are the responsibility of their SoReven if they are U.S. SoD products
DERs act only on behalf of the FAA and can only provide FAAapprovals as authorized by the FAA
Following countries require notificationprior to designee activity within their sovereign boarders: Israel, Malaysia, New Zealand, Russia, & Taiwan Also, all non-bilateral agreement countries
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DERs and International Policy, Contd Supporting a U.S. company in FV requests Your experience as a DER is a benefit even when not officially acting as a DER
Project Familiarization Meetings Know the differences between the foreign requirements and the U.S. requirements U.S. regulations are not always the more stringent standard
Be proactive in identifying differences and means for showing compliance
A few FCAAs set certification basis on date of application to FCAA (thus not to the FAA)
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DERs and International Policy, Contd Project Planning & Management Help your company develop a good relationship with the FCAA by: Submitting your application as early as possible to the FAA Many FCAAs have even more limited resources than us Do not expect success if unrealistic schedules are asked of the FAA and or the FCAA
Discussing problems and issues openly and immediately with your ACO project manager
Avoid supplying unnecessary data Some data is not allowed to be shared (i.e. Export Control or Sensitive Security Information (SSI))
Ref. the applicable IP and/or Order 8110.52B
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DERs and International Policy, Contd Project Planning & Management Stated again, keep your ACO involved in the process Report to ACO when meetings with the FCAA seem to become training sessions
Know your export control responsibilities
Raise issues with the ACO to avoid problems on follow-on projects e.g., type validation principles not being followed Note guidance within the applicable IP
These efforts support our internal requirements for our Bilateral Relationship Management (BRM) process
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DER Dos and Donts When Working on Foreign Activities DO
Read Order 8110.52 and the applicable bilateral agreement specifically the IPA (e.g., scopes of IPA vary greatly)
Recognize that bilateral agreements are government-to-government agreements, not applicant to authority
Be well prepared at meetings with the FCAA Work through your ACO; keep advisor involved Submit 8110-3s and data to FAA Contact your ACO if you feel pressured by a FCAA Keep your advisor aware of all international activities
DONT Work directly with FCAA unless instructed by ACO Provide 8110-3s or data directly to FCAA for validation projects Put your DER number on FCAA forms
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Helpful Links
AIR-400 Mailbox Address:
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mailto:[email protected] -
Even more Helpful Links
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Contact Info. Robert Sprayberry Aerospace Engineer / TVP Policy FAA Aviation Safety Aircraft Certification Service International Policy Branch, AIR-410
T: 202.267.1655 E: [email protected]
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mailto:[email protected] -
Engineering Certification Procedures Section New and Draft Policy
Presented to: 2018 Engineering Recurrent Seminar
By: Sue McCormick AIR-6C1
Federal Aviation Administration
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Federal Aviation Administration AIR-6C1 Policy Updates
Outline New Policy in the past ~18 months Policy in Work Remote Witnessing Tests Using Video FAA Order 8110.4, Revision E
Design Approval Holder Landing Page Matrix of Part 21 Rules to Orders, Policy and Guidance
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New Directives, Policy and Guidance
Purpose: Updates on New Directives, Policy and Guidance
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New Directives, Policy, and Guidance
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New Directives, Policy, and Guidance
Federal Aviation Administration AIR-6C1 Policy Updates 6
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New Directives, Policy, and Guidance
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New Directives, Policy, and Guidance
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Federal Aviation Administration AIR-6C1 Policy Updates
Draft Directives, Policy and Guidance
Purpose: Share Information on Future Directives, Policy and Guidance
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Draft Directives, Policy and Guidance
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Draft Directives, Policy and Guidance
Federal Aviation Administration AIR-6C1 Policy Updates 11
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Federal Aviation Administration AIR-6C1 Policy Updates 12
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Draft Directives, Policy and Guidance
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Use of Video and Connectivity Technologies (Draft Policy)
Purpose: This policy statement describes the policy and procedures to enable an FAA-authorized witness to remotely witness engineering tests, conformity inspections, and issue airworthiness approvals using video
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Federal Aviation Administration AIR-6C1 Policy Updates
Part 23 ARC Recommendation FAA develop policy to enable remote test witnessing
Remote witnessing could - Reduce designee travel-related costs Improve certification timeliness Reduce FAA oversight burden
Strong interest and support for policy
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Federal Aviation Administration AIR-6C1 Policy Updates
Current Status Drafted policy addressing witnessing for engineering tests Public comment period closed March 1, 2018 Mostly supportive comments Revising policy to address feedback
Industry feedback Policy should be less prescriptive Expand scope to include manufacturing and airworthiness aspects
Develop Advisory Circular to address broad use of technology
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Federal Aviation Administration AIR-6C1 Policy Updates
Request Process Proposed using Project Specific Certification Plan Describe:
Testing associated risks Clarity and maturity of test procedures and test complexities Skills of applicant representatives and overall experience with conducting test(s)
Designees experience and familiarity with the test and facility/ test personnel
Equipment setup Additional considerations Acknowledge risks
Concurrence needed from all applicable designees and project managing office
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Federal Aviation Administration AIR-6C1 Policy Updates
Documentation Additional details outlined within the test plan
Witness provides record for inclusion in test report Reference FAA Order 8110.4, paragraph 2-6(d)(1)
Equipment and setup must enable witness to verify all requisite conditions are met and a proper evaluation can be performed
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Federal Aviation Administration AIR-6C1 Policy Updates
Considerations Time stamping Multiple cameras, viewing angles, zoom Resolution and field of view appropriate for tests
Special Lighting Environmental / weather conditions Loss of sensory perception Policies restricting video usage
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Federal Aviation Administration AIR-6C1 Policy Updates
Procedures and Records
Same basic process as witnessing on-site Conformity complete Unsatisfactory comments dispositioned Video setup adequate for proper witnessing
Video will not be retained in the project file The video is a tool to verify proper test execution Witness provides in documentation: equipment used, chronological description of tests and adjustment of equipment and adequacy of the video
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Summary
Using video and connectivity technologies can be a viable option
Draft Policy being expanded to include conformity inspections and airworthiness approvals
ECD September 2018
Federal Aviation Administration AIR-6C1 Policy Updates 21
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Contacts
Federal Aviation Administration AIR-6C1 Policy Updates 22
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FAA Order 8110.4 Revision E(DRAFT)
Federal Aviation Administration AIR-6C1 Policy Updates
FAA Order 8110.4 Revision E (DRAFT)
Purpose: Update Type Certificate Order
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Federal Aviation Administration AIR-6C1 Policy Updates
Background
Order 8110.4C (current) Published October 26, 2005 (12 years old) Six changes have been published
Order 8110.4D (proposed 2012) Inclusion of risk-based decision making processes Further definition and refinement needed to mature concepts, tools, and processes
Order 8110.4E (in progress)
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Topics for Inclusion
Federal Aviation Administration AIR-6C1 Policy Updates
Topics for Inclusion
Incorporate Order 8110.120, Processing Surrendered, Abandoned, and Historical Aircraft Type Certificates, Chapter 3 Order will be cancelled after inclusion into 8110.4E
Software Conformity Process, Chapter 5 Requirements for S/W conformity (harmonized from Order 8110.49, Software Approval Guidelines)
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Topics for Inclusion
Federal Aviation Administration Order 8110.4C Change 6
Topics for Inclusion (continued) Statement of Compliance ( 21.20 and 21.97), Chapters 2 and 4
Remote Test Witnessing via Video, Chapter 5 Will be published as a policy statement first
Several forms listed in the appendices of the Order will be removed Either superseded (revised) or cancelled Several forms (including samples) will be replaced with references to the FAA forms webpages
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Topics for Inclusion
Federal Aviation Administration Order 8110.4C Change 6
Topics for Inclusion (continued) Incorporation of STCs into a TC product by the TC holder, Chapter 4 Incorporation by reference or in-draw process
Restricted Category Aircraft, Chapter 6 Miscellaneous revision to policy and procedures
Allow reduced AEG participation in typical TC program (maintenance and operations) Participation to review approval of maintenance manuals, ICAs, AFMs
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Topics for Inclusion
Federal Aviation Administration Order 8110.4C Change 6
Topics for Inclusion (continued) FAA Policy PS-AIR-2X-1701, Acceptable Methods for Demonstrating Compliance With Flammability Requirements including Traceability to Previously Approved Data
All (Major and Minor) Changes must comply with the Applicable Requirements
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Topics for Inclusion
Federal Aviation Administration Order 8110.4C Change 6
Topics for Inclusion (continued) Expanded Guidance on Applicability of Policy and Guidance Applicant must use policy and guidance on the date of application or
Use an issue paper to establish MOC
Extending the Application Date For TCs, Amended TCs, STCs and Amended STCs Guidance on how applicant applies for an extension to their TC, amended TC, STC or amended STC application (e.g., via letter) and the effects of that extension
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Topics for Inclusion
Federal Aviation Administration Order 8110.4C Change 6
Topics for Inclusion (continued)
AIR Transformation updates, Chapter 1 New organization names and routing symbols Placeholder until Refinement Phase Explanation of changes, definitions, organization roles and responsibilities chart, order scope, and related publications listings
Will be revised last to illustrate AIR after realignment and capture all the changes introduced to the Order
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Schedule ECD Fiscal Year 2020
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Contact Information
Maddie Miguel Aerospace Engineer
Order 8110.4 ( ) Program Manager Design Certification Procedures Section
AIR-6C1 [email protected]
202-267-1631
Federal Aviation Administration AIR-6C1 Policy Updates 33
mailto:[email protected] -
Design Approval HolderLanding Page
Federal Aviation Administration Order 8110.4C Change 6
Design Approval Holder Landing Page
Purpose: Communication of Policy and Guidance Information Specific to Part 21
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Design Approval Holder Landing Page Communication Tool Matrix of Policy/Guidance Materials Training/Outreach Materials Centralized location for Engineering Certification Information Regulations and Policy Library Training Resources Forms
Notification of Changes
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Rules Policy and Guidance Part 21 Specific
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DAHs Landing Page contd
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DAH Landing Page contd Create matrix similar to Part 25 AC and Policy https://www.faa.gov/aircraft/air_cert/design_approval s/transport/rules_acs_policy/
Federal Aviation Administration AIR-6C1 Policy Updates 38
https://www.faa.gov/aircraft/air_cert/design_approval -
Part 21 Regulations and Policy
Federal Aviation Administration AIR-6C1 Policy Updates 39
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Contact Information
Sue McCormick Aerospace Engineer
Design Certification Procedures Section AIR-6C1
[email protected] 206-231-3242
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mailto:[email protected] -
Federal Aviation Administration
Topics for Bonus Session
Presented to: 2018 DER Recurrent Seminar
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Bonus Session
Repairs and Alterations Repair Specification Management DERs
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Repairs and Alterations
Some Issues: DERs being asked to approve data for minor repairs Confusion over where the original 8110-3 is supposed to go New in 8110.37F
The DER must retain the original Form 8110-3 and send a copy to their managing office.
Insufficient data being used to approve the major repair (e.g. the thumb approach)
Use of prescribed 8110-3 notes (still seeing the is not an installation approval
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Repair Specification
Repair Specifications provide an alternative to the major repair technical data as well as the methods, techniques and/or practices contained in the current manufacturers manuals, service bulletins, or ICA
Approval as an RS is required for multiple-use major repairs that do not come from the DAH
They are used only for major repairs
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RS DER Role
Manage as a project (cert plan, compliance plan)
Account for all disciplines Account for maintenance requirements (ICA) when affected or no impact statement
Meet the 8110.37 policy requirements for an RS
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RS DER Role
Not used for part production unless part consumed in repair
Not used for process spec approval except for as used in the course of the major repair
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Repair Specification
Some of the issues weve seen: Not being used for major repairs Not containing sufficient data
Doesnt define the starting state with enough detail Doesnt contain sufficient instructions to accomplish repair
Approving the RS with a 8110-3 FAA not realizing that a DER with RS approval can approve (unless specifically limited) RS utilizing data from other DERs
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Management DERs
Do manage a project for the ACO May issue conformity requests when delegated
Act as a liaison between applicant and ACO Dont approve certification plans with a 8110-3
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Management DER (during a project) Use a cert plan & keep it updated, Coordinate necessary changes with ACO Resolve issues (changes in MoC, designees, suppliers, test details)
Refer to the compliance listing part of it as the method that compliance was shown (ref 21.20(a)/21.97)
Ensure applicant understands requirement to make a certifying statement and that its not based on DER findings
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Management DER (outside of a project) Make sure you are representing the FAA position when project planning with applicant
Dont oversell your authority or capability When you present yourself as a management DER are you doing what the FAA would otherwise do?
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Agenda.pdfSlide Number 1G0-Welcome-logistics-General Session-2018.pdfWELCOMELogisticsLogisticsLogisticsLogisticsNew FormatLogisticsTest TodayTest TodayEvaluations/CertificatesComment Sheets Are Included inParticipant Guides WELCOMEG1_Engineering_Designee_Training - Overview 2018 v2.pdfEngineering Designee Training OverviewSeminar Program OverviewDesignee Training Program WebsiteCourse FeesPolicy MemorandumAIR100-17-160-PM02Training ProgramNew Training Program (cont.)Recurrent Seminar General SessionSeminar LocationsCourse CertificateWe Need Your Help!Contact UsQuestionsG2-Stump The Regulator 2018 Ver 2.pdfStump the RegulatorStump the RegulatorSample questionsSample questionsSample questionsQuestions before we begin?Ok, then lets see if you can STUMP THE REGULATORSG3-New Policy 2018 Ver 3.pdfNew PolicyNew Regulations/Policy of NoteRecent PoliciesOrder 8110.37 Revision FWhats in 8110.37FWhats in 8110.37FQuestions?14 CFR Part 23 rewrite14 CFR Part 23 rewrite14 CFR Part 23 rewrite14 CFR Part 23 rewrite14 CFR Part 23 rewriteQuestions?AMOC Order 8110.103BPMA for minor modification articles PS-AIR-21-1601Lithium Battery policy memo AIR100-15-140-GM50Questions?The New DER Landing PageHow to find it?ScreenshotThe New DER Landing PageQuestions?G4-DMS 2018 Ver 1.pdfTitle PageWhat is DMS?What will DMS do?Current Deployment ScheduleDMSQuestions?G5-DERs Roles and Responsibilities 2018 Ver 3.pdfTitle PageRoles and ResponsibilitiesUse of DER NumbersUse of DER NumbersQuestions?Proper Use of Form 8110-3Proper Use of Form 8110-3Proper Use of Form 8110-3Questions?DERs and ConformityDERs and ConformityDERs and ConformityDERs and ConformityDERs and ConformityRequest for ConformityRequest for ConformityQuestions?Certification PlansQuestions?G6 - Aircraft Certification Transformation.pdfAircraft Certification TransformationIntroductionAIR Transformation is our holistic approach to becoming more efficient and effectiveRefresh Certification StrategyImprove Our Organization Next Steps for Implementation Evolution of FAA/Industry roles and responsibilitiesEvolution of FAA/Industry roles and responsibilitiesSummaryG7 - AIR-400_DER Seminar v2.pdfEngineering Designee Recurrent SeminarOverviewFAAs Global LeadershipFAAs Global Leadership, ContdInternational Policy Division (AIR-400)International Policy Division (AIR-400)Bilateral Agreement OverviewBilateral Agreement Overview, ContdBilateral Agreement Overview, ContdBilateral Agreement Overview, ContdFAA and EASA TIPFAA and EASA (TIP), ContdDERs and International PolicyDERs and International Policy, ContdDERs and International Policy, ContdDERs and International Policy, ContdDERs and International Policy, ContdDER Dos and DontsHelpful LinksEven more Helpful LinksContact Info.G8 - AIR 6C1 2018 DER Seminars v3.pdfEngineering Certification Procedures SectionOutlinePageNew Directives, Policy, and GuidanceNew Directives, Policy, and GuidanceNew Directives, Policy, and GuidanceNew Directives, Policy, and GuidanceNew Directives, Policy, and GuidancePageDraft Directives, Policy and GuidanceDraft Directives, Policy and GuidanceDraft Directives, Policy and GuidanceDraft Directives, Policy and GuidancePagePart 23 ARC RecommendationCurrent StatusRequest ProcessDocumentationConsiderationsProcedures and RecordsSummaryContactsFAA Order 8110.4 Revision E(DRAFT)BackgroundTopics for InclusionTopics for InclusionTopics for InclusionTopics for InclusionTopics for InclusionTopics for InclusionTopics for InclusionScheduleContact InformationDesign Approval HolderLanding PageDesign Approval Holder Landing PageRules Policy and GuidancePart 21 SpecificDAHs Landing Page contdDAH Landing Page contdPart 21 Regulations and PolicyContact InformationG9-Bonus Session 2018 v2.pdfTopics for Bonus SessionBonus SessionRepairs and AlterationsRepair SpecificationRS DER RoleRS DER RoleRepair SpecificationManagement DERsManagement DER (during a project)Management DER (outside of a project)Book Cover.pdfSlide Number 1Agenda.pdfSlide Number 1