The Future of Delegation D. Hempe, FAA & R. Simon, EASA

The Future of Delegation CONTENTS Today’s environment Challenges of design and certification worksharing Future scenarios

Need…Changes are necessary in today’s global environment Today’s environment Need…Changes are necessary in today’s global environment Limited Resources Systems approach/ Less people dependent Risk-Based Targeting Design worksharing among partners

Pluses and Minuses in FAA Delegation today Today’s environment Pluses and Minuses in FAA Delegation today Supplements FAA resources (+) Delegation can be a “crutch” (-) Allows people that have no experience with FAA to obtain approvals (-) Supports broad spectrum of applicants (+) Treats all applicants the same (-)

Pluses and Minuses in EASA system today Today’s environment Pluses and Minuses in EASA system today Common approach to certification (+) Eligibility for DOA limited (-) Competence not necessarily at design approval holder level (-) Treats all applicants the same (-) Clear responsibility for design approval (TC, STC…) holders (+)

Design and Certification Worksharing The design worksharing Complexity means share of know-how Partnership required to design complete products Optimisation of resources available worldwide

Design and Certification Worksharing Type certification of products Type certification possible for complete product only Compliance with applicable TC basis to be done at product level, but… …at lower level (sub-assemblies, systems…) Compliance data can be provided Specific certification tasks can be performed (tests, analysis…)

Design and Certification Worksharing How to optimise the use of resources and competence? Analysis Competence should be used “where it is” Duplications should be avoided Local regulatory systems should be used, whenever possible

Design and Certification Worksharing How to optimise the use of resources and competence? Possible options Further recognition of findings through bilateral agreements Develop modular approach to type certification Develop common design organisation approval approach Harmonise Authority involvement Industry self-certification

Design and Certification Worksharing Challenges Interface issues If certification made per “modules”, need to “assemble” them Interfaces between modules to be carefully addressed

Design and Certification Worksharing Challenges Responsibilities Responsibility for design and certification statements must be carefully defined, in the context of the overall type certificate holder responsibility for the complete product

Design and Certification Worksharing Challenges Do we need “sub-type certificates”? A “legal” means to define “modules” could be “sub-type certificates” (like for engine and propeller) Interface issues remain Need to adapt ICAO Annex 8?

Organizational Certified Delegation Organization Other Alternatives? Future scenarios Organizational Delegation Certified Organization Will one of these paths work for me? Other Alternatives? Big applicant FAA recognizes that changes will need to be made to accommodate certification in the future. Although there may be more than 2 paths, 2 of the paths we are considering are Organizational Delegation and Certified Organizations. Question: Does this work for both big applicants/complete products, as well as small applicants/parts??? Small applicant

Future scenarios Future scenarios Assuming that, both: Design competence Certification competence can (or will) be at system supplier level, 2 scenarios are proposed: 1- development of Delegation or Design Organisation (DO) concept for compliance demonstrations 2- development of Industry certification system

Future scenarios DOA 21-J Tomorrow Other DOA 21-J suppliers today System suppliers DOA 21-J today TC Holder

DOA at system supplier level: Future scenarios Development of Delegation or DO concept for compliance demonstrations (Europe-1) DOA at system supplier level: Eligibility related to a well defined scope New privileges related to: - Compliance demonstration - Approval of changes and repairs at system level Approval of related technical publication DOA at other suppliers level: Same, when deemed appropriate (e.g. material/flamability demonstration…)

Future scenarios Development of Delegation or DO concept for compliance demonstrations (Europe-2) Benefits: Recognition of capability where competence lies De-centralised privileges Challenges: Distribution of responsibilities New scopes for the DOA, to reflect work at system level or complete product level Interfaces Aircraft configuration control

Future scenarios Development of Delegation or DO concept for compliance demonstrations (USA - 1) Organizational Delegation: Systems-based delegation for qualified, experienced organizations Some compliance findings accepted without delegation review Risk targeting used to define surveillance requirements

Future scenarios Development of Delegation or DO concept for compliance demonstrations (USA - 2) Certified Design Organization (CDO): Qualified, experienced organizations Certification/manufacturing System produces compliant, safe products Certificate may be categorized by level of complexity of part/product

Industry certification system Future scenarios Industry certification system A system managed by Industry and recognised by the Airworthiness Authority Examples: Self-Certification 3rd Party Qualifying Organizations Would require Industry standards, and system of approving organizations

Industry certification system Future scenarios Industry certification system Benefits: More flexible than an Authority based system Does not require changes in existing regulations, except for Industry approach recognition Challenges: Authority control of Industry system

Other Future Scenarios Eliminate delegation Establish levels of delegation Future…True Globalisation in Certification Global System = Universally Accepted Design Approval + Universally Accepted Production Approval - New approach to validation

The Future of Delegation Accident Rate QUALITY SYSTEM This visual shows a path from the past to the future. The accident rate has gone down over the years. In the past, the FAA has focused on detailed inspections of aircraft and aircraft parts. Over time, we have reduced our detailed involvement and moved toward delegation of tasks, both individually and organizationally. This has worked to help reduce the accident rate. In the future, we look toward more organizational approvals with less detailed involvement of FAA. We can no longer afford to inspect each part, but must find a way to rely on a manufacturer’s system to produce a safe, compliant aircraft! Present Past Future

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