Information for Delegation Holders Peter Gill Airworthiness Engineer

Topics to be covered:  Delegation Changes since 2009  Major Design Change Authorisation Process  Manufacturing Considerations  STC’s  AC’s  Other Miscellaneous Topics Design Delegation Holder’s Seminar Design Delegation Holder’s Seminar

Delegation Changes since 2009  No approval of modification classified as “major design change” (schedule One) without CAA authorisation  CAA undertook to give authorisation for appropriate “one-off” modifications where not contrary to CAA policy  All delegations which included modifications were re-issued August 2010 Design Delegation Holder’s Seminar Design Delegation Holder’s Seminar

Authorisation Process Design Delegation Holder’s Seminar Design Delegation Holder’s Seminar

Authorisation Requests  Yes0 No  Yes5 No Reasons for No: 1 – Unusual design features 1 – HEC (CAA Policy – STC) 1 – (later authorised) 1 – Operational Concern 1 – TCDS Change  Yes0 No Design Delegation Holder’s Seminar Design Delegation Holder’s Seminar

Manufacturing Considerations  Part 146 organisations approve data – do not authorise manufacture  CAA expect part 146 organisations to promote compliance with Rules where possible  CAA has publicised compliance with to industry (Vector magasine article Nov/Dec 2010)  Factor in authorisation process Design Delegation Holder’s Seminar Design Delegation Holder’s Seminar

Manufacturing Considerations Contd  CAR – be manufactured “by a person performing maintenance on the product…”  No subcontracting (can supervise)  NOTE: “Subcontracting” term here is used in the manufacturing sense where the manufacturer takes responsibility for the subcontractors work.  Where the “subcontractor” has an organisation certificate of its own and can issue a release certificate, that is acceptable (they are then a “supplier” rather than a ‘subcontractor”.) Design Delegation Holder’s Seminar Design Delegation Holder’s Seminar

Manufacturing Considerations Contd  How to approved “existing” equipment (where origin unknown)?  Should be a document (Form One or Two) identifying part and origin  Part 21Q has always required part marking Design Delegation Holder’s Seminar Design Delegation Holder’s Seminar

STC’s  See later presentation from Beth  Small number of “New” STC’s  Large number started, stalled  Time delays – CAA extra assessment  Certification Basis – Determine iaw FAR Changed Product Rule  Requirement for any STC where FAA validation is likely to be sought  Should always specify why you can’t/don’t use the latest requirements Design Delegation Holder’s Seminar Design Delegation Holder’s Seminar

Advisory Circulars  Advisory Circulars to be revised or written by ACU (we welcome comments or suggestions):  AC Clarify CAA position on “one-man- bands”; Clarify Delegation Issue Process; General Update  AC – General Update; Remove Extraneous material; Clarify CAA position on Subcontractors, senior person qualifications, Critical Parts, Design Data. Design Delegation Holder’s Seminar Design Delegation Holder’s Seminar

Advisory Circulars Contd  AC 43-9 (Mods, Repairs, 337) – Complete re- write and update  AC 91-5 (PEDS) – General update  New AC on aircraft Electrical Load Analysis - Probably an AC 91-X – detailing how the owner should maintain an ELA for his aircraft Design Delegation Holder’s Seminar Design Delegation Holder’s Seminar

Miscellaneous Topics  Where making a minor change to a “major design change” – is this major?  Original approver?  Effect of change?  Continuation of Class A/B delegation classifications?  Not yet determined Design Delegation Holder’s Seminar Design Delegation Holder’s Seminar

Miscellaneous Topics Contd  Delegation of Part 146 activities:  Testing  Data (eg Weight & Balance data)  Electrical/Mechanical demarcation  1309 training – Seen by CAA as essential Design Delegation Holder’s Seminar Design Delegation Holder’s Seminar

Miscellaneous Topics Contd  Surveillance – effect of new policy  Increased preparation  More targeted audit  No change to delegate monitoring Design Delegation Holder’s Seminar Design Delegation Holder’s Seminar

Questions? Design Delegation Holder’s Seminar Design Delegation Holder’s Seminar