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

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

3. 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

4. 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 (-)

5. 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 (+)

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

7. 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…)

8. 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

9. 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

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

11. 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

12. 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?

13. 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

14. 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

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

16. 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…)

17. 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

18. 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

19. 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

20. 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

21. 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

22. 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

23. 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

24. THANK YOU!