AMC-GM Part 21
AMC-GM Part 21
AMC-GM Part 21
Change Information
1. Introduction
The Agency has adopted issue 2 of ‘AMC and GM to Part 21’ by ED Decision 2012/020/R of
30 October 2012 as a clean version consolidating the initial issue of ‘AMC and GM to Part 21’ of 17
October 2003 and all the changes adopted by the Agency since the initial issue. It also includes
additional changes triggered by the publication of the new recast of Part 21 in Regulation (EU) No
748/2012. All changes are listed and explained in the Explanatory Note to ED Decision 2012/020/R.
As an additional service to the readers this change information has been produced which makes
visible all the changes in the AMC/GM that were introduced after the last amendment of the AMC/GM
to Part 21 (Amending Decision No 2011/010/R of 1 December 2011).
However, considering the different nature of the changes (changes of substance versus
editorial/formal changes), the Agency does not consider practical to highlight all the changes the way
it normally does. The editorial changes as well as some formal changes of no relevance to the
technical content are repetitive and their highlighting would only worsen the readability of the text.
Therefore such changes are only presented in the introductory part below before the actual text of
‘AMC and GM to Part 21’ starts.
Old New
21A.xx 21.A.xx
21B.yy 21.B.yy
Part-21 Part 21
Page 1 of 264
3. Highlighted changes
3.1 Changes linked to the four Agency Opinions incorporated in Regulation 748/2012
See explanatory note.
Old New
(sub-)paragraph point
Issue 2
30 October 2012
Page 3 of 264
Log of amendments
Amending Decisions
AMC & GM to Part 21 Decision No. 2003/1/RM of the Executive Director of 17-10-2003
the Agency of 17 October 2003
AMC & GM Part 21/1 Decision No. 2006/13/R of the Executive Director of 27-12-2006
the Agency of 20 December 2006
AMC & GM Part 21/2 Decision No. 2007/008/R of the Executive Director of 03-04-2007
the Agency of 2 April 2007
AMC & GM Part 21/3 Decision No. 2007/006/R of the Executive Director of 05-04-2007
the Agency of 4 April 2007
AMC & GM Part 21/4 Decision No. 2007/012/R of the Executive Director of 29-11-2007
the Agency of 22 November 2007
AMC & GM Part 21/5 Decision No. 2009/011/R of the Executive Director of 31-08-2009
the Agency of 24 August 2009
AMC & GM Part 21/6 Decision No. 2010/001/R of the Executive Director of 30-03-2010
the Agency of 23 March 2010
AMC & GM Part 21/7 Decision No. 2010/016/R of the Executive Director of 23-12-2010
the Agency of 16 December 2010
AMC & GM Part 21/8 Decision No. 2011/006/R of the Executive Director of 26-08-2011
the Agency of 19 August 2011
AMC & GM Part 21/9 Decision No. 2011/010/R of the Executive Director of 08-12-2011
the Agency of 1 December 2011
Page 4 of 264
Table of Contents
SECTION A ....................................................................................................... 12
Subpart A — General ........................................................................................................................ 12
AMC No 1 to 21.A.3A(a) Collection, investigation and analysis of data related to Flammability
Reduction Means (FRM) reliability................................................................................................. 12
AMC No 2 to 21.A.3A(a) Collection, investigation and analysis of data related to ETOPS
significant occurrences .................................................................................................................. 12
GM 21.A.3A(a) The system for collection, investigation and analysis of data ............................ 12
GM 21.A.3A(b) Occurrence reporting .......................................................................................... 12
AMC 21.A.3A(b)(2) Reporting to the Agency .............................................................................. 13
GM 21.A.3B(d)(4) Defect correction – Sufficiency of proposed corrective action ....................... 13
AMC 21.A.3B(b) Unsafe condition ............................................................................................... 24
GM 21.A.3B(b) Determination of an unsafe condition ................................................................. 24
AMC 21.A.4 Transferring of information on eligibility and approval status from the design holder
to production organisations ............................................................................................................ 28
Subpart B — Type-certificates and restricted type-certificates ......................................................... 30
GM 21.A.14(b) Eligibility for alternative procedures .................................................................... 30
AMC 21.A.14(b) Alternative Procedures ..................................................................................... 30
GM 21.A.16B Special Conditions ................................................................................................ 34
AMC 21.A.20(b) Certification programme ................................................................................... 34
Appendix to AMC 21.A.20(b) - Means of compliance codes ........................................................ 35
GM 21.A.20(b) Update to the Certification Programme............................................................... 35
AMC 21.A.20(c) Compliance documentation .............................................................................. 35
GM 21.A.20(d) Final statement.................................................................................................... 36
GM 21.A.33 Inspection and Tests ............................................................................................... 36
GM 21.A.35 Flight Tests .............................................................................................................. 36
GM 21.A.35(b)(2) Objective and Content of Function and Reliability Testing ............................. 36
GM 21.A.35(f)(1) Flying Time for Function and Reliability Testing .............................................. 37
GM 21.A.35(f)(2) Flying Time for Function and Reliability Testing .............................................. 37
Subpart D — Changes to type-certificates and restricted type certificates ....................................... 38
GM 21.A.91 Classification of changes to type design ................................................................. 38
Appendix A to GM 21.A.91: Examples of Major Changes per discipline....................................... 40
GM 21.A.93(b) Major Changes: Application ................................................................................ 47
AMC 21.A.97 Compliance demonstration process for major changes ........................................ 47
GM 21.A.101 Establishment of the type-certification basis of changed aeronautical products .. 47
Appendix A. to GM 21.A.101 Classification of Changes ............................................................. 67
Appendix B to GM 21.A.101 Procedure for evaluating impracticality of applying latest
certification specifications to a changed product ......................................................................... 112
Appendix C to GM 21.A.101 The use of service experience in the certification process .......... 119
Appendix D to GM 21.A.101 Tables and figures to assist CPR understanding ...................... 123
Appendix E to GM 21.A.101 Related Part 21 Requirements .................................................. 127
Subpart E — Supplemental type-certificates ................................................................................... 128
GM 21.A.112B Demonstration of capability for supplemental type-certificate cases ................ 128
AMC 21.A.114 Compliance demonstration process for Supplemental Type-Certificate ........... 132
Subpart F — Production without production organisation approval ................................................ 133
GM No. 1 to 21.A.121 Applicability - Individual product, part or appliance ............................... 133
GM No. 2 to 21.A.121 Applicability – Applicable design data ................................................... 133
AMC No. 1 to 21.A.122 Eligibility – Link between design and production ................................. 133
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AMC No. 2 to 21.A.122 Eligibility – Link between design and production ................................. 134
GM 21.A.124(a) Application – Application form ......................................................................... 136
GM 21.A.124(b)(1)(i) Applicability - Inappropriate approval under Subpart G .......................... 136
GM 21.A.124(b)(1)(ii) Certification or approval needed in advance of the issue of a POA ....... 137
GM 21.A.124(b)(2) Application - Minimum information to include with the application ............. 137
GM No. 1 to 21.A.125A Letter of agreement - Meaning of individual ........................................ 137
GM No. 1 to 21.A.125A(b) Letter of agreement - Contents of the Manual ................................ 137
GM No. 2 to 21.A.125A(b) Letter of agreement - Production Inspection System: Functional
Tests ............................................................................................................................................ 138
GM 21.A.125A(c) Letter of agreement - Assistance .................................................................. 138
GM No. 1 to 21.A.125B(a) Uncontrolled non-compliance with applicable design data ............. 138
GM No. 2 to 21.A.125B(a) Examples for level one findings ...................................................... 138
GM 21.A.126 Production Inspection System ............................................................................. 139
GM 21.A.126(a)(1) Production Inspection System – Conformity of supplied parts, appliances
and material ................................................................................................................................. 139
GM 21.A.126(a)(2) Production Inspection System - Identification of incoming materials and parts
..................................................................................................................................................... 139
GM No. 1 to 21.A.126(a)(3) Production Inspection System - List of specifications ................... 139
GM No. 2 to 21.A.126(a)(3) Production Inspection System - Means of checking of the
production processes ................................................................................................................... 140
GM 21.A.126(a)(4) Production Inspection System – Applicable design/production data
procedures ................................................................................................................................... 140
GM 21.A.126(b)(1) Production Inspection System - Inspection of parts in process .................. 140
GM 21.A.126(b)(2) Production Inspection System – Suitable storage and protection .............. 140
GM 21.A.126(b)(3) Production Inspection System – Use of derived data instead of original
design data .................................................................................................................................. 141
GM 21.A.126(b)(4) Production Inspection System – Segregation of rejected material............. 141
GM 21.A.126(b)(5) Production Inspection System – Engineering and manufacturing review
procedure ..................................................................................................................................... 141
GM 21.A.126(b)(6) Production Inspection System – Recording and record keeping ............... 141
GM 21.A.127 Approved production ground and flight tests ....................................................... 142
GM No. 1 to 21.A.128 Acceptable functional test - Engines ..................................................... 142
GM No. 2 to 21.A.128 Acceptable functional test –Variable pitch propellers ............................ 142
GM No. 3 to 21.A.128 Acceptable functional test - Engines and Propellers ............................. 142
GM 21.A.129(a) Availability for inspection by the competent authority ..................................... 143
AMC No. 1 to 21.A.129(c) Obligations of the manufacturer – Conformity of prototype models
and test specimens ...................................................................................................................... 143
AMC No. 2 to 21.A.129(c) Obligations of the manufacturer – Conformity with Applicable Design
Data ............................................................................................................................................. 143
AMC No. 3 to 21.A.129(c) Obligations of the manufacturer – Condition for safe operation...... 143
AMC No. 1 to 21.A.130(b) Statement of Conformity for Complete Aircraft ............................... 144
AMC No. 2 to 21.A.130(b) Statement of Conformity for Products (other than complete aircraft),
parts, appliances and materials - The Authorised Release Certificate (EASA Form 1) .............. 146
Subpart G — Production organisation approval for products, parts and appliances ...................... 149
GM 21.A.131 Scope – Applicable design data .......................................................................... 149
GM 21.A.133(a) Eligibility – Approval appropriate for showing conformity ............................... 149
AMC No. 1 to 21.A.133(b) and (c) Eligibility – Link between design and production organisations
..................................................................................................................................................... 150
AMC No. 2 to 21.A.133(b) and (c) Eligibility – Link between design and production organisations
..................................................................................................................................................... 151
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GM 21.A.134 Application – Application form and manner ......................................................... 152
GM No. 2 to 21.A.139(a) Quality System – Conformity of supplied parts or appliances ........... 153
GM 21.A.139(b)(1) Quality System – Elements of the quality system ...................................... 154
AMC No. 1 to 21.A.139(b)(1)(ii) Vendor and sub-contractor assessment, audit and control –
Production Organisation Approval (POA) holder using documented arrangements with other
parties for assessment and surveillance of a supplier. ................................................................ 154
AMC No. 2 to 21.A.139(b)(1)(ii) Vendor and sub-contractor assessment, audit and control -
Production Organisation Approval (POA) holder using other party supplier certification ............ 155
GM No. 1 to 21.A.139(b)(2) Quality System – Independent quality assurance function ........... 157
GM No. 2 to 21.A.139(b)(2) Quality System – Adequacy of procedures and monitoring function
..................................................................................................................................................... 157
GM 21.A.143 Exposition – Production Organisation Exposition (POE) .................................... 157
GM 21.A.145(a) Approval Requirements .................................................................................. 158
GM 21.A.145(b)(2) Approval Requirements – Airworthiness, noise, fuel venting and exhaust
emissions /production data procedures ....................................................................................... 158
GM 21.A.145(c)(1) Approval Requirements – Accountable manager ....................................... 158
GM 21.A.145(c)(2) Approval Requirements – Responsible managers ..................................... 159
AMC 21.A.145(d)(1) Approval Requirements – Certifying staff ................................................. 159
AMC 21.A.145(d)(2) Approval Requirements – Record of certifying staff ................................. 160
AMC 21.A.145(d)(3) Approval requirements – Evidence of authorisation................................. 161
GM 21.A.147(a) Changes to the approved production organisation – Significant changes...... 161
AMC 21.A.148 Changes of location – Management during change of location ........................ 161
GM 21.A.149 Transferability ...................................................................................................... 162
GM 21.A.151 Terms of approval – Scope and categories ........................................................ 162
AMC 21.A.153 Changes to the terms of approval – Application for a change to the terms of
approval ....................................................................................................................................... 164
GM 21.A.157 Investigations – Arrangements ............................................................................ 164
GM No. 1 to 21.A.158(a) Uncontrolled non-compliance with applicable design data ............... 164
GM No. 2 to 21.A.158(a) Examples of level one findings .......................................................... 164
GM 21.A.159(a)(3) Evidence of a lack of satisfactory control ................................................... 165
AMC No 1 to 21.A.163(c) Computer generated signature and electronic exchange of the EASA
Form 1 .......................................................................................................................................... 165
AMC No 2 to 21.A.163(c) Completion of the EASA Form 1 ...................................................... 167
AMC 21.A.163(d) Privileges – Maintenance .............................................................................. 168
AMC 21.A.163(e) Procedure for the issue of a permit to fly including approval of the flight
conditions ..................................................................................................................................... 168
GM 21.A.165(a) Obligations of the holder – Basic working document ...................................... 169
GM No. 1 to 21.A.165(c) Obligations of the holder – Conformity of prototype models and test
specimens .................................................................................................................................... 170
GM No. 2 to 21.A.165(c) Obligations of holder – Conformity with type design ......................... 170
GM No. 3 to 21.A.165(c) Obligations of the holder – Condition for safe operation ................... 170
GM No. 4 to 21A.165(c) Airworthiness Release or Conformity Certificate ................................ 171
GM 21.A.165(d) and (h) Obligations of the holder – Recording and archiving system ............. 171
Subpart J — Design organisation approval ..................................................................................... 173
GM No. 1 to 21.A.239(a) Design assurance system ................................................................. 173
GM No. 2 to 21.A.239(a) Design assurance system for minor changes to type design or minor
repairs to products ....................................................................................................................... 177
AMC 21.A.239(a)(3) Design assurance system - Independent system monitoring .................. 177
AMC 21.A.239(b) Design assurance system - Independent checking function of the
demonstration of compliance ....................................................................................................... 177
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GM 21.A.239(c) Design assurance system ............................................................................... 178
AMC No. 1 to 21.A.243(a) Data requirements ........................................................................... 178
AMC No. 2 to 21.A.243(a) Data requirements - Model content of handbook for organisations
designing minor changes to type design or minor repairs to products ........................................ 179
GM No. 1 to 21.A.243(d) Statement of qualifications and experience ...................................... 180
GM No. 2 to 21.A.243(d) Data requirements - Statement of the qualification and experience-
Organisations designing minor changes to type design or minor repairs to products ................. 182
GM No. 1 to 21.A.245 Requirements for approval .................................................................... 182
GM No. 2 to 21.A.245 Requirements for approval - Organisations designing minor changes to
type design or minor repairs to products ..................................................................................... 183
GM 21.A.247 Significant changes in the design assurance system .......................................... 183
GM 21.A.249 Transferability ...................................................................................................... 184
GM No. 1 to 21.A.251 Terms of approval .................................................................................. 184
GM No. 2 to 21.A.251 Terms of approval - Organisations designing minor changes to type
design or minor repairs to products ............................................................................................. 185
GM 21.A.257(a) Investigations .................................................................................................. 185
GM 21.A.263(b) DOA privilege related to compliance documents ............................................ 185
AMC 21.A.263(b)(1) Compliance documents with conditions related to engine or propeller
without a type-certificate or with unapproved changes and fitted on aircraft for which a permit to
fly is requested ............................................................................................................................. 185
AMC No. 1 to 21.A.263(c)(1) Procedure for the classification of changes to type design and
repairs as minor and major .......................................................................................................... 186
AMC No. 2 to 21.A.263(c)(1) Privileges - Organisations designing minor changes to type design
or minor repairs to products : classification procedure ................................................................ 187
AMC No. 1 to 21.A.263(c)(2) Procedure for the approval of minor changes to type design or
minor repairs ................................................................................................................................ 188
AMC No. 2 to 21.A.263(c)(2) Privileges - Organisations designing minor changes to type design
or minor repairs to products : procedure for the approval of minor changes to type design or
minor repairs ................................................................................................................................ 189
GM 21.A.263(c)(3) Issue of information or instructions ............................................................. 190
GM 21.A.263(c)(4) Procedure for the approval of minor revisions to the aircraft flight manual191
AMC 21.A.263(c)(6) Procedure for the approval of the conditions for issue of a permit to fly .. 193
EASA Form 18A Issue 3 .............................................................................................................. 195
AMC 21.A.263(c)(7) Procedure for the issue of a permit to fly .................................................. 196
AMC 21.A. 265(a) Administration of the Handbook ................................................................... 196
GM 21.A.265(b) Use of the Handbook ...................................................................................... 197
Subpart K — Parts and appliances ................................................................................................. 198
AMC 21.A.303(c) Standard Parts .............................................................................................. 198
GM No. 2 to 21.A.303(c) Officially recognised Standards ......................................................... 198
Subpart M — Repairs ...................................................................................................................... 199
GM 21.A.431(a) Scope .............................................................................................................. 199
GM 21.A.431(d) Repairs to ETSO articles other than an APU .................................................. 199
AMC 21.A.433 (a) and 21.A.447 Repair design and record keeping ........................................ 199
GM 21.A.435(a) Classification of repairs ................................................................................... 200
GM 21.A.437 Issue of repair design approval ........................................................................... 201
GM 21.A.437(a) Issue of repair design approval ....................................................................... 202
AMC 21.A.437(b) Issue of repair design approval .................................................................... 202
GM 21.A.439 Production of repair parts ................................................................................... 203
GM 21.A.441 Repair Embodiment ............................................................................................. 203
GM 21.A.443 Limitations ........................................................................................................... 203
Page 8 of 264
GM 21.A.445 Unrepaired damage ............................................................................................. 203
Subpart O — European Technical Standard Order Authorisations ................................................. 205
AMC 21.A.602B(b)(2) Procedures for ETSO authorisations ..................................................... 205
AMC 21.A.608 Declaration of Design and Performance ........................................................... 206
GM to 21.A.611 Design changes ............................................................................................... 208
Subpart P — Permit to Fly ............................................................................................................... 209
GM to Subpart P .......................................................................................................................... 209
GM 21.A.701(a) Permit to fly when certificate of airworthiness or restricted certificate of
airworthiness is not appropriate ................................................................................................... 212
GM 21.A.701 Scope .................................................................................................................. 214
GM 21.A.703 Applicant for a permit to fly .................................................................................. 214
GM 21.A.705 Competent authority ............................................................................................ 214
GM 21.A.707(b) Application ....................................................................................................... 214
GM 21.A.708(b)(6) Continuing airworthiness ............................................................................ 215
GM No. 1 to 21.A.708(c) Safe flight ........................................................................................... 215
GM No. 2 to 21.A.708(c) Substantiations .................................................................................. 215
GM No. 3 to 21.A.708(c) Operation of Overweight Aircraft ....................................................... 215
GM 21.A.708(d) Control of aircraft configuration ....................................................................... 216
AMC 21.A.709(b) Submission of documentation supporting the establishment of flight conditions
..................................................................................................................................................... 217
EASA Form 18B Issue 3 .................................................................. Error! Bookmark not defined.
GM 21.A.710 Approval of flight conditions ................................................................................ 218
GM 21.A.711(e) Additional conditions and restrictions............................................................... 219
GM 21.A.713 Changes .............................................................................................................. 219
GM 21.A.719 Transfer of a permit to fly .................................................................................... 219
Subpart Q — Identification of products, parts and appliances ........................................................ 220
GM 21.A.804(a)(1) Identification of parts and appliances ......................................................... 220
SECTION B ..................................................................................................... 221
Subpart A — General provisions ..................................................................................................... 221
GM 21.B.20 Responsibility for implementation .......................................................................... 221
GM 21.B.25(a) Organisation ...................................................................................................... 221
GM 21.B.25(b) Resources ......................................................................................................... 222
GM 21.B.25(c) Qualification and training ................................................................................... 222
AMC 21.B.30(a) Documented procedures ................................................................................ 223
AMC 21.B.35(a) Changes .......................................................................................................... 223
GM 21.B.40 Principles for the resolution of disputes................................................................. 223
GM No. 1 to 21.B.45 Co-ordination with other related activities ................................................ 223
GM No. 2 to 21.B.45 Co-ordination ........................................................................................... 224
GM No. 3 to 21.B.45 Reporting - Information relevant to registers established by the Agency 224
GM 21.B.55 Record keeping for design approvals transferred to the Agency .......................... 224
Subpart F — Production without Production Organisation Approval .............................................. 226
AMC 21.B.120(a) Investigation team - Qualification criteria for the investigation team members
..................................................................................................................................................... 226
AMC 21.B.120(c)(1) Evaluation of applications ......................................................................... 226
EASA Form 60 Issue 2 ................................................................................................................ 227
GM 21.B.120(c)(3) Investigation preparation and planning ....................................................... 228
GM 21.B.120(c)(5) and (6) Auditing and investigation findings ................................................. 228
GM 21.B.125(a) Objective evidence .......................................................................................... 229
AMC 21.B.130 Issue of the letter of agreement ........................................................................ 229
Page 9 of 264
GM 21.B.130(b) Issue of the letter of agreement ...................................................................... 229
AMC 21.B.140 Amendment of a letter of agreement ................................................................. 229
GM 21.B.150(d) Record keeping - Traceability of release certificates ...................................... 229
Subpart G— Production Organisation Approval.............................................................................. 230
GM 21.B.220(a) Investigation team ........................................................................................... 230
AMC 21.B. 220(c) Procedures for investigation - Evaluation of applications ............................ 230
EASA Form 50 ............................................................................................................................. 231
GM No. 1 to 21.B.220(c) Procedures for investigation - Investigation preparation and planning
..................................................................................................................................................... 232
GM No. 2 to 21.B.220(c) Procedures for investigation – General ............................................. 233
EASA Form 56 Issue 3-– POAT Recommendation Audit Report - Part 1 of 5, Page 1 of 1
MONTH YEAR 236
GM No. 3 to 21.B.220(c) Procedures for investigation - POA applications received from
organisations with facilities/partners/suppliers/sub-contractors located in a third country .......... 248
GM No. 4 to 21.B.220(c) Procedures for investigation – Competent authority surveillance of
suppliers of a POA holder located in other Member States ........................................................ 249
EASA Form 58A – Request for reporting on sub-contractor surveillance, Page x of x ............... 252
EASA Form 58B – Report on sub-contractor surveillance, Page x of x GM 21.B.225(a) Objective
evidence ....................................................................................................................................... 254
AMC 21.B.225(a) Notification of findings ................................................................................... 255
AMC No. 1 to 21.B.230 Issue of the certificate .......................................................................... 255
GM 21.B.235(a)(4) Guide to the conduct of monitoring production standards. ......................... 255
GM 21.B.235(b) Maintenance of the POA - Work allocation within the competent authority .... 256
GM 21.B.235(b) and (c) Continued surveillance ....................................................................... 256
AMC 21.B.235(c) Continuation of POA ..................................................................................... 256
AMC No. 1 to 21.B.240 Application for significant changes or variation of scope and terms of the
POA ............................................................................................................................................. 256
EASA Form 51 ............................................................................................................................. 257
GM 21.B.245 Continued validity ................................................................................................ 258
AMC 21.B.245 Corrective action plan........................................................................................ 259
Subpart H — Airworthiness certificates and restricted certificates of airworthiness ....................... 260
GM 21.B.320(b)(6) Investigation ................................................................................................ 260
GM 21.B.325(a) Airworthiness certificates ................................................................................ 260
GM 21.B.325(b) Completion of the Airworthiness Review Certificate by a Member State ....... 260
Subpart I — Noise certificates ......................................................................................................... 261
GM 21.B.425(a) Noise certificates ............................................................................................. 261
Subpart P — Permit to fly ................................................................................................................ 264
AMC 21.B.520(b) Application for a permit to fly ........................................................................ 264
EASA Form 21 ............................................................................................................................. 264
Page 10 of 264
TERMINOLOGY
“Certification Specifications” (CS) refers when used in the text to the airworthiness codes and
associated acceptable means of compliance developed by the Agency in accordance with Articles
13(b) and 14.2(a) of the Basic Regulation.
“Acceptable Means of Compliance” (AMC) illustrate a means, but not the only means, by which a
requirement contained in an airworthiness code or an implementing rule can be met.
“Competent Authority” should be understood in accordance with 21.1 (see Part 21).
Page 11 of 264
SECTION A— Subpart A — General
SECTION A
Subpart A — General
Page 12 of 264
SECTION A— Subpart A — General
Where an occurrence is judged by the person identifying the possible unsafe condition to have
resulted in an immediate and particularly significant hazard the Agency (or the competent authority of
the Member State as required) expects to be advised immediately and by the fastest possible means
(telephone, fax, email, telex, etc.) of whatever details are available at that time. This initial report must
be followed up by a full written report within 72 hours. A typical example would be an uncontained
engine failure resulting in damage to aircraft primary structure.
Where the occurrence is judged to have resulted in a less immediate and less significant hazard,
report submission may be delayed up to the maximum of three days in order to provide more details.
Page 13 of 264
SECTION A— Subpart A — General
Page 14 of 264
SECTION A— Subpart A — General
-7
1 x 10 for 2.5% of the aircraft's life; or
-7
5 x 10 for 0.5% of the aircraft's life; or
-6
1 x 10 for 0.25% of the aircraft's life; or
-5
1 x 10 for 0.025% of the aircraft's life, etc.
without exceeding the agreed 'allowance' set aside for this purpose.
3.8 Thus a 'reaction table' can be created as indicated in Table 1 (the last two columns
assuming a typical aircraft design life of 60,000 hours and an annual utilisation of 3 000
hours per annum) showing the flying or calendar time within which a defect should be
corrected if the suggested targets are to be met.
Table 1
3.9 These principles may be applied to a single aircraft or a number of aircraft of a fleet but in
calculating risk, all the risk should be attributed to those aircraft which may carry it, and
should not be diluted by including other aircraft in the fleet which are known to be free of
risk. (It is permissible to spread the risk over the whole fleet when a source is known to
exist without knowing where). Where a fleet of aircraft is involved Column 2 may be
interpreted as the mean time to rectification and not the time to the last one.
3.10 There is one further constraint. However little effect a situation may have on the 'whole
life' risk of an aircraft, the risk should not be allowed to reach too high a level for any
given flight. Thus while a very high risk could be tolerated for a very short period without
unacceptable degradation of the overall airworthiness target, the few flights involved
would be exposed to a quite unacceptable level of risk. It is therefore proposed that the
Table 1 should have a cut-off at the 2 x 10-6 level so that no flight carries a risk greater
than 20 times the target. At this level the defect is beginning to contribute to a greater
likelihood of catastrophe than that from all other causes, including non-airworthiness
causes, put together. If the situation is worse than this, grounding appears to be the only
alternative with possibly specially authorised high-risk ferry flights to allow the aircraft to
return to base empty. Figures 2 and 3 show a visualisation chart equivalent to Table 1,
giving average rectification time (either in flight hours or months) based on probability of
defect that must be corrected.
3.11 It will be seen that the above suggestions imply a probability of catastrophe from the
campaign alone of 1.5/10 000 per aircraft during each separate campaign period (i.e., p
= 0.015 per 100 aircraft fleet).
Page 15 of 264
SECTION A— Subpart A — General
3.12 In addition, in order to take into account large fleet size effect, the expected probability of
the catastrophic event during the rectification period on the affected fleet shall not
exceed 0.1. See Figure 4.
3.13 It should also be noted that in assessing campaign risks against 'design risk', an element
of conservatism is introduced, since the passenger knows only 'total risk' (i.e.
airworthiness plus operations risks) and the fatal accident rate for all reasons is an order
of magnitude greater than that for airworthiness reasons only (i.e., 10 -6 as against 10-7).
The summated campaign risk allowance proposed by this GM is therefore quite a small
proportion of the total risk to which a passenger is subject. When operating for short
periods at the limit of risk proposed (2 x 10 -6 per hour) the defect is however contributing
100 % more risk than all other causes added together.
3.14 A similar approach is proposed to cover the case of defects associated to hazardous
failure conditions for which the safety objectives defined by the applicable airworthiness
requirementscertification specifications are not met. According to CS 25.1309, the
allowable probability for each hazardous failure condition is set at 10-7 per flight hour
compared to 10-9 per flight hour for a catastrophic failure condition. Figure 5 is showing a
visualisation chart giving average rectification time based on probability of defect that
should be corrected. This is similar to Figure 2 but with lower and upper boundaries
adapted to cover the case of hazardous failure conditions (probabilities of 10-7 and 2x10-
4 respectively).
3.15 In addition, in order to take into account large fleet size effect, the expected probability of
the hazardous event during the rectification period on the affected fleet shall not exceed
0.5. See Figure 6.
4. GUIDELINES
4.1 The above would lead to the following guidelines for a rectification campaign to remedy a
discovered defect associated to a catastrophic failure condition without grounding the
aircraft:
(i) Establish all possible alleviating action such as inspections, crew drills, route
restrictions, and other limitations.
(ii) Identify that part of the fleet, which is exposed to the residual risk, after compliance
has been established with paragraph (i).
(iii) Using reasonably cautious assumptions, calculate the likely catastrophic rate for
each aircraft carrying the risk in the affected fleet.
(iv) Compare the speed with which any suggested campaign will correct the deficiency
with the time suggested in Figure 2. The figure should not be used beyond the
-6
2x10 level, except for specially authorised flights.
(v) Also ensure that the expected probability of the catastrophic event during the
rectification period on the affected fleet is in accordance with Figure 4.
4.2 Similarly, the following guidelines would be applicable for a rectification campaign to
remedy a discovered defect associated to a hazardous failure condition without
grounding the aircraft:
(i) Establish all possible alleviating action such as inspections, crew drills, route
restrictions, and other limitations.
(ii) Identify that part of the fleet, which is exposed to the residual risk, after compliance
has been established with paragraph (i).
(iii) Using reasonably cautious assumptions, calculate the likely hazardous rate for
each aircraft carrying the risk in the affected fleet.
(iv) Compare the speed with which any suggested campaign will correct the deficiency
with the time suggested in Figure 5.
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SECTION A— Subpart A — General
(v) Also ensure that the expected probability of the hazardous event during the
rectification period on the affected fleet is in accordance with Figure 6.
4.3 It must be stressed that the benefit of these guidelines will be to form a datum for what is
considered to be the theoretically maximum reaction time. A considerable amount of
judgement will still be necessary in establishing many of the input factors and the final
decision may still need to be tempered by non-numerical considerations, but the method
proposed will at least provide a rational 'departure point' for any exercise of such
judgement.
4.4 It is not intended that the method should be used to avoid quicker reaction times where
these can be accommodated without high expense or disruption of services.
Page 17 of 264
SECTION A — Subpart A — General
20.E-07: MAXIMUM PERMITTED SHORT TERM CAMPAIGN RISK EXCEPT FOR RETURN TO BASE
20.E-07
CAMPAIGN PERIODS
RISK PER HR OF FLIGHT
MEAN TARGET
AIRWORTHINESS
THROUGH LIFE
RISK
0.75 E-07
BASIC DESIGN RISK
0
Life of aircraft
life
* (campaign risk) (exposure time) = 0.25 E-07 per hr. of flight through total life
0
Page 18 of 264
SECTION A — Subpart A — General
1.E-05
1.E-06 Upper Boundary
1.E-08
1.E-09
Lower Boundary (No Action Necessary)
1.E-10
1.E+00 1.E+01 1.E+02 1.E+03 1.E+04 1.E+05 1.E+06
Page 19 of 264
SECTION A — Subpart A — General
1.E-04
per Aircraft Flight Hour
1.E-05
1.E-06 Upper Boundary
1.E-08
1.E-09
Lower Boundary (No Action Necessary)
1.E-10
1 10 100 1000
Page 20 of 264
SECTION A — Subpart A — General
1.E-04
per Aircraft Flight Hour
1.E-05
1.E-06 Upper Boundary Maximum Event Level (0.1)
1.E-07
(Mandatory Action)
1.E-08
1.E-09
Lower Boundary (No Action Necessary)
1.E-10
1.E+03 1.E+04 1.E+05 1.E+06 1.E+07 1.E+08 1.E+09
Affected fleet exposure (Flight Hours)
Page 21 of 264
SECTION A — Subpart A — General
1.E-02
per Aircraft Flight Hour
1.E-03
1.E-04 Upper Boundary
1.E-06
1.E-07
Lower Boundary (No Action Necessary)
1.E-08
1.E+00 1.E+01 1.E+02 1.E+03 1.E+04 1.E+05 1.E+06
Average individual aircraft exposure (Flight Hours)
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SECTION A — Subpart A — General
1.E-03
per Aircraft Flight Hour
1.E-04
Upper boundary
1.E-06
1.E-07
Lower (No Action necessary)
boundary
Page 23 of 264
SECTION A — Subpart A — General
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SECTION A — Subpart A — General
- the system components reliability figures are predicted values derived from
general experience, tests or analysis,
- the crew is expected to have the skill to apply the procedures correctly, and
- the aircraft is assumed to be maintained in accordance with the prescribed
instructions for continued airworthiness (or maintenance programme), etc.
In service experience, additional testing, further analysis, etc., may show that certain initially
accepted assumptions are not correct. Thus, certain conditions initially demonstrated as safe,
are revealed by experience as unsafe. In this case, it is necessary to mandate corrective
actions in order to restore a level of safety consistent with the applicable certification
requirements.
See AMC 21.A.3B(b) for definition of ‘unsafe condition’ used in 21.A.3A(b).
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SECTION A — Subpart A — General
- The handling qualities, although having been found to comply with the
applicable airworthiness requirementscertification specifications at the
time of initial approval, are subsequently shown by service experience
not to comply.
2.1.2.2 Structural or mechanical systems
An unsafe condition exists if the deficiency may lead to a structural or
mechanical failure which:
- Could exist in a Principal Structural Element that has not been
qualified as damage tolerant. Principal Structural Elements are
those which contribute significantly to carrying flight, ground, and
pressurisation loads, and whose failure could result in a
catastrophic failure of the aircraft.
Typical examples of such elements are listed for large aeroplanes
in AMC 25.571(a) ‘Damage tolerance and fatigue evaluation of
structure’, and in the equivalent material for rotorcraft.
- Could exist in a Principal Structural Element that has been
qualified as damage tolerant, but for which the established
inspections, or other procedures, have been shown to be, or may
be, inadequate to prevent catastrophic failure.
- Could reduce the structural stiffness to such an extent that the
required flutter, divergence or control reversal margins are no
longer achieved.
- Could result in the loss of a structural piece that could damage
vital parts of the aircraft, cause serious or fatal injuries to persons
other than occupants.
- Could, under ultimate load conditions, result in the liberation of
items of mass that may injure occupants of the aircraft.
- Could jeopardise proper operation of systems and may lead to
hazardous or catastrophic consequences, if this effect has not
been taken adequately into account in the initial certification safety
assessment.
2.1.2.3 Systems
The consequences of reported systems components malfunctions,
failures or defects should be analysed.
For this analysis, the certification data may be used as supporting
material, in particular systems safety analyses.
The general approach for analysis of in-service events caused by
systems malfunctions, failures or defects will be to analyse the actual
failure effects.
As a result of this analysis, an unsafe condition will be assumed if it
cannot be shown that the safety objectives for hazardous and
catastrophic failure conditions are still achieved, taking into account the
actual failure modes and rates of the components affected by the
reported deficiency.
The failure probability of a system component may be affected by:
- A design deficiency (the design does not meet the specified
reliability or performance).
Page 26 of 264
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AMC 21.A.4 Transferring of information on eligibility and approval status from the design
holder to production organisations
Where there is a need to provide (normally outside the design organisation) a visible statement of
approved design data or airworthiness or environmental protection data associated with the approved
design data, the following minimum information must be provided. The need for a visible statement
may be in relation to Company holding a production organisation approval (POA) in relation to
21.A.163(c).
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SECTION A — Subpart A — General
The procedures related to the use of forms or other electronic means to provide this information must
be agreed with the Agency.
Information to be provided:
Company Name: the name of the responsible design organisation (TC, STC, approval of repair or
minor change design, ETSO authorisation holder) issuing the information.
Date: the date at which the information is released.
Eligibility: indicate the specific products or articles, in case of ETSO authorisation, for which data
have been approved.
Identification: the part number of the part or appliance. Preference should be given to the use of the
Illustrated Parts Catalogue (IPC) designation. Alternatively the reference to the instruction for
continued airworthiness (e.g., SB, AMM, etc.) could be stated. Marking requirements of Part 21
Section A Subpart Q should be taken into account.
Description: the name or description of the part or document should be given. In the case of a part or
appliance preference should be given to use of IPC designation. The description is to include
reference to any applicable ETSO authorisation or EPA marking, or previous national approvals still
valid.
Purpose of data: the reason for the provision of the information should be stated by the design
approval holder.
Examples:
a) Provision of approved design data to a production organisation to permit manufacture (AMC No
1 to 21.A.133(b) and (c))
b) Information regarding eligibility for installation (replacement parts, repair, modification, etc.)
c) Direct Delivery Authorisation (AMC No 1 to 21.A.133(b) and (c))
If the data is in support of a change or repair, then reference to the aircraft level approval should be
given (make reference to the approved STC, change or repair).
Limitations/Remarks: state any information, either directly or by reference to supporting
documentation that identifies any particular data or limitations (including specific importing
requirements) needed by a production organisation to complete Block 1312 of the EASA Form 1.
Approval: provide reference information related to the approval of the data (Agency document or
DOA privilege).
Authorised signature: name and hand-written normal or electronic signature of a person who has
written authority from the design organisation, as indicated in the procedures agreed with the Agency.
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SECTION A —Subpart B — Type-certificates and restricted type-certificates
For a particular project, at the beginning of the process, the applicant must propose to the
Agency for acceptance a certification programme that includes:
Part 1 Procedures for the management of the certification programme: creation and update all
along the certification process to integrate the progress of the activities, distribution.
This part must also include the milestones of the project development up to the type
certification or approval of the major change, with the minimum administrative delays
imposed by the Agency when necessary.
Part 4 Working methods for showing of compliance and providing to the Agency the means by
which such compliance has been shown.
This includes all or part of the following, depending on the complexity of the product:
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SECTION A —Subpart B — Type-certificates and restricted type-certificates
The applicant must submit all revisions of the certification programme to the Agency for
acceptance.
A numbering system to identify the compliance documents must be defined in order to have an
adequate link with the certification programme.
Except as otherwise agreed with the Agency, all compliance documents must be produced
before issuance of the final statement of compliance required by 21A.20(b) or 21A.97(a)(3).
2.3 There are no privileges associated with alternative procedures, however the Agency will decide
on the extent of its involvement in the verification of compliance documents. This involvement
may vary according to the Agency knowledge of the applicant from previous and on-going
activities and the resulting assessment of competence, and must be addressed in the
certification programme.
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SECTION A —Subpart B — Type-certificates and restricted type-certificates
3.2 Classification
3.2.1 Content
The procedure must address the following points:
- identification of changes to type design
- airworthiness classification
- changes to type design initiated by sub-contractors
- documents to justify the classification
- authorised signatories
Criteria used for classification must be in compliance with 21.A.91 and
corresponding interpretations.
3.2.2 Identification of changes to type design
The procedure must indicate how the following are identified:
- major changes to type design
- those minor changes to type design where additional work is necessary to
show demonstrate compliance with the airworthiness requirements
certification specifications
- other minor changes to type design requiring no further showing
demonstrating of compliance.
3.2.3 Airworthiness classification
The procedure must show how the effects on airworthiness are analysed, from the
very beginning, by reference to the applicable requirements certification
specifications.
If no specific requirements certification specifications are applicable to the change,
the above review must be carried out at the level of the part or system where the
change is integrated and where specific requirements certification specifications are
applicable.
3.2.4 Control of changes to type design initiated by sub-contractors
The procedure must indicate, directly or by cross-reference to written procedures,
how changes to type design initiated by sub-contractors are controlled.
3.2.5 Documents to justify the classification
All decisions of classification of changes to type design must be documented and
approved by the Agency. It may be in the format of meeting notes or register.
3.2.6 Authorised signatories
The procedure should identify the persons authorised to sign the proposed
classification before release to the Agency for approval.
3.3 Approval of changes to type design
3.3.1 Content
The procedure must address the following points:
- compliance documentation
- approval process
- authorised signatories
3.3.2 Compliance documentation
For major changes and those minor changes to type design where additional work to
show demonstrate compliance with the applicable airworthiness requirements
certification specifications is necessary, compliance documentation must be
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SECTION A —Subpart B — Type-certificates and restricted type-certificates
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SECTION A —Subpart B — Type-certificates and restricted type-certificates
The persons authorised to sign before release of information and instructions to the
Agency for approval should be identified in the procedure.
The procedure should include the information or instructions prepared by sub-contractors
or vendors, and declared applicable to its products by the TC, STC, approval of changes to
type design or approval of repair design holders.
4.3 Statement
The information and instructions should contain a statement showing Agency approval.
5. Obligations addressed in 21.A.44 (TC holder), 21.A.118A (STC holder) or 21.A.451 (repair design
approval holder)
The applicant should establish the necessary procedures to show to the Agency how it will fulfil
the obligations required under 21.A.44, 21.A.118A or 21.A.451, as appropriate.
6. Control of design sub-contractors
The applicant should establish the necessary procedures to show to the Agency how it will control
design sub-contractors.
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SECTION A —Subpart B — Type-certificates and restricted type-certificates
Associated Compliance
Type of Compliance Means of Compliance
Documents
MC8: Simulation
Page 35 of 264
SECTION A —Subpart B — Type-certificates and restricted type-certificates
The requirements of 21.A.33(a) should not preclude the applicant requesting the Agency to make
flight or other tests of particular aspects of the product during its development and before the type
design is fully defined and a Declaration of Compliance can be issued for all the applicable
certification specifications (CS). However in case of flight test the applicant should have performed
subject tests before the Agency tests and should ensure that no features of the product preclude the
safe conduct of the evaluation requested. The Agency may require to repeat any such tests once the
type design is fully defined to ensure that subsequent changes have not adversely affected the
conclusions from any earlier evaluation. A statement of compliance with sub-paragraph point
21.A.33(b) is also required for the above tests.
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SECTION A —Subpart B — Type-certificates and restricted type-certificates
Page 37 of 264
SECTION A — Subpart D — Changes to type-certificates and restricted type certificates
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SECTION A — Subpart D — Changes to type-certificates and restricted type certificates
(i) Where the change requires an adjustment of the type-certification basis (such as
special condition, equivalent safety finding, elect to comply, exemption, , earlier
certification specification (reversion), later requirements certification specification).
(ii) Where the applicant proposes a new interpretation of the requirements certification
specifications used for the type type-certification basis, that has not been published
as AMC material or otherwise agreed with the Agency.
(iii) Where the demonstration of compliance uses methods that have not been previously
accepted as appropriate for the nature of the change to the product or for similar
changes to other products designed by the applicant.
(iv) Where the extent of new substantiation data necessary to comply with the
applicable airworthiness requirements certification specifications and the degree to
which the original substantiation data has to be re-assessed and re-evaluated is
considerable.
(v) The change alters the Airworthiness Limitations or the Operating Limitations.
(vi) The change is made mandatory by an airworthiness directive or the change is the
terminating action of an airworthiness directive (ref. 21.A.3B). See note 1.
(vii) Where the change introduces or affects functions where the failure effect is classified
catastrophic or hazardous
Note 1: The design change previously classified minor and approved prior to the
airworthiness directive issuance decision needs no re-classification. However,
the Agency retains the right to review the change and re-classify/re-approve if
found necessary.
Note 2: These above conditions are an explanation of the criteria noted in 21.A.91.
For an understanding of how to apply the above conditions it is useful to take note of the
examples given in Appendix A to GM 21.A.91.
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SECTION A — Subpart D — Changes to type-certificates and restricted type certificates
(i) Where failure effect is 'Catastrophic' or 'Hazardous', the change should be classified as
major.
(ii) Where failure effect is 'major', the change should be classified as major if:
- aspects of the compliance demonstration use means that have not been previously
accepted for the nature of the change to the system; or
- the change affects the pilot/system interface (displays, controls, approved
procedures); or
- the change introduces new types of functions/systems such as GPS primary, TCAS,
Predictive windshear, HUD.
The assessment of the criteria for software changes to systems also needs to be performed.
When software is involved, account should be taken also of the following guidelines:
Where a change is made to software produced in accordance with the guidelines of EUROCAE
ED12B/RTCA DO-178B "Software Considerations in Airborne Systems and Equipment
Certification", the latest edition of AMC 20-115 (see AMC-20 document) the change should be
classified as major if either of the following apply, and the failure effect is Catastrophic,
Hazardous or Major:
(1(i) the executable code for software, determined to be Level A or Level B in accordance with
the guidelines, is changed unless that change involves only a variation of a parameter
value within a range already verified for the previous certification standard; or
(2ii) the software is upgraded to or downgraded from Level A, Level B or Level C; or
(3iii) the executable code, determined to be level C, is deeply changed, e.g., after a software re-
engineering process accompanying a change of processor.
For software developed to guidelines other than ED-12B/DO-178B the latest edition of AMC 20-
115, the applicant should assess changes in accordance with the foregoing principles.
For other codes the principles noted above may be used. However, due consideration should be
given to specific requirements certification specifications/interpretations.
5. Propellers
Changes to:
- diameter
- airfoil
- planform
- material
- blade retention system, etc.
6. Engines
Changes:
(i) that adversely affect operating speeds, temperatures, and other limitations.
(ii) that affect or introduce parts identified by CS E-510 where the failure effect has been
shown to be hazardous.
(iii) that affect or introduce engine critical parts (CS E-515) or their life limits.
(iv) to a structural part which requires a re-substantiation of the fatigue and static load
determination used during certification.
(v) to any part of the engine which adversely affects the existing containment capability of
the structure.
(vi) that adversely affect the fuel, oil and air systems, which alter the method of operation, or
require reinvestigation against the type-certification basis.
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SECTION A — Subpart D — Changes to type-certificates and restricted type certificates
- a reduction in the noise certification level(s) for which the applicant wishes to take
credit.
Examples of noise-related changes that might lead to a major change classification are:
(1) For jet and heavy (maximum take-off mass greater than 8618 kg) propeller-driven
aeroplanes:
- A change that might affect the aircraft’s take-off performance including:
• a change to the maximum take-off mass;
• a change to V2 (‘take-off safety speed’); or
• a change to the lift augmentation devices, including their configuration
under normal take-off operating conditions.
- A change that might affect the aircraft’s landing performance including:
• a change to the maximum landing mass;
• a change to VREF (reference landing speed); or
• a change to the lift augmentation devices, including their deployment
under normal landing operating conditions.
- A change to the Centre of Gravity (CG) limits;
- A change that increases the aircraft’s drag;
- A change that alters the external profile of the aircraft, including the
installation or change of shape or size of any item on the external surface of
the aircraft that might protrude into the airflow such as winglets and vortex
generators; generally the installation of small antennas does not represent
an acoustical change;
- A change that introduces an open-ended hollow cavity at more or less right
angles to the airflow (e.g. hollow pins in undercarriage assemblies);
- A change of engine or, if fitted, propeller type;
- A change in engine thrust rating;
- A change to the engine rotating parts or stators, such as geometry, blade
profile or blade number;
- A change to the aerodynamic flow lines through the engine;
- A change that affects the engine thermodynamic cycle, including a change
to the engine’s bypass ratio;
- A change to the engine nacelle, including a change to the acoustic liners;
- A change to the engine exhaust;
- A change to the engine bleed valves, including bleed valve scheduling;
- A change in the operation of engine power off-takes (e.g. the operation of
the Environmental Control System (ECS) during a normal take-off or
approach);
- A change to the Auxiliary Power Unit (APU), including associated operating
limitations (e.g. a change that allows the APU to be operated during a
normal approach when previously it was not allowed);
- A change to the propeller pitch and/or propeller speed during a normal take-
off or approach;
- A change that causes a change to the angle at which air flows into the
propeller.
(2) For light (maximum take-off mass 8618 kg or less) propeller-driven aeroplanes:
- A change that might affect the aircraft’s take-off performance including:
Page 43 of 264
SECTION A — Subpart D — Changes to type-certificates and restricted type certificates
Page 44 of 264
SECTION A — Subpart D — Changes to type-certificates and restricted type certificates
- A change that affects the engine thermodynamic cycle, specifically relevant engine
cycle parameters (e.g. combustor pressure P3, combustor entry temperature T3,
Air Fuel Ratio (AFR));
- A change to the compressor that might influence the combustor inlet conditions
and engine overall pressure ratio;
- A change to the combustor design (geometry);
- A change to the cooling of the combustor;
- A change to the air mass flow through the combustor;
- A change that affects the fuel spray characteristics.
Page 45 of 264
SECTION A — Subpart D — Changes to type-certificates and restricted type certificates
Classification process
Classification process
Change inn Type Design
Des gn
Classification
Classification
C ass ca on oof Des gn Change
Design Changeacc.acc.21A.91
acc 21A.91
21A 91
Goals:
Goals:
Goa s -- determine
e m ne approval
determine
de ova route
approval
app route
ou e
--assess
assess eeffect
effect on aairworthiness
ec on airworthiness
wo h ness
Agency decides
Agency Request for
Reques o Any good reason
eason
classification
decides
dec des reclassification
reclassification
ec ass ca on totooreclassify
ec ass yminor
reclassify no ?
minor
m
yes
Minor Major
Page 46 of 264
SECTION A — Subpart D — Changes to type-certificates and restricted type certificates
Foreword
This guidance material (GM) provides guidance for the application of the Changed Product Rule (CPR)
21A.101 and 21A.19, for changes made to type-certificated aeronautical products.
Chapter 1. Introduction
1. Purpose
a. The Agency wrote this GM to provide guidance for establishing the type-certification
basis for changed aeronautical products in accordance with 21.A.101 and to help identify
if it will be necessary to apply for a new type-certificate (TC) under 21.A.19. The guidance
describes the process for establishing the type-certification basis for changes to type
certificates or restricted type-certificates, supplemental type certificates (STC) and
amended STCs, detailing evaluations, classifications, and decisions made throughout the
process.
b. The content of this GM is divided into 4 Chapters and 5 Appendices:
(1) Chapter 1 explains the purpose of this GM, describes its content, specifies the
intended audience, and clarifies which changes are within the scope of applicability
of this GM. Chapter 1 also contains definitions and terminology used in this GM for
application of 21.A.101 and 21.A.19.
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SECTION A — Subpart D — Changes to type-certificates and restricted type certificates
(2) Chapter 2 provides a general overview of 21.A.101 and 21.A.19, clarifies the
principles and safety objectives and directs applicants to the applicable guidance
contained in subsequent chapters of this GM.
(3) Chapter 3 contains guidance for implementation of 21.A.101(a) and (b) to establish
the type-certification basis for changed aeronautical products. Chapter 3 describes
in detail the various steps of the ‘top-down’ certification basis development
approach. Chapter 3 also addresses 21.A.19 considerations to identify conditions
under which an applicant for a type design change is required to submit application
for a new TC and provides guidance at which stage of the process this
assessment is to be performed.
(4) Chapter 4 contains considerations for design related operating requirements,
guidance for establishing type-certification basis for changes on certain small
aeroplanes and rotorcraft under specified maximum weight (‘excepted products’),
guidance for use of special conditions under 21.A.101 (d), guidance on the
effective period of an application, guidance for establishing the type-certification
basis for changes on aircraft designed or modified for a special purpose (to
operate under a restricted certificate of airworthiness) and guidance for
documentation of revisions to the type-certification basis.
(5) Appendix A contains examples of typical type design changes for small aeroplanes,
large aeroplanes, rotorcraft, engines, and propellers which are categorised by the
Agency into individual tables according to the classifications to the level of design
change - substantial, significant, and not significant.
(6) Appendix B provides detailed guidance with examples for evaluating when
compliance would be impractical under the ‘impracticality’ exception in the rule.
(7) Appendix C provides guidance with examples on use of relevant service experience
in the certification process as one way to show that a later amendmentthe latest
certification specifications may not contribute materially to the level of safety,
allowing the use of earlier certification specifications.
(8) Appendix D contains figures and tables considered useful for understanding of the
basic terms used and their mutual relations to assist correct application of this GM.
(9) Appendix E contains cross-references to relevant requirements of Part 21 related to
application of 21.A.19 and 21.A.101.
c. This GM describes an acceptable means, but not the only means to comply with
21.A.101 and 21.A.19. However, if an applicant chooses to use the means described in
this GM, they must follow it entirely.
2. Audience
This GM is for applicants applying for:
- major changes to type design of products under 21.A.97 and to type design of Auxiliary
Power Units (APUs) under 21.A.604(b)),
- supplemental type-certificates (STCs) under 21.A.113, or
- major changes to STCs under 21.117 (b).
3. Applicability
a. Reserved.
b. This GM applies to major type design changes under 21.A.101 for aeronautical products
type-certificated, restricted type-certificated, supplemental type-certificated or ETSO
approved (APU) under Part 21 (ref. 21.A.21. 21.A.23, 21.A.115, 21.A.604), with
application for the type-certification basis of the airworthiness code of the applicable CS
(CS-VLA, CS-22, CS-23, CS-25 etc.).
c. Minor type design changes are automatically considered not significant under 21.A.101(b)
and the existing type-certification basis is considered adequate for their approval under
21.A.95.
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SECTION A — Subpart D — Changes to type-certificates and restricted type certificates
d. Reserved.
e. For the purpose of this GM, the term aeronautical products, or products, means type-
certificated or restricted type-certificated aircraft, engines, and propellers or ETSO
approved APUs.
f. This GM is not intended to be used to determine the applicable environmental protection
requirements (aircraft noise, fuel venting and exhaust emission requirements) for
changed products.
4. Definitions and Terminology
Adequate Type-certification Basis – The type-certification basis for a changed product under
21.A.101 is considered adequate when the Agency determines that it provides adequate
standards for the design change, i.e. when the certification specifications of the applicable
airworthiness code and prescribed special conditions provide an appropriate level of safety for
the changed product and do not result in any unsafe design features.
Aeronautical product – The terms aeronautical product or product(s) used in this guidance
material include type-certificated or restricted type-certificated aircraft, engines, propellers and
ETSO approved Auxiliary Power Units (APUs).
Affected area, system, part or appliance – any system, part, or appliance which is either
physically altered by a proposed design change or, even if not altered physically, its functional
characteristics are altered due to the effects of the physical change.
Design change – A change in the type design of an aeronautical product. In the context of this
document the terms ‘change’, ‘design change’ and ‘type design change’ are synonymous.
Earlier certification specifications – The certification specifications of the applicable
airworthiness code in effect prior to the date of application for the change, but not prior to the
existing type-certification basis.
Existing type-certification basis – The certification specifications of the applicable
airworthiness code, special conditions and equivalent level of safety findings incorporated by
reference in the type-certificate of the product to be changed.
Latest certification specifications – The certification specifications of the applicable
airworthiness code in effect on the date of application for the change.
Previous relevant design changes – Previous design changes, the cumulative effect of which
could result in a product significantly or substantially different from the original product or model,
when considered from the last time the latest certification specifications were applied.
Product level change – A change or combination of changes that makes the product distinct
from other models of the product (for example, range, payload, speed, design philosophy).
Product level change is defined at the aircraft, engine, propeller, or APU level of change.
Secondary change – A change is a secondary change if compliance to the latest amendment
would not contribute materially to the level of safety and where it is part of and consequential to
an overall significant change. A secondary change is a physical change that restores without
changing the system, structural capacity, or functionality, but is necessary to support a
significant change.
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. The significance of the change must be considered in the context of all previous
relevant design changes and all related revisions to the certification specifications of the
applicable airworthiness code. Not all product level changes are significant.
Significant change in an area (for excepted aircraft under 21.A.101(c) only) – A change in an
area is significant if the general configuration or the principles of construction in that area are
not retained, or the assumptions used for certification of that area do not remain valid.
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 type certificate, in accordance with 21.A.19.
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1. 21.A.19
a. 21.A.19 requires an applicant to obtain a new type-certificate (TC) for a changed product if the
change in design, power, thrust, or weight is found by the Agency so extensive that a
substantially complete investigation of compliance with the applicable type-certification basis is
required.
b. Changes that require a substantial re-evaluation of the product’s compliance findings are
referred to as ‘substantial changes’. For guidance, see Section 3 of Chapter 3. Appendix A to
this GM provides examples of type design changes that will require application for a new TC.
c. If the Agency has determined through 21.A.19 that the proposed design change does not
require a new TC, see 21.A.101 for the applicable implementing rules to establish the type-
certification basis for the proposed design change. For guidance, see Chapter 3 and the
examples in Appendix A of this GM.
2. 21.A.101
a. 21.A.101(a) requires a change to a TC to comply with the latest certification specifications of
the airworthiness code that is applicable to the changed product and that is in effect at the date
of the application for the change, unless the change meets the criteria for the exceptions
identified in 21.A.101(b) and (c) or compliance with certification specifications of later effective
amendments is chosen by the applicant or required under 21.A.101(e) and (f). The intent of
21.A.101 is to enhance safety through the incorporation of the latest regulatory standards in the
type-certification basis for changed products to the greatest extent practicable.
b. An applicant can comply with certification specifications of an earlier amendment of the
airworthiness code consistent with the requirements of 21.A.101(b), when:
• a change is not significant (see 21.A.101(b)(1)), or
• an area, system, part or appliance is not affected by the change (see 21.A.101 (b) (2)), or
• compliance with the latest amendment for a significant change does not contribute
materially to the level of safety (see 21.A.101(b)(3)), or
• compliance with the latest amendment would be impractical (see 21.A.101(b)(3)).
c. Note that earlier amendments may not precede the corresponding amendment of the
airworthiness code incorporated by reference in the type-certificate.
d. 21.A.101(b) allows a changed product to comply with an earlier amendment of the applicable
airworthiness code, provided one of the criteria in 21.A.101(b)(1),(2) or (3) are met and the
earlier amendment is considered adequate. However, when a proposed design change involves
features or characteristics considered novel or unusual, or the intended use of the changed
product is unconventional, or experience from other similar products in service or products
having similar design features has shown that unsafe conditions may develop, and the
proposed airworthiness standards certification specifications do not contain adequate or
appropriate standards for the changed product, later amendments and/or special conditions will
be applied.
e. 21.A.101(b)(1)(i) and (ii) describe the automatic criteria establishing that a change is significant.
f. 21.A.101(c) provides an exception from the requirements of 21.A.101(a) for a change to certain
aircraft with less than specified maximum weight. If an applicant applies for a type design
change to an aircraft (other than rotorcraft) of 2 722 kg (6 000 pounds) or less maximum weight,
or to a non-turbine powered rotorcraft of 1 361 kg (3 000 pounds) or less maximum weight, the
applicant can show demonstrate that the changed product complies with the type-certification
basis incorporated by reference in the TC. The applicant can also elect to comply, or may be
required to comply, with a later amendment. See Chapter 4, Section 2 in this GM for specific
guidance on this provision.
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g. 21.A.101(d) provides for the use of special conditions, under 21.A.16B, when the proposed
amendment of the applicable airworthiness code and any later amendment do not provide
adequate standards to the proposed change.
h. 21.A.101(e) prescribes the effective period an application will remain valid for a change. This
section is consistent with the requirements of 21.17 for a new TC.
i. 21.A.101(f) requires that if an applicant chooses (elects) to comply with a certification
specification of an amendment to the airworthiness codes that is effective after the filing of the
application for a change to a type, the applicant shall also comply with any other certification
specification that the Agency finds is directly related.
Chapter 3. The process for establishing the type-certification basis for changed products
21.A.101 (a) and (b)
1. Overview
a. Both the applicant and the Agency have responsibility under 21.A.101(a) and (b). The
applicant must show demonstrate that the change complies with the latest applicable
certification specifications unless use of an exception per 21.A.101(b) is justified. If an
exception is proposed, the applicant should make a preliminary classification whether the
change is significant or not significant, and propose an appropriate type-certification
basis. The Agency determines whether the applicant’s classification of the change and
proposal for the type-certification basis are consistent with the applicable rules and their
interpretation, but should not be dependent on whether the TC holder or applicant for a
STC is originating the change. The type-certification basis can vary depending on the
magnitude and scope of the change. The steps below present a streamlined approach for
making this determination. In addition to assisting in the determination of significance and
establishing the type-certification basis, this guidance will help to establish the
appropriate amount of coordination required between the applicant and the Agency.
b. Classifications of typical type design changes are in Appendix A, Classification of
Changes. See paragraph 6(c) of this chapter for instructions on how to use Appendix A.
c. In cases where the examples in Appendix A are not applicable for the proposed change,
use the following steps in conjunction with Figure 1 on the next page to establish the
appropriate type-certification basis for the type design change.
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Step 1.
Propose major type design change
- Identify type design to be changed
- Identify proposed change
- Use high level descriptors
Step 2.
Is the change
substantial?
21.A.19
Step 4.
Arrange changes into
No related & unrelated groups
Step 5.
Step 3. No Is the proposed
Will the latest No Not significant
change significant?
specifications be used? 21.A.101(b)(1)
21.A.101(a)
Yes
Will the
Yes latest specifications
be used?
Yes
No
Step 6.
For every area,
is the area affected No Unaffected areas
by the proposed change?
21.A.101(b)(2)
Yes
Step 7.
Yes Are the latest
Impractical or not
specifications practical
contributing
and do they contribute materially to No
materially to the
the level
level of safety
of safety?
21.A.101(b)(3)
Yes
A STOP
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PROPOSED
CERTIFICATION
BASIS FOR THE
CHANGE
Step 8.
Is the proposed
No TC basis Yes
adequate?
2. Step 1 of Figure 1. Identify the proposed type design change to an aeronautical product
Step 1.
Propose major type design change
- Identify type design to be changed
- Identify proposed change
- Use high level descriptors
a. Prior to describing the proposed change(s), it is important to clearly identify the type
design configuration to be changed. A series of derivative aircraft, engines, or propellers
(for example, x-100, x-200, x-300) may evolve based on predecessor type designs, each
with its own design changes that make it distinct from the other series. The applicant
should identify which model or series within that model is the specific configuration that
will be modified.
Note: An STC is not a product; it is a change to a product. When changing or amending
an STC the starting point is the existing modified product (TC with existing STC
installed). For example, if an applicant were amending an STC for an external
cargo locker and the applicant proposed changing the configuration of the locker,
then the starting point would be the existing TC with the existing STC installed.
The applicant would then compare that configuration (TC with existing STC
installed) to the changed product (TC with proposed amended STC installed).
b. Changes to a product can include physical design changes, changes to an operating
envelope and/or performance changes. The change can be a single change or a
collection of changes. The purpose of this process step is to identify and describe the
change to the aeronautical product. The applicant for a type design change should
consider all previous related design changes and the amendment level of the type-
certification basis for these changes.
Note 1: By definition all previously incorporated changes have been approved. The
purpose of step 1 is to consider the net cumulative effect of the changes since
the last time the certification basis for the changed/affected area was upgraded
from that of the original type design.
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Note 2: Substantiating data for the proposed type design change can include compliance
findings from a previously approved design change, in supporting compliance
findings for the proposed change. However, for the purpose of classifying the
proposed design change, such previously approved design and compliance data
should be now considered in relation to the proposed type design change and
should be taken into account as a part of the proposed design change
classification.
c. When identifying the changes being proposed as part of a modification, consider
previous relevant changes that create a cumulative effect, as these may influence the
decisions regarding substantial and significant changes later in the process. By previous
relevant changes those design changes are meant whose effects accumulate, such as
successive thrust increases, incremental weight increases, or sectional increases in
fuselage length. Any previous relevant design changes in the area affected by the current
change that did not involve an upgrade of the existing type-certification basis should be
taken into account in the next design change proposal.
(1) Example 1: A 5 % weight increase is currently being proposed, but a previous 10 %
and another 15 % weight increase has been incorporated into this aircraft without
upgrading the existing type-certification basis. In the current proposal for a 5 %
weight increase, the cumulative effects of the two previous weight increases that
did not involve upgrade of the type-certification basis will now be accounted for as
an approximately 30 % increase in weight, for the purpose of making the
substantial and/or significant decisions. Note that the cumulative effects to be
considered are only those incremental increases from the last time the applicable
certification specifications in the type-certification basis were upgraded.
(2) Example 2: The TC for aeroplane model X lists three series, namely X-300, X-200,
and X-100. The X-300 is a derivative of the X-200 which is a derivative of the
original X-100 series. An applicant proposes a design change to the X-300 series
aeroplane. During the review of the X-300 type-certification basis and the
certification specifications affected by the proposed change, it was identified that
one certification specification, CS-25.571 (damage tolerance), remained at the
same amendment level as the X-100 original type-certification basis (derogation
from 21.A.101(a) was allowed). Since the amendment level for this particular
certification specification was not changed for the two subsequent aeroplane
series (X-200 and X-300), the cumulative effects of these two previous design
changes that are related to the proposed change and the damage tolerance
requirements should now be addressed.
d. To identify and describe the proposed changes to any aeronautical product, use a high-
level description of the design change that characterises the intent of, or the reason for,
the change. No complex technical details are necessary at this stage. For example, a
proposal to increase maximum passenger-carrying capacity may require an addition of a
fuselage plug, and as such a ‘fuselage plug’ becomes one possible high-level description
of this design change. Similarly, a thrust increase, a complete new interior, an avionics
system upgrade, or a passenger-to-cargo conversion are all high-level descriptions that
characterise typical changes to the aircraft, each driven by a specific goal, objective or
purpose.
e. Evolutionary Changes. Evolutionary changes that occur during the course of a
certification programme may require re-evaluation of the type-certification basis and may
result in re-classification of the change. That is, any evolution in the proposed design
change after the type-certification basis has been agreed to (or established) will
necessitate a revisit of the type-certification basis to ensure that ‘evolved’ aspects of the
design change are still covered by the agreed upon certification basis.
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Step 2.
Is the change
substantial?
(21.A.19)
a. 21.A.19 requires an applicant to apply for a new TC for a changed product if the
proposed change in design, power, thrust, or weight is so extensive that a substantially
complete investigation of compliance with the applicable regulationstype-certification
basis is required. A new TC could be required for either an extensive change to a
previously type-certificated product or for a changed design derived through the
cumulative effect of a series of design changes from a previously type-certificated
product.
b. A ‘substantially complete investigation’ of compliance is required when most of the
existing substantiation is not applicable to the changed product. A substantial change
proposal will require the need to comply with all the certification specifications applicable
to a particular category of product. The number of certification specifications to which
compliance must be re-established for the changed product may not necessarily be the
sole determination criteria as to whether the change is substantial, but rather the extent
of effort to establish compliance, or the depth of investigation required to be done. In
other words, the design change may be considered substantial if it is so extensive
(making the product sufficiently different from its predecessor) that the design models,
methodologies and approaches used to demonstrate a previous compliance finding could
not be used.
c. To address the question if a change is substantial at the beginning of the process, the
applicant should evaluate the total or combined effect of all the proposed changes
identified in Step 1, including the cumulative effects of previous relevant design changes
since the last update of the type-certification basis (as explained in Step 1).
d. If it is not initially clear that a new TC is required, Appendix A provides some examples of
substantial changes to aid in this classification. A substantial change requires application
for a new TC under 21.A.17 and 21.A.19. If the change is not substantial, then follow the
21.A.101 process.
Step 3.
Will the latest specs
be used?
21.A.101(a)
a. The applicant can upfront elect to use the latest certification specifications for their
proposed type design change. If the latest certification specifications are used, the
applicant will meet the intent of 21.A.101 and no further classification (significant or not
significant) and justification is needed. However, the decision to voluntarily comply with
the latest certification standards specifications for a design change sets a new regulatory
baseline for all future related changes in the same affected area. Even though one
applicant elects to use the latest certification requirements specifications, another
applicant could apply 21.A.101 for a similar design change proposal, and use the
exceptions in accordance with 21.A.101(b). If the latest certification specifications are not
used, then proceed as follows:
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Step 4
Arrange changes into
related & unrelated groups
a. Once the proposed changes are identified using high-level descriptions, the next step is
to determine if any of these changes are related to each other. Related changes are
those that cannot exist without one another, are co-dependent, or a prerequisite of one
another. For example, a need to carry more passengers could require the addition of a
fuselage plug, which will result in a weight increase, and may necessitate a thrust
increase. Thus the fuselage plug, weight increase and thrust increase are all related
high-level changes that will be needed to achieve the goal of carrying more passengers.
A decision to upgrade the cockpit to more modern avionics at the same time as these
other design changes may be considered unrelated, as the avionics upgrade is not
necessarily needed to carry more passengers (it has a separate purpose, likely just
modernisation). The proposed avionics upgrade would then be considered an unrelated
(or a stand-alone) change. However, the simultaneous introduction of a complete new
interior may be considered related since a cabin length change will have an impact on
occupant safety considerations. Even if a new cabin interior is not included in the product
level change, the functional effect of the fuselage plug has implications on occupant
safety (e.g., the dynamic environment in an emergency landing, emergency evacuation,
etc.), and thus the cabin interior becomes an affected area.
b. Once the change(s) are organised into groupings of those that are related and those that
are unrelated (or stand-alone), the applicant is ready for Step 5 of Figure 1. The grouping
of related and unrelated changes is particularly relevant to the ‘significant’ Yes/No
decision, (21.A.101(b)(1)), described in Step 5 of Figure 1. Each group of related
changes and each unrelated (stand-alone) change is evaluated on its own merit for
significance.
c. After describing the groupings and the associated or supporting technical details for each
change, the applicant should identify areas, systems, parts or appliances of the product
that are affected by the design change and the corresponding certification specifications
associated with these areas. For each group, the applicant should assess the physical
and/or functional effects of the change on other areas, systems, parts, or appliances of
the product. The characteristics affected by the change are not only physical changes,
but also functional changes brought about by the physical changes. Examples of physical
aspects are: structures, systems, parts and appliances, software in combination with the
affected hardware. Examples of functional characteristics are performance, handling
qualities, aeroelastic characteristics, and emergency egress. The intent is to encompass
all aspects where there is a need for re-evaluation, that is, where the substantiation
presented for the product being changed should be updated or rewritten.
Step 5.
Is the proposed
change grouping
significant?
21.101(b)(1)
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f. Typically, a change to a single area, system, part or appliance may not result in a product
level change. However, there may be distinct cases where the change to a single system
or part may, in fact, result in a significant change due to its effect on the product overall.
Examples may include addition of winglets, leading edge slats or change in primary flight
controls to fly-by-wire system.
g. A change is a secondary change if compliance to the latest amendment does not
contribute materially to the level of safety and where it is part of and consequential to an
overall significant change. A secondary change is a physical change that restores without
changing the system, structural capacity or functionality, but is necessary to support a
significant change. Based on this description, a secondary change is not required to
comply with the latest certification specifications because it is considered ‘not contributing
materially to the level of safety’, and therefore eligible for an exception under
21.A.101(b)(1)(3). Determining whether a change meets the description for secondary
change, and thus is eligible for an exception, should be straightforward. Hence the
substantiation or justification need only be minimal. If this determination is not
straightforward, then the proposed change is very likely not a secondary change.
(1) In some cases the change which restores functionality may in fact contribute
materially to the level of safety by meeting a later amendment. If this is the case, it
would not be considered a secondary change.
(2) An example of secondary change is lengthening existing control cables passing
through the new fuselage plug to restore existing functions to systems that could
be situated within or beyond the new plug. The lengthening of these cables can be
accepted as not adding system capacity or capability, so these changes can be
identified as secondary changes and not be required to meet the latest
amendment.
h. A new model number designation to a changed product is not necessarily indicative that
the design change is significant under 21.A.101. Conversely, retaining the existing model
designation does not mean that the design change is not significant. All changes are
considered in light of the magnitude of the type design change.
i. Making the determination. The final determination of whether a design change is
significant or not significant is retained by the Agency. To assist the applicant in their
assessment, the Agency has predetermined the classification of several typical design
changes that can be used for reference, and these examples are listed in Appendix A to
this GM.
j. At this point, the determination of significant or not significant for each of the groupings of
related changes and each stand-alone change has been made. For significant changes,
if the applicant proposes to comply with an earlier requirement, the procedure outlined in
paragraph 7 below should be used.
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affected by the change to justify use of the exception in 21.A.101(b)(2) (see Section 9 for
guidance on whether or not an area is affected by the proposed change).
c. Reserved.
d. 21.A.101(b)(3) provides two more exceptions applicable to areas, systems, parts or
appliances which are affected by the significant change but for which compliance with the
latest requirements certification specifications would either not contribute materially to the
level of safety or would be impractical (see Section 10 for more guidance).
e. Reserved.
f. The applicant should provide acceptable justification for the application of earlier
amendments for areas affected by a significant change. Your justification should show
that compliance with later amendment in these areas would not contribute materially to
the level of safety or would be impractical. Such justification should address all the
aspects of the area, system, part or appliance affected by the significant change.
g. The final type-certification basis may combine certification specifications at the latest
amendment level, earlier (intermediate) amendment levels, and the amendment level of
the existing type-certification basis, but cannot contain certification specifications
preceding the existing type-certification basis.
h. Note that should an applicant decide to use the latest certification specifications without
any exceptions, no further evaluations and justifications are needed. In such a case,
proceed to step 8 (Section 11).
a. When a change is classified not significant, the rule (21.A.101(b)(1)) allows the use of the
earlier certification specifications, but not dated prior to the existing type-certification
basis. Within this limit, the applicant is allowed to propose an amendment level for each
certification specification for the affected area. However, the applicant should be aware
that their proposal for the type-certification basis will be reviewed by the Agency to
ensure that the type-certification basis is adequate for the proposed change (see
paragraph 8.d).
b. Reserved
c. When choosing the above option of the existing type-certification basis, an applicant can
elect to comply with a specific certification specification or a subset of certification
specifications at later amendments. In such a case, the applicant should consult with the
Agency to ensure the type-certification basis includes other certification specifications
that are directly related. Some later certification specifications may be less restrictive;
therefore, the applicant may see advantage in using them on the elect to comply basis.
However, the applicant is recommended not to make a final decision until they have
learned from the Agency which other certification specifications are considered directly
related.
d. For a design change that contains features which are not covered in the proposed type-
certification basis, i.e. when the type-certification basis is not considered ‘adequate’ (see
the definition of ‘adequate type-certification basis’ in 1.d of Chapter 1, Section 4), the
Agency will designate the applicable certification specifications at the appropriate
amendment level, beginning with the existing type certification basis and progressing to
the most appropriate later amendment level for the change. For a change that contains
new design features that are novel or unusual, for which there is no later applicable
certification specification, the Agency will designate special conditions.
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Step 6.
For every area,
is the area affected
by the proposed
change?
a. A not affected An unaffected area is any area, system, part, or appliance that is not
affected by the proposed type design change. For a type design change, it is important
that the effects of such change on other areas, systems, parts, or appliances of the
product are properly assessed because areas that have not been physically changed
may still be considered part of the affected area. If a new compliance finding is required,
regardless of its amendment level, it is an affected area. If the significant change does
not affect the area, then the type-certification basis of that area does not need to be
revisited, in other words, the unaffected area continues to comply with the existing
amendment level without further substantiation.
b. To determine whether an area is affected or not, consider the following aspects of a type
design change:
(1) Physical aspects. The physical aspects include direct changes to structures,
systems, parts, and appliances (physical aspects may include software/airborne
electronic hardware changes and the resulting effect on systems functions).
(2) Performance/functional characteristics. The less obvious aspect of the word ‘areas’
covers general characteristics of the type-certificated product, such as
performance features, handling qualities, emergency egress, structural integrity,
aeroelastic characteristics, or crashworthiness. These characteristics may be
affected by a product level change. For example, adding a fuselage plug could
affect performance and handling qualities, and thus specifications associated with
these aspects would be considered part of the affected area. Another example is
the addition of a fuel tank and new fuel conditioning unit. This change affects the
fuel transfer and fuel quantity indication system resulting in the aeroplane’s
unchanged fuel tanks being affected. Thus, the entire fuel system (changed and
unchanged areas) becomes part of the affected area due to the change in
functional characteristics.
Note: Substantiating data for the affected area for a proposed type design change can
include compliance findings from a previously approved design change, in
supporting compliance findings for your proposal. However, your proposal to use
previously approved compliance data must be considered part of the entire
proposed type design change and should be approved as part of your proposed
design change.
c. All areas affected by the proposed design change must comply with the latest
certification specifications, unless the applicant can show that demonstrating compliance
with the latest amendment of a certification specification would not contribute to the level
of safety or would be impractical. Step 7 provides further explanation.
10. Step 7 of Figure 1. Are the latest certification specifications practical and do they
contribute materially to the level of safety? (21A.101(b)(3))
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Step 7.
Are the new
specifications practical
and do they contribute
materially to the level
of safety?
21.101(b)(3)
a. Contribute materially to the level of safety. Compliance with the latest certification
specifications could be considered not to contribute materially to the level of safety if the
existing type design and/or relevant experience demonstrates a level of safety
comparable to that provided by the latest certification specifications. The applicant should
provide sufficient justification to allow the Agency to make this determination. This
exception could be applicable in the situations described in the paragraphs below:
Note: Compliance with later certification specifications would not be required where the
amendment is of administrative nature and has been made only to correct
inconsequential errors or omissions, consolidate text, or clarify an existing
certification specification.
(1) Design features that exceed the existing type-certification basis specifications, but
do not meet the latest certification specifications, can be used as a basis for
granting an exception under the ‘does not contribute materially’ exception. These
design features, if accepted as a justification for an exception, must be
incorporated in the amended type design configuration and recorded in the TCDS
or STC, where necessary, as an integral part of the type-certification basis. For
1
example , an applicant proposes to install winglets on a Part-25 airplane. Part of
the design involves adding a small number of new wing fuel tank fasteners. The
latest § 25.981 at amendment 25-102 requires structural lightning protection. The
applicant proposes an exception from these latest structural lightning protection
requirements certification specifications because the design change uses new
wing fuel tank fasteners with cap seals installed. The cap seal is a design feature
that exceeds the requirement of § 25.981 at a previous amendment level, but does
not meet the latest amendment 25-102. If the applicant can successfully
substantiate that compliance with amendment 25-102 would not materially
increase the level of safety of the changed product, then this design feature can be
accepted as an exception to compliance with the latest amendment.
(2) Consistency of design should be considered when applying the latest certification
specifications. Below, an aeroplane example is provided for describing how this
provision may be used; however, the rationale in this example may be applied to
any product covered by this GM.
For example, when a small fuselage plug is added, additional seats and
overhead bins are likely to be installed, and the lower cargo hold extended.
These components may be identical to the existing components. The level
of safety may not materially increase by applying the latest certification
specifications.
1
This example is taken from the FAA experience gained prior to the Agency’s start, therefore the references to
the FAA sections and amendments are kept.
Page 62 of 264
SECTION A — Subpart D — Changes to type-certificates and restricted type certificates
utilisation over time (relevant flight hours or cycles), is one way of showing that a
later amendment may not contribute materially to the level of safety, so the use of
earlier certification specifications could be appropriate. Appendix C provides
additional guidance on the use of service experience, along with examples.
There may be cases for rotorcraft and small aeroplanes where relevant data
may not be sufficient or not available at all because of the reduced utilisation
and the different amount and type of data available. In such cases, other
service history information may provide sufficient data to justify the use of
earlier certification specifications, such as: warranty, repair, and parts usage
data; accident, incident, and service difficulty reports; Service Bulletins;
airworthiness directives; or other pertinent and sufficient data collected by
the manufacturers, authorities, or other entities.
The service experience levels necessary to demonstrate the appropriate
level of safety as they relate to the proposed design change would have to
be reviewed and agreed to by the Agency.
b. Impractical. Compliance with the latest certification specifications may be considered
impractical if the applicant can justify that it would result in additional resource
requirements that are not commensurate with the incremental safety benefit (difference
between the latest and the proposed type-certification basis). The additional resource
requirements could include those arising from design changes required for compliance
and the effort required to demonstrate compliance, but excludes resource expenditures
for prior product changes.
(1) The position that compliance is impractical should be supported with a
substantiating data and analyses. While evaluating the applicant’s position and
their substantiating data regarding impracticality, the Agency may consider other
factors (for example, the costs and safety benefits for a comparable new design).
(2) A review of large aeroplane projects showed that in certain cases, where an earlier
amendment to applicable certification specifications was allowed, design changes
were made to nearly comply with the latest amendments. In these cases, the
applicants were able to successfully demonstrate that full compliance would
require a substantial increase in the outlay or expenditure of resources with a very
small increase in the level of safety. These design features can be used as a basis
for granting an exception under the ‘impracticality’ exception.
(3) Appendix B provides additional guidance and examples for determining
procedures for evaluating impracticality of applying latest certification
specifications to a changed product rule.
a) The exception of impracticality is a qualitative and/or quantitative cost/safety
benefit assessment for which it is difficult to specify clear criteria. Experience
to date with applicants has shown that justification of impracticality is more
feasible when both applicant and authority agree at an earlier discussion
that the effort (in terms of cost, changes in manufacturing, etc.), required to
comply would not be commensurate with a small incremental safety gain.
This would be clear even without the need to perform any detailed
cost/safety benefit analysis (although cost analysis could always be used to
support an appropriate amendment level).
Note: The impractical exception should not be based on the size of the applicant’s
company or their financial resources. Costs to comply with a later
amendment should be evaluated against the safety benefit of complying with
the later amendment. Applicants that may not be able to afford the cost
because of reasons such as fewer resources, will not be granted the
impractical exception when the cost is comparable to the safety benefit
achieved by complying with a later amendment.
b) For example, a complex redesign of an area of the baseline aircraft may be
required to comply with a new certification specification, and that redesign
may make the changed product uncommon with respect to design and
Page 63 of 264
SECTION A — Subpart D — Changes to type-certificates and restricted type certificates
Step 8.
Is the proposed
TC basis
adequate?
a. Regardless of whether the change is significant or not, the applicant’s proposed type-
certification basis may be deemed inadequate – that is, the change includes features or
characteristics that were not foreseen during the initial (or previously approved) type-
certification. These features or characteristics, if not adequately addressed, may make
the product unsafe for the uses for which certification is requested. This would obstruct
issuance of the requested approval for the change. The change must comply with later
standards (such as, a later amendment or a special condition). An example is adding a
flight critical system such as an electronic air data display on PartCS-25 aeroplane
whose existing type-certification basis did not have lightning protection requirements
certification specifications. In this case, compliance with the certification specification for
lightning protection will be required, even though this is not a significant change.
b. In cases where inadequate or no airworthiness standards certification specifications exist
for the change in the proposed type-certification basis, but adequate standards exist in a
subsequent amendment of the applicable airworthiness code, the subsequent
amendment will be made part of the type-certification basis to assure its adequacy.
c. In cases where no adequate standard exists in any subsequent amendment of the
applicable airworthiness code because of one or more reasons specified in 21.A.16B(a),
the Agency will prescribe special conditions containing necessary safety standard per
21.A.16B(b). 21.A.101(d) allows for the application of special conditions, or for changes
to the existing special conditions, to address the changed designs where the proposed
type-certification basis does not provide adequate standards with respect to the proposed
change. Reference Section 3 of Chapter 4 for additional information pertaining to special
conditions.
d. Reserved
e. The final type-certification basis may consist of a combination of the certification
specifications of the applicable airworthiness code at different amendment levels ranging
from the original type-certification basis to the most current amendments, and special
conditions.
Page 64 of 264
SECTION A — Subpart D — Changes to type-certificates and restricted type certificates
The use of exceptions under 21.A.101 is not intended to alleviate or preclude compliance with
applicable operating rules or directives that prescribe compliance with the applicable additional
airworthiness (design-related) specifications for operations.
3. Special conditions, 21.A.101(d.101(d) allows for the application of special conditions, or for
changes to existing special conditions, to address the changed designs where the proposed
type-certification basis does not provide adequate standards for an area, system, part or
appliance related to the change and no adequate standard exist in any subsequent amendment
of the applicable airworthiness code up to the airworthiness code in effect on the date of the
application for the change. The objective is to achieve a level of safety consistent with that
provided for other areas, systems, parts or appliances affected by the change by the other
certification specifications of the proposed type-certification basis. The application of special
conditions to a design change is not, in itself, a reason for it to be classified as either a
substantial change or a significant change. When the change is significant with earlier
certification specifications allowed through exceptions, or not significant, the level of safety
intended by the special conditions should be consistent with the agreed type-certification basis.
Note that special conditions may also be applied under 21.A.16B when the intended use of the
changed product is unconventional or experience from other similar products in service or
products having similar design features has shown that unsafe conditions may develop.
Page 65 of 264
SECTION A — Subpart D — Changes to type-certificates and restricted type certificates
1. File a new application for a change to the type-certificate and comply with all the
provisions of paragraph 21.A.101 (a) applicable to an original application for a change; or
2. File for an extension of the original application and comply with the provisions of
paragraph (a) for an effective date of application, to be selected by the applicant, not
earlier than the date which precedes the date of approval of the change by the time
period established under this subparagraph for the original application for the change.
This is consistent with the requirements of 21.A.17 for a new TC and defines the process of
updating the type-certification basis if these time limits are exceeded.
6. Reserved
7. Documentation.
All changes that result in a revision to the product’s type-certification basis should be reflected
on the amended TC or STC. The resulting type-certification basis should be retained as it forms
part of the compliance record required by the applicable Agency’s internal working procedures.
Page 66 of 264
SECTION A — Subpart D — Changes to type-certificates and restricted type certificates
Page 67 of 264
SECTION A — Subpart D — Changes to type-certificates and restricted type certificates
The following examples are for SUBSTANTIAL changes for Small Aeroplanes (CS-23):
Description of Is there a change Is there a change Have the Notes
change to the general to the principles of assumptions used
construction? for certification
configuration?
21.A.101(b)(1)(i) been invalidated?
21.A.101(b)(1)(i) 21.A.101(b)(1(ii)
Change in wing N/A N/A N/A Proposed change in
location (tandem, design is so
forward, canard, extensive that a
high/low)
substantially
complete
investigation of
compliance with the
applicable
requirementscertificat
ion specifications is
required.
Fixed wing to tilt N/A N/A N/A Proposed change in
wing design is so
extensive that a
substantially
complete
investigation of
compliance with the
applicable
requirementscertificat
ion specifications is
required.
Increase or N/A N/A N/A Proposed change in
decrease in the design is so
number of engines
extensive that a
substantially
complete
investigation of
compliance with the
applicable
requirementscertificat
ion specifications is
required.
Replacement of N/A N/A N/A Proposed change in
piston or turbo-prop design is so
engines with
extensive that a
turbojet or turbofan
engines substantially
complete
investigation of
compliance with the
applicable
requirementscertificat
ion specifications is
required.
Change in engine N/A N/A N/A Proposed change in
configuration design is so
(tractor to pusher) extensive that a
Page 68 of 264
SECTION A — Subpart D — Changes to type-certificates and restricted type certificates
The following examples are for SUBSTANTIAL changes for Small Aeroplanes (CS-23):
Description of Is there a change Is there a change Have the Notes
change to the general to the principles of assumptions used
construction? for certification
configuration?
21.A.101(b)(1)(i) been invalidated?
21.A.101(b)(1)(i) 21.A.101(b)(1(ii)
substantially
complete
investigation of
compliance with the
applicable
requirementscertificat
ion specifications is
required.
Change from an N/A N/A N/A Proposed change in
all metal design is so
aeroplane to all extensive that a
composite substantially
primary structure complete
(fuselage, wing, investigation of
empennage). compliance with the
applicable
requirementscertificat
ion specifications is
required.
Increase from N/A N/A N/A Proposed change in
subsonic to design is so
supersonic flight extensive that a
regime substantially
complete
investigation of
compliance with the
applicable
requirementscertificat
ion specifications is
required.
The following examples are for SIGNIFICANT changes for Small Aeroplanes (CS-23):
Description of Is there a Change to Is there a Change to Have the Notes
change the General the Principles of assumptions used
Construction? for Certification
Configuration?
21.A.101(b)(1)(i) been invalidated?
21.A.101(b)(1)(i) 21.A.101(b)(1(ii)
Conventional tail to Yes No Yes Change in general
T-tail or Y-tail, or configuration.
vice versa Requires extensive
structural, flying
qualities and
performance
re-investigation.
Requires a new AFM
to address
performance and
flight characteristics.
Page 69 of 264
SECTION A — Subpart D — Changes to type-certificates and restricted type certificates
The following examples are for SIGNIFICANT changes for Small Aeroplanes (CS-23):
Description of Is there a Change to Is there a Change to Have the Notes
change the General the Principles of assumptions used
Construction? for Certification
Configuration?
21.A.101(b)(1)(i) been invalidated?
21.A.101(b)(1)(i) 21.A.101(b)(1(ii)
Changes in wing Yes No Yes Change in general
configuration such configuration. Likely
as change in
requires extensive
dihedral, or changes
changes to wing
in wing span, flap or
aileron span, structure.
addition of winglets, Requires a new AFM
or increase of more to address
than 10% of the performance and
original wing sweep flight characteristics.
at the quarter chord Note: Small changes
to wingtip are not
significant changes.
See table for not
significant changes.
Page 70 of 264
SECTION A — Subpart D — Changes to type-certificates and restricted type certificates
The following examples are for SIGNIFICANT changes for Small Aeroplanes (CS-23):
Description of Is there a Change to Is there a Change to Have the Notes
change the General the Principles of assumptions used
Construction? for Certification
Configuration?
21.A.101(b)(1)(i) been invalidated?
21.A.101(b)(1)(i) 21.A.101(b)(1(ii)
is expanded flight characteristics.
Page 71 of 264
SECTION A — Subpart D — Changes to type-certificates and restricted type certificates
The following examples are for SIGNIFICANT changes for Small Aeroplanes (CS-23):
Description of Is there a Change to Is there a Change to Have the Notes
change the General the Principles of assumptions used
Construction? for Certification
Configuration?
21.A.101(b)(1)(i) been invalidated?
21.A.101(b)(1)(i) 21.A.101(b)(1(ii)
performance and
flight characteristics.
Page 72 of 264
SECTION A — Subpart D — Changes to type-certificates and restricted type certificates
The following examples are for SIGNIFICANT changes for Small Aeroplanes (CS-23):
Description of Is there a Change to Is there a Change to Have the Notes
change the General the Principles of assumptions used
Construction? for Certification
Configuration?
21.A.101(b)(1)(i) been invalidated?
21.A.101(b)(1)(i) 21.A.101(b)(1(ii)
certification
assumptions and the
fundamental
approach used in
decompression,
structural strength,
and fatigue.
Page 73 of 264
SECTION A — Subpart D — Changes to type-certificates and restricted type certificates
The following examples are for SIGNIFICANT changes for Small Aeroplanes (CS-23):
Description of Is there a Change to Is there a Change to Have the Notes
change the General the Principles of assumptions used
Construction? for Certification
Configuration?
21.A.101(b)(1)(i) been invalidated?
21.A.101(b)(1)(i) 21.A.101(b)(1(ii)
originally designed is
generally not a
significant change. In
this case, the
assumptions used for
certification of the
basic product remain
valid and the results
can be applied to
cover the changed
product with
predictable effects or
can be demonstrated
without significant
changes to the
product.
Page 74 of 264
SECTION A — Subpart D — Changes to type-certificates and restricted type certificates
The following examples are for SIGNIFICANT changes for Small Aeroplanes (CS-23):
Description of Is there a Change to Is there a Change to Have the Notes
change the General the Principles of assumptions used
Construction? for Certification
Configuration?
21.A.101(b)(1)(i) been invalidated?
21.A.101(b)(1)(i) 21.A.101(b)(1(ii)
re-evaluation of
certification design
assumptions.
Page 75 of 264
SECTION A — Subpart D — Changes to type-certificates and restricted type certificates
The following examples are for NOT SIGNIFICANT changes for Small Aeroplanes (CS-23):
Description of change Is there a Is there a Change Have the Notes
Change to the to the Principles of assumptions used
Construction? for Certification
General
21.A.101(b)(1)(i) been invalidated?
Configuration? 21.A.101(b)(1(ii)
21.A.101(b)(1)(i)
Addition of wingtip No No No Although a major
modifications (not change to the
winglets)
aeroplane, likely the
original general
configuration,
principles of
construction and
certification
assumptions remain
valid.
Addition of a turbo- No No No
charger that does not
appreciably change the
power envelope,
Page 76 of 264
SECTION A — Subpart D — Changes to type-certificates and restricted type certificates
The following examples are for NOT SIGNIFICANT changes for Small Aeroplanes (CS-23):
Description of change Is there a Is there a Change Have the Notes
Change to the to the Principles of assumptions used
Construction? for Certification
General
21.A.101(b)(1)(i) been invalidated?
Configuration? 21.A.101(b)(1(ii)
21.A.101(b)(1)(i)
operating range, or
limitations (e.g., a
turbo—normalised
engine), (e.g., where
the additional power is
used to enhance high
altitude or hot day
performance)
Substitution of one No No No
method of bonding for
another (e.g., change in
type of adhesive)
Substitution of one type No No No
of metal for another
Any change in No No No
construction or
fastening not involving
primary structure
A new fabric type for No No No
fabric skinned aircraft
Increase in flap speed No No No Although a major
or undercarriage limit change to the
speed
aeroplane, likely the
original general
configuration,
principles of
construction and
certification
assumptions remain
valid.
Page 77 of 264
SECTION A — Subpart D — Changes to type-certificates and restricted type certificates
The following examples are for NOT SIGNIFICANT changes for Small Aeroplanes (CS-23):
Description of change Is there a Is there a Change Have the Notes
Change to the to the Principles of assumptions used
Construction? for Certification
General
21.A.101(b)(1)(i) been invalidated?
Configuration? 21.A.101(b)(1(ii)
21.A.101(b)(1)(i)
Fuel lines, where No No No
engine horsepower is
increased but fuel flow
is not increased beyond
the certified maximum
amount
Fuel tanks, where fuel No No No
is changed from
gasoline to diesel fuel
and tank support loads
are small enough that
an extrapolation from
the previous analysis
would be valid.
Chemical compatibility
would have to be
substantiated.
Limited changes in a No No No Although a major
pressurisation system, change to the
e.g., number of outflow aeroplane, likely the
valves, type of
controller, or size of original general
pressurised configuration,
compartment, but the principles of
system must be re- construction and
substantiated if the certification
original test data is assumptions remain
invalidated.
valid.
Page 78 of 264
SECTION A — Subpart D — Changes to type-certificates and restricted type certificates
The following examples are for NOT SIGNIFICANT changes for Small Aeroplanes (CS-23):
Description of change Is there a Is there a Change Have the Notes
Change to the to the Principles of assumptions used
Construction? for Certification
General
21.A.101(b)(1)(i) been invalidated?
Configuration? 21.A.101(b)(1(ii)
21.A.101(b)(1)(i)
FuelsChanging fuels of No No No Although a major
substantially the same change to the
type: Such as AvGas to
aeroplane, likely the
AutoGas, AvGas
(80/87) to AvGas original general
(100LL), Ethanol to configuration,
Isopropyl Alcohol, Jet B principles of
to Jet A (although Jet A construction and
to Jet B may be certification
considered significant assumptions remain
due to the fact that Jet
valid.
B is considered
potentially more
explosive).
Fuels that specify No No No Although a major
different levels of change to the
‘conventional’ fuel
aeroplane, likely the
additives that do not
change the primary fuel original general
type. Different additive configuration,
levels (controlled) of principles of
additives (MTBE, construction and
ETBE, ethanol, amines, certification
etc.) in AvGas would assumptions remain
not be considered a
valid.
significant change.
A change to the No No No Although a major
maximum take-off change to the
weight of less than 5 % aeroplane, likely the
unless assumptions
made in justification of original general
the design are thereby configuration,
invalidated principles of
construction and
certification
assumptions remain
valid. (Unless this
weight increase
would result in a
shift to commuter
category.)
Page 79 of 264
SECTION A — Subpart D — Changes to type-certificates and restricted type certificates
The following examples are for NOT SIGNIFICANT changes for Small Aeroplanes (CS-23):
Description of change Is there a Is there a Change Have the Notes
Change to the to the Principles of assumptions used
Construction? for Certification
General
21.A.101(b)(1)(i) been invalidated?
Configuration? 21.A.101(b)(1(ii)
21.A.101(b)(1)(i)
control cables with no
change in routing, or
other system design
Autopilot installation No No No Although a major
(for Instrument Flight change to the
Rules (IFR) use, where aeroplane, likely the
the original certification
does not indicate that original general
the aeroplane is not configuration,
suitable as an IFR principles of
platform) construction and
certification
assumptions remain
valid.
Increased battery No No No
capacity or relocate
battery
Replace generator with No No No
alternator
Additional lighting (e.g., No No No
navigation lights,
strobes)
Higher capacity brake No No No
assemblies
Increase in fuel tank No No No Not a product level
capacity change, unless it is
tied with an increase
in gross weight.
Addition of an oxygen No No No
system
Relocation of a galley. No No No
Page 80 of 264
SECTION A — Subpart D — Changes to type-certificates and restricted type certificates
The following examples are for NOT SIGNIFICANT changes for Small Aeroplanes (CS-23):
Description of change Is there a Is there a Change Have the Notes
Change to the to the Principles of assumptions used
Construction? for Certification
General
21.A.101(b)(1)(i) been invalidated?
Configuration? 21.A.101(b)(1(ii)
21.A.101(b)(1)(i)
New cabin interior with No No No
no fuselage length
change
Installation of new seat No No No
belt or shoulder
harness
A small increase in CG No No No At product level, no
range change in general
configuration,
principles of
construction &
certification
assumptions.
An alternative autopilot No No No
Addition of Class B No No No
Terrain Awareness and
Warning Systems
(TAWS)
Page 81 of 264
SECTION A — Subpart D — Changes to type-certificates and restricted type certificates
The following examples are for SUBSTANTIAL changes for Large Aeroplanes (CS-25):
Description of Is there a Is there a Change Have the Notes
change Change to the to the Principles of assumptions used
Construction? for Certification
General
21.A.101(b)(1)(i) been invalidated?
Configuration? 21.A.101(b)(1(ii)
21.A.101(b)(1)(i)
Change in the number N/A N/A N/A Proposed change in
or location of engines, design is so
e.g., four to two wing- extensive that a
mounted engines or
two wing-mounted to substantially
two body-mounted complete
engines investigation of
compliance with the
applicable
requirementscertificati
on specifications is
required.
Page 82 of 264
SECTION A — Subpart D — Changes to type-certificates and restricted type certificates
The following examples are for SUBSTANTIAL changes for Large Aeroplanes (CS-25):
Description of Is there a Is there a Change Have the Notes
change Change to the to the Principles of assumptions used
Construction? for Certification
General
21.A.101(b)(1)(i) been invalidated?
Configuration? 21.A.101(b)(1(ii)
21.A.101(b)(1)(i)
subsonic to supersonic design is so
flight regime extensive that a
substantially
complete
investigation of
compliance with the
applicable
regulationscertificatio
n specifications is
required.
The following examples are for SIGNIFICANT changes for Large Aeroplanes (CS-25):
Description of Is there a Is there a Change Have the Notes
change Change to the to the Principles of assumptions used
Construction? for Certification
General
21.A.101(b)(1)(i) been invalidated?
Configuration? 21.A.101(b)(1(ii)
21.A.101(b)(1)(i)
Reduction in the Yes No NoYes Extensive changes
number of flight crew to avionics and
(In conjunction with
aircraft systems.
flight deck update)
Impact to crew
workload and
human factors, pilot
type rating.
Page 83 of 264
SECTION A — Subpart D — Changes to type-certificates and restricted type certificates
The following examples are for SIGNIFICANT changes for Large Aeroplanes (CS-25):
Description of Is there a Is there a Change Have the Notes
change Change to the to the Principles of assumptions used
Construction? for Certification
General
21.A.101(b)(1)(i) been invalidated?
Configuration? 21.A.101(b)(1(ii)
21.A.101(b)(1)(i)
Increase in cabin No No Yes Typically, a change
pressurisation system. greater than 10 % in
operational cabin
pressure differential.
May require
extensive airframe
changes affecting
load paths, fatigue
evaluation,
aeroelastic
characteristics, etc.
Invalidates design
assumptions.
Addition of leading Yes No No Requires extensive
edge slats changes to wing
structure, adds
aircraft level
systems, and
requires a new AFM
to address
performance and
flight characteristics.
Page 84 of 264
SECTION A — Subpart D — Changes to type-certificates and restricted type certificates
The following examples are for SIGNIFICANT changes for Large Aeroplanes (CS-25):
Description of Is there a Is there a Change Have the Notes
change Change to the to the Principles of assumptions used
Construction? for Certification
General
21.A.101(b)(1)(i) been invalidated?
Configuration? 21.A.101(b)(1(ii)
21.A.101(b)(1)(i)
large opening in aircraft level
fuselage systems, and
requires a new
aeroplane flight
manual to address
performance and
flight characteristics.
Page 85 of 264
SECTION A — Subpart D — Changes to type-certificates and restricted type certificates
The following examples are for SIGNIFICANT changes for Large Aeroplanes (CS-25):
Description of Is there a Is there a Change Have the Notes
change Change to the to the Principles of assumptions used
Construction? for Certification
General
21.A.101(b)(1)(i) been invalidated?
Configuration? 21.A.101(b)(1(ii)
21.A.101(b)(1)(i)
flight characteristics.
(NOTE: Potentially
substantial if it is a
change from a high
wing to a low wing,
or a new wing.)
Change in type or Yes No Yes The new emergency
number of emergency egress
exits or an increase in
requirementscertificati
the maximum
certificated number of on specifications
passengers exceed those
demonstrated previously
substantiated.
Page 86 of 264
SECTION A — Subpart D — Changes to type-certificates and restricted type certificates
The following examples are for SIGNIFICANT changes for Large Aeroplanes (CS-25):
Description of Is there a Is there a Change Have the Notes
change Change to the to the Principles of assumptions used
Construction? for Certification
General
21.A.101(b)(1)(i) been invalidated?
Configuration? 21.A.101(b)(1(ii)
21.A.101(b)(1)(i)
to address
performance and
flight characteristics.
Page 87 of 264
SECTION A — Subpart D — Changes to type-certificates and restricted type certificates
The following examples are for SIGNIFICANT changes for Large Aeroplanes (CS-25):
Description of Is there a Is there a Change Have the Notes
change Change to the to the Principles of assumptions used
Construction? for Certification
General
21.A.101(b)(1)(i) been invalidated?
Configuration? 21.A.101(b)(1(ii)
21.A.101(b)(1)(i)
is generally not a
significant change.
In this case, the
assumptions used
for certification of
the basic product
remain valid and the
results can be
applied to cover the
changed product
with predictable
effects or can be
demonstrated
without significant
physical changes to
the product.
Conversion from a No No Yes Completely new
passenger floor to a floor loading and
cargo floor and design.
installation of a cargo
handling system Redistribution of
internal loads,
change in cabin
safety
requirementscertificati
on specifications,
system changes.
Page 88 of 264
SECTION A — Subpart D — Changes to type-certificates and restricted type certificates
The following examples are for SIGNIFICANT changes for Large Aeroplanes (CS-25):
Description of Is there a Is there a Change Have the Notes
change Change to the to the Principles of assumptions used
Construction? for Certification
General
21.A.101(b)(1)(i) been invalidated?
Configuration? 21.A.101(b)(1(ii)
21.A.101(b)(1)(i)
The following examples are for NOT SIGNIFICANT changes for Large Aeroplanes (CS-25):
Description of Is there a Is there a Change Have the Notes
change Change to the to the Principles of assumptions used
Construction? for Certification
General
21.A.101(b)(1)(i) been invalidated?
Configuration? 21.A.101(b)(1(ii)
21.A.101(b)(1)(i)
Alternate engine No No No Typically it is not
installation or hush kit significant so long
at same position as there is not more
than a 10% increase
in thrust or a change
in the principles of
propulsion.
Page 89 of 264
SECTION A — Subpart D — Changes to type-certificates and restricted type certificates
The following examples are for NOT SIGNIFICANT changes for Large Aeroplanes (CS-25):
Description of Is there a Is there a Change Have the Notes
change Change to the to the Principles of assumptions used
Construction? for Certification
General
21.A.101(b)(1)(i) been invalidated?
Configuration? 21.A.101(b)(1(ii)
21.A.101(b)(1)(i)
assumptions.
Initial installation of an No No See note It may be possible
autopilot system that the modification
is adaptive in
nature, with no
change to original
certification
assumptions.
However, in certain
cases the
installation of an
auto-pilot may
include extensive
changes and design
features which
change the
assumptions for
certification (i.e.
installation of the
auto-pilot may
introduce a number
of additional
mechanical and
electronic failure
modes and change
the hazard
classification of
given aircraft level
failures).
Page 90 of 264
SECTION A — Subpart D — Changes to type-certificates and restricted type certificates
The following examples are for NOT SIGNIFICANT changes for Large Aeroplanes (CS-25):
Description of Is there a Is there a Change Have the Notes
change Change to the to the Principles of assumptions used
Construction? for Certification
General
21.A.101(b)(1)(i) been invalidated?
Configuration? 21.A.101(b)(1(ii)
21.A.101(b)(1)(i)
aeroplane.
Page 91 of 264
SECTION A — Subpart D — Changes to type-certificates and restricted type certificates
The following examples are for NOT SIGNIFICANT changes for Large Aeroplanes (CS-25):
Description of Is there a Is there a Change Have the Notes
change Change to the to the Principles of assumptions used
Construction? for Certification
General
21.A.101(b)(1)(i) been invalidated?
Configuration? 21.A.101(b)(1(ii)
21.A.101(b)(1)(i)
APU would be an
option to be
independent of
airport power.
Page 92 of 264
SECTION A — Subpart D — Changes to type-certificates and restricted type certificates
The following examples are for SUBSTANTIAL changes for Rotorcraft (CS-27 and CS-29):
Description of Is there a Is there a Change Have the Notes
change Change to the to the Principles of assumptions used
Construction? for Certification
General
21.A.101(b)(1)(i) been invalidated?
Configuration? 21.A.101(b)(1(ii)
21.A.101(b)(1)(i)
Change from the N/A N/A N/A Proposed change in
number and/or design is so
configuration of rotors extensive that a
(e.g. main & tail rotor
system to two main substantially
rotors complete
investigation of
compliance with the
applicable
requirementscertificati
on specifications is
required.
The following examples are for SIGNIFICANT changes for Rotorcraft (CS-27 and CS-29):
Description of Is there a Is there a Change Have the Notes
change Change to the to the Principles of assumptions used
Construction? for Certification
General
21.A.101(b)(1)(i) been invalidated?
Configuration? 21.A.101(b)(1(ii)
21.A.101(b)(1)(i)
Comprehensive flight No No Yes Affects basic
deck upgrade, such as avionics and
conversion from electrical systems
entirely federated,
independent electro- integration and
mechanical flight architecture
instruments to highly concepts and
integrated and philosophies.
combined electronic
display systems with
extensive use of
software and/or
complex electronic
hardware
Certification for flight No No Yes
into known icing
conditions
Page 93 of 264
SECTION A — Subpart D — Changes to type-certificates and restricted type certificates
The following examples are for SIGNIFICANT changes for Rotorcraft (CS-27 and CS-29):
Description of Is there a Is there a Change Have the Notes
change Change to the to the Principles of assumptions used
Construction? for Certification
General
21.A.101(b)(1)(i) been invalidated?
Configuration? 21.A.101(b)(1(ii)
21.A.101(b)(1)(i)
(Fixed) flying controls No No Yes This drives a
from mechanical to fly complete re-
by wire
assessment of the
rotorcraft
controllability and
flight control failure.
Page 94 of 264
SECTION A — Subpart D — Changes to type-certificates and restricted type certificates
The following examples are for SIGNIFICANT changes for Rotorcraft (CS-27 and CS-29):
Description of Is there a Is there a Change Have the Notes
change Change to the to the Principles of assumptions used
Construction? for Certification
General
21.A.101(b)(1)(i) been invalidated?
Configuration? 21.A.101(b)(1(ii)
21.A.101(b)(1)(i)
typically considered
a significant
change .
Page 95 of 264
SECTION A — Subpart D — Changes to type-certificates and restricted type certificates
The following examples are for SIGNIFICANT changes for Rotorcraft (CS-27 and CS-29):
Description of Is there a Is there a Change Have the Notes
change Change to the to the Principles of assumptions used
Construction? for Certification
General
21.A.101(b)(1)(i) been invalidated?
Configuration? 21.A.101(b)(1(ii)
21.A.101(b)(1)(i)
specifications in
order to obtain
operational
approval. HEC
include fatigue,
Quick Release
Systems, High
Intensity Radio
Frequency (HIRF),
One Engine
Inoperative (OEI)
performance and
OEI procedures.
The following examples are for NOT SIGNIFICANT changes for Rotorcraft (CS-27 and -29):
Description of Is there a Is there a Change Have the Notes
change Change to the to the Principles of assumptions used
Construction? for Certification
General
21.A.101(b)(1)(i) been invalidated?
Configuration? 21.A.101(b)(1(ii)
21.A.101(b)(1)(i)
Emergency floats No No No Must comply with
the specific
applicable
requirementscertifica
tion specifications
for emergency
floats. This
installation, in itself,
does not change
the rotorcraft
configuration,
overall
performance, or
operational
capability.
Expanding an
operating envelope
(such as operating
altitude and
temperature) and
mission profile
Page 96 of 264
SECTION A — Subpart D — Changes to type-certificates and restricted type certificates
The following examples are for NOT SIGNIFICANT changes for Rotorcraft (CS-27 and -29):
Description of Is there a Is there a Change Have the Notes
change Change to the to the Principles of assumptions used
Construction? for Certification
General
21.A.101(b)(1)(i) been invalidated?
Configuration? 21.A.101(b)(1(ii)
21.A.101(b)(1)(i)
(such as passenger
carrying operations
to external load
operations, or flight
over water, or
operations in snow
conditions) are not
by themselves so
different that the
original certification
assumptions are no
longer valid at the
type-certificated
product level.
Page 97 of 264
SECTION A — Subpart D — Changes to type-certificates and restricted type certificates
The following examples are for NOT SIGNIFICANT changes for Rotorcraft (CS-27 and -29):
Description of Is there a Is there a Change Have the Notes
change Change to the to the Principles of assumptions used
Construction? for Certification
General
21.A.101(b)(1)(i) been invalidated?
Configuration? 21.A.101(b)(1(ii)
21.A.101(b)(1)(i)
Page 98 of 264
SECTION A — Subpart D — Changes to type-certificates and restricted type certificates
The following examples are for NOT SIGNIFICANT changes for Rotorcraft (CS-27 and -29):
Description of Is there a Is there a Change Have the Notes
change Change to the to the Principles of assumptions used
Construction? for Certification
General
21.A.101(b)(1)(i) been invalidated?
Configuration? 21.A.101(b)(1(ii)
21.A.101(b)(1)(i)
change the
rotorcraft
configuration,
overall
performance, or
operational
capability.
Expanding an
operating envelope
(such as operating
altitude and
temperature) and
mission profile
(such as passenger
carrying operations
to external load
operations, or flight
over water, or
operations in snow
conditions) are not
by themselves so
different that the
original certification
assumptions are no
longer valid at the
type-certificated
product level.
Page 99 of 264
SECTION A — Subpart D — Changes to type-certificates and restricted type certificates
complete
investigation of
compliance with the
applicable
regulationscertificatio
n specifications is
required.
Changes to
principles of
construction: Digital
controllers and
sensors require new
construction
techniques and
environmental
testing.
Add turbocharger that Yes No Yes Change in general
increases performance configuration:
Certification
assumptions
invalidated: Change
in operating
envelope and
performance.
Convert from air- Yes No Yes Change in general
cooled cylinders to configuration:
liquid cooled cylinders. Installation interface
of engine changed
(cooling lines from
radiator, change to
cooling baffles).
Certification
assumptions
invalidated:
Change in operating
envelope and
engine temperature
requirements.
specifications.
Convert from spark- Yes No Yes Change in general
ignition to configuration:
compression-ignition Installation interface
of engine changed
(no mixture lever).
Certification
assumptions
invalidated: Change
in operating
envelope and
performance.
The following are examples of NOT SIGNIFICANT changes for Engines (CS-E):
Description of change Is there a Is there a change Have the Notes
change to the to the principles assumptions used
of construction? for certification
general
21.A.101(b)(1)(i) been invalidated?
configuration? 21.A.101(b)(1)(ii)
21.A.101(b)(1)(i)
Turbine Engines
The following are examples of NOT SIGNIFICANT changes for Engines (CS-E):
Description of change Is there a Is there a change Have the Notes
change to the to the principles assumptions used
of construction? for certification
general
21.A.101(b)(1)(i) been invalidated?
configuration? 21.A.101(b)(1)(ii)
21.A.101(b)(1)(i)
Possible changes in
principles of
construction are
insignificant.
Software changes No No No
Rub-strip design No No No
changes
A new combustor that No No No
does not change the
approved limitations, or
dynamic behaviour*
(* excludes life limits)
Bearing changes No No No
The following are examples of NOT SIGNIFICANT changes for Engines (CS-E):
Description of change Is there a Is there a change Have the Notes
change to the to the principles assumptions used
of construction? for certification
general
21.A.101(b)(1)(i) been invalidated?
configuration? 21.A.101(b)(1)(ii)
21.A.101(b)(1)(i)
changes
Bump ratings within the No No No
product’s physical
capabilities that may be
enhanced with gas path
changes such as blade
re-stagger, cooling hole
patterns, blade coating
changes, etc.
A change in principal No No No
physical properties and
mechanics of load
transfer of a material of
primary structure or
highly loaded
components. For
example, change from
traditional metal to either
an exotic alloy or a
composite material on a
highly loaded
component.
Piston engine
A change in principal No No No
physical properties and
mechanics of load
transfer of a material of
primary structure or
highly loaded
components. For
example, change from
traditional metal to either
an exotic alloy or a
composite material on a
highly loaded
component.
New or redesigned No No No
cylinder head, or valves
or pistons.
Changes in crankshaft No No No
Changes in crankcase No No No
Changes in carburettor No No No
Changes in mechanical No No No
fuel injection system
Changes in mechanical No No No
fuel injection pump
Engine model change to No No No
accommodate new
The following are examples of NOT SIGNIFICANT changes for Engines (CS-E):
Description of change Is there a Is there a change Have the Notes
change to the to the principles assumptions used
of construction? for certification
general
21.A.101(b)(1)(i) been invalidated?
configuration? 21.A.101(b)(1)(ii)
21.A.101(b)(1)(i)
aeroplane installation.
No change in principles
of operation of major
subsystems; no
significant expansion in
power or operating
envelopes or in
limitations.
No change in basic No No No
principles of operation,
or a simple mechanical
change. For example,
change from dual
magneto to two single
magnetos on a model.
Subsystem change No No No
produces no changes in
base engine input
parameters, and
previous analysis can be
reliably extended.
For example, a change
in turbocharger where
induction system inlet
conditions remain
unchanged, or if
changed, the effects can
be reliably extrapolated.
Change in material of No No No Component Level
secondary structure or Change
not highly loaded
component. For
example, a change from
metal to composite
material in a non-highly
loaded component, such
as an oil pan that is not
used as a mount pad.
Change in material that No No No Component Level
retains the physical Change
properties and
mechanics of load
transfer. For example, a
change in trace
elements in a metal
casting for ease of
pouring or to update to a
newer or more readily
available alloy with
similar mechanical
properties.
Assumptions used
for certification are
no longer valid or
were not addressed
in the original
certification, i.e.,
high intensity radio
frequency (HIRF)
and lightning
protection, fault
tolerance, software
certification and
other aspects.
The propeller will
require special
conditions under
21.A.16B.
The following are examples of NOT SIGNIFICANT changes for Propellers (CS-P):
Description of Is there a Is there a Change Have the Notes
change Change to the to the Principles of assumptions used
Construction? for Certification
General
21.A.101(b)(1)(i) been invalidated?
Configuration? 21.A.101(b)(1(ii)
21.A.101(b)(1)(i)
Change in the material No No No
of a blade bearing
Change to a No No No
component in the
control system
Change to a de-icer No No No
boot
Changes to the No No No Propeller's operating
operational design characteristics and
envelope such as an inherent strength
increase in power.
require re-
evaluation.
1. Introduction
a. The basic principle of enhancing the level of safety of changed aeronautical products is
to apply the latest certification specifications for significant design changes to the
greatest extent practical. In certain cases, the cost of complying fully with a later
certification specification may not be commensurate with the small safety benefit
achieved. It is recognised that the existing fleet and newly produced aeroplanes, engines
and propellers are safe, and any unsafe condition is immediately addressed through the
airworthiness directive process. These factors form the basis where compliance with the
latest certification specification may be considered impractical, thereby allowing
compliance with an earlier certification specification. This appendix gives one method of
determining if compliance with a later requirement standard is impractical; however, this
does not preclude the use of other methods for improving the safety of aeronautical
products.
b. This GM recognises that other procedures can be used and have historically been
accepted on a case-by-case basis. The acceptance of results through the use of these
procedures may vary from state to state. Consequently, they may not be accepted
through all bilateral certification processes. Regardless of which method is used, the
process should show that a proposed type-certification basis is able to achieve a positive
safety benefit for the overall product.
c. In this regard, any method used should encourage incorporating safety enhancements
that will have the most dramatic impact on the level of safety of the aircraft while
considering effective use of resources. This important point is illustrated graphically in the
accompanying figure. This figure notionally shows the interrelation between the total
resources required for incorporating each potential safety enhancement with the
corresponding net increase in safety benefit.
Resources to
implement the
certification
specification
d. Typically, one will find that there are proposals that can achieve a positive safety benefit
and that are resource effective. Conversely, there are proposals that may achieve a small
safety benefit at the expense of a large amount of resources to implement. Clearly, there
will be a point where a large percentage of the potential safety benefit can be achieved
with a reasonable expenditure of resources. The focus of the methods used should be to
determine the most appropriate standards relative to the respective cost to reach this
point.
e. This Appendix to GM 21.A.101 provides procedural guidance for determining the
practicality of applying a certification specification at a particular amendment level to a
changed product. This guidance can be used to evaluate the safety benefit and resource
impact of implementing the latest airworthiness certification specifications in the type-
certification basis of a changed product. The procedure is generic in nature and
describes the steps and necessary inputs that any applicant can use on any project to
develop a position.
f. The procedure is intended to be used, along with good engineering judgment, to evaluate
the relative merits of a changed product complying with the latest certification
specifications. It provides a means, but not the only means, for an applicant to present its
position in regard to impracticality.
g. The type-certification basis for a change to a product will not be at an amendment level
earlier than the existing type-certification basis. Therefore, when determining the
impracticality of applying a certification specification at the latest amendment level, only
the increase in safety benefits and costs beyond compliance with the existing type-
certification basis should be considered.
The following are steps to determine the impracticality of applying a certification specification at
a particular amendment level. The first step will be to identify the regulatory change being
evaluated.
a. Step 1: Identify the regulatory change being evaluated.
In this step, it will be necessary to document:
(1) The specific certification specification (for example, CS 25.365);
(2) The amendment level of the existing type-certification basis for the certification
specification; and
(3) The latest amendment level of the certification specification.
b. Step 2: Identify the specific hazard that the Requirement certification specification
addresses
(1) Each certification specification and subsequent amendments are intended to
address a hazard or hazards. In this step the specific hazard(s) is/are identified.
This identification will allow for a comparison of the effectiveness of amendment
levels of the certification specification at addressing the hazard.
(2) In many cases the hazard and the cause of the hazard will be obvious. When the
hazard and its related cause are not immediately obvious, it may be necessary to
review the available background information from development and adoption of
this certification specification (Explanatory Note and Comment/Response
Document to the NPA. It may also be helpful to discuss the hazard with the
Agency).
c. Step 3: Review the consequences of the hazard(s)
(1) Once the hazard has been identified, it is possible to identify the types of
consequences that may occur because of the presence of the hazard. More than
one consequence can be attributed for the same hazard. Typical examples of
consequences would include, but are not be limited to:
• Incidents where only injuries occurred;
• Accidents where less than 10 % of the passengers died;
• Accidents where 10 % or more passengers died; and
• Accidents where a total hull loss occurred.
(2) The background information from development and adoption of the certification
specification may provide useful information regarding the consequences of the
hazard the requirement is intended to address.
e. Step 5: Determine how effective full compliance with the latest amendment of the
Requirement certification specification would be at addressing the hazard
(1) When each amendment is promulgated, it is usually expected that compliance with
the certification specification would be completely effective at addressing the
associated hazard. It is expected that the hazard would be eliminated, avoided, or
dealt with. However, in a limited number of situations, this may not be the case. It
is also possible that earlier amendment levels may have addressed the hazard but
were not completely effective. Therefore, in comparing the benefits of compliance
with the existing type-certification basis to the latest amendment level, it is useful
to estimate the effectiveness of both amendment levels in dealing with the hazard.
(2) It is recognised that the determination of levels of effectiveness is normally of a
subjective nature. These are relative assessments of a qualitative nature that
should not be treated as absolute determinations. Therefore, prudence should be
exercised when making these determinations. In all cases, it is necessary to
document the assumptions and data that support the determination.
(3) The following five levels of effectiveness are provided as a guideline:
(a) Fully effective in all cases.
Compliance with the requirement certification specification eliminates the
hazard or provides a means to avoid the hazard completely.
(b) Considerable potential for eliminating or avoiding the hazard.
Compliance with the requirement certification specification eliminates the
hazard or provides a means to avoid completely the hazard for all probable
or likely cases, but it does not cover all situations or scenarios.
(c) Adequately deals with the hazard.
(4) Step 2: Identify the specific hazard that the Regulation certification specification
addresses
Fuel tank access covers have failed in service due to impact with high-energy
objects such as failed tire tread material and engine debris following engine
failures. In one accident, debris from the runway impacted a fuel tank access cover,
causing its failure and subsequent fire, which resulted in fatalities and loss of the
aeroplane. Amendment 3 ensures that all access covers on all fuel tanks are
designed or located to minimise penetration by likely foreign objects, and are fire
resistant.
(5) Step 3: Review the history of the consequences of the hazard(s)
Occurrences with injuries and with more than 10 % deaths.
(6) Step 4: Identify the historical and predicted frequency of each consequence
(a) In 200 million departures of large jets:
• One occurrence with more than 10 % deaths; and
• One occurrence with injuries.
(b) There is no reason to believe that the future rate of accidents will be
significantly different than the historical record.
(7) Step 5: Determine how effective full compliance with the latest amendment of the
Regulation certification specification would be at addressing the hazard
(a) Considerable potential for eliminating or avoiding the hazard.
(b) Compliance with Amendment 3 eliminates the hazard or provides a means
to avoid the hazard completely for all probable or likely cases. However, it
does not cover all situations or scenarios.
(8) Step 6: Determine resource costs and cost avoidance
(a) Costs:
• For a newly developed aeroplane, there would be minor increases in
labour resulting from design and fabrication.
• There would be a negligible increase in costs related to materials,
operating costs, and revenue utility loss.
(b) Cost avoidance:
• There were two accidents in 200 million departures. The applicant
believes that it will manufacture more than 2 000 of these aeroplanes
or derivatives of these aeroplanes. These aeroplanes would average
five flights a day. Therefore, statistically there will be accidents in the
future if the hazard is not alleviated. Compliance will provide cost
benefits related to avoiding lawsuits, accident investigations, and
public relation costs.
• There are cost savings associated with meeting a single type-
certification basis for the Agency and foreign regulations.
(9) Conclusion
It is concluded that compliance with the latest certification specification increases
the level of safety at a minimal cost to the applicant. Based on the arguments and
information presented by the applicant through the Certification Review Item (CRI)
process, the Agency determined that meeting the latest amendment would be
practical.
b. Example 2: 14 CFR § 25.365 pressurised compartment loads
Note: This example is taken from the FAA certification experience gained before the
Agency’s start, so references to FAR sections and amendments are kept.
(b) Design changes made to the proposed derivative airplane bring it closer to full
compliance with 14 CFR § 25.365 at Amendment 25-54. The original airplane was
shown to meet the requirements for a hole size of 1.1 square feet. Amendment 25-
54 would require a hole size of 5.74 square feet, and the current reinforcements for
the converted airplane can sustain a hole size of 3.65 square feet in the forward
area and 2.65 at the aft area. This is 3.1 and 2.4 times respectively better than the
original design condition of Amendment 25-0 and is a significant improvement over
the worldwide passenger fleet in service.
(8) Step 6: Determine resource costs and cost avoidance
(a) Costs: There would be savings in both labour and capital costs if compliance were
shown demonstrated to Amendment 25-0 instead of Amendment 25-54. Major
modifications to the floor beams would be necessary to meet the formula hole size
requirement in Amendment 25-54.
(b) Cost Avoidance:
(1) There were four accidents in 200 million departures. The applicant believes
that it will manufacture more than 2 000 of these airplanes or derivatives of
these airplanes. These airplanes would average two flights a day. Therefore,
statistically there will be accidents in the future if the hazard is not alleviated.
Compliance will provide cost benefits related to avoiding lawsuits, accident
investigations, and public relation costs.
(2) There are cost savings associated with meeting a single certification basis
for FAA and foreign regulations.
(9) Step 7: Document conclusion regarding practicality.
The design complies with 14 CFR § 25.365 at Amendment 25-0, 25-71/72, and 25-87,
and is nearly in full compliance with Amendment 25-54 (and certain aspects of
Amendments 25-71/72 and 25-87). The design would adequately address the hazard at
an acceptable cost. Therefore, based on arguments of impracticality discussed in an
issue paper, the FAA accepts the applicant’s proposal to comply with 14 CFR § 25.365 at
Amendment 25-0.
1. Introduction
Service experience may be utilised to support the application of an earlier airworthiness
standard certification specifications if, in conjunction with the applicable service experience and
other compliance measures, the earlier standard provides certification specifications provide a
level of safety comparable to that provided by the latest certification specifications. It is
incumbent on the applicant to provide sufficient substantiation to allow the Agency to make this
determination. A statistical approach may be used, subject to the availability and relevance of
data, however sound engineering judgement must be used. For service history to be acceptable,
the data must be both sufficient and pertinent.
The essentials of the process involve:
a. A clear understanding of the requirement certification specification change and the
purpose for the change and hazard addressed;
b. A determination based on detailed knowledge of the proposed design feature;
c. The availability of pertinent and sufficient service experience data, and
d. A comprehensive review of that service experience data.
2. Guidelines
The Certification Review Item (CRI) procedure (either a stand-alone CRI or included in the CRI
A-1) would be used and the applicant should provide documentation to support the following:
a. The identification of the differences between the certification specification in the existing
basis and the certification specification as amended, and the effect of the change in the
certification specification.
b. A description as to what aspect of the latest certification specification the proposed
changed product would not meet.
c. Evidence showing that the proposed type-certification basis for the changed product,
together with applicable service experience, provides a level of safety consistent with
complying with the latest certification specifications.
d. A description of the design feature and its intended function.
e. Data for the product pertinent to the certification specification:
(1) Service experience from such sources as the following:
(a) Accident reports;
(b) Incident reports;
(c) Service Bulletins;
(d) Airworthiness directives;
(e) Repairs;
(f) Modifications;
(g) Flight hours/cycles for fleet leader and total fleet;
(h) World airline accident summary data;
(i) Service Difficulty Reports;
(j) Reports from accident investigation boards;
(k) Warranty, repair and parts usage data.
(2) Show that the data presented represents all relevant service experience for the
product, including the results of any operator surveys, and is comprehensive
enough to be representative.
(3) Show that the service experience is relevant to the hazard.
(4) Identification and evaluation of each of the main areas of concern, with regard to:
(a) recurring and/or common failure modes;
(b) cause;
(c) probability, by qualitative reasoning; and
(d) measures already taken and their effects.
(5) Relevant data pertaining to aircraft of similar design and construction may be
included.
(6) Evaluation of failure modes and consequences through analytical processes. The
analytical processes should be supported by:
(a) A review of previous test results; and
(b) Additional detailed testing as required; or
(c) A review aircraft functional hazard assessments (FHA) and any applicable
system safety assessments (SSA) as required.
f. A conclusion that draws together the data and the rationale.
g. These guidelines are not intended to be limiting, either in setting required minimum
elements or in precluding alternative forms of submission. Each case may be different,
based on the particulars of the system being examined and the requirement to be
addressed.
3. Example: Transport Airplanes: § 25.1141(f) Powerplant controls: Auxiliary Power Unit (APU)
Fuel Valve Position Indication
NOTE: This example is taken from FAA certification experience gained prior to the Agency’s
start, so references are made to FAR sections and amendments are kept.)
a. The following example, for transport airplanes (14 CFR § 25.1141(f) Auxiliary Power Unit
(APU) Fuel Valve Position Indication System), illustrates the typical process an applicant
follows. The process will be the same for all product types.
b. This example comes from a derivative model transport aeroplane where significant
changes were made to the main airframe components, engines and systems, and APU.
The baseline airplane has an extensive service history. The example shows how the use
of service experience supports a finding that compliance with the latest requirement
would not contribute materially to the level of safety, and that application of the existing
type-certification basis (or earlier amendment) would be appropriate. The example is for
significant derivatives of transport airplanes with extensive service history, and illustrates
the process, following the guidelines in this appendix, but does not include the level of
detail normally required.
(1) Determine the differences between the requirement in the existing type-
certification basis and the requirement as amended, and the effect of the change in
the requirement.
The existing type-certification basis of the airplane that is being changed is the
initial release of part 25. Amendment 25-40 added the requirement 14 CFR
§25.1141(f), which mandates that power-assisted valves must have a means to
indicate to the flight crew when the valve is in the fully open or closed position, or
is moving between these positions. The addressed hazard would be risk of APU
fire due to fuel accumulation caused by excessive unsuccessful APU start
attempts.
(2) What aspect of the proposed changed product would not meet the latest
requirements?
The proposed APU fuel valve position indication system does not provide the flight
crew with fuel valve position or transition indication, and, therefore, does not
comply with the requirements of 14 CFR §25.1141(f).
(3) Evidence that the proposed type-certification basis for the changed product,
together with applicable service experience and other compliance measures
provide an acceptable level of safety.
The APU fuel shut-off valve and actuator are unchanged from those used on the
current family of airplanes, and have been found to comply with the earlier
amendment 25-11 of 14 CFR §25.1141(f). The existing fleet has achieved
approximately (#) flights during which service experience of the existing design
has been found to be acceptable. If one assumes a complete APU cycle, i.e. start
up and shutdown for each flight, the number of APU fuel shut off valve operations
8
would be over 10 cycles, which demonstrates that the valve successfully meets its
intended function and complies with the intent of the requirement. In addition, the
system design for the changed product incorporates features, which increase the
level of functionality and safety.
(4) A description of the design feature and its intended function
The fuel shut off valve, actuator design, and operation is essentially unchanged,
with the system design ensuring that the valve is monitored for proper cycling from
closed to open at start initiation. If the valve is not in the appropriate position (i.e.,
closed) then the APU start is terminated, an indication is displayed on the flight
deck and any further APU starts are prevented. Design improvements using the
capability of the APU Electronic Control Unit (ECU) have been incorporated in this
proposed product change. These design changes ensure that the fuel valve
indication system will indicate failure of proper valve operation to the flight crew,
but the system does not indicate valve position as required by 14 CFR §25.1141(f).
(5) Data for the product pertinent to the requirement
The FAA and applicant record the data in an issue paper (G-1 or a technical issue
paper). An issue paper was co-ordinated which included data, or referenced
reports, documenting relevant service experience that has been compiled from
incident reports, fleet flight hour/cycle data, and maintenance records. The issue
paper also discussed existing and proposed design details, failure modes, and
analyses showing to what extent the proposed aeroplane complies with the latest
amendment of 14 CFR §25.1141. Information is presented to support the
applicant’s argument that compliance with the latest amendment would not
materially increase the level of safety. Comparative data pertaining to aircraft of
similar design and construction are also presented.
(6) Conclusion
Conclusion, drawing together the data and rationale, is documented in the G-1
issue paper. The additional features incorporated in the APU fuel shut-off valve will
provide a significant increase in safety to an existing design with satisfactory
service experience. The applicant proposes that compliance with the latest
amendment would not materially increase the level of safety, and that compliance
with 14 CFR §25.1141 at amendment 25-11 would provide an acceptable level of
safety for the proposed product change.
Secondary
Changes
Changed
Area
Figure 4: Example of Related and Unrelated changes –Increase in Maximum Number of Passengers
Grouping of related
changes
(Significant change)
New Interior
Thrust Increase
(Physical and performance
changes)
Unaffected
Area Comprehensive Flight Desk Upgrade
Affected Area (typically, a stand–alone significant
Changed Area physical change)
Figure 5: Establishing TC basis for Substantial, Significant and Not significant changes according to 21.A.101 (a) and ((b)
Full product Affected area Unaffected area Affected area Unaffected area
(Changed areas and/or physically unchanged but functionally affected areas)
No new (Changed areas and/or
New New showingdemonstration of compliance is required showingdemonstration physically unchanged
showingdemonstrati of compliance is but functionally No new
on of compliance Compliance with the latest amendment No material contribution to required. affected areas). showingdemonstration
for full changed materially contributes to safety safety of compliance is
product required. Unaffected area New required.
continues to comply showingdemonstration
Previously (Practical) Impractical Secondary (and not with the existing TC of compliance is Unaffected area
approved type secondary) basis. required. continues to comply
design and with the existing TC
compliance data The applicant may propose a The applicant may The applicant may basis.
certification basis using an The applicant may propose a
may be allowed if certification basis using an elect to comply with propose a certification
valid for the earlier amendment but not later certification basis using an earlier The applicant may elect
earlier than the existing TC earlier amendment but not
changed product. earlier than the existing TC specifications. amendment but not to comply with later
basis. earlier than the certification
basis.
existing TC basis. specifications.
Certification specifications of Certification specifications of an earlier amendment Elects to comply An earlier amendment Elects to comply
the latest amendment + elects to comply (later than the existing + elects to comply (later than the existing
+ elects to comply TC basis TC basis)
TC basis recorded by the Agency
Certification specifications of Certification specifications of Certification specifications of Elects to comply The proposed Elects to comply
the latest amendment the proposed amendment the proposed amendment as proposed amendment (if as proposed
+ SC or, (if adequate) adequate)
(if the latest amendment is not adequate) if not adequate, the first or, or
+ elects to comply appropriate later amendment if not adequate, the first First appropriate later
(if available) appropriate later amendment amendment (if
or (if available) available)
SC + elects to comply or or
SC + elects to comply SC + elects to comply
Certification specifications of The existing TC basis The existing TC basis The existing TC basis Elects to comply
a later amendment or, or, or, (later than the existing TC basis)
designated by the Agency + if not adequate, the first if not adequate, the first appropriate if not adequate, the first
SC + elects to comply appropriate later amendment later amendment (if available) appropriate later amendment (if
(if available) or available)
or (if not) SC +elects to comply or
(if not) SC + elects to comply (if not) SC +elects to comply
Aircraft
Conversion to tail wheel configuration 1
Spoiler installation 1
Increase in MTOW 1
Structures
Propulsion
Engine model change 1
Equipment
WX radar installation 2
CS-25
Cabin Safety
Note : Cabin layout (installation of seats (16G),
Basically all changes related to cabin galleys, single class or business / economy 2
configuration should be in Group 2. class, etc.)
Floor path marking 2
Crew rest compartment 1
Change of cargo compartment classification
(from class D to class C) 1
Structure
Note : Cargo door 1
STC which leads to reassess the loads
on large parts of primary structure
should be in Group 1.
Change from Passenger to Freighter 1
configuration
Avionics
Notes : CVR 2
For CS-25 products, the existence of
ETSO is not taken into account for the
classification ;
Impact on aircraft performance, and
influence of aircraft performance are
criteria to assess the classification ;
Subjective assessment of human factors
is considered for determination of
classification.
VHF 2
NAV (ADF, VOR, GPS, BRNAV) 2
Autopilot, HUD, EFIS, FMS 1
DFDR 2/1
Meteo radar 2
ILS Cat 3 1
In this context, ‘demonstrating the conformity with the applicable design data of a product, part and
appliance’ means that conformity with the applicable design data has to be established and shown for
each and every product, part or appliance.
[Decision 2007/012/R, 29.11.2007]
ARRANGEMENT
i.a.w. in accordance with 21.A.122
The undersigned agree on the following commitments: Relevant interface procedures
The design organisation [NAME] and the person producing under Part 21 Subpart
F [NAME] take joint responsibility to:
deal adequately with production deviations and non-conforming parts in
accordance with the applicable procedures of the design organisation and the
manufacturer producing under Part 21 Subpart F.
achieve adequate configuration control of manufactured parts, to enable the
manufacturer producing under Part 21 Subpart F to make the final
determination and identification for conformity or airworthiness release and
eligibility status.
The scope of production covered by this arrangement is detailed in [DOCUMENT REFERENCE/ATTACHED LIST]
[When the design organisation is not the same legal entity as the manufacturer producing under Part 21 Subpart F ]
For the [NAME of the design organisation/DOA holder] For the [NAME of the person producing under Part 21
Subpart F]
and /or feasible. In making the determination that Subpart F may apply, the competent authority
may take into account one or a combination of parameters such as the following:
no flow production (infrequent or low volume of production).
simple technology (enabling effective inspection phases during the manufacturing
process).
very small organisation.
2 Declaration by the applicant certifying the conformity of the manual to the requirements defined
in Part 21 Section A Subpart F
3 Jobs, power and responsibilities of the accountable personnel
4 Organisation chart, if required by the competent authority
5 Description of the resources, including human resources, with an indication of the personnel
qualification criteria
6 Description of location and equipment
7 Description of the scope of work, the production processes and techniques, and reference to
the ‘capability list’
8 Communications with the competent authority, and specifically those required by 21.A.125A(c)
9 Assistance and communication with the design approval holder, and the means of compliance
with 21.A.125A (c)
10 Amendments to the Manual
11 Description of the Inspection System (including test, see GM No. 2 to 21.A.125A(b), and
21.A.127 and 21.A.128), and the procedures to meet 21.A.126 and associated GM
12 List of suppliers
13 Issuing of the Statement of Conformity and competent authority inspection for validation
If the information is listed in the Manual in a different order a cross-reference to the above list should
be made available in the Manual.
It should be anticipated that a non-compliance with these paragraphspoints is only considered a level
one finding when objective evidence has been found that this finding is an uncontrolled non-
compliance that could affect the safety of the aircraft.
1 The designer, to define all necessary processes, techniques and methods to be followed during
manufacture (21.A.31) and this information will be provided as part of the applicable design
data.
2 The manufacturer, to ensure that all processes are carried out strictly in accordance with the
specifications provided as part of the applicable design data.
2. All parts should be protected from extremes of temperatures and humidity and, where needed,
temperature-controlled or full air-conditioned facilities should be provided.
3. Racking and handling equipment should be provided such as to allow storage, handling and
movement of parts without damage.
4. Lighting should be such as to allow safe and effective access and handling, but should also
cater for items which are sensitive to light e.g., rubber items.
5. Care should be taken to segregate and shield items which can emit fumes (e.g., wet batteries),
substances or radiation (e.g., magnetic items) which are potentially damaging to other stored
items.
6. Procedures should be in place to maintain and record stored parts identities and batch
information.
7. Access to storage areas should be restricted to authorised personnel who are fully trained to
understand and maintain the storage control arrangements and procedures.
8. Provisions should be made for segregated storage of non-conforming items pending their
disposition (see GM 21.A.126(b)(4)).
All forms of recording media are acceptable (paper, film, magnetic ...) provided they can meet
the required duration for archiving under the conditions provided.
2. The related procedures should:
2.1 Identify records to be kept.
2.2 Describe the organisation of and responsibility for the archiving system (location,
compilation, format) and conditions for access to the information (e.g., by product,
subject).
2.3 Control access and provide effective protection from deterioration or accidental damage.
2.4 Ensure continued readability of the records.
2.5 Demonstrate to the competent authority proper functioning of the records system.
2.6 Clearly identify the persons involved in conformity determination.
2.7 Define an archiving period for each type of data taking into account importance in
relation to conformity determination subject to the following:
a Data which supports conformity of a product, part, or appliance should be kept for
not less than three years from the issue date of the related Statement of
Conformity or Authorised Release Certificate.
b Data considered essential for continuing airworthiness should be kept throughout
the operational life of the product, part or appliance.
2.8 Data related to supplied parts may be retained by the supplier if the supplier has a
system agreed under Part 21 Section A Subpart F by the competent authority. The
manufacturer should, in each case, define the archiving period and satisfy himself or
herself and the competent authority that the recording media are acceptable.
inspections will normally be determined on the basis of the positive results of previous inspections
conducted on the first production engines, and on the basis of service experience.
AMC No. 3 to 21.A.129(c) Obligations of the manufacturer – Condition for safe operation
Before issue of the Statement of Conformity to the competent authority the manufacturer under this
Subpart should make an investigation so as to be satisfied in respect to each of the items listed
below. The documented results of this investigation should be kept on file by the manufacturer.
Certain of these items may be required to be provided (or made available) to the operator or owner
of the aircraft, and, for validation of the statement of conformity, to the competent authority.
1 Equipment or modifications which do not meet the requirements of the state of manufacture
but have been accepted by the competent authority of the importing country.
2 Identification of products, parts or appliances which:
2.1 Are not new
2.2 Are furnished by the buyer or future operator (including those identified in 21.A.801 and
805).
3 Technical records which identify the location and serial numbers of components that have
traceability requirements for continued airworthiness purposes including those identified in
21.A.801 and 21.A.805.
4 Log book and a modification record book for the aircraft as required by the Agency.
5 Log books for products identified in 21.A.801 installed as part of the type design as required
by the Agency.
6 A weight and balance report for the completed aircraft.
7 A record of missing items or defects which do not affect airworthiness these for example could
be furnishing or BFE (Items may be recorded in a technical log or other suitable arrangement
such that the operator and Agency are formally aware).
Page 143 of 264
SECTION A —.Subpart E — Supplemental type-certificates
8 Product support information required by other associated implementing rules and CS or GM,
such as a Maintenance Manual, a Parts Catalogue, or MMEL all of which are to reflect the
actual build standard of the particular aircraft. Also an Electrical load analysis and a wiring
diagram.
9 Records which demonstrate completion of maintenance tasks appropriate to the test flight
flying hours recorded by the aircraft. These records should show the relationship of the
maintenance status of the particular aircraft to the manufacturers recommended maintenance
task list and the Maintenance Review Board (MRB) document/report.
10 Details of the serviceability state of the aircraft in respect of, a) the fuel and oil contents, b)
provision of operationally required emergency equipment such as life rafts, etc.
11 Details of the approved interior configuration if different from that approved as part of the type
design.
12 An approved Flight Manual which conforms to the build standard and modification state of the
particular aircraft should be available.
13 Show that inspections for foreign objects at all appropriate stages of manufacture have been
satisfactorily performed.
14 The registration has been marked on the exterior of the aircraft as required by national
legislation. Where required by national legislation fix a fireproof owners nameplate.
15 Where applicable, there should be a certificate for noise and, for the aircraft radio station.
16 The installed compass and or compass systems have been adjusted and compensated and a
deviation card displayed in the aircraft.
17 Software criticality list.
18 A record of rigging and control surface movement measurements.
19 Details of installations which will be removed before starting commercial air transport
operations (e.g., ferry kits for fuel, radio or navigation).
20 List of all applicable Service Bulletins and airworthiness directives that have been
implemented.
The Statement of Conformity must comply with the format attached including block numbers
and the location of each Block. The size of each Block may however be varied to suit the
individual application, but not to the extent that would make the Statement of Conformity
unrecognisable. If in doubt consult the competent authority.
The Statement of Conformity must either be pre-printed or computer generated but in either
case the printing of lines and characters must be clear and legible. Pre-printed wording is
permitted in accordance with the attached model but no other certification statements are
permitted.
Statements of Conformity must be issued in one or more of the official language(s) of the
issuing competent authority with translations in English shown below, if required. Completion
may be either machine/computer printed or hand-written using block letters to permit easy
reading.
A copy of the Statement of Conformity and all referenced attachments are to be retained by
the manufacturer. A copy of the validated Statement of Conformity is to be retained by the
competent authority.
3 COMPLETION OF THE AIRCRAFT STATEMENT OF CONFORMITY BY THE ORIGINATOR
There must be an entry in all Blocks to make the document a valid Statement.
A Statement of Conformity must not be issued for validation by the competent authority,
unless the design of the aircraft and its installed products are approved.
The information required in Blocks 9, 10, 11, 12, 13 and 14 may be by reference to separate
identified documents held on file by the manufacturer, unless the competent authority agrees
otherwise.
This Statement of Conformity is not intended to provide for the complete equipment fit
required by the applicable operational rules. However, some of these individual items may be
included in Block 10 or in the approved type design. Operators are therefore reminded of their
responsibility to ensure compliance with the applicable operational rules for their own
particular operation.
Block 14 Remarks: Any statement, information, particular data or limitation which may
affect the airworthiness of the aircraft. If there is no such information or data,
state; ‘NONE’.
Block 15 Enter ‘Certificate of Airworthiness’ or ‘Restricted Certificate of Airworthiness’ for
the Certificate of Airworthiness requested.
Block 16 Additional requirements such as those notified by an importing country should be
noted in this Block.
Block 17 Validity of the Statement of Conformity is dependent on full completion of all
Blocks on the form. A copy of the flight test report together with any recorded
defects and rectification details should be kept on file by the manufacturer. The
report should be signed as satisfactory by the appropriate certifying staff and a
flight crew member, e.g., test pilot or flight test engineer. The flight tests
performed are those required by 21.A.127 and GM 21.A.127, to ensure that the
aircraft conforms to the applicable design data and is in condition for safe
operation.
The listing of items provided (or made available) to satisfy the safe operation
aspects of this statement should be kept on file by the manufacturer.
Block 18 The Statement of Conformity may be signed by the person authorised to do so
by the manufacturer in accordance with 21.A.130(a). A rubber stamp signature
should not be used.
Block 19 The name of the person signing the certificate should be typed or printed in a
legible form.
Block 20 The date the Statement of Conformity is signed must be given.
Block 21 For production under Part 21 Subpart F, state ‘NOT APPLICABLE’
Additionally, for production under Part 21 Section A Subpart F, this Block must include
validation by the competent authority. For this purpose, the validation statement below should
be included in the Block 21 itself, and not referred in a separate document. The statement can
be pre-printed, computer generated or stamped, and should be followed by the signature of
the representative of the competent authority validating the certificate, the name and the
position/identification of such representative of the competent authority, and the date of such
validation by the competent authority.
VALIDATION STATEMENT:
‘After due inspection the identify the issuing competent authority is satisfied that this
document constitutes an accurate and valid Statement of Conformity in accordance with Part
21 Section A Subpart F.’
AMC No. 2 to 21.A.130(b) Statement of Conformity for Products (other than complete aircraft),
parts, appliances and materials - The Authorised Release Certificate (EASA Form 1)
A. INTRODUCTION
This AMC relates specifically to the use of the EASA Form 1 for manufacturing purposes under
Part 21 Subpart F. It can be used as a supplement to the completion instructions in Part 21,
Appendix I which covers the use of the EASA Form 1.
2. GENERAL FORMAT
Refer to Part 21 Appendix I.
3. COPIES
Refer to Part 21 Appendix I.
The Part 21 Subpart F originator must retain a copy of the certificate in a form that allows
verification of original data.
AMC No. 1 to 21.A.133(b) and (c) Eligibility – Link between design and production
organisations
An arrangement is considered appropriate if it is documented and satisfies the competent authority
that co-ordination is satisfactory.
To achieve satisfactory coordination the documented arrangements must at least define the following
aspects irrespective of whether the two organisations are separate legal entities or not:
• The responsibilities of a design organisation which assure correct and timely transfer of up-to-
date airworthiness data (e.g., drawings, material specifications, dimensional data, processes,
surface treatments, shipping conditions, quality requirements, etc.);
• The responsibilities and procedures of a POA holder/applicant for developing, where applicable,
its own manufacturing data in compliance with the airworthiness data package;
• The responsibilities of a POA holder/applicant to assist the design organisation in dealing with
continuing airworthiness matters and for required actions (e.g., traceability of parts in case of
direct delivery to users, retrofitting of modifications, traceability of processes’ outputs and
approved deviations for individual parts as applicable, technical information and assistance,
etc.);
• The scope of the arrangements must cover Part 21 Subpart G requirements and associated
AMC and GM, in particular: 21.A.145(b), 21.A.165(c), (f) and (g);
• The responsibilities of a POA holder/applicant, in case of products prior to type certification to
assist a design organisation in showingdemonstrating compliance with CS (access and
suitability of production and test facilities for manufacturing and testing of prototype models and
test specimen);
• The procedures to deal adequately with production deviations and non-conforming parts;
• The procedures and associated responsibilities to achieve adequate configuration control of
manufactured parts, to enable the production organisation to make the final determination and
identification for conformity or airworthiness release and eligibility status;
• The identification of the responsible persons/offices who control the above;
• The acknowledgment by the holder of the TC/STC/repair or change approval/ETSO
authorisation that the approved design data provided, controlled and modified in accordance
with the arrangement are recognised as approved.
In many cases the production organisation may receive the approved design data through an
intermediate production organisation. This is acceptable provided an effective link between the design
approval holder and the production organisation can be maintained to satisfy the intent of 21.A.133.
When the design and production organisations are two separate legal entities a Direct Delivery
Authorisation must be available for direct delivery to end users in order to guarantee continued
airworthiness control of the released parts and appliances.
Where there is no general agreement for Direct Delivery Authorisation, specific permissions may be
granted (refer to AMC 21.A.4).
AMC No. 2 to 21.A.133(b) and (c) Eligibility – Link between design and production
organisations
In accordance with AMC No.1 to 21.A.133(b) and (c) the POA holder must demonstrate to the
competent authority that it has entered into an arrangement with the design organisation. The
arrangement must be documented irrespective of whether the two organisations are separate legal
entities or not.
The documented arrangement must facilitate the POA holder to demonstrate compliance with the
requirement of 21.A.133(b) and (c) by means of written documents agreed.
In the case where the design organisation and POA holder are part of the same legal entity these
interfaces may be demonstrated by company procedures accepted by the competent authority.
In all other cases to define such a design/production interface the following sample format is offered:
ARRANGEMENT
i.a.w. in accordance with 21.A.133(b) and (c)
The undersigned agree on the following commitments: Relevant interface procedures
The design organisation [NAME] and the POA holder [NAME] take joint
responsibility to
deal adequately with production deviations and non-conforming parts in
accordance with the applicable procedures of the design organisation and the
production organisation approval holder
achieve adequate configuration control of manufactured parts, to enable the
POA holder to make the final determination and identification for conformity.
The scope of production covered by this arrangement is detailed in [DOCUMENT REFERENCE/ATTACHED LIST]
[When the design organisation is not the same legal entity as the production organisation approval holder ]
[When the design organisation is not the same legal entity as the production organisation approval holder]
For the [NAME of the design organisation/DOA holder] For the [NAME of the POA holder]
xx.xx.xxxx xx.xx.xxxx
[NAME in block letters] [NAME in block letters]
Title: The title of the relevant document must clearly indicate that it serves the purpose of a
design/production interface arrangement in accordance with 21.A.133(b) and (c).
Commitment: The document must include the basic commitments between the design organisation
and the POA holder as addressed in AMC 21.A.4 and AMC No. 1 to 21.A.133(b) and (c).
Relevant Procedures: Identify an entry point into the documentary system of the organisations with
respect to the implementation of the arrangement (for example a contract, quality plan, handbooks,
common applicable procedures, working plans etc.).
Scope of arrangement: The scope of arrangement must state by means of a list or reference to
relevant documents those products, parts or appliances that are covered by the arrangement.
Transfer of applicable design data: Identify the relevant procedures for the transfer of the applicable
design data required by 21.A.131 and AMC 21.A.131 from the design organisation to the POA holder.
The means by which the design organisation advises the POA holder whether such data is approved
or not approved must also be identified (ref. 21.A.4/AMC 21.A.4).
Direct Delivery Authorisation: Where the design organisation and the POA holder are separate legal
entities the arrangement must clearly identify whether authorisation for direct delivery to end users is
permitted or not.
Where any intermediate production/design organisations are involved in the chain between the
original design organisation and the POA holder evidence must be available that this intermediate
organisation has received authority from the design organisation to grant Direct Delivery
Authorisation.
Signature: AMC No. 1 to 21.A.133(b) and (c) requests the identification of the responsible
persons/offices who control the commitments laid down in the arrangement. Therefore the basic
document must be signed mutually by the authorised representatives of the design organisation and
the POA holder in this regard.
The quality system should be documented in such a way that the documentation can be made
easily available to personnel who need to use the material for performing their normal duties, in
particular:
procedures, instructions, data to cover the issues of 21.A.139(b)(1) are available in a written
form,
distribution of relevant procedures to offices/persons is made in a controlled manner,
procedures which identify persons responsible for the prescribed actions are established,
the updating process is clearly described.
The manager responsible for ensuring that the quality system is implemented and maintained
should be identified.
The competent authority will verify on the basis of the exposition and by appropriate
investigations that the production organisation has established and can maintain their
documented quality system.
A supplier who does not hold a POA is considered as a sub-contractor under the direct control of
the POA quality system.
The POA holder retains direct responsibility for inspections/tests carried out either at its own
facilities or at supplier’s facilities.
[Decision 2010/016/R, 16.12.2010]
AMC No. 1 to 21.A.139(b)(1)(ii) Vendor and sub-contractor assessment, audit and control –
Production Organisation Approval (POA) holder using documented arrangements with other
parties for assessment and surveillance of a supplier.
1. General
Note:
For the purpose of this AMC, vendors and sub-contractors are hereafter referred to as
‘suppliers’, regardless of whether or not they hold a POA and audit and control is hereafter
referred to as ‘surveillance’.
The production organisation is required by Part 21 to demonstrate that it has established and
maintains a quality system that enables the organisation to ensure that each item produced
conforms to the applicable design data and is in a condition for safe operation. To discharge
this responsibility, the quality system should have, among other requirements, procedures to
adequately carry out the assessment and surveillance of suppliers.
The use of Other Parties (OP), such as a consulting firm or quality assurance company, for
supplier assessment and surveillance does not exempt the POA holder from its obligations
under 21.A.165. The supplier assessment and surveillance, corrective action and follow-up
activity conducted at any of its supplier’s facilities may be performed by OP.
The purpose of using an OP cannot be to replace the assessment, audit and control of the POA
Holder. It is to allow an element (i.e. the assessment of the quality system) to be delegated to
another organisation under controlled conditions.
The use of OP to perform supplier assessments and surveillance should be part of the
production organisation quality system and fulfil the conditions of this AMC.
This AMC is applicable to a method whereby a POA holder has a documented arrangement
with OP for the purpose of assessing and/or surveying a POA's supplier.
2. Approval by the competent authority
Implementing or changing procedures for using OP for supplier assessment and surveillance is
a significant change to the quality system and requires approval in accordance with 21.A.147.
3. Conditions and criteria for the use of OP to perform supplier assessment and surveillance
(a) The POA holder should include the use of OP for supplier assessment and surveillance
in the POA holders’ quality system to demonstrate compliance with the applicable
requirements of Part 21.
(b) Procedures required for using OP for supplier assessment and surveillance should be
consistent with other procedures of the POA holders’ quality system.
(c) Procedures of the POA holder that uses OP to perform supplier assessment and
surveillance should include the following:
(1) Identification of the OP that will conduct supplier assessment and surveillance.
(2) A listing of suppliers under surveillance by the OP. This listing should be
maintained by the POA holder and made available to the competent authority
upon request.
(3) The method used by the POA holder to evaluate and monitor the OP. The method
should include the following as a minimum:
(i) Verification that standards and checklists used by the OP are acceptable for
the applicable scope.
(ii) Verification that the OP is appropriately qualified and have sufficient
knowledge, experience and training to perform their allocated tasks.
(iii) Verification that the OP surveillance frequency of the suppliers is
commensurate with the complexity of the product and with the surveillance
frequency established by the POA holder’s suppliers control programme.
(iv) Verification that the suppliers’ assessment and surveillance is conducted
on-site by the OP.
(v) Verification that the OP has access to applicable proprietary data to the
level of detail necessary to survey suppliers functions.
Where the POA holder uses an OP accredited by a signatory to the European
cooperation for Accreditation (EA) Multilateral Agreement and working in
accordance with an aviation standard (e.g. EN 9104 series of requirements) that
describes requirements for the other party assessment and surveillance, the items
(ii) and (iv) shall be deemed to be complied with.
(4) A definition to what scope the OP will conduct suppliers surveillance on behalf of
the POA holder. If the OP replaces surveillance in part, the POA holder should
identify the functions that will continue to be surveyed by the POA holder.
(5) The procedures used by the OP to notify the POA holder of non-conformities
discovered at the suppliers facility, corrective action and follow-up.
(d) The POA should make arrangements that allow the competent authority to make
investigation in accordance with 21.A.157 to include OP activities.
AMC No. 2 to 21.A.139(b)(1)(ii) Vendor and sub-contractor assessment, audit and control -
Production Organisation Approval (POA) holder using other party supplier certification
1. General
Note:
For the purpose of this AMC, vendors and sub-contractors are hereafter referred to as
‘suppliers’, regardless of whether or not they hold a POA and audit and control is hereafter
referred to as ‘surveillance’.
Other party supplier certification is a method whereby a supplier contracts with an appropriately
recognised or accredited Other Party (OP) for the purpose of obtaining a certification from that
OP. Certification indicates that the supplier has satisfactorily demonstrated to meet the
applicable standard on a continuing basis. OP certification results in placing the supplier on the
OP list of certified organisations, or in the supplier receiving a certificate identifying the
requirements that have been met. Periodic follow-up evaluations are conducted by the OP to
verify continued compliance with the requirements of the applicable standard.
The production organisation is required by Part 21 to demonstrate that it has established and
maintains a quality system that enables the organisation to ensure that each item produced
conforms to the applicable design data and is in a condition for safe operation. To discharge
this responsibility, the quality system should have, among other requirements, procedures to
adequately carry out the assessment and surveillance of suppliers.
The assessment and surveillance of suppliers by an OP should be deemed to satisfy the
requirements of 21.A.139(b)(1)(ii) when the conditions of this AMC are satisfied. The
assessment and surveillance of suppliers by OP as part of supplier certification does not
exempt the POA holder from its obligations under 21.A.165. The supplier assessment and
surveillance, corrective action and follow-up activity conducted at any of its supplier’s facilities
may be performed by OP.
The purpose of using an OP cannot be to replace the assessment, audit and control of the POA
Holder. It is to allow an element (i.e. the assessment of the quality system) to be delegated to
another organisation under controlled conditions.
The use of suppliers that are certified by OP in accordance with this AMC should be part of a
production organisation quality system.
2 Approval by the competent authority
Implementing or changing procedures for using suppliers that are certified by an OP is a
significant change to the quality system and requires approval in accordance with 21.A.147.
3 Conditions and criteria for using supplier certification for the supplier assessment and
surveillance
(a) The POA holder should include the use of supplier certification for the supplier
assessment and surveillance in the POA holder’s quality system to demonstrate
compliance with the applicable requirements of Part 21.
(b) Procedures required for use of supplier certification for the supplier assessment and
surveillance should be consistent with other procedures of the POA holders’ quality
system.
(c) Procedures of the POA holder that uses supplier certification for the supplier assessment
and surveillance should include the following:
(1) Listing of the OP that has certified or will certify suppliers and will conduct supplier
assessment and surveillance or the scheme under which the accreditation of the
OP is controlled. This listing should be maintained by the POA holder and made
available to the competent authority upon request.
(2) A listing of the certified suppliers under surveillance by the OP and used by the
POA holder. This listing should be maintained by the POA holder and made
available to the competent authority upon request.
(3) The method used by the POA holder to evaluate and monitor the certification
process of any OP certification body or OP certification scheme used. This applies
not only to new suppliers, but also to any decision by the POA holder to rely on OP
certification of current suppliers. The method should include the following as a
minimum:
(i) Verification that certification standards and checklists are acceptable and
applied to the applicable scope.
(ii) Verification that the OP is appropriately qualified and has sufficient
knowledge, experience and training to perform its allocated tasks.
(iii) Verification that the OP surveillance frequency of the suppliers is
commensurate with the complexity of the product and with the surveillance
frequency established by the POA holder’s suppliers control programme.
(iv) Verification that the suppliers’ surveillance is conducted on-site by the OP.
(v) Verification that the surveillance report will be made available to the
competent authority upon request.
(vi) Verification that the OP continues to be recognised or accredited.
(vii) Verification that the OP has access to applicable proprietary data to the
level of detail necessary to survey suppliers functions.
Where the POA holder uses an OP accredited by a signatory to the European cooperation for
Accreditation (EA) Multilateral Agreement and working in accordance with an aviation standard
(e.g. EN 9104 series of requirements) that describes requirements for the OP certification, the
items (ii), (iv) and (v) shall be deemed to be complied with:
(4) A definition to what scope the OP will conduct suppliers surveillance on behalf of
the POA holder. If the OP replaces surveillance in part, the POA holder should
identify the functions that will continue to be surveyed by the POA holder.
(5) Procedures that ensure that the POA is aware of the loss of an existing
certification.
(6) Procedures that ensure that the POA holder is aware of non-conformities and has
access to detailed information of these non-conformities.
(7) Procedures to evaluate the consequences of non-conformities and take
appropriate actions.
(d) The POA should make arrangements that allow the competent authority to make
investigation in accordance with 21.A.157 to include OP activities.
her to fulfil the function provided his or her position and authority in the organisation permits to
discharge the attached responsibilities.
The manager is responsible for ensuring that all necessary resources are available and properly
used in order to produce under the production approval in accordance with Part 21 Section A
Subpart G.
The manager needs to have sufficient knowledge and authority to enable him or her to respond to
the competent authority regarding major issues of the production approval and implement
necessary improvements.
The manager needs to be able to demonstrate that he or she is fully aware of and supports the
quality policy and maintains adequate links with the quality manager.
6 The organisation must keep the record for at least two years after the certifying person has
ceased employment with the organisation or withdrawal of the authorisation, whichever is
the sooner.
GM 21.A.149 Transferability
Transfer of approval would normally only be agreed in cases where the ownership changes but
the organisation itself remains effectively unchanged. For example:
An acceptable transfer situation could be a change of company name ( supported by the
appropriate certificate from the National Companies Registration Office or equivalent) but with no
changes to site address, facilities, type of work, staff, accountable manager or person nominated
under 21.A.145.
Alternatively, in the event of receivership (bankruptcy, insolvency or other equivalent legal
process) there may be good technical justification for continuation of the approval provided that
the company continues to function in a satisfactory manner in accordance with their POE. I t is
likely that at a later stage the approval might be voluntarily surrendered or the organisation
transferred to new owners in which case the former paragraphs apply. If it does not continue to
operate satisfactorily then the competent authority could suspend or revoke the approval under
21.B.245.
In order for the competent authority to agree to a transfer of approval, it will normally prescribe it
as a condition in accordance with 21.A.147(b) that the obligations and responsibilities of the
former organisation should be transferred to the new organisation, otherwise transfer is not
possible and application for a new approval will be required.
B1 Turbine Engines ‘
B2 Piston Engines ‘
B3 APU’s ‘
B4 Propellers
AMC 21.A.153 Changes to the terms of approval – Application for a change to the terms of
approval
EASA Form 51 (see AMC No 1 to 21.B.240) must be obtained from the competent authority and
completed in accordance with the procedures of the POE.
The information entered on the form is the minimum required by the competent authority to
assess the need for change of the production organisation approval.
The completed form and an outline of the changed production organisation expositionPOE, and
details of the proposed change to POA terms of approval must be forwarded to the competent
authority.
In addition, the failure to arrange for investigations under 21.A.157, in particular to obtain access to
facilities, after denial of one written request should be classified as a level one finding.
AMC No 1 to 21.A.163(c) Computer generated signature and electronic exchange of the EASA
Form 1
1 Submission to the competent authority
Any POA holder/applicant intending to implement an electronic signature procedure to issue
EASA Form 1 and/or to exchange electronically such data contained on the EASA Form 1,
should document it and submit it to the competent authority as part of the documents attached
with its exposition.
2 Characteristics of the electronic system generating the EASA Form 1
The electronic system should:
guarantee secure access for each certifying staff;
ensure integrity and accuracy of the data certified by the signature of the Form and be
able to show evidence of the authenticity of the EASA Form 1 (recording and record
keeping) with suitable security, safeguards and backups;
be active only at the location where the part is being released with an EASA Form 1;
not permit to sign a blank form;
provide a high degree of assurance that the data has not been modified after signature (if
modification is necessary after issuance, i.e. re-certification of a part), a new form with a
new number and reference to the initial issuance should be made);
provide for a ‘personal’ electronic signature, identifying the signatory. The signature
should be generated only in the presence of the signatory.
An electronic signature means data in electronic form which are attached to or logically
associated with other electronic data and which serve as a method of authentication and should
meet the following criteria:
it is uniquely linked to the signatory;
it is capable of identifying the signatory;
it is created using means that the signatory can maintain under their sole control.
The electronic signature is defined as an electronically generated value based on a
cryptographic algorithm and appended to data in a way to enable the verification of the data’s
source and integrity.
POA holders/applicants are reminded that additional national and/or European requirements
may need to be satisfied when operating electronic systems. ‘Directive 1999/93/EC of the
European Parliament and of the Council of 13 December 1999 on a Community framework for
electronic signatures’, as last amended may constitute a reference.
Page 165 of 264
SECTION A — Subpart G — Production organisation approval for products, parts and appliances
The electronic system should be based on a policy and management structure (confidentiality,
integrity and availability), such as:
administrators, signatories;
scope of authorisation, rights;
password and secure access, authentication, protections, confidentiality;
track changes;
minimum blocks to be completed, completeness of information;
archives;
etc.
The electronic system generating the EASA Form 1 may contain additional data such as:
manufacturer code;
customer identification code;
workshop report;
inspection results;
etc.
3 Characteristics of the computer generated signature
To facilitate understanding and acceptance of the EASA Form 1 released with an electronic
signature, the following statement should be in Block 13b: ‘Electronic Signature on File’.
In addition to this statement, it is accepted to print or display a signature in any form such as a
representation of the hand-written signature of the person signing (i.e. scanned signature) or
their name.
When printing the electronic form, the EASA Form 1 should meet the general format as
specified in Appendix I to Part 21. A watermark-type ‘PRINTED FROM ELECTRONIC FILE’
should be printed on the document.
When the electronic file contains a hyperlink to data, required to determine the airworthiness of
the item(s), the data associated to the hyperlink, when printed, should be in a legible format
and be identified as a reference from the EASA Form 1.
Additional information not required by the EASA Form 1 completion instructions may be added
to the printed copies of EASA Form 1 as long as the additional data do not prevent a person
from filling out, issuing, printing, or reading any portion of the EASA Form 1. This additional
data should be provided only in block 12 unless it is necessary to include it in another block to
clarify the content of that block.
4. Electronic exchange of the electronic EASA Form 1
The electronic exchange of the electronic EASA Form 1 should be accomplished on a voluntary
basis. Both parties (issuer and receiver) should agree on electronic transfer of the EASA Form
1.
For that purpose, the exchange needs to include:
all data of the EASA Form 1, including data referenced from the EASA Form 1;
all data required for authentication of the EASA Form 1.
In addition, the exchange may include:
data necessary for the electronic format;
additional data not required by the EASA Form 1 completion instructions, such as
manufacturer code, customer identification code.
The system used for the exchange of the electronic EASA Form 1 should provide:
a high level of digital security; the data should be protected, unaltered or uncorrupted;
traceability of data back to its source should be possible.
Trading partners wishing to exchange EASA Form 1 electronically should do so in accordance
with these means of compliance stated in this document. It is recommended that they use an
established, common, industry method such as Air Transport Association (ATA) Spec 2000
Chapter 16.
Page 166 of 264
SECTION A — Subpart G — Production organisation approval for products, parts and appliances
The applicant(s) is/are reminded that additional national and/or European requirements may
need to be satisfied when operating the electronic exchange of the electronic EASA Form 1.
The receiver should be capable of regenerating the EASA Form 1 from the received data
without alteration; if not the system should revert back to the paper system.
When the receiver needs to print the electronic form, refer to the subparagraph 3 above.
Such maintenance activity outside the capability of the Aircraft POA holder may still be
accomplished under the production approval of the original release organisation. In such
circumstances the engine(s), propeller(s), parts and appliances will require re -release in
accordance with GM 21.A.163(c) (EASA Form 1).
Records relevant to continued airworthiness or retirement lives, such as engine runs, flight hours,
landings, etc., which affect part retirement of maintenance schedules must be specified on any
re-release.
As an alternative the engine, propeller, part or appliance may be maintained by the holder of an
approval in accordance with Part 145, classified and released as ‘used’.
AMC 21.A.163(e) Procedure for the issue of a permit to fly including approval of the flight
conditions
1 INTENT
This acceptable means of compliance provides means to develop a procedure for the issue
of a permit to fly including approval of the flight conditions.
Each POA applicant or holder must develop its own internal procedure following this AMC,
in order to obtain the privilege of 21.A.163(e) to issue permits to fly for an aircraft under
procedures agreed with its competent authority for production, when the production
organisation itself is controlling under its POA the configuration of the aircraf t and is
attesting conformity with the design conditions approved for the flight.
2 PROCEDURE FOR THE ISSUE OF A PERMIT TO FLY
2.1 Content
The procedure must address the following points:
as relevant, in accordance with 21.A.710(b), the approval of flight conditions;
conformity with approved conditions;
issue of the permit to fly under the POA privilege;
authorised signatories;
interface with the local authority for the flight.
2.2 Approval of the flight conditions (when relevant)
The procedure must include the process to establish and justify the flight conditions,
in accordance with 21.A.708 and how compliance with 21.A.710(c) is established,
and include the EASA Form 18B as defined in AMC 21.A.709(b) for the approval
under the POA privilege.
2.3 Conformity with approved conditions
The procedure must indicate how conformity with approved conditions is made,
documented and attested by an authorised person.
2.4 Issue of the permit to fly under the POA privilege
The procedure must describe the process to prepare the EASA Form 20b and how
compliance with 21.A.711(c) and (e) is established before signature of the permit to
fly.
2.5 Authorised signatories
The person(s) authorised to sign the permit to fly under the privilege of 21.A.163(e)
must be identified (name, signature and scope of authority) in the procedure, or in an
appropriate document linked to the Production Organisation Exposition.
2.6 Interface with the local authority for the flight
The procedure must include provisions describing the communic ation with the local
authority for compliance with the local requirements which are outside the scope of
the conditions of 21.A.708(b) (see 21.A.711(e)).
[Decision 2007/006/R, 5.4.2007]
[Decision 2010/001/R, 30.03.2010]
GM No. 1 to 21.A.165(c) Obligations of the holder – Conformity of prototype models and test
specimens
21.A.33 requires determination of conformity of prototype models and test specimens to the
applicable design data. The EASA Form 1 may be used as a conformity certificate as part of the
assistance a POA holder/applicant provides to a design approval holder/applicant.
14. The registration has been marked on the exterior of the aircraft as required by national
legislation. Where required by national legislation fix a fireproof owners nameplate.
15. Where applicable there should be a certificate for noise and for the aircraft radio station.
16. The installed compass and or compass systems have been adjusted and compensated and
a deviation card displayed in the aircraft.
17. Software criticality list.
18. A record of rigging and control surface movement measurements.
19. Details of installations which will be removed before starting commercial air transport
operations (e.g., ferry kits for fuel, radio or navigation).
20. Where maintenance work has been performed under the privilege of 21.A.163(d) issue a
release to service that includes a statement that the aircraft is in a condition for safe
operation.
21. List of all applicable Service Bulletins and airworthiness directives that have been
implemented.
As a conformity certificate, only when by virtue of the arrangement described in 21.A. 133(b)
and (c), it can be determined that the part conforms to applicable design data which is not
(yet) approved, for a reason that is indicated in Block 12. Parts released with an EASA
Form 1 as a conformity certificate are not eligible for installation in a type-certificated
aircraft.
The EASA Form 1 should only be used for conformity release purposes when it is possible to
indicate the reason that prevents its issue as for airworthiness release purposes.
[Decision 2010/001/R, 30.03.2010]
GM 21.A.165(d) and (h) Obligations of the holder – Recording and archiving system
Records within a production environment satisfy two purposes. Firstly, they are required, during
the production process to ensure that products, parts, or appliances are in conformity w ith the
controlling data throughout the manufacturing cycle. Secondly, certain records of milestone
events are needed to subsequently provide objective evidence that all prescribed stages of the
production process have been satisfactorily completed and that compliance with the applicable
design data has been achieved.
Therefore, the approved production organisation should implement a system for the compilation
and retention of records during all stages of manufacture, covering short -term and long-term
records appropriate to the nature of the product and its production processes.
The management of such information should be subject to appropriate procedures in the Quality
System required by 21.A.139.
All forms of recording media are acceptable (paper, film, m agnetic, ...) provided they can meet
the required duration for archiving under the conditions provided.
The related organisation procedures should:
Page 171 of 264
SECTION A — Subpart G — Production organisation approval for products, parts and appliances
Describe the organisation of and responsibility for the archiving system (locat ion,
compilation, format) and conditions for access to the information (e.g., by product, subject).
Control access and provide effective protection from deterioration or accidental damage.
Define an archiving period for each type of data taking into account importance in relation
to conformity determination subject to the following:
a Data which supports conformity of a product, part, or appliance should be kept for
not less than three years from the issue date of the related Statement of Conformity
or Authorised Release Certificate.
b Data considered essential for continuing airworthiness should be kept throughout
the operational life of the product, part or appliance.
Ensure that the recording and record-keeping system used by the partners, supplier and
sub-contractors meet the objective of conformity of the product, part or appliance with the
same level of confidence as for their own manufacture. They should define in each case
who is to retain the record data (organisation or partner, supplier or sub -contractor). They
should also define method for surveillance of the recording/record keeping system of the
partners, suppliers or sub-contractors.
CERTIFICATION
SPECIFICATIONS AND PRODUCT
ENVIRONMENTAL PROTECTION SPECIFICATION
REQUIREMENTS
DESIGN
ANALYSIS &
TYPE TEST
INVESTIGATION
CERTIFICATION
SYSTEM MONITOR
SHOW
TYPE INVESTIGATION
COMPLIANCE
VERIFICATION OF
COMPLIANCE
DECLARATION
OF COMPLIANCE
21.A.20(bd)
ACCEPTANCE
BY THE AGENCY
TYPE
CERTIFICATION
to determine that they meet the respective requirements, and that they are
provided to the Agency for approval.
3.1.5 Maintenance and Operating Instructions
a. Ensuring the preparation and updating of all maintenance and operating
instructions (including Services Bulletins) needed to maintain airworthiness
(continuing airworthiness) in accordance with relevant CS. For that purpose,
the applicant should:
establish the list of all documents it is producing to comply with the
Appendix referred to in CS 23.1529, CS 25.1529, CS 27.1529, CS
29.1529, CS-E 25 or CS-P 40 (NPA P-3);
define procedures and organisation to produce and issue these
documents, using where applicable and so elected 21.A.263(c)(3)
privilege.
b. In accordance with 21.A.57, 21.A.61, 21.A.107, 21.A.119, 21.A.120 and
21.A.449, ensuring that these documents are provided to all affected
operators and all involved authorities.
3.2 Continued effectiveness of the design assurance system. The organisation should
establish the means by which the continuing evaluation (system monitoring) of the design
assurance system will be performed in order to ensure that it remains effective.
GM No. 2 to 21.A.239(a) Design assurance system for minor changes to type design or minor
repairs to products
1. Purpose
This GM outlines some basic principles and objectives in order to comply with 21.A.239(a) for
organisations designing only minor changes to type design or minor repairs to products.
2. Design assurance system
The design assurance system should include the following:
an organisational structure to:
- control the design
2. The verification should be shown by signing compliance documents, including test programmes
and data.
3. For a product, there is normally only one compliance verification engineer nominated for each
relevant subject. A procedure should cover the non-availability of nominated persons and their
replacement when necessary.
4. For STC cases, when compliance statement and associated documentation are produced by the
TC holder, and when these data are approved under the system of the authority of TC holder,
then the STC applicant does not need to provide, within its own DOA, the independent checking
function required in 21.A.239(b) for these data.
b. The procedures for classifying design changes as ‘major’ or ‘minor’ and for the approval of
minor changes.
c. The procedures for classifying and approving unintentional deviations from the approved
design data occurring in production (concessions or non-conformance’s).
d. The procedure for classifying and obtaining approval for repairs.
5 A general description of the way in which the organisation performs its functions in relation to the
continuing airworthiness of the product it designs, including co-operation with the production
organisation when dealing with any continuing airworthiness actions that are related to production
of the product, part or appliance, as applicable.
6. A description of the human resources, facilities and equipment, which constitutes the means for
design, and where appropriate, for ground and flight testing.
7. An outline of a system for controlling and informing the Staff of the organisation of current
changes in engineering drawings, specifications and design assurance procedures.
8. A description of the recording system for:
a. The type design, including relevant design information, drawings and test reports, including
inspection records of test specimens.
b. The means of compliance.
c. The compliance documentation (compliance check list, reports...).
9. A description of the record keeping system to comply with 21.A.55 and 21.A.105.
10. A description of the means by which the organisation monitors and responds to problems
affecting the airworthiness of its product during design, production and in service in particular to
comply with 21.A.3 (see also GM No. 1 to 21.A.239, paragraphs 3.1.4(s) and (u)).
11. The names of the design organisation authorised signatories. Nominated persons with specific
responsibilities such as mentioned in 21.A.33 and 21.A.35 should be listed.
12. (Reserved).
13. A clear definition of the tasks, competence and areas of responsibility of the Office of
Airworthiness.
14. A description of the procedures for the establishment and the control of the maintenance and
operating instructions (see 21.A.57, 21.A.61, 21.A.107, 21.A.119, 21.A.120 and 21.A.449).
15. A description of the means by which the continuing evaluation (system monitoring) of the design
assurance system will be performed in order to ensure that it remains effective.
AMC No. 2 to 21.A.243(a) Data requirements - Model content of handbook for organisations
designing minor changes to type design or minor repairs to products
Part 1. Organisation
1.1 Objective of handbook and binding statement
1.2 Responsible person for administration of handbook
1.3 Amendment procedure
1.4 List of effective pages
1.5 Distribution list
1.6 Presentation of design organisation (including locations)
1.7 Scope of work (with identification of type and models of products)
1.8 Organisation charts
1.9 Human resources
1.10 Management staff
1.11 Certifying personnel (see GM No. 2 to 21.A.243(d), paragraph 2)
Page 179 of 264
SECTION A — Subpart J — Design organisation approval
Part 2. Procedures
2.1 Management of changes to type design and design of repairs
- configuration control
- classification
- approval of minor changes to type design and minor repairs
2.2 Control of design sub-contractors
2.3 Collecting/Investigating of failures, malfunctions and defects
2.4 Co-ordination with production
2.5 Documentation control
- in relations with the changes and repairs
- in relation with failures/malfunctions and defects (i.e. Services Bulletins)
2.6 Record keeping
Agency on EASA Form Four [EASA form expected]4-DOA (see format in EASA
administrative procedures)EASA website:
http://easa.europa.eu/certification/application-forms.php) in order that they may be seen to
be appropriate in terms of relevant knowledge and satisfactory experience related to the
nature of the design activities as performed by the organisation.
The responsibilities and the tasks of each individual manager should be clearly defined, in
order to prevent uncertainties about the relations, within the organisation. Responsibilities
of the managers should be defined in a way that all responsibilities are covered.
3.3 Personnel making decisions affecting airworthiness and environmental protection
For these personnel, no individual statement is required. The applicant should show to the
Agency that there is a system to select, train, maintain and identify them for all tasks where
they are necessary.
The following guidelines for such a system are proposed:
These personnel should be identified in the handbook, or in a document linked to the
handbook. This, and the corresponding procedures, should enable them to carry out
the assigned tasks and to properly discharge associated responsibilities.
The needs, in terms of quantity of these personnel to sustain the design activities,
should be identified by the organisation.
These personnel should be chosen on the basis of their knowledge, background and
experience.
When necessary, complementary training should be established, to ensure sufficient
background and knowledge in the scope of their authorization. The minimum
standards for new personnel to qualify in the functions should be established. The
training should lead to a satisfactory level of knowledge of the procedures relevant
for the particular role.
Training policy forms part of the design assurance system and its appropriateness
forms part of investigation by the Agency within the organisation approval process
and subsequent surveillance of persons proposed by the organisation.
This training should be adapted in response to experience gained within the
organisation
The organisation should maintain a record of these personnel which includes details
of the scope of their authorisation. The personnel concerned should be provided
with evidence of the scope of their authorisation.
The following minimum information should be kept on record:
a) Name
b) Date of birth
c) Experience and training
d) Position in organisation
e) Scope of the authorisation
f) Date of first issue of the authorisation
g) If appropriate, date of expiry of the authorisation
the Head of the design organisation still carries the ultimate responsibility for compliance of the
organisation with Part 21Subpart J.
4.2 An Office of Airworthiness, or equivalent function, has been established and staffed on a
permanent basis to act as the focal point for co-ordinating airworthiness and environmental
protection matters (see GM No. 1 to 21.A.239 (a) paragraph 3.1.4); it reports directly to the Head
of the design organisation or is integrated into an independent quality assurance organisation
reporting to the Head of the design organisation.
4.3 [Reserved]
4.4 Responsibilities for all tasks related to Type Investigations are assigned in such a way that gaps
in authority are excluded.
4.5 The responsibility for a number of tasks as in paragraph 4.4 may be assigned to one person
especially in the case of simple projects.
4.6 Co-ordination between technical departments and the persons in charge of the system
monitoring required by 21.A.239(a)(3) has been established :
a. to ensure quick and efficient reporting and resolution of difficulties encountered using the
handbook and associated procedures
b. to maintain the design assurance system
c. to optimise auditing activities.
- the Head of the design organisation [GM No. 1 to 21.A.239(a), para.3.1.2, GM No. 1
to 21.A.245, para.4.1, GM 21.A.265(b)]
- the Chief of the Office of Airworthiness [GM No. 1 to 21.A.245, para. 4.2]
- the Chief of the independent monitoring function of the design assurance system
[21.A.239(a)(3) and AMC No. 1 to 21.A.243(a), para.2]
New distribution of responsibilities affecting airworthiness or environmental protection
For organisations designing minor changes to type design or minor repairs to products,
change of the persons identified in GM No. 2 to 21.A.243(d).
3. Procedures
Change to the principles of procedures related to :
the type certification
the classification of changes and repairs as ‘ major ‘ or ‘ minor ‘ [21.A.263(c)(1)]
the treatment of major changes and major repairs
the approval of the design of minor changes and minor repairs [21.A.263(c)(2)]
the issue of information and instructions under the privilege of 21.A.263(c)(3)
the approval of minor revisions to the Aircraft Flight Manual [21.A.263(c)(4)]
the approval of the design of major repairs [21.A.437 or 21.A.263(c)(5)]
continued airworthiness (see 21.A.3)
the configuration control, when airworthiness or environmental protection is affected
the acceptability of design tasks undertaken by partners or sub-contractors [21.A.239(c)].
4. Resources
Substantial reduction in number and/or experience of staff (see 21.A.245(a)).
GM 21.A.249 Transferability
1. Transfer of the approval would normally only be agreed in cases where the organisation itself
remains substantially unchanged.
2. An acceptable transfer situation could be for example a change of company name (supported by
the appropriate certificate from the National Companies Registration Office or equivalent) but with
no changes to site address or Chief Executive. However, if the same legal entity were to relocate
to new premises with a new Chief Executive and/or new departmental heads, then a substantial
investigation by the Agency would be necessary such that the change would be classified as a
re-approval.
3. In the event of receivership there may be good technical justification for continuation of the
approval provided that the company continues to function in a satisfactory manner. It is likely that
at a later stage the approval might be surrendered by the receiver or transferred to another legal
entity in which case the former paragraphs apply.
4. Scopes of work are, for example, ‘subsonic turbojet aeroplanes’, ‘turbopropeller aeroplanes’,
‘small aeroplanes’, ‘rotorcraft’... Technologies are quoted in the scope of work when it is
considered by the Agency as a limitation for the design organisation approval.
5. For repair design activities, the certificate states the scope of work with the appropriate limitations
for which the approval has been granted.
GM 21.A.257(a) Investigations
Arrangements that allow the Agency to make investigations include the complete design organisation
including partners, sub-contractors and suppliers, whether they are in the State of the applicant or not,
assisting and co-operating with the Agency in performing inspections and audits conducted during initial
assessment and subsequent surveillance.
Assistance to the Agency includes all appropriate means associated with the facilities of the design
organisation to allow the Agency to perform these inspections and audits, such as a meeting room and
office support.
When the organisation responsible for the design of the engine/propeller has a DOA, the establishment
and substantiation of these conditions must be done under the relevant DOA procedures. For that
purpose, the associated documentation must be processed like any other compliance document. It
must be provided to the organisation responsible for the design of the aircraft that will use it for the
establishment of the aircraft flight conditions.
[Decision 2007/006/R, 5.4.2007]
AMC No. 1 to 21.A.263(c)(1) Procedure for the classification of changes to type design and
repairs as minor and major
1. INTENT
This acceptable means of compliance provides means to develop a procedure for the
classification of changes to type design and repairs.
Each DOA applicant must develop its own internal classification procedure following this AMC, in
order to obtain the associated 21.A.263(c)(1) privilege.
2. PROCEDURE FOR THE CLASSIFICATION OF CHANGES TO TYPE DESIGN AND REPAIRS
2.1 Content
The procedure must address the following points:
the identification of changes to type design or repairs
classification
justification of the classification
authorised signatories
supervision of changes to type design or repairs initiated by sub-contractors.
For changes to type design, criteria used for classification must be in compliance with
21.A.91 and GM 21.A.91.
For repairs, criteria used for classification must be in compliance with 21.A.435 and GM
21.A.435.
2.2 Identification of changes to type design or repairs
The procedure must indicate how the following are identified:
major changes to type design or major repairs
those minor changes to type design or minor repairs where additional work is
necessary to showdemonstrate compliance with the CS and environmental
protection requirements
other minor changes to type design or minor repairs requiring no further
showingdemonstration of compliance.
2.3 Classification
The procedure must show how the effects on airworthiness and environmental protection
are analysed, from the very beginning, by reference to the applicable requirements.
If no specific CS or environmental protection requirements are applicable to the change or
repairs, the above review must be carried out at the level of the part or system where the
change or repair is integrated and where specific CS or environmental protection
requirements are applicable.
2.4 Justification of the classification
All decisions of classification of changes to type design or repairs as ‘major’ or ‘minor’ must
be recorded and, for those which are not straightforward, also documented. These records
must be easily accessible to the Agency for sample check.
2.5 Authorised signatories
AMC No. 2 to 21.A.263(c)(1) Privileges - Organisations designing minor changes to type design
or minor repairs to products : classification procedure
1. Content
The procedure must address the following points:
configuration control rules, especially the identification of changes to type design or repairs
classification, in compliance with 21.A.91 and GM 21.A.91 for changes and GM 21.A.435
for repairs
justification of the classification
authorised signatories.
2. Identification of changes to type design or repairs
The procedure must indicate how the following minor changes to type design or minor repairs are
identified:
those minor design changes to type design or minor repairs where additional
substantiation data is necessary to showdemonstrate compliance with the CS or
environmental protection requirements
other minor design changes to type design or minor repairs requiring no further
showingdemonstration of compliance.
3. Classification
The procedure must show how the effects on airworthiness and environmental protection are
analysed, from the very beginning, by reference to the applicable requirements.
If no specific requirements are applicable to the change or the repair, the above review must be
done at the level of the part or system where the change or repair is integrated and where
specific CS or environmental protection requirements are applicable.
For repair, see also GM 21.A.435.
4. Justification of the classification
All decisions of classification of changes to type design or repairs as ‘minor‘ must be recorded
and, for those which are not straightforward, also documented. These records must be easily
accessible to the Agency for sample check.
It may be in the format of meeting notes or register.
5. Authorised signatories
All classifications of changes to type design or repairs must be accepted by an appropriate
authorised signatory.
The procedure must indicate the authorised signatories for the various products listed in the
terms of approval.
AMC No. 1 to 21.A.263(c)(2) Procedure for the approval of minor changes to type design or
minor repairs
1. INTENT
This acceptable means of compliance provides means to develop a procedure for the approval of
minor changes to type design or minor repairs.
Each DOA applicant must develop its own internal procedures following this AMC, in order to
obtain the associated privilege under 21.A.263(c)(2).
2. PROCEDURE FOR THE APPROVAL OF MINOR CHANGES TO TYPE DESIGN OR MINOR
REPAIRS
2.1 Content
The procedure must address the following points:
compliance documentation
approval under the DOA privilege
authorised signatories
supervision of minor changes to type design or minor repairs handled by sub-
contractors.
2.2 Compliance documentation
For those minor changes to type design or minor repairs where additional work to
showdemonstrate compliance with the applicable CS and environmental protection
requirements is necessary, compliance documentation must be established and
independently checked as required by 21.A.239(b).
The procedure must describe how the compliance documentation is produced and
checked.
2.3 Approval under the DOA privilege
2.3.1 For those minor changes to type design or minor repairs where additional work to
showdemonstrate compliance with the applicable CS and environmental protection
requirements is necessary, the procedure must define a document to formalise the
approval under the DOA privilege.
This document must include at least:
identification and brief description of the change or repair and reasons for
change or repair
applicable CS or environmental protection requirements and methods of
compliance
reference to the compliance documents
effects, if any, on limitations and on the approved documentation
evidence of the independent checking function of the showingdemonstration
of compliance
evidence of the approval under the privilege of 21.A.263(c)(2) by an
authorised signatory
date of the approval.
For repairs, see AMC 21.A.433(a).
2.3.2 For the other minor changes to type design or minor repairs, the procedure must
define a means to identify the change or repair and reasons for the change or repair,
and to formalise its approval by the appropriate engineering authority under an
authorised signatory. This function may be delegated by the Office of Airworthiness
but must be controlled by the Office of Airworthiness, either directly or through
appropriate procedures of the DOA holder’s design assurance system.
Page 188 of 264
SECTION A — Subpart J — Design organisation approval
AMC No. 2 to 21.A.263(c)(2) Privileges - Organisations designing minor changes to type design
or minor repairs to products : procedure for the approval of minor changes to type design or
minor repairs
1. Content
The procedure must address the following points:
compliance documentation
approval under the DOA privilege
authorised signatories.
2. Compliance documentation
For those minor changes to type design or minor repairs where additional work to
showdemonstrate compliance with the applicable CS and environmental protection requirements
is necessary, compliance documentation must be established and independently checked as
required by 21.A.239(b).
The procedure must describe how the compliance documentation is produced and checked.
3. Approval under the DOA privilege
3.1. For those minor changes to type design or minor repairs where additional work to
showdemonstrate compliance with the applicable CS or environmental protection
requirements is necessary, the procedure must define a document to formalise the
approval under the DOA privilege.
This document must include at least:
identification and brief description of the change or the repair and reason for change
or repair
applicable CS or environmental protection requirements and methods of compliance
reference to the compliance documents
effects, if any, on limitations and on the approved documentation
evidence of the independent checking function of the showingdemonstration of
compliance
evidence of the approval under the privilege of 21.A.263(c)(2) by an authorised
signatory
date of the approval
For repairs, see also AMC 21.A.433(a).
3.2. For the other minor changes to type design or minor repairs, the procedure must define a
means to identify the change or repair and reasons for the change or repair, and to
formalise its approval by the appropriate engineering authority under an authorised
signatory. This function must be controlled through appropriate procedures of the DOA
holder's design assurance system.
4. Authorised signatories
The persons authorised to sign for the approval under the privilege of 21.A.263(c)(2) must be
identified (name, signature and scope of authority) in appropriate documents that may be linked
to the handbook.
2.1 The following revisions to the AFM are defined as minor revisions:
(a) Revisions to the AFM associated with changes to type design classified as minor in
accordance with 21.A.91
(b) Revision to the AFM not associated with changes to type design (also identified as
stand-alone revisions), that falls under one of the following:
- Changes to limitations or procedures that are achieved without altering or
exceeding certification data (e.g. weight, structural, noise, etc.)
- Consolidation of two or more previously approved and compatible AFMs into
one, or compilation of different parts taken from previously approved and
compatible AFMs that are directly applicable to the subject aircraft
- The introduction of compatible and previously approved AFM amendments,
revisions, appendices or supplements.
(c) Administrative revisions to the AFM, defines as follows:
- Changes to weight limitations parts of the AFM that are within all
previously EASA approved limitations (e.g., structural, noise, etc.)not
required to be approved by EASA
- Conversions of previously FAA or EASA approved combinations of
units of measurement added to the AFM supplement in a previously
approved manner.
- The addition of aircraft serial numbers to an existing AFM supplement
where the aircraft configuration, as related to the AFM supplement, is
identical to aircraft already in that AFM supplement.
- The addition of a new STC to an existing AFM supplement, when this
supplement is fully applicable to the new STC
- The removal of reference to aircraft serial numbers no longer applicable
to that AFM supplement.
- The translation of an EASA approved AFM into the language of the
State of Design or the State of Registration.
2.2 No other revision can be classified as minor, unless specifically agreed by the Agency.
- distribution.
3.2 Preparation
The procedure should indicate how revisions to the AFM changes are prepared and how
the co-ordination with people in charge of design changes is performed.
3.3 Classification
The procedure should indicate how revisions to the AFM changes are classified as
documentary changesminor, in accordance with the criteria of paragraph 2.
All decisions of classification of minor revisions to the AFM that are not straightforward
must be recorded and documented. These records must be easily accessible to the
Agency for sample check.
All classifications of minor revisions to AFM must be accepted by an appropriate
authorised signatory.
The procedure must indicate the authorised signatories for the various products listed in
the terms of approval.
Changes to the AFM of an editorial nature should be non-technical and should normally
only affect existing approved data.
3.54 Approval
Any change to the AFM should be approved, either by the Agency, or under the privilege of
21A.263(c)(4) for documentary AFM changes.
For documentary AFM changes, t The procedure should indicate how the approval under
the privilege of 21.A.263(c)(4) will be formalised.
The authorised signatories should be identified (name, signature), together with the scope
of authorisation, in a document that can be linked to the DOA handbook.
Revisions of the AFM under the privilege of 21.A.263(c)(4) containing only documentary changes
should be issued with the approval statement defined in 21A.263(c)(4) on the front page and/or in
the log of revisions..
When approval status is shown on each page, a simplified statement such as "Approved under
the authority of DOA nr.[EASA].J.[xyz] " may be used.
The authorised signatories should be identified (name, signature), together with the scope of
authorisation, in a document that can be linked to the DOA handbook.
AMC 21.A.263(c)(6) Procedure for the approval of the conditions for issue of a permit to fly
1. INTENT
This AMC provides means to develop a procedure to determine that an aircraft can fly, under the
appropriate restrictions compensating for noncompliance with the certification specifications
applicable to the aircraft category.
Each DOA applicant or holder must develop its own internal procedure following this AMC, in
order to obtain the privilege to make this determination and approve associated conditions
without Agency involvement, under 21.A.263(c)(6). When the privilege does not apply, the DOA
holder will prepare all necessary data required for the determination in accordance with the same
procedure required for the privilege, and will apply for Agency approval.
2. PROCEDURE FOR THE APPROVAL OF THE CONDITIONS FOR ISSUE OF A PERMIT TO
FLY
2.1 Content
The procedure must address the following points:
- decision to use the privilege
- management of the aircraft configuration
- determination of the conditions that must be complied with to perform safely a flight
- documentation of flight conditions substantiations
- approval under the DOA privilege, when applicable
- authorised signatories.
2.2 Decision to use the privilege of 21.A.263(c)(6)
The procedure must include a decision to determine:
- flights for which the privilege of 21.A.263(c)(6) will be exercised.; and
- flights for which the approval of flight conditions by the Agency will be required
according to the criteria of 21A.263(c)(6).
2.3 Management of the aircraft configuration
The procedure must indicate:
- how the aircraft, for which an application for permit to fly is made, is identified;
- how changes to the aircraft will be managed.
2.4 Determination of the conditions that must be complied with to perform safely a flight
The procedure must describe the process used by the DOA holder to justify that an aircraft
can perform the intended flight(s) safely. This process should include:
- identification of deviations from applicable certification specifications or non-
compliance with Part 21 conditions for the issue of a certificate of airworthiness;
- analysis, calculations, tests or other means used to determine under which
conditions or restrictions the aircraft can perform safely a flight;
- the establishment of specific maintenance instructions and conditions to perform
these instructions;
- independent technical verification of the analysis, calculations, tests or other means
used to determine under which conditions or restrictions the aircraft can perform the
intended flight(s) safely;
- statement by the office of airworthiness (or equivalent), that the determination has
been made in accordance with the procedure and that the aircraft has no features
and characteristics making it unsafe for the intended operation under the identified
conditions and restrictions;
- approval by an authorised signatory.
2.5 Documentation of flight conditions substantiations
1. The analysis, calculations, tests, or other means used to determine under which
conditions or restrictions the aircraft can perform safely a flight, must be compiled in
compliance documents. These documents must be signed by the author and by the
person performing the independent technical verification.
2. Each compliance document must have a number and issue date. The various issues
of a document must be controlled.
3. The data submitted and approved by the type-certificate holder can be used as
substantiations. In that case, the independent technical verification referred to in 2.4
is not required.
2.6 Approval under the DOA privilege
2.6.1 Initial approval
The procedure must include the following EASA Form 18A to support the approval
under the DOA privilege:
5. Purpose
[Purpose in accordance with 21.A.701(a)]
6. Aircraft configuration
The above aircraft for which a permit to fly is requested is defined in [add reference to the
document(s) identifying the detailed configuration of the aircraft]
[For change(s) affecting the initial approval form: description of change(s). This form must be re-
issued]
7. Substantiations
[References to the document(s) justifying that the aircraft (as described in 56.) can perform the
intended flight(s) safely under the defined conditions or restrictions.]
[For change(s) affecting the initial approval form: reference(s) to additional substantiation(s). This
form must be re-issued]
8. Conditions/Restrictions
The above aircraft must be used with the following conditions or restrictions:
[Details of these conditions/restrictions, or reference to relevant document, including specific
maintenance instructions and conditions to perform these instructions]
9. Statement
The determination of the flight conditions has been made in accordance with the relevant DOA
procedure agreed by the Agency.
The aircraft as defined in block 6 above has no features and characteristics making it unsafe for the
intended operation under the identified conditions and restrictions.
[strikethrough what is not applicable]
10a. Approved under the authority of DOA EASA.21J.xyz [when privilege of 21.A.263(c)(6)
applies]
10b. Submitted under the authority of DOA EASA.21J. xyz [when privilege of 21.A.263(c)(6)
does not apply]
When the privilege of 21.A.263(c)(6) is not applicable, the signed form should be
presented by the office of airworthiness (or equivalent) to the Agency.
2.6.2 Approval of changes
Except for changes that do not affect the conditions approved for the issue of the
permit to fly, the procedure must specify how changes will be approved by the DOA
Holder. The form of paragraph 2.6.1EASA Form 18A must be updated.
2.7 Authorised signatories
The person(s) authorised to sign the approval form must be identified (name, signature
and scope of authority) in the procedure, or in an appropriate document linked to the DOA
handbook.
[Decision 2007/006/R, 5.4.2007]
[Decision 2010/001/R, 30.03.2010]
Subpart M — Repairs
GM 21.A.431(a) Scope
Manuals and other instructions for continued airworthiness (such as the Manufacturers Structural
Repair Manual, Maintenance Manuals and Engine Manuals provided by the holder of the type -
certificate, supplemental type-certificate, design approval or APU ETSO authorisation as
applicable) for operators, contain useful information for the development and approval of repairs.
When these data are explicitly identified as approved, they may be used by operators without
further approval to cope with anticipated in-service problems arising from normal usage provided
that they are used strictly for the purpose for which they have been developed.
Approved data is data which is approved either by the Agency, or by an appropriately approved
design organisation.
NB: Flow Chart 1 addresses the procedures that should be followed for products where the State of
design is a Member State
Flow Chart 2 addresses procedures that should be followed for products where the State of
design is not a Member State.
When specific repair data is approved outside of the Community, conditions for acceptance may be
defined in the bilateral arrangements between the Community and the competent authority of a third
country. In the absence of such arrangement, the repair data shall follow the approval route as if it
was designed and approved within the Community.
AMC 21.A.433 (a) and 21.A.447 Repair design and record keeping
1. Relevant substantiation data associated with a new major repair desi gn and record keeping
should include:
a. damage identification and reporting source,
b. major repair design approval sheet identifying applicable requirementsspecifications
and references of justifications,
c. repair drawing and/or instructions and scheme identifier,
d. correspondence with the TC, STC, design approval or ETSOAAPU ETSO
authorisation holder, if its advice on the design has been sought,
e. structural justification (static strength, fatigue, damage tolerance, flutter etc .) or
references to this data,
f. effect on the aircraft, engines and/or systems, (performance, flight handling, etc ., as
appropriate)
gravity and aircraft load distribution. Control surfaces are par ticularly sensitive to the
changes due to the effect upon the stiffness, mass distribution and surface profile
which may have an effect upon flutter characteristics and controllability.
iii) Systems
Repairs to any elements of a system should be assessed for the effect intended on
the operation of the complete system and for the effect on system redundancy. The
consequence of a structural repair on an adjacent or remote system should also be
considered as above, (for example: airframe repair in area of a s tatic port).
iv) Operational characteristics
Changes may include:
- stall characteristics
- handling
- performance and drag
- vibration
v) Other characteristics
- changes to load path and load sharing
- change to noise and emissions
- fire protection / resistance
Note: Considerations for classifying repairs 'Major/Minor' should not be limited to those
listed above.
3. Examples of 'Major' repairs
i) A repair that requires a permanent additional inspection to the approved
maintenance programme, necessary to ensure the continued airworthiness of the
product. Temporary repairs for which specific inspections are required prior to
installation of a permanent repair do not necessarily need to be classified as 'Major'.
Also, inspections and changes to inspection frequencies not required as part of the
approval to ensure continued airworthiness do not cause classification as 'Major' of
the associated repair.
ii) A repair to life limited or critical parts.
iii) A repair that introduces a change to the Aircraft Flight Manual.
These are repairs that are life limited, to be removed and replaced by a permanent repair
after a limited service period. These repairs should be classified under 21.A.435 and the
service period defined at the approval of the repair.
4) Fatigue and damage tolerance.
When the repaired product is released into service before the fatigue and damage
tolerance evaluation has been completed, the release should be for a limited service
period, defined at the issue of the repair.
v) A summary list of all major repair approvals being provided to the Agency on a
regular basis as agreed with the Agency.
vi) Whether the repair design is affected by the presence of any supplemental type -
certificate.
GM 21.A.443 Limitations
Instructions and limitations associated with repairs should be specified and controlled by those
procedures required by the applicable operations rules.
Damage
Initial assessment
Other DOA TC/STC Holder EASA
& DOA
Is there an (Member States) (Member States)
existing solution
available and yes
approved ?
APPLY
SOLUTION
no
Agency
New design
TC/STC Holder
Legend: A : go to “ Apply solution “ B : go to EASA or TC/STCH for approval of major repair (only if T C/STC holder has
DOA privilege for major repair)
Initial assessment
Other DOA EASA
( Member States)
Is there an
existing solution
available and yes
approved ?
APPLY
SOLUTION
no
Agency
New design
STANDARD FORM
The following are examples of information to be given under this heading depending on the
nature of the article and the requirementsspecifications of the ETSO.
(a) Environmental Qualification
i. Temperature and Altitude
ii. Temperature Variation
iii. Humidity
iv. Operational Shocks and Crash Safety
v Vibration
vi. Explosion Proofness
vii. Waterproofness
viii. Fluids Susceptibility
ix. Sand and Dust
x. Fungus Resistance
xi. Salt Spray
xii. Magnetic Effect
xiii. Power Input
xiv. Voltage Spike
xv. Audio Frequency Conducted Susceptibility - Power Inputs
xvi. Induced Signal Susceptibility
Page 206 of 264
SECTION A/Subpart O AMC & GM for PART 21
……………………………………………………………………………………(name of manufacturer)
(Manufacturer’s name) cannot accept responsibility for equipment used outside the limiting
conditions stated above without their agreement.
GM to Subpart P
The process allowing a flight under a permit to fly can be described as follows:
1. Flow-chart 1: overview
2. Flow-chart 2: approval of flight conditions
3. Flow-chart 3: issue of permit to fly
4. Flow-chart 4: changes after first issue of permit to fly
Flow-chart 1: overview
Operator/Owner
1
Need for a
permit to fly
NO Flight
Are there flight
conditions
conditions available
approval
and approved?
2
YES
Issue of permit to
fly 3
Changes
4
Application to
Related to
YES EASA, with data
safety of the
and approval
design?
form
[21.A.709(a)(1)]
NO
Case covered NO
by privilege?
Application to
Has the applicant the
NO competent authority
privilege to issue the
[21.A.707/21.A.711]
permit to fly?
YES
permit to
fly
Application to
Related to
YES EASA, with data
safety of the
and approval
design?
form
[21A.709(a)(1)
NO ]
Case covered NO
by privilege?
Need to re-issue
YES 3
the permit to fly
itself? [21A.713]
NO
END
of a (restricted) certificate of airworthiness may not be possible or appropriate and this paragraphGM
provides further information and typical examples for clarification where appropriate: -
Note: This list of examples is not exhaustive
(1) Development:
- testing of new aircraft or modifications
- testing of new concepts of airframe, engine, propeller and equipment;
- testing of new operating techniques;
(2) ShowingDemonstration of compliance with regulations or certification specifications:
- certification flight testing for type certification, supplemental type certificates, changes to
type certificates or ETSO authorisation;
(3) Design organisations or production organisations crew training:
- Flights for training of crew that will perform design or production flight testing before the
design approval andor Certificate of Airworthiness (C of A) can be issued.
(4) Production flight testing of new production aircraft:
- For establishing conformity with the approved design, typically this would be the same
program for a number of similar aircraft;
(5) Flying aircraft under production between production facilities:
- green aircraft ferry for follow on final production.
(6) Flying the aircraft for customer acceptance:
- Before the aircraft is sold and/or registered.
(7) Delivering or exporting the aircraft:
- Before the aircraft is registered in the State where the C of A will be issued.
(8) Flying the aircraft for Authority acceptance:
- In the case of inspection flight test by the authority before the C of A is issued.
(9) Market survey, including customer’s crew training:
- Flights for the purpose of conducting market survey, sales demonstrations and customer
crew training with non type-certificated aircraft or aircraft for which conformity has not yet
been established or for non-registered a/c and before the Certificate of Airworthiness is
issued.
(10) Exhibition and air show:
- Flying the aircraft to an exhibition or show and participating to the exhibition or show
before the design approval is issued or before conformity with the approved design has
been shown.
(11) Flying the aircraft to a location where maintenance or airworthiness review are to be performed,
or to a place of storage:
- Ferry flights in cases where maintenance is not performed in accordance with approved
programmes, where an AD has not been complied with where certain equipment outside
the Master Minimum Equipment List (MMEL) is unserviceable or when the aircraft has
sustained damage beyond the applicable limits.
(12) Flying an aircraft at a weight in excess of its maximum certificated take-off weight for flight
beyond the normal range over water, or over land areas where adequate landing facilities or
appropriate fuel is not available:
- Oversees ferry flights with additional fuel capacity.
(13) Record breaking, air racing or similar competition:
- Training flight and positioning flight for this purpose are included
GM 21.A.701 Scope
An aircraft registered outside the Member States and used for flight testing by an organisation which
has its principle place of business in a Member State, remains under the authority of its state of
registry. The Agency or an appropriately approved design organisation can provide, on request,
technical assistance to the state of registry for the issue of a permit to fly, or equivalent authorisation,
under the state of registry applicable regulations.
[Decision 2007/006/R, 5.4.2007]
GM 21.A.707(b) Application
EASA Form 21 (see AMC 21.B.520(b)) should be obtained from the competent authority.
[Decision 2007/006/R, 5.4.2007]
c. Are the fuel tanks vented to the outside? Are all areas in which tanks are located
ventilated to reduce fire, explosion, and toxicity hazards?
d. Are the tanks even when empty strong enough to withstand the differential pressure at
maximum operating altitude for a pressurized aircraft?
e. Have means been provided for determining the fuel quantity in each tank prior to flight?
f. Are shutoff valves, accessible to the pilot, provided for each additional tank to disconnect
these tanks from the main fuel system?
g. Are the additional fuel tank filler connections designed to prevent spillage within the
aircraft during servicing?
h. Is the engine oil supply and cooling adequate for the extended weight and range?
3. LIMITATIONS.
The following types of limitations may be necessary for safe operation of the aircraft:
a. Revised operational airspeeds for use in the overweight condition.
b. Increased pilot skill requirements.
c. A prescribed sequence for using fuel from various tanks as necessary to keep the aircraft
within its centre of gravity range.
d. Notification to the control tower of the overweight take-off condition to permit use of a
runway to minimize flight over congested areas.
e. Avoidance of severe turbulence. If encountered, the aircraft should be inspected for
damage as soon as possible.
EXAMPLE of operating limitations which may be prescribed as part of the permit to fly:
Aircraft type: xxxxxx Model: yyyy
Limitations:
1. Maximum weight must not exceed 8 150 pounds.
2. Maximum quantity of fuel carried in auxiliary tanks must not exceed 106 gallons in fwd tank,
164 gallons in centre tank, and 45 gallons in aft tank.
3. Centre of gravity limits must not exceed (fwd) +116.8 and (aft) +124.6.
4. Aerobatics are prohibited.
5. Use of autopilot while in overweight condition is prohibited.
6. Weather conditions with moderate to severe turbulence should be avoided.
7. When an overweight landing is made or the aircraft has been flown through moderate or severe
turbulence while in an overweight condition, the aircraft must be inspected for damage after
landing. The inspections performed and the findings must be entered in the aircraft log. The
pilot must determine, before the next take-off, that the aircraft is airworthy.
8. When operated in the overweight condition, the cruising speed (Vc) shall not exceed 185 m.p.h.
and the maximum speed (Vne) shall not exceed 205 m.p.h.
9. Operation in the overweight condition must be conducted to avoid areas having heavy air traffic,
to avoid cities, towns, villages, and congested areas, or any other areas where such flights
might create hazardous exposure to person or property on the ground.
[Decision 2007/006/R, 5.4.2007]
All other changes should be approved in accordance with 21.A.713 and when necessary a new permit
to fly should be issued in accordance with 21.A.711.
[Decision 2007/006/R, 5.4.2007]
5. Purpose
6. Aircraft configuration
The above aircraft for which a permit to fly is requested is defined in [add reference to the
document(s) identifying the configuration of the aircraft]
[For change(s) affecting the initial approval form: description of change(s). This form must be re-issued]
7. Substantiations
[References to the document(s) justifying that the aircraft (as described in 56) can perform the intended flight(s)
safely under the defined conditions or restrictions.]
[For change(s) affecting the initial approval form: reference(s) to additional substantiation(s). This form must be
re-issued]
8. Conditions/Restrictions
The above aircraft must be used with the following conditions or restrictions:
When the flight conditions are approved under a privilege, this form should be used by the approved
organisation to document the approval.
[Decision 2007/006/R, 5.4.2007]
[Decision 2010/001/R, 30.03.2010]
GM 21.A.713 Changes
Changes to the conditions or associated substantiations that are approved but do not affect the text
on the permit to fly do not require issuance of a new permit to fly.
In case a new application is necessary, the substantiation for approval of the flight conditions only
needs to address the change.
[Decision 2007/006/R, 5.4.2007]
For designs (TC, STC, ETSO, repair, change) approved after 28 December 2009 (the date of entry
into force of Commission Regulation (EC) No 1194/2009 amending Regulation 1702/2003,), the
design approval holder is required to identify to the manufacturer how the marking in accordance with
21.A.804(a)(1) should be done. This can be limited to identifying a marking field, possible depth
and/or means etc., without prescribing the actual text or symbols to be used.
SECTION B
Subpart A — General provisions
GM 21.B.25(a) Organisation
The competent authority designated by each Member State should have an organisation in such a
way that -
a) there is specific and effective management authority in the conduct of all relevant activities,
b) the functions and processes described in Part 21 and its CSAMC and GM may be properly
implemented,
c) the competent authority of the Member State policy, organisation and operating procedures for
the implementation of Part 21 are properly documented and applied,
d) all competent authority of the Member State personnel involved in the related activities are
provided with training where necessary,
e) specific and effective provision is made for the communication and interface as necessary with
the Agency and the competent authorities of the Member States,
f) all functions related to the implementation of Part 21 are adequately described and shown
(Standardisation).
A general policy in respect of Part 21 activities should be developed, sponsored and implemented by
the manager at the highest appropriate level, for example the top of the functional area of the
competent authority of the Member State that is responsible for the related matters.
Appropriate steps should be taken to ensure that the policy is known and understood by all staff
involved, and all necessary steps should be taken to implement and maintain the policy.
Whilst satisfying also additional national regulatory responsibilities, the general policy should in
particular take into account:
(a) the provisions of the Basic Regulation (EC) No 216/2008
(b) the provisions of Part 21 and its CSAMC and GM
(c) the needs of industry
(d) the needs of the Agency and of the competent authorities of the Member States.
The policy should define specific objectives for key elements of the organisation and processes for
implementation of related Part 21 activities, including the corresponding control procedures and the
measurement of the achieved standard.
GM 21.B.25(b) Resources
The organisation for related Part 21 activities should be clearly defined within the general organisation
of the competent authority of the Member State, with the hierarchical and functional links, and the
names of the senior staff. Although final responsibility should be placed at the top of the functional
area that is responsible for the related Part 21 activities as a whole, all subordinate levels of
management should be suitably resourced and empowered to fulfil their delegated tasks.
The definition of an organisation for the implementation of related Part 21 activities should include the
specification of
a) a manager responsible for the specific Part 21 activity acting as internal and external focal point.
The responsibility is best placed with the manager who is in control of the day-to-day functions
concerning the specific Part 21 activity, although he may delegate specific tasks to other
individuals;
b) individual or group responsibilities, duties and associated reporting lines;
c) the resources, human and material;
d) the documented procedures to be operated in respect of the relevant Part 21 activities.
The various tasks and responsibilities of the personnel involved in the related Part 21 activities should
be clearly identified. The authority attached to the responsibilities should be enough to ensure that the
activities will be performed correctly.
These responsibilities include among others:
a) the management of the organisation
b) the management of investigation teams
c) the team leadership/membership
d) the investigation and surveillance activities
e) the administrative management of certificates and approvals including record keeping
f) the external and internal interface activities including feedback to the Agency
g) the control and distribution of documentation
The definition of the organisation should include means to ensure continued effectivity of the
organisation. The means should provide for a regular assessment of the organisation and its related
activities as well as a feedback system for the follow up of necessary corrective actions (e.g., through
the implementation of a quality system, internal audit system, etc.).
c) optimise the use of the Agency and the competent authorities resources to minimise disruption
and cost.
Therefore, for a given organisation / applicant the responsible person(s) of the Agency or competent
authorities of the Member State should arrange for exchange of information with, and provide
necessary assistance, as appropriate, to the relevant competent authority of the Member State or
Agency teams or staff - e.g.:
a) the appropriate certification teams;
b) the design organisation approval team;
c) the production organisation approval team;
d) the maintenance organisation approval team; or
e) other approval or certification teams as appropriate.
1. Type-certificate
a) Copy of the type-certificate
b) Copy of the type-certificate data sheet
c) Environmental protection approval data
d) Documents defining the type-certification basis including information to justify special
conditions, equivalent safety findings and exemptions (Certification Review Items or
equivalent)
e) List of approved modifications,
f) List of the competent authority’s approved publications (Flight Manual, Repair Manual,
Airworthiness Limitations, Certification Maintenance Requirements)
g) Airworthiness directives
h) Master Minimum Equipment List
i) Maintenance Review Board Report
2. Supplemental type certificate
AMC 21.B.120(a) Investigation team - Qualification criteria for the investigation team
members
The competent authority must ensure that the team leader and team members have received
appropriate training in the relevant Subpart of Part 21 and in the related competent authority
documentation before performing investigations. They must also have knowledge and experience at
the appropriate level in aviation production and inspection activities relative to the particular
application for a letter of agreement.
EASA Form 60
Application for agreement of production under Part 21 Subpart F
Competent authority
of
a an EU Member State of the European Union or
EASA
7. Human resources:
Date Signature
EASA Form 60 Issue 3
Block 1: The name of the applicant must be entered. For legal entities the name must be as stated in
the register of the National Companies Registration Office. In this case a copy of the entry in
the register of the National Companies Registration Office must be provided to the
competent authority.
Block 2: State the trade name by which the applicant is known to the public if different from the
information given in Block 1. The use of a logo may be indicated in this Block.
Block 3: State all locations of manufacturing activities that are covered by the application. Only those
locations must be stated that are directly under the control of the applicant stated in Block 1.
Block 4: This Block must include further details of the manufacturing activities under the approval for
the addresses indicated in Block 3. The Block ‘Identification’ must indicate the products,
parts or appliances intended to be produced, while the Block ‘Termination’ must address
any information on the limitation of the activity, e.g., by stating the intended number of units
to be manufactured or the expected date of completion of the manufacturing activities.
Block 5: This Block must state evidence supporting the determination of applicability as stated in
21.A.121. In addition an outline of the manual required by 21.A.125(b) must be provided
with the application.
Block 6: The information entered here is essential for the evaluation of eligibility of the application.
Therefore special attention must be given concerning the completion of this Block either
directly or by reference to supporting documentation in relation to the requirements of
21.A.122 and AMC 21.A.122.
Block 7: The information to be entered here must reflect the number of staff, or in case of an initial
approval the intended number of staff, for the manufacturing activities under this application
and therefore must include also any associated administrative staff.
Block 8: State the name of the person authorised to sign the application.
[Decision 2007/012/R, 29.11.2007]
manufacturer describing its inspection procedures or non-conformities related to the items under
inspection. The manner in which the findings will be handled by the competent authority before and
during the validity of the letter of agreement, should be detailed in its procedures.
EASA Form 50
Application for Part 21 production organisation approval
Competent authority
of
a an EU Member State of the European Union or
EASA
a) General:
b) Scope of approval:
c) Nature of privileges:
5. Description of organisation:
Block 1: The name of the organisation must be entered as stated in the register of the National Companies
Registration Office. For the initial application a copy of the entry in the register of the National
Companies Registration Office must be provided to the competent authority.
Block 2: State the trade name by which the organisation is known to the public if different from the
information given in Block 1. The use of a logo may be indicated in this Block.
Block 3: State all locations for which the approval is applied for. Only those locations must be stated that are
directly under the control of the legal entity stated in Block 1.
Block 4: This Block must include further details of the activities under the approval for the addresses
indicated in Block 4. The Block ‘General’ must include overall information, while the Block ‘Scope
of approval’ must address the scope of work and products/categories following the principles laid
down in the GM 21.A.151. The Block ‘nature of privileges’ must indicate the requested privileges
as defined in 21.A.163(b)-(de). For an application for renewal state ‘not applicable’.
Block 5: This Block must state a summary of the organisation with reference to the outline of the production
organisation exposition, including the organisational structure, functions and responsibilities. The
nomination of the responsible managers in accordance with 21.A.145(c)(2) must be included as far
as possible, accompanied by the corresponding EASA Forms 4.
For an application for renewal state ‘not applicable’.
Block 6: The information entered here is essential for the evaluation of eligibility of the application. Therefore
special attention must be given concerning the completion of this Block either directly or by
reference to supporting documentation in relation to the requirements of 21.A.133(b) and (c) and
the AMC to 21.A.133(b) and (c).
Block 7: The information to be entered here must reflect the number of staff, or in case of an initial approval
the intended number of staff, for the complete activities to be covered by the approval and
therefore must include also any associated administrative staff.
Block 8: State the position and name of the accountable manager.
3.3 co-ordinates with the appropriate Part 21 Section A Subpart J design organisation approval
Teams sufficiently for both parties to have confidence in the applicants co-ordination links with
the holder of the approval of the design (as required by 21.A.133)
3.4 establishes liaison with the applicant to plan mutually suitable dates and times for visits at each
location needing investigation, and also to agree the investigation plan and approximate time
scales with the applicant
4. Investigation
The POAT:
4.1 makes a check of the POE for compliance with Part 21 Subpart G
4.2 audits the organisation, its organisational structure, and its procedures for compliance with Part
21 Subpart G, using EASA Form 56 as a guide during the investigation, and as a checklist at
the end of it
4.3. generates compliance checklists for investigations of working processes and procedures on site
as required
4.4 accepts or rejects each EASA Form 4 completed by the key nominated personnel in
accordance with 21.A.145(c)(2)
4.5 checks that the production organisation exposition (POE) standard reflects the organisation, its
procedures, practices and 21.A.143. Having checked and agreed a POE issue or subsequent
amendment, the competent authority should have a clear procedure to indicate its acceptance
or rejection
4.6 makes sample audits at working level to verify that:-
(i) work is performed in accordance with the system described in the POE
(ii) products, parts, appliances or material produced by the organisation are in conformity
with the applicable design data (see GM 21.B.235(b)(4)).
(iii) facilities, working conditions, equipment and tools are in accordance with the POE and
appropriate for the work being performed
(iv) competence and numbers of personnel is appropriate for the work being performed
(v) co-ordination between production and design is satisfactory
4.7 at an advanced stage of the investigation, conducts an interim team review of audit results and
matters arising, in order to determine any additional areas requiring investigation.
Each investigation team should be accompanied during the process by company representatives who
are knowledgeable of the applicants organisation and procedures. This will ensure that the
organisation is aware of audit progress and problems as they arise. Access to information will also be
facilitated.
The POATL should co-ordinate the work of POAT members for an efficient investigation process,
which will provide a consistent and effective investigation and reporting standards.
5. Conclusions
5.1 The POATL holds a team meeting to review findings and observations so as to produce a final
agreed report of findings.
5.2 The POATL, on completion of the investigation, holds a meeting to verbally presents the report
to the applicant.
The POATL should be the chairman of this meeting, but individual team members may present
their own findings and observations.
5.3 The meeting should agree the findings, corrective action time scales, and preliminary
arrangements for any follow up that may be necessary.
5.4 Some items may as a result of this meeting be withdrawn by the POATL but if the investigation
has been correctly performed, at this stage there should be no disagreement over the facts
presented.
5.5 Inevitably there will be occasions when the POAT member carrying out the audit may find
situations in the applicant or POA holder where it is unsure about compliance. In this case, the
organisation is informed about possible non-compliance at the time and advised that the
situation will be reviewed within the competent authority before a decision is made. The
organisation should be informed of the decision without undue delay. Only if the decision results
in a confirmation of non-compliance this is recorded in Part 4 of EASA Form 56.
5.6 The POATL will transmit the final signed report on EASA Form 56 together with notes of the
final meeting with the applicant to the competent authority where the applicant is located. The
report will include recommendations and significant findings, together with appropriate
conclusions and corrective actions. In particular, it should indicate if the POE is acceptable, or
changes are required.
5.7 Completion of EASA Form 56 includes the need to record in Part 4 comments, criticisms, etc.,
and this must reflect any problems found during the visit and must be the same as the
comments, criticisms made to the organisation during the debrief. Under no circumstances
should additional comments, criticisms, etc., be included in Part 4 of the report unless the
applicant or POA holder has previously been made aware of such comments.
Many applicants may need to take corrective action and amend the proposed exposition before
the competent authority is able to conclude its investigation. Such corrective actions should be
summarised in Part 4 of the EASA Form 56 and a copy always given to the applicant, so that
there is a common understanding of the actions necessary before approval can be granted.
The intention of the EASA Form 56 Part 4 is to provide a summary report of findings and
outstanding items during initial investigation and major changes. The competent authority will
need to operate a supporting audit system to manage corrective action monitoring, closure etc.
While the EASA Form 56 Part 4 format may be used for monitoring purposes, it is not adequate
on its own to manage such system.
5.8 If the findings made during the investigation mean that approval recommendation will not or
cannot be issued, then it is essential that such findings are confirmed in writing to the
organisations within two weeks of the visit. The reason for confirmation in writing is that many
organisations take a considerable time to establish compliance. As a result, it is too easy to
establish a position of confusion where the organisation claims it was not aware of the findings
that prevented issue of an approval.
6. Management Involvement
The accountable manager will be seen at least once during the investigation process and preferably
twice, because he or she is ultimately responsible for ensuring compliance with the requirements for
initial grant and subsequent maintenance of the production organisation approval. Twice is the
preferred number of visits to the accountable manager, with one being conducted at the beginning of
the audit to explain the investigation process and the second, at the end, to debrief on the results of
the investigation.
Competent authority
of
EUROPEAN UNION or
EASA
Date(s) of survey:
Names and positions of the organisation's senior management attended during survey:
Note: If it is determined that recommendation for issue/continuation/variation/significant change of approval cannot be made because
of non-compliance with Part 21 Subpart G, the reasons for non-compliance need to be identified in PART 4 of the report. A copy
of PART 1 and PART 4, or at least the information included in these parts, must be given to the organisation to ensure that the
organisation, in failing to obtain Part 21 Subpart G approval, even if only temporarily, has the same information as is on the files
of the competent authority.
EASA Form 56 Issue 3-– POAT Recommendation Audit Report - Part 1 of 5, Page 1 of 1 MONTH YEAR
Competent authority
of
EUROPEAN UNION or
EASA
Name of organisation:
Approval of organisation:
Note A: This form has been compiled according those paragraphspoints of Part 21 Subpart G which are relevant to an organisation
trying to demonstrate compliance.
Note B: The right hand part of each box must be completed with one of three indicators:
1. a tick () which means compliance;
2. NR which means the requirement is Not Relevant to the activity at the address surveyed; (the reason for NR should
be stated in Part 4 of the report, unless the reason is obvious)
3. a number relating to a comment which must be recorded in Part 4 of the report.
The left hand part of each box is optional for use by the competent authority.
21.A.133 Eligibility
Any natural or legal person (‘organisation’) shall be eligible as an applicant for an approval under this Subpart. The applicant shall:
(a) justify that, for a defined scope of work, an approval under this Subpart is appropriate for the purpose of showing conformity
with a specific design; and
(c) have ensured, through an appropriate arrangement with the applicant for, or holder of, an approval of that specific design,
satisfactory co-ordination between production and design.
21.A.134 Application
Each application for a production organisation approval shall be made to the competent authority in a form and manner established by
that authority, and shall include an outline of the information required by 21Apoint 21.A.143 and the terms of approval requested to
be issued under 21Apoint 21.A.151.
EASA Form 56 Issue 3- POAT Recommendation Report POA Audit Report - Part 2 of 5, Page 1 of 65 MONTH YEAR
(iii) verification that incoming products, parts, materials, and equipment, including items supplied new or used by
buyers of products, are as specified in the applicable design data;
(ix) airworthiness co-ordination with the applicant for, or holder of, a design approval;
(xv) work within the terms of approval performed at any location other than the approved facilities;
(xvi) work carried out after completion of production but prior to delivery, to maintain the aircraft in a condition for
safe operation;
(xvii) issue of permit to fly and approval of associated flight conditions.
The control procedures need to include specific provisions for any critical parts.
______________________________________________________________________________________________________________
____
(b) The quality system shall contain (cont’d) –
(2) An independent quality assurance function to monitor compliance with, and adequacy of, the documented procedures of
the quality system. This monitoring shall include a feedback system to the person or group of persons referred to in
21Apoint 21.A.145(c)(2) and ultimately to the manager referred to in 21Apoint 21.A.145 (c)(1) to ensure, as necessary,
corrective action.
EASA Form 56 Issue 3- POAT Recommendation Report POA Audit Report - Part 2 of 5, Page 2 of 65 MONTH YEAR
(b) The production organisation exposition shall be amended as necessary to remain an up-to-date description of the
organisation, and copies of any amendments shall be supplied to the competent authority.
(a) with regard to general approval requirements, facilities, working conditions, equipment and tools, processes and associated
materials, number and competence of staff, and general organisation are adequate to discharge obligations under 21.A.165;
(b) with regard to all necessary airworthiness, noise, fuel venting and exhaust emissions data:
(1) the production organisation is in receipt of such data from the Agency, and from the holder of, or applicant for, the type-
certificate, restricted type-certificate or design approval to determine conformity with the applicable design data;
(2) the production organisation has established a procedure to ensure that airworthiness, noise, fuel venting and exhaust
emissions data are correctly incorporated in its production data;
(3) such data are kept up to date and made available to all personnel who need access to such data to perform their duties;
(2) a person or a group of persons have been nominated by the production organisation to ensure that the organisation is in
compliance with the requirements of this Annex I (Part, 21), and are identified, together with the extent of their authority. Such
person(s) shall act under the direct authority of the accountable manager referred to in subparagraphpoint (1). The knowledge,
background and experience of the persons nominated shall be appropriate to discharge their responsibilities;
(3) staff at all levels have been given appropriate authority to be able to discharge their allocated responsibilities and that
there is full and effective co-ordination within the production organisation in respect of airworthiness, noise, fuel venting and
exhaust emission data matters;
(d) with regard to certifying staff, authorised by the production organisation to sign the documents issued under point 21.A.163
under the scope or terms of approval:
(1) the knowledge, background (including other functions in the organisation), and experience of the certifying staff are
appropriate to discharge their allocated responsibilities;
(2) the production organisation maintains a record of all certifying staff which shall include details of the scope of their
authorisation;
(3) certifying staff are provided with evidence of the scope of their authorisation.
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(b) The competent authority shall establish the conditions under which a production organisation approved under this Subpart
may operate during such changes unless the competent authority determines that the approval should be suspended.
21.A.149 Transferability
Except as a result of a change in ownership, which is deemed significant for the purposes of 21A point 21.A.147, a production
organisation approval is not transferable.
21.A.157 Investigations
A production organisation shall make arrangements that allow the competent authority to make any investigations, including
investigations of partners and sub-contractors, necessary to determine compliance and continued compliance with the applicable
requirements of this Subpart.
21.A.163 Privileges
Pursuant to the terms of approval issued under point 21.A.135, the holder of a production organisation approval may:
(a) perform production activities under this Annex I (Part 21).
(b) in the case of complete aircraft and upon presentation of a statement of conformity (EASA Form 52) under point 21.A.174,
obtain an aircraft certificate of airworthiness and a noise certificate without further showing;
(c) in the case of other products, parts or appliances, issue authorised release certificates (EASA Form 1) under 21.A.307 without
further showing;
(d) maintain a new aircraft that it has produced and issue a certificate of release to service (EASA Form 53) in respect of that
maintenance;
(e) under procedures agreed with its competent authority for production, for an aircraft it has produced, and when the production
organisation itself is controlling under its POA the configuration of the aircraft and is attesting conformity with the design conditions
approved for the flight, to issue a permit to fly in accordance with point 21.A.711(c) including approval of the flight conditions in
accordance with point 21.A.710(b).
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(b) maintain the production organisation in conformity with the data and procedures approved for the production organisation
approval;
(c) (1) determine that each completed aircraft conforms to the type design and is in condition for safe operation prior to
submitting statements of conformity to the competent authority; or
(2) determine that other products, parts or appliances are complete and conform to the approved design data and are in a
condition for safe operation before issuing an EASA Form 1 to certify conformity to approved design data and in a condition for
safe operation, and additionally in case of engines, determine according to data provided by the engine type-certificate holder
that each completed engine is in compliance with the applicable emissions requirements as defined in 21Apoint 21.A.18(b),
current at the date of manufacture of the engine, to certify emissions compliance; or
(3) determine that other products, parts or appliances conform to the applicable data before issuing EASA Form 1 as a
conformity certificate;
(e) establish and maintain an internal occurrence reporting system in the interest of safety, to enable the collection and
assessment of occurrence reports in order to identify adverse trends or to address deficiencies, and to extract reportable
occurrences. This system shall include evaluation of relevant information relating to occurrences and the promulgation of
related information;
(f) (1) report to the holder of the type-certificate or design approval, all cases where products, parts or appliances have been
released by the production organisation and subsequently identified to have possible deviations from the applicable design
data, and investigate with the holder of the type-certificate or design approval in order to identify those deviations which could
lead to an unsafe condition;
(2) report to the Agency and the competent authority of the Member State, or both, the deviations which could lead to an
unsafe condition identified according to subparagraph point (1). Such reports shall be made in a form and manner established
by the Agency under point 21.A.3A(b)(2) or accepted by the competent authority of the Member State;
(3) where the holder of the production organisation approval is acting as a supplier to another production organisation,
report also to that other organisation all cases where it has released products, parts or appliances to that organisation and
subsequently identified them to have possible deviations from the applicable design data;
(g) provide assistance to the holder of the type-certificate or design approval in dealing with any continuing airworthiness actions
that are related to the products parts or appliances that have been produced;
(h) establish an archiving system incorporating requirements imposed on its partners, suppliers and sub-contractors, ensuring
conservation of the data used to justify conformity of the products, parts or appliances. Such data shall be held at the disposal
of the competent authority and be retained in order to provide the information necessary to ensure the continuing
airworthiness of the products, parts or appliances;
(i) where, under its terms of approval, the holder issues a certificate of release to service, determine that each completed aircraft
has been subjected to necessary maintenance and is in condition for safe operation, prior to issuing the certificate;
(j) where applicable, under the privilege of point 21.A.163(e), determine the conditions under which a permit to fly can be issued;
(k) where applicable, under the privilege of point 21.A.163(e), establish compliance with point 21.A.711(c) and (e) before issuing a
permit to fly to an aircraft.
EASA Form 56 Issue 3- POAT Recommendation Report POA Audit Report - Part 2 of 5, Page 5 of 65 MONTH YEAR
Competent authority of
of an EU Member State of the or
Name of organisation:
Approval of organisation:
Note B: The exposition may be compiled in any subject order as long as all applicable subjects are covered.
Note C: If the organisation holds another Part approval requiring an exposition or handbook it is acceptable to use this index as a
supplement to the existing exposition or handbook and to cross-refer each subject to the position in the existing exposition or
handbook.
(1) A statement signed by the accountable manager confirming that the production organisation exposition and
any associated manuals which define the approved organisation’s compliance with this Subpart will be
complied with at all times;
(2) the title(s) and names of the managers accepted by the competent authority in accordance with point
21.A.145(c)(2);
(3) the duties and responsibilities of the manager(s) as required by point 21.A.145(c)(2) including matters on
which they may deal directly with the competent authority on behalf of the organisation.
(4) an organisational chart showing associated chains of responsibility of the managers as required by point
21.A.145(c)(1) and (c)(2);
EASA Form 56 Issue 3- POAT Recommendation Report POA Audit Report - Part 3 of 5, Page 1 of 2 MONTH YEAR
(7) a general description of the facilities located at each address specified in the production organisation’s
certificate of approval.
(8) a general description of the production organisation’s scope of work relevant to the terms of approval;
(9) the procedure for the notification of organisational changes to the competent authority;
(11) a description of the quality system and the procedures as required by point 21.A.139(b)(1);
EASA Form 56 Issue 3 - POAT Recommendation Report POA Audit Report - Part 3 of 5, Page 2 of 2 MONTH YEAR
Competent authority
ofSheet 1 of a an EU Member State of the
EUROPEAN UNION or
EASA
Name of organisation:
Note A: Each finding must be identified by number and the number must cross-refer to the same number in a box in Part 2 or 3 of
the Part 21 Subpart G survey report.
Note B: As stated in Part 1 any comments recorded in this Part 4 should be copied to the organisation surveyed together with Part
1.
Note C: In case of a partial clearance of a finding with some outstanding action remaining, this action has to be identified.
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Competent authority
of
a an EU Member State of the
EUROPEAN UNION or
EASA
Name of organisation:
The following Part 21 Subpart G Terms of approval are recommended for the above organisation at the
address(es) specified in Part 1 of this report:
or
It is recommended that the Part 21 Subpart G Terms of approval identified in EASA Form 55 referenced
_______________ be continued.
EASA Form 56 Issue 3 - POAT Recommendation Report POA Audit Report - Part 5 of 5, Page 1 of 1 MONTH YEAR
These arrangements are between authorities and do not relieve the applicant of its obligations.
In all cases, even though surveillance tasks are delegated to the competent authority of the
third country, the competent authority remains the responsible authority and may consequently
exercise direct surveillance if necessary.
In case that it is not possible to delegate surveillance tasks to the competent authority of the
third country, the competent authority will have to establish a direct surveillance program in
accordance with its procedure concerning supplier control as part of the overall surveillance of
the POA holder.
Competent authority
of
a an EU Member State of the European Unionor
EASA
As part of the surveillance as required for the Part 21 Section A Subpart G approved production organisation,
according to GM No. 4 to 21.220(c) the competent authority of the sub-contractor is requested to perform authority
surveillance on the specific sub assemblies and parts as details and requirements are defined below.
Competent authority
of
a an EU Member State of the European Unionor
EASA
According to GM No. 4 to 21.220(c) and on request of the competent authority of the contractor company the
<COMPETENT AUTHORITY> reports on the results of its authority surveillance on the specific parts and
appliances defined below:
Note: Exchange of information between national authorities according to this procedure is strictly confidential
and should not be disclosed to other parties.
GM 21.B.235(b) Maintenance of the POA - Work allocation within the competent authority
After issue of the approval the competent authority should appoint a suitable member of its technical staff as
the POATL to be in charge of the approval for the purpose of continued surveillance.
Where the POA holder facilities are located in more than one Member State the competent authority of the
State of manufacture will liaise with the competent authorities of the various partners/members to ensure
appropriate continued surveillance.
AMC No. 1 to 21.B.240 Application for significant changes or variation of scope and terms of the
POA
The competent authority must receive an application for significant changes or variation of scope and terms
of the POA on an EASA Form 51 (see below) completed by the applicant.
EASA Form 51
Application for significant changes or variation of scope and terms of Part 21 POA
Competent authority
of
a an EU Member State of the European Unionor
EASA
a) General:
b) Scope of approval:
c) Nature of privileges:
Block 1: The name must be entered as written on the current approval certificate. Where a change in the
name is to be announced state the old name and address here, while using Block 5 for the
information about the new name and address. The change of name and/or address must be
supported by evidence, e.g. by a copy of the entry in the register of commerce.
Block 2: State the current approval reference number.
Block 3: State the locations for which changes in the terms of approval are requested or state ‘not applicable’
if no change is to be anticipated here.
Block 4: This Block should include further details for the variation of the scope of approval for the addresses
indicated in Block 3. The Block ‘General’ must include overall information for the change (including
changes e.g. in workforce, facilities etc.), while the Block ‘Scope of approval’ must address the
change in the scope of work and products/categories following the principles laid down in the GM
21.A.151. The Block ‘nature of privileges’ must indicate a change in the privileges as defined in
21.A.163(b)-(d). State ‘not applicable’ if no change is anticipated here.
Block 5: This Block must state the changes to the organisation as defined in the current production
organisation exposition, including changes the organisational structure, functions and
responsibilities. This Block must therefore also be used to indicate a change in the accountable
manager in accordance with 21.A.145(c)(1) or a change in the nomination of the responsible
managers in accordance with 21.A.145(c)(2). A change in the nomination of responsible managers
must be accompanied by the corresponding EASA Forms 4. State ‘not applicable’ if no change is
anticipated here.
Block 6: State the position and name of the accountable manager here. Where there is a change in the
nomination of the accountable manager, the information must refer to the nominee for this position.
State ‘not applicable’ if no change is anticipated here.
In case of an application for a change of the accountable manager the EASA Form 51 must be
signed by the new nominee for this position. In all other cases the EASA Form 51 must be signed
by the accountable manager.
GM 21.B.320(b)(6) Investigation
1. Determination of necessary conditions, restrictions and/or limitations on the airworthiness
certificate issued by a Member State
The competent authority of the Member State of registry may issue under its own legislation a
document to list and identify all necessary conditions, restrictions and limitations that result from
the investigation by the Agency and/or from the legislation of the competent authority of the
Member State of registry. This document could take the form of an addendum to the approved
flight manual or operating instruction or comparable document and should be referenced in
Block 5 (limitations/remarks) of the appropriate certificate of airworthiness.
1
The Convention on International Civil Aviation on 7 December 1944
Page 261 of 264
SECTION B/Subpart I AMC & GM for PART 21
The maximum landing mass associated with the certificated noise levels of
the aircraft in kilograms. The unit (kg) should be specified explicitly in order
to avoid misunderstanding. If the primary unit of mass for the State of
manufacture of the aircraft is different form kilograms, the conversion factor
used should be in accordance with Annex 5 to the Chicago Convention.
This item will only be included in the noise certification documentation for
noise certificates issued under Chapter 2, 3, 4, 5 and 12.
Block 11. Noise certification standard
The Chapter to which the subject aircraft is noise certificated. For chapters
2, 8, 10 and 11, the section specifying the noise limits should also be
included.
Block 12. Additional modifications incorporated for the purpose of compliance with
the applicable noise certification standards
This item should contain as a minimum all additional modifications to the
basic aircraft as defined by Blocks 5, 7 and 8 that are essential in order to
meet the requirements of this Annex to which the aircraft is certificated as
given under Block 11. Other modifications that are not essential to meet the
stated chapter but are needed to attain the certificated noise levels as
given may also be included at the discretion of the certificating authority.
The additional modifications should be given using unambiguous
references, such as supplemental type certificate (STC) numbers, unique
part numbers or type/model designators given by the manufacturer of the
modification.
Block 13. Lateral/full-power noise level
The lateral/full-power noise level as defined in the relevant Chapter. It
should specify the unit (e.g. EPNdB (unit of the effective perceived noise
level)) of the noise level and the noise level should be stated to the nearest
tenth of a decibel (dB). This item is included only in noise certification
documentation for aircraft certificated to Chapters 2, 3, 4, 5 and 12.
Block 14. Approach noise level
The approach noise level as defined in the relevant chapter. It should
specify the unit (e.g. EPNdB) of the noise level and the noise level should
be stated to the nearest tenth of a dB. This item is included only in noise
certification documentation for aircraft certificated to Chapters 2, 3, 4, 5, 8
and 12.
Block 15. Flyover noise level
The flyover noise level as defined in the relevant chapter. It should specify
the unit (e.g. EPNdB) of the noise level and the noise level should be
stated to the nearest tenth of a dB. This item is included only in noise
certification documentation for aircraft certificated to Chapters 2, 3, 4, 5 and
12.
Block 16. Overflight noise level
The overflight noise level as defined in the relevant chapter. It should
specify the unit (e.g. EPNdB or dB(A) (unit of the A-weighted noise level))
of the noise level and the noise level should be stated to the nearest tenth
of a dB. This item is included only in noise certification documentation for
aircraft certificated to Chapters 6, 8 and 11.
Block 17. The take-off noise level
The take-off noise level as defined in the relevant chapter. It should specify
the unit (e.g. EPNdB or dB(A)) of the noise level and the noise level should
be stated to the nearest tenth of a dB. This item is included only in noise
certification documentation for aircraft certificated to Chapters 8 and 10.
Block 18. Statement of compliance, including reference to Annex 16 to the Chicago
Convention, Volume I
3. Aircraft owner:
6. Purpose of flight
[Use terminology of 21.A.701(a) and add any additional information for accurate description of the
purpose, e.g. place, itinerary, duration…]
[For an application due to a change of purpose (ref. 21.A.713): reference to initial request and description
of new purpose]
8.2 The aircraft is in the following situation related to its maintenance schedule:
[Describe status]
9. Approval of flight conditions [if not available at the time of application, indicate reference of request
for approval]
[Reference to:
1. EASA approval, if flight conditions are approved by EASA; or
2. DOA approval form (see AMC 21.A.263(c)(6)), if approved under DOA privilege; or
3. Competent authority approval.
EASA Form 21