Sofema Aviation Services (SAS) www.sassofia.com considers the various changes and requirements to ensure compliance with the objectives of EASA Classification CM No.: CM–21.A–CS–001 Issue 02 dated 30 April 2021.
The purpose of this CM is to provide specific guidance for the classification of design changes to cabin interiors of Large Aeroplanes, considering the intent of the guidance material currently included in GM 21.A.91.
Notes:
- EASA Certification Memoranda clarify EASA’s expected and typical action.
- CM provides guidance on a particular subject and, as nonbinding material, may provide complementary information and guidance for compliance demonstration with current standards.
- Certification Memoranda are provided for information purposes only and must not be misconstrued as formally adopted Acceptable Means of Compliance (AMC) or as Guidance Material (GM).
- CM are not intended to introduce new certification requirements or to modify existing certification requirements and do not constitute any legal obligation.
Introduction – Point 21.A.91 of Annex I (Part 21) to Regulation (EU) No 748/2012 reads as follows:
- ‘Changes to a type certificate are classified as minor and major.
o A ‘minor change’ is one that has no appreciable effect on the mass, balance, structural strength, reliability, operational characteristics, noise, fuel venting, exhaust emission, operational suitability data, or other characteristics affecting the airworthiness of the product.
o Without prejudice to point 21.A.19, all other changes are ‘major changes’ under this Subpart.
- Major and minor changes shall be approved in accordance with points 21.A.95 or 21.A.97 as appropriate, and shall be adequately identified.’
This CM also takes into account the provisioning for risk-based compliance verification and the new privileges for Design Organisation implemented by Commission Regulation (EU) 2019/897 amending Regulation (EU) No 748/2012, and clarifies that the classification of design changes to the cabin interiors of Large Aeroplanes must be performed solely based on the impact on airworthiness.
GM 21.A.91 clarifies that the intent of the GM is:
- To provide guidance on the term ‘appreciable effect’ affecting the airworthiness of the product or affecting any of the other characteristics mentioned in 21.A.91, where ‘airworthiness’ is interpreted in the context of a product in conformity with type design and in condition for safe operation.’
- Additional guidance on the classification of design changes in the cabin safety domain that is provided in paragraph 2(i) of Appendix A of GM 21.A.91:
o Cabin Safety
- Changes which introduce a new cabin layout of sufficient change to require a re-assessment of emergency evacuation capability or which adversely affect other aspects of passenger or crew safety.
o Items to consider include, but are not limited to:
- Changes to or introduction of dynamically tested seats.
- Change to the pitch between seat rows.
- Change of distance between seat and adjacent obstacle like a divider.
- Changes to cabin layouts that affect evacuation path or access to exits.
- Installation of new galleys, toilets, wardrobes, etc.
- Installation of a new type of electrically powered galley insert.
* In accordance with 21.A.91, if a worst-case non-compliance of a change to type certificate may have an appreciable effect on the airworthiness that includes crashworthiness and occupant safety, the change needs to be classified as major.
This applies irrespective of previous compliance demonstration that might be reused or assumed no-safety effect due to compliant design or processes.
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Tags:
Aircraft, Aircraft Cabin, Aircraft Design Changes, Cabin safety, Certification Memoranda, CM–21.A–CS–001, Commission Regulation (EU) No 748/2012, EASA, EASA Certification, EASA changes, EASA CS-25, GM 21.A.91
