February 23, 2018

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EASA & FAA Supplemental Type Certificate (STCs) Aircraft Maintenance Considerations

A Supplemental Type Certificate (STC) is an FAA or EASA approved major modification or repair to an existing type certified aircraft, engine or propeller. As it adds to the existing type certificate, it is deemed ‘supplemental’. As its name suggests, an STC is a certificate. It defines the product design change, states how the modification affects the existing type design, and lists serial number effectively. It also identifies the certification basis, listing specific regulatory compliance for the design change.

An STC being a supplemental type design approval for a major alteration and specific to a make and model or even a specific serial number as a one “off” STC

The STC Holder – STCH remains ultimately responsible for the certification of the modification. An STC is a design approval, however it doesn’t allow the holder to produce anything. (typically created by Part 21 /FAR 21 Subpart J Organisation Design Approval Holder (DAH) Design Organisation Approval (DOA)).

Note – The STC, which incorporates by reference the related Type Certificate (TC), approves not only the modification, but how the modification affects the original design.

The application must be made in the form and manner prescribed by the FAA or EASA.

The STC and its related information – all drawings, data and specifications – are the property of the STC holder. However to also consider that the Continuing Airworthiness Management Organisation (CAMO) remains responsible for the Continuing Airworthiness Compliance including STC Conformity. Therefore the CAMO should always ensure that you have the necessary access to the full design information package. (such data forms part of the back to birth continuing airworthiness records)

 

EASA STC Related Manufacturing

In order to manufacture replacement or modification parts, you have to have to hold a production approval. (typically produced by Part 21 /FAR 21 Subpart G Production organisation Approval Holder (PAH) Production Organisation Approval (DOA)).

STCs provide an opportunity to enable DOA/PAH to offer performance and or maintenance related changes as well as customized modifications with airworthiness considerations.

Examples of STC’s include the following

Re-engining an existing airframe, installation of advanced avionics, pax -to-freighter conversions.

 

STC Potential Concerns

Due to their inherent criticality, all changes to the design of an aircraft are required to be approved. In particular to assess the STC for Continuing Airworthiness implications

Under the U.S. FAA’s regulatory system there are a number of methods to obtain approval for a major modification or repair to a type certified aircraft. For example a data approval issued by a Designated Engineering Representative which is usually issued on a FAA Form 8110-3 equivalent to 8100-9 being one example ( Note that there may be EASA Part 21 issues with this statement)

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EASA & FAA, supplemental type Certificate