EASA Part 21 Classification of Changes Considerations – Review by Sofema Aviation Services www.sassofia.com
Introduction
Please refer to the following document: EASA CM No.: CM–21.A–CS–001 Issue 02 dated 30 April 2021 concerning regulatory requirement(s): Point 21.A.91 of Annex I to Regulation (EU) No. 748/2012 – Classification of changes to a type-certificate.
Concerning Changes
- Changes (or modifications) to an aircraft, engine, or propeller are any change to the approved type design.
- The change may be physical such as the installation of a new system or replacement of a part for one of a new part number but could also only be a change to documentation such as the Aircraft Flight Manual (AFM) or Operational Suitability Data (OSD).
Concerning Repairs
- Repairs are the result of design activities for the elimination of damage and/or restoration of the aircraft/engine/propeller to an airworthy condition.
- This could also include the assessment of damage to allow continued operation without physical repair of that damage.
Approval of Changes
- All changes and repairs need to be approved.
- The means of approval depends on the classification of the change or repair and whether Design Organisation Approval (DOA) privileges can be used.
Changes and Repairs are classified as major or minor.
Minor – A minor change has ‘no appreciable effect’ on airworthiness or environmental characteristics.
Major – All other changes are major.
- The criteria and guidance material for determining the correct classification is in 21.A.91.
- For repairs, there are additional criteria and guidance in 21.A.435.
Concerning EASA CM No.: CM–21.A–CS–001 Issue 02
- The purpose of this Certification Memorandum 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.
Background Information
- Point 21.A.91 of Annex I (Part 21) to Regulation (EU) No 748/2012 reads as follows:
o Changes to a type-certificate are classified as minor and major. 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.’
EASA Certification Policy
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.’
- The present Certification Memorandum follows the same philosophy as that of GM 21.A.91 and includes a non-exhaustive list of examples of design changes to cabin interiors that should be classified as major based on paragraph 3.4 of the GM and on the 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
Cabin Safety
Changes that 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.
- Items to consider include, but are not limited to:
o Changes to or introduction of dynamically tested seats.
o Change to the pitch between seat rows.
o Change of distance between seat and adjacent obstacle like a divider.
o Changes to cabin layouts that affect evacuation path or access to exits.
o Installation of new galleys, toilets, wardrobes, etc.
o Installation of a new type of electrically powered galley insert.
Next Steps
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