Sofema Aviation Services (SAS) www.sassofia.com Considers the various elements involved in the generation of the “compliance” statement.
Introduction – 21.A.239 Design Assurance System – (Regulation (EU) No 69/2014
The design organisation shall demonstrate that it has established and is able to maintain a design assurance system for the control and supervision of the design and of design changes, of products, parts, and appliances covered by the application.
This design assurance system shall be such as to enable the organisation:
- To ensure that the design of the products, parts, and appliances or the design change thereof, comply with the applicable type-certification basis,
- The applicable operational suitability data certification basis and environmental protection requirements; and
- To ensure that its responsibilities are properly discharged in accordance with:
o The appropriate provisions of this Annex I (Part 21); and
o The terms of approval issued under point 21.A.251;
- To independently monitor the compliance with, and adequacy of, the documented procedures of the system.
o This monitoring shall include a feedback system to a person or a group of persons having the responsibility to ensure corrective actions.
The design assurance system shall include an independent checking function of the showings of compliance on the basis of which the organisation submits compliance statements and associated documentation to the Agency.
The design organisation shall specify the manner in which the design assurance system accounts for the acceptability of the parts or appliances designed or the tasks performed by partners or subcontractors according to methods that are the subject of written procedures.
The Compliance Statement Considers the following Areas:
- Certification Program
- Classification Assessment Form
- Certification Compliance Sheet, Compliance Verification Sheet
- Declaration of Compliance
- Project Description
- Engineering Order
- Project Report
- Pilot Info Sheet
- ICAW (Instructions for Continued Airworthiness)
- AFMS (Aircraft Flight Manual Supplement)
What is a Compliance Statement? (Appendix A to AMC 21.A.15(b) Means of Compliance Codes)
Engineering Evaluation
MC 0 (Means of Compliance 0)
- Compliance Statement
- Reference to design change documents
- Election of methods, factors
- Definition
Associated Documents
- Type Design Documents,
- Recorded Statements:
MC 1 (Design Review)
Associated Documents
- Description,
- Drawings
MC 2 (Calculation / Analysis)
Associated Documents
- Substantiation Reports
MC 3 (Safety Assessment)
Associated Documents
- Safety Analysis:
Tests
MC 4 (Laboratory Tests)
MC 5 (Ground Tests on Related Products)
MC 6 (Flight Tests)
MC 8 (Simulation)
Associated Documents
- Test programmes
- Test reports
- Test interpretations
Inspection
MC 7 (Design Inspection)
Associated Documents
- Inspection / Audit Reports
Equipment Qualification
MC 9 (Equipment Qualification)
Associated Documents
- Note: Equipment Qualification is a process that may include all previous means of compliance:
Demonstration of Compliance
MOC 2 – 9 (excluding MOC 7)
- Analysis (e.g. Stress report)
- Test (e.g. EMI test)
- Assessment (e.g. Equipment assessment)
- All documents must be listed in the CCL
- All documents must list the requirements to which they show compliance
- All must be signed by a CVE
The following would be typical documents;
- Stress report
- Electrical Load Analysis
- System Safety Assessment
- Weight and Balance
- Equipment Assessment
- Flammability
- (Test plans/reports)
It is not necessary to make statements against every requirement.
- Some companies do this
- Some surveyors require this
Statements can vary in content.
- Remember to differentiate between design docs and compliance documents.
Compliance documents MUST state the requirements they show compliance to.
Company Scope
- Defined either
– Per ATA
– Per CS topic
– Per EASA Panel
– As per EASA TOC chart (preferable)
– Compliance can only be shown within the scope
- Statements should be readily understood by a subject matter expert!
Next Steps
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Sofema Aviation Services (SAS) www.sassofia.com and Sofema Online (SOL) www.sofemaonline.com provide EASA Regulatory Compliant and Vocational training including more than 20 courses specifically related to Part 21 / CS 25 – for details please see the websites or email us at team@sassofia.com
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aviation safety, Compliance, EASA, easa part 21, Design Assurance System, SAS blogs, (Regulation (EU) No 69/2014), Certification Programme, Compliance Statement Consideration, EASA Part 21 Compliance, Annex I (Part 21), Compliance Statement, ICAW (Instructions for Continued Airworthiness), AFMS (Aircraft Flight Manual Supplement), Engineering Evaluation, Flight Tests
