Sofema Aviation Services (SAS) www.sassofia.com considers the certification basis of changed aeronautical product
Introduction
EASA has collaborated with the Federal Aviation Administration (FAA) and Transport Canada (TCCA) on the further improvement of the guidance on the implementation of the ‘Changed Product Rule’ (Part 21.A.101). With this rule, EASA establishes the type-certification basis for changes to Type Certificates (TCs) and Supplemental Type Certificates (STCs).
21.A.101 Establishing the certification basis of changed aeronautical products ED Decision 2019/018/R
This guidance material (GM) provides guidance for the application of the ‘Changed Product Rule (CPR)’, pursuant to point 21.A.101, Designation of the applicable certification specifications and environmental protection requirements, and 21.A.19, Changes requiring a new type certificate, for changes made to type-certified aeronautical products.
Please see the following link to access the full guidance material: Easy Access Rules for Airworthiness and Environmental Certification (Regulation (EU) No 748/2012)
This GM provides guidance for establishing the certification basis for changed aeronautical products pursuant to point 21.A.101, Designation of the applicable certification specifications and environmental protection requirements.
- The guidance is also intended to help an applicant and approved design organisations determine whether it will be necessary to apply for a new type certificate (TC) under point 21.A.19, Changes requiring a new type certificate.
- The guidance describes the process for establishing the certification basis for a change to a TC, for a supplemental type certificate (STC), or for a change to an STC, detailing the requirements (evaluations, classifications, and decisions) throughout the process.
Considerations Related to Minor Changes
According to point 21.A.95(c), minor changes to a type-certificate can be approved using Certifications Specifications which became applicable after those incorporated by reference in the type-certificate, provided that they do not affect the demonstration of compliance.
- The ‘demonstration of compliance’ mentioned in point 21.A.95(c) is to be read as the ‘demonstration of compliance’ which the applicant would have performed in case ‘the type certification basis and environmental protection requirements incorporated by references in the TC’ are demonstrated compliant as required by point 21.A.95(b)(1);
- If a later amendment of the CS is elected to be used as the certification basis for the minor change, the demonstration of compliance as per point 21.A.95(b)1 still needs to be covered;
- This means that an analysis needs to be performed on the differences between the ‘the type certification basis and environmental protection requirements incorporated by references in the TC’ and the later amendment of the CS for the following items:
- Any applicable Special Condition needs to be covered appropriately;
- Any applicable Equivalent Level Of Safety needs to be covered appropriately;
- Any later CS paragraph needs to be applicable to the particular aircraft and compliance demonstration needs to feasible.
Next Steps
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Tags:
Aircraft, aviation safety, Compliance, EASA, Airworthiness, Certification, SAS blogs, EASA Minor Changes, Supplemental Type Certificate (STC), Federal Aviation Administration (FAA), Transport Canada (TCCA), Type Certificates (TCs), aeronautical product
