Sofema Aviation Services Considers the functioning relationship between EASA Part 21 J Design Organisations & EASA Part 21 G Production Organisation DOA-POA Relationship.
What do the Regulations Require?
AMC No 1 to 21.A.133(b) and (c) Eligibility – Link between design and production organisations.
Authors Note – Such a Relationship enables the provision of approved data, support for formal reporting, and joint engagement for investigation of any issues including non-conforming parts as well as the development of mitigations including support for Airworthiness Directive (AD) & Service Bulletin (SB) Development.
· An arrangement is considered appropriate if it is documented and satisfies the competent authority that co-ordination is satisfactory.
· To achieve satisfactory coordination the documented arrangements must at least define the following aspects irrespective of whether the two organisations are separate legal entities or not:
o a) The responsibilities of a design organisation which assure correct and timely transfer of up-to-date airworthiness data (e.g., drawings, material specifications, dimensional data, processes, surface treatments, shipping conditions, quality requirements, etc.);
o b) The responsibilities and procedures of a POA holder/applicant for developing, where applicable, its own manufacturing data in compliance with the airworthiness data package;
o c) The responsibilities of a POA holder/applicant to assist the design organisation in dealing with continuing airworthiness matters and for required actions (e.g., traceability of parts in case of direct delivery to users, retrofitting of modifications, traceability of processes’ outputs, and approved deviations for individual parts as applicable, technical information and assistance, etc.).
What is Required to be Covered by the Scope of the Arrangement?
The scope of the arrangements must cover Part 21 Subpart G requirements and associated AMC and GM, in particular: 21.A.145(b), 21.A.165(c), (f) and (g).
· The responsibilities of a POA holder/applicant, in case of products prior to type certification, to assist a design organisation in demonstrating compliance with CS (access and suitability of production and test facilities for manufacturing and testing of prototype models and test specimen);
· The procedures to deal adequately with production deviations and non-conforming parts;
· The procedures and associated responsibilities to achieve adequate configuration control of manufactured parts, to enable the production organisation to make the final determination and identification for conformity or airworthiness release and eligibility status;
· The identification of the responsible persons/offices who control the above;
· The acknowledgment by the holder of the TC/STC/repair or change approval/ETSO authorisation that the approved design data provided, controlled and modified in accordance with the arrangement are recognised as approved;
Note 1 – In many cases the production organisation may receive the approved design data through an intermediate production organisation.
· This is acceptable provided an effective link between the design approval holder and the production organisation can be maintained to satisfy the intent of 21.A.133.
Note 2 – When the design and production organisations are two separate legal entities a Direct Delivery Authorisation must be available for direct delivery to end users in order to guarantee continued airworthiness control of the released parts and appliances.
Definition – Direct Delivery Authorization (DDA), includes an Appropriate Arrangement (AA) between the Production Organisation (PO) and the Design Organization (DO). In this process, the DO is responsible for ensuring the continuous updating of design and airworthiness data to the PO, whilst the PO is responsible for assurance that the manufactured article conforms to Approved Design and Airworthiness Data. The PO is responsible to provide airworthiness release documentation.
Where there is no general agreement for Direct Delivery Authorisation, specific permissions may be granted (refer to AMC 21.A.4).
POA Holder Obligations
AMC No 2 to 21.A.133(b) and (c) Eligibility – Link between design and production organisations.
· In accordance with AMC No 1 to 21.A.133(b) and (c) the POA holder must demonstrate to the competent authority that it has entered into an arrangement with the design organisation.
· The arrangement must be documented irrespective of whether the two organisations are separate legal entities or not.
· The documented arrangement must facilitate the POA holder to demonstrate compliance with the requirement of 21.A.133(b) and (c) by means of written documents agreed.
Note – In the case where the design organisation and POA holder are part of the same legal entity these interfaces may be demonstrated by company procedures accepted by the competent authority.
Next Steps
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Airworthiness Directives, aviation, Design Organisation Approval (DOA), DOA, easa part 21, EASA Part 21 Subpart G, EASA Part 21 Subpart J, POA, Production Organisation Approval (POA), SAS blogs, Service Bulletins
