diapositive 1 - european defence...
TRANSCRIPT
MAWA Conference
French experience in implementing a
military airworthiness regulation
Warsaw, July 2011
Direction de la Sécurité Aéronautique d’État 2 MAWA Conference Warsaw 06.07.2011
The international civil regulation
ICAO: shall be applicable to civil aircraft, and shall not be applicable to State
aircraft (Chapter I, art. 3 a) ;
aircraft used in military, customs and police services shall be deemed to be State aircraft (Chapter I, art. 3 b) ;
the contracting States undertake, when issuing regulation for their State aircraft, that they will have due regard for the safety of navigation of civil aircraft (Chapter I, art. 3 d).
Regulation (EC) n°1592/2002 creating EASA Art 1 : This Regulation shall not apply when products, parts, appliances,
personnel and organisations … are engaged in military, customs, police, or similar services. The Member States shall undertake to ensure that such services have due regard as far as practicable to the objectives of this Regulation
N.B. Current Regulation is (EC) n°216/2008 : Art 1.2 has not changed
Regulation
Organisation
Implementation
Issues
Direction de la Sécurité Aéronautique d’État 3 MAWA Conference Warsaw 06.07.2011
Prior situation
Airworthiness requirements were not mandatory in the technical
specifications of DGA contracts for aircraft procurement
JAR/FAR requirements sometimes specified for civil derivative aircraft :
JAR/FAR 25 for cargo aircraft
JAR/FAR 29 for helicopters (including Tiger and NH90)
Certification is explicitly part of qualification process
No equivalent available for fighter aircraft, even if practically done
Specification of various norms (AIR, Stanags…)
Specification of safety objectives
Safety of flight assessed during qualification process in particular during
flight tests by CEV (now DGA Flight testing)
Certification is implicitly part of qualification process
Aircraft maintenance has always been performed according to
the state of the art, but was not based on a formal airworthiness
regulation
Regulation
Organisation
Implementation
Issues
Direction de la Sécurité Aéronautique d’État 4 MAWA Conference Warsaw 06.07.2011
Why a regulation ?
Three accidents occurred in 2000/2001:
US C130 firefighter leased by Civil Safety service
Not considered as a State owned aircraft
Mirage F1 after engine stopped
Modification declared mandatory to restore airworthiness 15 years before but never
procured
CAP232 during an acceptance test flight by CEV
(now DGA Flight testing)
Civil registered but with invalid permit to fly
No particular higher crash rate,
but lawsuits more likely to happen
Need of an airworthiness regulation for legal protection
Regulation
Organisation
Implementation
Issues
Direction de la Sécurité Aéronautique d’État 5 MAWA Conference Warsaw 06.07.2011
French regulation
France issued an airworthiness regulation for military and State
owned aircraft on 09 Dec 2006 under the Decree n°2006-1551
(signed by the Prime Minister) with 3 ministerial orders
Edicts rules for the use, the airworthiness and the registration of military
aircraft and state owned aircraft engaged in customs, police and similar
services
Defines three categories of military aircraft
1° State owned Aircraft used by the organisations concerned with the authority of
the Minister of Defence;
2° Aircraft not belonging to the State classified as armaments or military systems;
3° On joint decision of the Minister of Defence and the Minister in charge for the
civil aviation, aircraft not belonging to the State, but used to carry out missions
for the State and piloted by a crew under the authority of the Minister of
Defence.
Excludes from its scope the foreign military aircraft used by their armed
forces and flying in France
Designates also the head of DGA as the certification authority for the
State owned aircraft engaged in custom, police and similar services
Regulation
Organisation
Implementation
Issues
Direction de la Sécurité Aéronautique d’État 6 MAWA Conference Warsaw 06.07.2011
The EASA regulation speaks of “competent authority”
Identify the competent authority for each domain
The original organisation was based on :
1 Technical Authority :
PtF, type certification, continued airworthiness of type design, DOA/POA,
registration for flight test aircraft
7 End Users (called Operating Authorities) :
CoA, continuing airworthiness of individual aircraft, registration of aircraft in
service, continuing airworthiness management /maintenance/training
organisation approvals and personnel licences
French State aviation organisation
Regulation
Organisation
Implementation
Issues
Direction de la Sécurité Aéronautique d’État 7 MAWA Conference Warsaw 06.07.2011
French State aviation organisation
Possible conflicts of interest :
Technical Authority :
The head of DGA is both Technical Authority and responsible manager of
all armament programmes
The decision makers who have a delegation of authority from the head of
DGA are in separate directorates to guarantee sufficient independence
DGA instruction defining the level of airworthiness decisions that can be
signed by the officially appointed authorized signatories
End Users (called Operating Authorities) :
The End Users have both operating responsibility and oversight
responsibility
Need for splitting
Regulation
Organisation
Implementation
Issues
Direction de la Sécurité Aéronautique d’État 8 MAWA Conference Warsaw 06.07.2011
Creation of DSAE : State aviation authority
(Airworthiness directorate)
Technical
Authority
End Users
(incl. CAMO)
May grant exemption, by a justified decision and for a limited
period, with the requirements of the CoA in the event of
Exceptional circumstances or of urgent operational needs
Civil aviation
Current situation Prior situation
in 2006
Current situation
in 2011
Military aviation
Continuing
Airworthiness
Authorities
Operators
Regulation
Organisation
Implementation
Issues
Direction de la Sécurité Aéronautique d’État 9 MAWA Conference Warsaw 06.07.2011
Civil vs military : who does what ?
Technical Authority
Military stakeholders
Operators
EASA
Civil stakeholders Rulemaking and executive functions
• Establishes the essential
requirements
• Conduct Type certification
• Approve flight test conditions
• Ensure Continued airworthiness
• Approves Design organisations
National authorities
• Establish the rules for continuing airworthiness
Aviation Safety Authority
Technical Authority
End Users / CAMOs
• Issues permit to fly (flight tests)
• Registration of flight test aircraft
• Approves Production
organisations
• Appreciates the compliance of
new products to the type design
• Approves organisations (maintenance,
continuing airworthiness management, training)
• Issues maintenance personnel licences
• Issues Individual CoAs
• Registration of aircraft in service
Aviation Safety Authority
• Apply the rules
• Manages Continuing airworthiness
• Can grant exemptions for urgent
operational needs
European Commission
Regulation
Organisation
Implementation
Issues
Direction de la Sécurité Aéronautique d’État 10 MAWA Conference Warsaw 06.07.2011
Transitional provisions of the regulation
Transitional provisions in order not to ground fleets :
for the Technical Authority :
- The types of product in service before the publishing date of this ministerial
order or already qualified by the DGA are considered type certified.
- Within three years from the publishing date of this ministerial order, the
technical authority issues a Type Certificate for each type of product mentioned
in the previous subparagraph, with the associated Type design definition, and
designates a Type Certificate Holder (TCH).
for the End Users :
- Within five years from the publishing date of this ministerial order, the end
users issue, according to the corresponding Type Certificates, the certificates
of airworthiness:
1° to aircraft in service before the publishing date of this ministerial order and in
conformity, if necessary, with the decisions taken in the configuration
management board, maintained in accordance with the maintenance rules in
force and with the directives issued by the technical authority;
2° to aircraft, of which the contract of acquisition or rent was notified at the latest
on the publishing date of this ministerial order, in conformity with their qualified
definition.
Regulation
Organisation
Implementation
Issues
Direction de la Sécurité Aéronautique d’État 11 MAWA Conference Warsaw 06.07.2011
Late 2006 : Ambitious original schedule but limited scope
- TCs for all product types (legacy products included)
- CoAs for all aircraft in service after 2011
- Broad requirements for TCH organisations
- No requirements for maintenance organisations and personnel
Late 2009 Late 2011
Continued airworthiness of type design
CoAs
TCs
Late 2006
Regulation
Organisation
Implementation
Issues
Direction de la Sécurité Aéronautique d’État 12 MAWA Conference Warsaw 06.07.2011
Type certificates
Schedule for issuing TCs almost met
The Technical Authority has issued so far
67 aircraft TCs + 2 UAVs,
48 engine TCs,
22 propeller TCs,
24 STCs
No TC issued for fleets to be retired before 31.12.2014
Each TC is issued with :
a TCDS (Type Certificate Data Sheet)
for legacy products, an “Airworthiness Reference Data Sheet” listing :
the Technical Authority’s decisions related to continued airworthiness
the modifications decided by the Configuration Management Board and
considered as airworthiness mandatory (from a mutually agreed Board decision
rank up to TC issuance : modifications decided before this rank are supposed to
be implemented no need to sort out mandatory modifications)
The Airworthiness Reference Data Sheet is then to be updated by the End Users
Regulation
Organisation
Implementation
Issues
Direction de la Sécurité Aéronautique d’État 13 MAWA Conference Warsaw 06.07.2011
FRA annexes
Instruction n°2009-16880/DEF/DGA/DET/CEP/ASA dated 16 Jan
2009 related to essential requirements with 4 annexes : • Annex 1 : essential requirements for the airworthiness of military aircraft and State
owned aircraft (based on OCCAR document adapted from annex I to EC regulation 216/2008)
• Annex 2 : a list of certification specifications and associated means of compliance
(mostly civil except for UAVs) recognized to meet the essential requirements
• Annex 3 : FRA 21 (based on Part 21 of EC regulation 1702/2003 + Subpart Z “Alternative
procedures” based on GM and AMC 21A14(B))
• Annex 4 : FRA forms (based on EASA forms) 1a, 52, 53, 25
Instruction n°017/DEF/IGA-Air/BSMN dated 30 Jul 2010
(based on EC regulation 2042/2003) related to continuing airworthiness,
organisation approvals and maintenance personnel licences
with 4 annexes : • Annex 1 : FRA M (based on Part M)
• Annex 2 : FRA 145 (based on Part 145)
• Annex 3 : FRA 66 (based on Part 66)
• Annex 4 : FRA 147 (based on Part 147)
Regulation
Organisation
Implementation
Issues
Direction de la Sécurité Aéronautique d’État 14 MAWA Conference Warsaw 06.07.2011
FRA scope vs EASA scope
DGA
DSAÉ
Decree + Order n°1 + Essential
Requirements (instr DGA annex 1)
Order n° 2 +
FRA 21 (instr DGA
annex 3)
+ Forms (instr DGA
annex 4)
list of certification
specifications & associated
means of compliance
(instr DGA annex 2)
FRA M
FRA 145
FRA 66
FRA 147
and associated AMC’s
Regulation
Organisation
Implementation
Issues
Direction de la Sécurité Aéronautique d’État 15 MAWA Conference Warsaw 06.07.2011
Other amendments and add on
Order n°2 was amended by the order dated December 17th,
2009 :
Notion of primary certification authority, civil or military
Possibility to recognise the certification process performed by a primary authority
Precision of DGA scope of work in that case
Instruction n°2010-84372/DEF/DGA/DT/ST/DGA_IP/ASA
dated 16 Mar 2010 defining the conditions of approval and application of:
- the airworthiness directives issued by…
- the supplemental type certificates issued by…
- the SB’s, repair solutions and some technical directives issued by the
manufacturers and approved by …
…a recognized civil primary authority to (civil) types certified aircraft used
by MoD, Customs, Public Safety and Civil Safety services
In case the OEM is not or is no longer the TCH, possibility to limit the
obligations of the actual TCH
ex : SIAé (State industrial maintenance organisation)
Modifications on conditions of PtF issuance for acceptance flights
Regulation
Organisation
Implementation
Issues
Direction de la Sécurité Aéronautique d’État 16 MAWA Conference Warsaw 06.07.2011
Issues : TC/STC
General provisions : The manufacturer applies for obtaining a TC/STC
Transitional provision : The Technical authority issues a TC/STC and designates a TCH
What if the manufacturer refuses to be the TCH Find another TCH (ex : SIAé for C160)
Contracting TCH support to assume the duties of continued
airworthiness Possible additional costs
Possible gaps between 2 subsequent contracts
GFE (Government furnished equipment) If within airworthiness scope, issue a TSO or a STC
Stores and mission equipment Define which are within airworthiness scope and which are not work in progress
Controlled environment additional costs
thus limit the scope strictly to airworthiness related stores and mission equipment
Incomplete documentation for some “exotic” legacy aircraft Difficulties to consolidate the airworthiness reference data sheet
Regulation
Organisation
Implementation
Issues
Direction de la Sécurité Aéronautique d’État 17 MAWA Conference Warsaw 06.07.2011
Issues : airworthiness reviews
Airworthiness reviews not well prepared by some CAMO units
because of lack of experience (CAMO units relying on airworthiness
reviews to address deviations) Requires airworthiness review complements to check corrective actions
Rely on transitional provisions in order not to ground aircraft with level 1 deviations
Original schedule based on the assumption that the next 2 extensions
of the airworthiness review certificates are issued by CAMO under
FRA M approval privilege : Very few CAMOs are FRA M approved Unexpected additional workload for the
Aviation Safety Authority to fill the gap unless introducing a new transitional provision :
maximum 3-year validity of the first airworthiness review certificates until FRA M
approval
Regulation
Organisation
Implementation
Issues
Direction de la Sécurité Aéronautique d’État 18 MAWA Conference Warsaw 06.07.2011
Issues : DOA/POA (FRA 21)
The Design and Production organisation approvals may be granted with
privileges. The possible privileges are defined in : Design : Subpart J FRA21A.263
“…is approved under the authority of design organisation approval (DOA) n° C.[xyz]-DGA ”
Approval of flight conditions except for initial flights
PtF issued by the Technical authority (≠ civil regulation)
Production : Subpart G FRA21A.163
Issue flight clearance, within the frame of a general PtF
Production without POA remains possible Subpart F
Civil organisation approvals may be recognized if the civil airworthiness
authority is recognized and if the scope is applicable
Audits although limited to OEMs with direct contracts means consistent and
skilled workforce to perform them
Approved modifications (in the airworthiness sense) still need to be accepted
by the Configuration Management Board before being implemented
Organisation approval does not replace Quality Assurance : it is just part of it
Regulation
Organisation
Implementation
Issues
Direction de la Sécurité Aéronautique d’État 19 MAWA Conference Warsaw 06.07.2011
Issues : Form 1
FRA form 1a : Authorized release certificate for parts and appliances
from production according to FRA 21 Subpart G
FRA form 1b : Authorized release certificate for parts and appliances
from maintenance organisations according to FRA 145
Possibility to merge FRA Form 1a and CoC (Certificate of Conformity)
to have a single certificate valid both for airworthiness and contract ?
Introduce transitional provisions to cope with the absence of POA
For civil certified aircraft types, EASA Form 1 is recognized for new
products but dispute with the company acting on behalf of the FR CAA for oversight about products
aimed for military aircraft not taken into account for fee calculation
for maintained parts and appliances, the use of EASA form 1 is forbidden by EASA
No FRA Form 1a for Supplier furnished spare equipment because there
is no direct contract with subcontractors
Regulation
Organisation
Implementation
Issues
Direction de la Sécurité Aéronautique d’État 20 MAWA Conference Warsaw 06.07.2011
Issues : MMEL/MEL
Aircraft with equipment unserviceable cannot be authorized to fly with
just the green light of the chief of operations
Records of such unauthorized configurations in the aircraft logbook
may lead to level 1 deviations during the airworthiness reviews
Introduce the civil principle of MMEL/MEL in the regulation MMEL : Master Minimum Equipment List
- Defined by the TCH and approved by the Technical Authority during the certification process
MEL : Minimum Equipment List
- Defined by the End User and approved by the Aviation Safety Authority (DSAE)
- Cannot be less restrictive than MMEL
Already used on civil type certified aircraft, but not addressed on specific military aircraft
like fighters
Mandatory for future aircraft types
Introduce also transitional provisions For legacy aircraft, in the absence of MMEL, define and validate an
Operating & Technical Tolerance List (OTTL) based on grandfather law
Until 31.12.2014, Airworthiness Review Certificates can still be issued and extended in
spite of the absence of MEL or OTTL
Regulation
Organisation
Implementation
Issues
Direction de la Sécurité Aéronautique d’État 21 MAWA Conference Warsaw 06.07.2011
Issues : organisation approvals and
maintenance personnel licences
FRA M approvals CAMO to be appropriately appointed
Responsibilities to be properly endorsed by the accountable manager
Incremental approval process by product types
The approved maintenance plan based on the recommended maintenance plan
issued by the TCH during certification does not exist for some legacy aircraft
Draft a maintenance plan for approval by the CAMO
FRA 145 approvals For state maintenance organisations, incremental approval process by product types
For private maintenance organisations, approval process to be programmed
according to award or renewal of MRO contracts
Obligation of the main contractor to oversee its subcontractors, which cannot have a
FRA 145 approval as they is no direct contract
Traceability of spare parts in stock : maintenance data often not approved or even
absent
Regulation
Organisation
Implementation
Issues
Direction de la Sécurité Aéronautique d’État 22 MAWA Conference Warsaw 06.07.2011
Issues : organisation approvals and
maintenance personnel licences
FRA 66 licences : Grandfather law to issue FRA 66 licences to skilled maintenance personnel
difficulty to have a single grandfather law among the 7 End users
FRA 66 licences to be issued also for maintenance personnel of private FRA 145
maintenance organisations
Need to synchronize with FRA 145 approvals
Military turnover to be anticipated
FRA 147 approvals Incremental approval process by product types
No return of experience yet
Regulation
Organisation
Implementation
Issues
Direction de la Sécurité Aéronautique d’État 23 MAWA Conference Warsaw 06.07.2011
~ 1500 CoAs
~ 200 maintenance organisations to approve
~ 70 design or production organisations to approve
~ 5000 licensed maintenance personnel
CoAs
CAMO,
Training
organisations
State maintenance
organisations
Production(*)
Private maintenance
organisations
OK
New and more realistic implementation schedule
with updated or new transitional provisions
Controlled environment : Late 2016
2011 2012 2013 2014 2015 2016 FRA 21 G
2016
2009 2010 2011 2012 2013 2014
2011 2012 2013 2014
2011 2012 2013 2014 2015
2011 2012 2013 2014 2015 2016
100% CoAs (Sustainable fleets)
Late 2014
100% FRA M, FRA 147
Late 2014
100% FRA 145 NSO
Mid-2015
100% FRA 145 NSI
2016
D
G
A
D
S
A
É
Regulation
Organisation
Implementation
Issues
(*) FRA 21 J Design : no real timeframe constraint as, in the absence of DOA,
any airworthiness approval is done by the Technical Authority
Direction de la Sécurité Aéronautique d’État 24 MAWA Conference Warsaw 06.07.2011
A 310
A330 AUG
A 340 TLRA
A400M
Alouette III
Alphajet
ATL2
C135 FR
CAP 10B
CASA 212
CASA 235
CL 415
Cougar
Dauphin
Dauphin Pedro
Dauphin SP
DHC 6
DRAC
E-2 C Hawkeye
E-3 F AWACS
EC 135
EC 145
EC 725
Ecureuil
Epsilon
Extra 300/330
F 406
F10 MER
Falcon Gardian
Falcon 50
Falcon 50 Surmar
Falcon 900
Falcon ARPEGE
Falcon 7X
Fennec
Gazelle
Hercules C130 H
Jodel D140
KC 135 R
Lynx
Mirage 2000 D
Mirage 2000 C
Mirage 2000 N
Mirage 2000-5
Mirage 2000 B
Mirage F1 CR
Mirage F1 CT
Mirage F1 B
Mystère 20
NH90
Panther
PC 7
PC 6
Gliders
Puma
Q 400
Rafale M
Rafale B
Rafale C
Rallye
SEM
SIDM Harfang
SDTI Sperwer
Super Puma
TBM 700
Tigre HAD
Tigre HAP
Transall C160
Transall Gabriel
Turbofirecat
Xingu