1st Airworthiness safety conference. DGAC regulations/procedures relating to Parts 66/147
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1 1st Airworthiness safety conference DGAC regulations/procedures relating to Parts 66/147
2 Content of presentation DGAC Activity key figures DGAC/DSAC general organisation DGAC/OSAC general organisation OSAC control Return on experience: implementation of Part 66/147 in France 2
3 Introduction: airworthiness - activity figures Aircraft on registry: 9722 (Aeroplanes and Helicopters) Commercial aircraft: 885 POA: 199 MOA Part 145: 292 Part M/F: 159 CAMO: 260 MTOA Part 147: 31 Aircraft Maintenance License Part-66 Licenses: National Licenses
4 DGAC organisation chart MINISTRY OF ECOLOGY, SUSTAINABLE DEVELOPMENT AND ENERGY DIRECTION GENERALE DE L AVIATION CIVILE (FRENCH CIVIL AVIATION AUTHORITY) DTA Directorate for Aviation Transport DSAC CIVIL AVIATION SAFETY DIRECTORATE SG General Administation DSNA Air Navigation Services Directorate Core Activities Supervision and Certification Support functions Air Navigation Services and Training 4
5 The Civil Aviation Safety Directorate (DSAC) DSAC is the certification body of the DGAC. Its scope of activities encompasses: Airworthiness & Operations Flight crew licencing Airports & Air navigation Security 5 5
6 Designation documents Article 6 of décret dated 9 July 2008 designates the Direction Générale de l Aviation Civile (DGAC) as the Competent Authority for Civil Aviation. décret dated 11 December 2008 creates the Direction de la Sécurité de l Aviation Civile (DSAC) and defines its missions French arrêté Ref DEVA A dated 19 December 2008 defines the organisation of DSAC French arrêté dated 22 february 2013 designates OSAC as part of the competent authority for control and inspection in the field of civil aviation safety 6
7 DSAC/NO organisation DSAC Quality manager Florence Leblond Airworthiness and operations Bernard Marcou Aeroplanes operations Helicopter operations & Aerial work International activities & operations quality Organisations approval & continuing airworthiness (5+1) Certification, continued airworthiness and General Aviation (8) Technical specialists (4) OSAC 7
8 Legislation structure Opt-outs Regulation (EC) No 216/2008 and its implementation rules French legislation structure Code des Transports Décrets Arrêtés In particular, the French regulation defines who is in charge of the application of the basic regulation n 216/2008 and its implementation rules. 8
9 Legislation structure Opt-outs Opt-Outs Article 3 of French arrêté dated 24 September 2012 precises, as allowed by the paragraphs 3(h) and 3(i) of article 7 of regulation (EC) n 2042/2003 : for the maintenance of piston-engine non-pressurised aeroplanes of 2000 kg MTOM and below not involved in CAT : Requirement to have certifying staff qualified in accordance with Part66/147 applicable on 28 September 2014 for the maintenance of ELA1 aeroplanes not involved in CAT : Requirement to have certifying staff qualified in accordance with Part66/147 applicable on 28 September 2015 Requirement for the competent authority to issue licences in accordance with Part66/147 applicable on 28 September
10 DSAC/NO Documentation structure Quality Manual R8 Process Certify the actors in the field of airworthiness MCT TP Procedures for oversight of AOCs including Part M/G approval R8 procedures -General -Accreditation activities MCT navigabilité Airworthiness manual OSAC control and supervision -MPH (Manuel du pilotage de l habilitation -MCH (Manuel du Contrôle de l Habilitation DGAC procedures and guidance issued for users OSAC procedures 10
11 DGAC/OSAC IT tools ORIGIN certification projects exemptions IDEAL Permits to fly EMPIC Organisations approvals Aircraft Maintenance licenses Aircraft 11
12 OSAC - Legal framework, principles Legal Framework : arrêté dated 22 February 2013 which supersedes the arrêté dated 7 June 2010 Content : OSAC is designated as part of the competent authority until 31 December 2016 The scope of delegation is defined in the Annex to the Arrêté Addition of the issuance of the maintenance licence The operating principles (technical and financial arrangements, supervision by the DGAC) are defined in a Convention dated 25/06/10 (revision in progress) 12
13 OSAC - Legal framework, principles (cont d) Content of the Convention : Nature of services and Evolution process Insurance and Bank guarantee requirements Financial dispositions Supervision by the DGAC IT Tool Technical requirements applicable to OSAC Coercive measures and resiliation 13
14 OSAC - Legal framework, principles (cont d) Supervision performed by the DGAC 2 aspects : Steering Principles defined in the Convention and in the MPH MPH = Manuel de Pilotage de l Habilitation (Steering Manual) Control Principles defined in the Convention and in the MCH MCH = Manuel de Contrôle de l Habilitation (Control Manual) 14
15 OSAC - Steering MPH : Written in coordination between OSAC and the DGAC, and approved by the DGAC Content : DGAC involvement in OSAC activities (other than control) Definition of objectives Validation of Interpretation of the rules / unusual Means of compliance Validation of significant evolutions of OSAC organisation and methods Committees / meetings Requirements applicable to OSAC (details the generic requirements defined in the Convention) Compliance with applicable regulation & DGAC directives Continuity of service Conflicts of interest Staff Organisation, quality system, methods Stakeholders consultation 15
16 OSAC - Steering (cont d) Committees / meetings Steering Committee (OSAC and DSAC Top management) Technical and financial results, service quality Definition of policy ; validation of overall strategy and objectives Designation of management personnel 2 meetings per year Follow-up Committee (OSAC and DSAC technical management) Follow-up of technical activities ; definition of solutions Results of control ; review of corrective actions Preparation of issues dealt with by the Management Committee 3 meetings per year Periodic technical meetings (OSAC and DSAC) 16
17 OSAC - Control The MCH is written and approved by DSAC Controls based on : Programmed audits Process audits Product audits (in undertakings) Observation of an inspection performed by an OSAC inspector Sample checks on recommendation files The procedure R8-P505 lists the tools to be used for these controls. 17
18 OSAC - Control Audits The different regulation parts are audited during a period of 2 years An audit program is defined every year An audit report is issued at the end of the audit which lists : o o o o o o Major findings Non major findings Remarks UNC The follow up of the corrective actions is done through actions plan Regular review of the progress of the corrective actions plans are performed during the transverse meetings 18
19 OSAC - Control 2013 Audits program 19
20 OSAC - Control OSAC control: use of IT tools (EMPIC) 4 novembre
21 OSAC - Control Osac Control: Notifications 4 novembre
22 Return on experience Part 66/147 Implementation of Part-66/147 in France Before entry into force of Part-66 requirements Choice of options For examination For conversion Key issues Examination Conversion of national qualifications in Part-66 licenses General overview. 22
23 Return on experience Part66/147 Before Part-66 licences No national licenses but certifying staff authorization Qualification of the certifying described in the maintenance organisation exposition Choice of options For examination: Examinations not organized by French CAA o o o o The easiest way was chosen Cost efficiency Reduced workload Private organisations had no objections 23
24 Return on experience Part66/147 No central data bank for MCQs o o o Cost efficiency Reduced workload Staff competencies (if training isn t performed by FNAA, how to create MCQs?) Only type examination are conducted by French CAA o By approved examiners on behalf of DGAC o When the type training doesn t exist in France (Thrush aircraft, R22) o In overseas territories Conversion provisions Different conversion procedures: standard; privileges maintain 24
25 Return on experience Part 66/147 Key issues Examination process, especially examinations without training Reported fraud and irregularities Doubt about candidates knowledge 25
26 Return on experience Part 66/147 Example Questions too easy Time unlimited Cheating Talking Training exam questions Providing exam questions for training Providing answers during exam Providing Certificate of recognition without exam 26
27 Return on experience Part 66/147 To ensure the security of the exams: Conduct focused audits Exchange information with EASA and other NAAs Improve examination procedure: Secure storage Password protection Limited access Reduce staff involved Reduce lifecycle Preventing questions can circulate Limit use and refresh 27
28 Return on experience Part66/147 Key issues Conversion process: Identify the scope of a national certifying staff qualifications (type of qualifications, associated privileges) Aircraft maintenance license : means to prove that the national certifying staff qualification meet the basic the basic knowledge requirements and the basic examination standards of Part-66 Possible for qualifications given in JAR-145 and Part-145 organisations but not in General Aviation organisations. 28
29 Return on experience Part66/147 Conversion report and General Aviation policy Certifying staff privilege before entry into force of Regulation Privilege of the converted Part-66 license Limitations 29
30 Return on experience Part66/147 What kind of limitations? Definition of 3 types of limitations 1) Generic limitation: resulting from the qualification framework 2) Technical limitation on aircrafts: limiting the scope of aircrafts (ex: all scope except aircraft with retractable landings gears) 3) Technical limitation on tasks: limiting the scope of tasks (ex: scope limited to electrical and avionic tasks) 30
31 Return on experience Part66/147 Example: license with a generic limitation 4 novembre
32 Return on experience Part66/147 Example: license with a technical limitation on aircrafts 4 novembre
33 Return on experience Part66/147 Example: license with a technical limitation 4 novembre
34 Return on experience Part66/147 How to remove the limitations? Determine the conditions of removal for each limitation, in specifying the module/subjects on which examination is needed Publish a public procedure: R
35 Return Qualification experience Part66/147 Generic Limitation framework Category A, B1, B2 Category B3 AEA, Conditions Part M/F to remove Scope Generic limited to Limitations: Scope limited to non Commercial Air non Commercial Air The removal Transport of a generic (CAT) limitation Transport requires (CAT) the success and on non the large basic exams for all the relative modules aircraft of Partie-66 in the category UEA of the license. Scope limited to Scope limited to non CAT and to non CAT Exemple: aircrafts with MTOM < 2730kgs LNMA Not applicable Scope limited to non CAT Maintenance statement without LNMA Scope limited to non CAT and to aircraft type ratings endorsed Scope limited to non CAT 35
36 Return on experience Part66/147 Conditions to remove a technical limitation on aircrafts. Example: 36
37 Return on experience Part66/147 Conditions to remove a technical limitation on tasks. Example: 37
38 Return on experience Part66/147 That was the plan! But in reality.. We didn t have the concept of Generic Limitation France was audited by EASA in 2008 We received a finding, and had to review about 1200 licenses 38
39 Return on experience Part66/147 That is why: When the new B3 license was introduced by the amendment 1149/2011, we tried to anticipate A national license was introduced, similar to the EASA B3 license, to facilitate the conversion 39
40 General overview Organisation DGAC/OSAC Part-66 licenses in France Implementation of Part-147 approvals 40
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