# Master EASA Compliance: Introduction Webinar by David Hope | September 2024 Part 1

https://www.youtube.com/watch?v=I5y8Zv0nMMQ

[00:08] Hello and welcome to this Safa Aviation Services three-part course on the introduction to AASA regulations for initial and continuing airworthiness.
[00:19] We will be looking at Parts 21 J and G, Part 145 maintenance, Part M, and Part CAMO.
[00:31] The objective of this short course of video-based instruction is to provide an introduction and overview of the AASA regulations which contain the implementing rules for regulatory areas related to design, production, maintenance, and continuing airworthiness management.
[00:49] The instruction covers the basic structure and content of the following regulations: Regulation 2018/1139, the basic regulation for aviation; Regulation 748/2012, the initial airworthiness requirements of Part 21J and Part.
[01:10] 21g regulation 1321 Stroke 2014 the continuing air worthiness requirements found in Parts 145 part M and part camo.
[01:23] We will commence with an introduction to the general iasa regulatory environment and the basic Reg regulation EC 2018 stroke 1139.
[01:36] I'll start by looking at the role of the international civil aviation organization Iko.
[01:42] Today's Aviation regulations have a high degree of commonality across all countries and this is largely because of the work done by AO over the last well nearly 80 years.
[01:54] IO is a specialist agency located in Montreal in Canada and was established under the Chicago convention which was a landmark agreement um in 1945 just after the second world war with the intent of.
[02:11] Establishing safe and orderly introduction of civil air transport and aviation activities across the world, the intent was that aviation regulation should be established on the basis of opportunity and operated soundly, safely, and economically.
[02:30] ICAO's core mandate is to help independent states or signatories to achieve the highest possible degree of uniformity in civil aviation regulations, the standards, procedures, and organizations.
[02:43] It has enacted this through the development of a number of annexes which contain over 12,000 international standards and recommended practices, or SARPs, all of which have been agreed by consensus by ICAO's now 193 member states, and they form the basis of global aviation regulation.
[03:07] So here we have the annexes; there are, um, all together...
[03:13] Annex One deals with personnel licensing, such as flight crew licensing.
[03:20] Rules of the air are obviously essential to have those common across the world.
[03:24] Meteorological services, aeronautical charts formats.
[03:27] Annex 5 is units of measurements in air and ground ops standardization of those.
[03:33] Annex 6 relates to the operation of aircraft.
[03:39] Annex 7 is about standardizing aircraft nationality and registration markings.
[03:46] Annex 8, which we'll be concerned with in this series of lectures, deals with the airworthiness of aircraft, both initial and continuing.
[03:52] Annex 9 is facilitation.
[03:56] Annex 10 deals with aeronautical telecommunication, such as radio air traffic services.
[04:00] Annex 11, and so it goes down through to Annex 19, which is the most recent of the annexes.
[04:10] And that was introduced in 2013 for safety management systems and that.
[04:15] Has been one of the most major changes in the ICAO SARPs in the last 30 years.
[04:25] The SARPs as developed by ICAO are turned into conventions and articles which mandate their adoption.
[04:35] So the adoption of the SARPs practices from ICAO is enabled in the Contracting States via the regulators, via EASA, FAA, and other national regulators.
[04:46] So the recommended practices form the basis of aviation laws and regulations in all of the Contracting States across the world.
[04:56] The implementation of that is performed by the national aviation authorities in each country, and the oversight is from both ICAO and the national authorities.
[05:05] So this is how we achieve standardization of general aviation regulatory practices across the globe.
[05:13] It originates with ICAO and is.
[05:17] Passed down to the individual aviation authorities around the world to turn into laws through their individual systems.
[05:28] The EASA has been in existence since 2003, and it took over regulation in Europe from that date from the JAA, the Joint Airworthiness Authority.
[05:41] And started its work in 2003 working from, um, basically Brussels, which is the head of the European Union.
[05:50] And then moved to Cologne in Germany late in, so 20 years ago in late 2004, uh.
[05:57] And it's taken over the responsibility for regulating airworthiness and maintenance issues within all of the EU member states.
[06:07] This shows the countries regulated under the EASA system of regulations.
[06:12] There are 27 member states.
[06:15] There used to be 28, but the UK, um, came.
[06:18] Out under Brexit, so we've got 27 member states.
[06:22] Each of which have one representative member in the IASA board and um have one vote in in his decision making.
[06:31] The other body associated with law making in Europe is the European commission which has two members from each member State uh and therefore two votes.
[06:45] So the functions of AAS are managed under a management board which brings together representatives from those member states um and also Observer countries which are countries that are not actually part of the European Union but they're uh got a a stake in following the regulation system for aviation in Europe.
[07:08] Also involved are the asasa stakeholder Advisory Board uh with its members drawn primarily from the aviation industry uh manufacturers maintenance companies.
[07:21] Etc, uh, and these parties, they take place as observers in the rule-making process.
[07:28] The European Commission is actually the body that develops and adopts the high-level aviation regulations, uh, but he does so with assistance from EASA, which is the industry expert, so to speak, in Europe.
[07:42] The EASA management board meets on a regular basis, and it takes its decisions in support of the key principle and goal of ensuring aviation safety and environmental protection in Europe.
[07:53] And the decisions taken by the EASA board are regularly published on the EASA's website.
[08:04] Decision-making at a European Union level involves various European institutions, in particular the European Parliament, which represents the EU citizens and is in fact directly elected by them.
[08:18] The European Council, which consists of the heads of state or.
[08:23] Governments of the EU member states and the European Commission, which represents the interest of the EU as a whole, the European Council defines the general political direction and the priorities of the EU, but it does not exercise any legislative functions.
[08:42] Generally, it's the European Commission that proposes and develops new laws, including aviation laws, and it's the European Parliament and European Council that adopt them into law.
[08:53] Essentially, they're adopting a set of essential requirements specifying the objectives to be met by the legislation.
[09:01] So the European Commission then adopts what we know are implementing rules for achieving these high-level objectives.
[09:10] And this is what we call the detailed regulations.
[09:16] So the European Commission is responsible for implementing regulations in the member states which reflect the essential.
[09:25] The essential intent of the higher level laws, the legislative acts passed down from the European Parliament and Council.
[09:32] Now, the primary responsibility for implementing the EU laws lies with the EU countries, and they can in fact do that through their own laws.
[09:44] However, in areas where uniform conditions for implementation of the law are needed, such as finance and tax, agriculture, internal European market, food safety, and to a large degree aviation, the European Commission adopts an implementing act.
[10:01] An implementing act means that the Commission must implement legal instruments, which are regulations, directives, etc., which exactly reflect the content intent of the higher level legislative act with no deviations.
[10:17] Where it is not necessary to ensure absolutely uniform application of the legislative act across all member states, a delegated act.
[10:28] Can be adopted by the EU commission with delegated acts.
[10:32] The commission has some power to make amendments or add supplements to the higher level law to provide flexibility or to optimize its implementation.
[10:41] Effectively, the EU Parliament has delegated the responsibility for enacting the intent of the particular legislative act down to the commission and hence to member states.
[10:50] However, this does have strict limits and the delegated act cannot change the Essential Elements of the law passed by the parliament.
[10:57] Um, and the legislative act must define the objectives, content, scope, and duration of the delegation of power.
[11:06] The implementation of EU Aviation legislation has moved to some degree in recent years, uh, towards delegated acts.
[11:14] Although I'd say that 95% of the legislation related to Aviation is in fact an implemented act, which means it has to be, um, copied exactly across all the member states.
[11:29] Followed to the letter the basic uh regulation for Aviation.
[11:36] Now EASA's legal powers derive from this regulation, the basic regulation which originally was EC number 216/2008.
[11:45] Um, now the current regulation as amended in 2018 is EC 2018/1139.
[11:54] That represents the latest thinking and objectives of Aviation regulation in Europe.
[12:00] So this amended basic regulation, the latest version, defines the agency's roles and responsibilities and establishes common rules in the field of Aviation.
[12:11] Now EASA undertakes its role, uh, what it does, it undertakes its role in regulation through the application of a wide range of provisions which expand upon and interpret the requirements of this basic regulation, which you can call the...
[12:29] Parent regulation for aviation in a manner that provides sufficient technical detail and guidance to be applicable.
[12:39] The enforcement of the uh regulations uh are put in place by the European commission supported by EASA and indeed the National Aviation authorities of each of the member states.
[12:56] So what does basic regulation 2018/1139 cover?
[13:00] Well, everything including design, production, maintenance, and operation of aircraft in EU territory as well as the operational infrastructure such as aerodromes, air traffic control, and air navigation systems.
[13:15] So all those things: operation of aircraft in and out of EU territory, design, production, and operation of safety-related aerodrome equipment and support of aerodromes.
[13:30] Including uh safeguarding of their surroundings.
[13:37] This is a a quick high level overview of the European regulatory structure.
[13:43] The basic regulation 1139 derives as we said earlier from the ICAO, so it adopts all of the regulations or rather recommendations coming out of the 19 annexes of ICAO.
[14:03] Secondly, the regulation includes the European Union's own objectives for Aviation safety and efficiency and that is derived from a plan for Aviation safety, but there's also economic considerations as well.
[14:19] So underneath the basic regulations we have the sort of four functional groups of Aviation, there air worthiness which we're mostly concerned with in this uh set of instruction and that.
[14:31] Includes the regulation of initial air worthiness and the regulation for continuing air worthiness.
[14:39] Also flight standards, uh, things like air crew which covers training and licensing and medical aspects, uh, regulation of air operations, and so it goes on.
[14:53] There's a number of different categories there, but as I said, we're going to be focusing on air worthiness in this course.
[15:04] The basic regulation, as amended in 2018, provides the common rules for civil aviation and it's based upon a risk-based and operation-centric approach to legislate for aviation safety.
[15:19] Its objectives as a regulation are to provide a high uniform level of civil aviation safety throughout Europe.
[15:28] To focus European Safety Action Resources on addressing the highest.
[15:33] Safety risks to reduce risk levels by uh excellent communication across the states and the direct involvement in decision making of those states and collaboration of resources across the EU to be efficient.
[15:47] So there we have it, EASA aims to be a performance-driven regulatory agency operating at quite a high level.
[15:56] And it's focused on refining and standardizing regulation in those areas which it sees to have the most influence on aviation safety and economic benefit for the EU.
[16:08] So coming out of that is a decision from EASA to now delegate more of the routine regulatory functions, such as licensing and approving organizations, to the member State National Aviation authorities.
[16:21] And this frees up EASA's resources to support its high level aims.
[16:26] So there we have it in summary, delivering better governance, making better use of limited.
[16:33] Resources, uh, it should be a flexible and performance-based system regulation and to patch up any gaps and inconsistencies in existing laws.
[16:47] Some of the changes progressively being introduced are, if they haven't already been introduced, the creation of a pan-European pool of aviation inspectors.
[16:56] Uh, meaning that, uh, inspectors from any country in Europe can participate in inspection activities across other states, thereby making good use of, uh, skilled resources.
[17:09] Framework for transferring responsibilities, oversight mechanisms, a central database for, uh, collecting all the certified persons and organizations together in one source of data and, in generally, improved work at the international.
[17:34] Level so on a European level in the context of EPAS, which is the European Plan for Aviation Safety, the intent of the EASA is to be proactive and predictive when it comes to safety.
[17:49] To look ahead, identify persistent or emerging risks in aviation and put in place safety actions to deal with them, and then track the results to see if they're effective.
[18:02] So the main objectives and priorities of EPAS under EASA are closely aligned with the goals of improving aviation safety and environmental sustainability.
[18:13] So the plan identifies specific safety risks and outlines actions to mitigate those risks through regulatory changes, oversight activities, and safety promotion efforts.
[18:25] For example, enhancing operational safety, including efforts to reduce runway excursions, loss of control in flight events, and midair.
[18:35] Collisions, uh, improving organizational safety by strengthening Safety Management Systems, or SMS, across the industry, that's a very, um, high-profile item for the EPAS.
[18:48] Enhancing oversight capabilities of organizations and promoting a safety culture within those organizations.
[18:54] Also addressing emerging threats, such as cybersecurity threats to critical aviation infrastructure and the safe integration of drones into shared aerospace.
[19:06] Environmental sustainability, EPAS, also incorporates objectives related to reducing, uh, aviation's environmental footprint.
[19:17] Focusing on noise reduction, lowering emissions, and promoting sustainable aviation fuels.
[19:21] So the EPAS has a quite a wide-ranging, uh, set of projects, but I would say that the focus is largely on safety, uh, and on design and certification.
[19:37] Activities, in fact, this is reflected by the um, this is a chart which shows the uh activities or rather actions that have been put into the European plan for Aviation safety.
[19:53] Um, you know, something like 10,080 action items.
[19:58] And uh 51 of those are related to implementing effective Safety Management Systems in organization, so that's a very, a very big and important theme for YASA.
[20:09] Uh, the second uh highest number of project actions are design and production related, sustaining high levels of certification compliance and dealing with new technologies.
[20:22] So the overall strategic theme for EPAS during its review period of three years is to, is to focus on a safe, secure, sustainable and resilient Aviation system which is capable of coping with this disruptive events of any type.
[20:37] I mean, we've learned.
[20:39] quite a bit from the pandemic a few
[20:40] years back and it was good to see that
[20:43] during the pandemic uh the eu's aviation
[20:47] safety system uh maintained a high
[20:50] safety record it wasn't impacted really
[20:53] any way by the the the uh the problems
[20:57] brought about by by covid on the world
[21:00] supply chain and
[21:02] on on uh people's communication and many
[21:05] other
[21:08] factors so what is the role of
[21:12] aasa well you can break it down into
[21:14] about four things really there's Ru
[21:17] making so that's drafting or drafting
[21:20] amendments to the high level basic
[21:23] regulation and also the implementing
[21:25] rules at a a lower level below that
[21:27] regulation
[21:30] iasa also drafts and adopts what we call
[21:33] soft law which is certification
[21:35] specifications uh AMC's uh acceptable
[21:39] means of compliance and uh guidance
[21:43] material the
[21:44] second most important function of the
[21:47] ASA is certification management or
[21:50] oversight uh the issue of design
[21:52] approvals for modifications under type
[21:55] certificate and supplemental type
[21:56] certificate systems the issue of
[21:59] organization approvals for design
[22:01] organizations and production
[22:04] organizations issue maintenance
[22:06] organization approvals MOA and also POA
[22:10] for non-european States and continued
[22:13] oversights of those certificates of
[22:17] approval on the certification side asasa
[22:20] checks all the European Union products
[22:22] for their air worthiness including their
[22:24] operational suitability and their
[22:26] environmental performance against
[22:28] technical standards and
[22:30] requirements for any new product a
[22:32] certification team is established in the
[22:34] ASA and they start their work by
[22:36] familiarizing themselves with the
[22:37] product design the applicable technical
[22:40] standards and requirements are
[22:41] determined and the certification program
[22:43] is
[22:44] agreed the compliance is demonstrated by
[22:47] the improved design organization and
[22:49] checked by the ASA certification team
[22:52] according to the agreed certification
[22:53] program so ultimately the Assa team
[22:56] issues a final report and issues a
[22:58] certificate for the design only if the
[23:01] product passes all technical
[23:03] requirements and if no unsafe feature
[23:05] has been
[23:07] detected so European rules and oversight
[23:10] mechanisms including the maintenance of
[23:12] products ensure that the initial levels
[23:14] of safety uh from a design and from a
[23:16] type certificate are maintained
[23:18] throughout the product's
[23:22] life the two principles which you might
[23:24] say operate in the ASA are the central
[23:27] role of the type certificate holder um
[23:30] for owning the air worthiness of their
[23:34] products throughout their life cycle
[23:37] secondly the delegation of compliance
[23:39] verification to approved organizations
[23:42] unlike the FAA system
[23:44] Thea has gone to a system where there is
[23:47] a high level of Delegation and Trust if
[23:49] you like in approved organizations to
[23:53] carry out the functions of verifying
[23:55] approval to the airworthiness standards
[24:00] standardization is another element of
[24:03] aasa's role ensuring that uh the rules
[24:06] are implemented equally and fully across
[24:10] all the member states and they also
[24:12] report back to the European commission
[24:15] it is actually the European commission's
[24:17] role to ensure that all member states
[24:19] implement the asasa rules or the
[24:21] implementing rules as they're called but
[24:23] it does rely on aasa to act as a monitor
[24:25] on this and report back to the
[24:26] commission what's going on in each of
[24:28] the countries he alsoa also forms a
[24:31] center of expertise on Aviation
[24:32] regulation and operations in the EU and
[24:36] it has a function to manage
[24:37] International
[24:38] relationships um developing harmonized
[24:41] rules for regulations for example
[24:43] between the major Regulators between say
[24:45] the US and Europe um also to put in
[24:50] place mechanisms for accepting
[24:52] certificates and air crew licenses from
[24:55] other countries that are not in the EU
[25:01] the National Air worthiness authorities
[25:03] in the EU States also have a role to
[25:05] play in the certific in the regulation
[25:07] of aviation in Europe their function is
[25:11] to do some of the things that the ASA
[25:13] used to do such as issue certificates
[25:15] air worthiness certificates CFA Etc
[25:18] noise
[25:20] certificates uh approve and issue
[25:22] certificates for organizations such as
[25:24] part M part 145 which is maintenance
[25:28] part 147 training and part 66 uh
[25:31] engineer
[25:33] licensing issue production organization
[25:36] approvals uh for and also part 21
[25:39] approvals and these are done following a
[25:43] strict set of rules laid down by aasa so
[25:45] aasa is delegated to the Naas the
[25:48] responsibility for making sure that any
[25:50] organization that sets itself up in
[25:52] Europe to do maintenance or design or
[25:55] continuous aworth management is
[25:57] following those
[25:59] regulations the Naas also help provide
[26:03] expertise for future easa rule making
[26:06] certification
[26:08] activities and overall they have a
[26:10] requirement or sorry a responsibility uh
[26:13] each of the na is has a responsibility
[26:15] to ensure that the requirements for
[26:17] airor worthiness product design
[26:19] organization approval and also Personnel
[26:21] licensing are followed within the member
[26:24] states
[26:28] so you can see here that multiple
[26:30] parties are stakeholders in the aviation
[26:32] Regulatory and safety framework in
[26:35] Europe when a new set of Aviation
[26:38] legislation is brought into official EU
[26:40] law this is done by the European
[26:42] Parliament and
[26:43] Council the European commission is the
[26:46] politically independent executive arm of
[26:48] the EU which proposes and adopts changes
[26:50] to Aviation legislation following a rul
[26:53] making procedure in which iasa provides
[26:56] the proposed implementing rules based on
[26:58] Aviation safety objectives and the data
[27:01] gathered from
[27:03] industry the IRS or implementing rules
[27:06] are the rules implemented to enable the
[27:08] essential requirements of the basic
[27:09] regulation for
[27:11] Aviation iasa develops the detailed
[27:13] technical rules oversees the adoptions
[27:16] of the regulations by industry such as
[27:18] operators manufacturers and maintenance
[27:20] organizations and provides an
[27:22] overarching Safety Management function
[27:24] under the European plan for Aviation
[27:26] safety which includes a collection of
[27:28] data about safety
[27:31] concerns the whole iasa regulatory
[27:33] system is based on monitoring safety
[27:36] performance and then making reg
[27:39] recommendations uh they're called
[27:41] opinions to the EC the European
[27:43] commission for regulatory changes where
[27:46] these changes will improve safety and or
[27:50] efficiency the National Aviation uh
[27:53] authorities of individual EU states
[27:55] which are called the competent
[27:56] authorities by yasa
[27:58] have certain responsibilities to
[28:00] establish the Frameworks for approval
[28:02] and oversight of Aviation organizations
[28:05] operating on their territory in
[28:07] accordance with the common Esa
[28:09] requirements not their own so member
[28:12] states cannot issue uh their own
[28:14] Aviation rules they can't Devi deviate
[28:16] at all from the EU rules nor can they
[28:19] make any other arrangements with other
[28:21] countries regarding Aviation
[28:24] regulations industry at the lower level
[28:27] uh that's the operators Airlines and
[28:28] maintenance organizations Etc are
[28:31] required to comply with the established
[28:34] regulations and also provide feedback on
[28:37] their operational safety to both their
[28:39] nias and to
[28:40] iasa um and also the nias and The
[28:44] Operators and Industry do participate in
[28:47] developing Aviation
[28:50] regulations in fact the ass's working
[28:52] method is to be totally transparent
[28:54] about this um about for the adoption of
[28:58] opinions which is opinion being a
[29:00] recommendation to change a
[29:02] regulation and also um in their
[29:04] development of acceptable means of
[29:06] compliance and guidance material within
[29:08] regulations so if they're making any
[29:10] changes they publish them and get input
[29:12] from the industry and from The Wider uh
[29:14] community of aviation in
[29:16] Europe um so these transparent
[29:19] procedures ensure that the right people
[29:21] are involved we get the expertise
[29:23] focused on developing the
[29:25] regulations uh there's adequate
[29:27] Consulting ation and feedback and each
[29:30] member state in the EU in the EU has the
[29:33] uh right to be associated with the
[29:35] adoption
[29:37] process there's also special procedures
[29:39] that allow the agency to take more uh
[29:42] direct and immediate action in the case
[29:43] of emerging safety
[29:45] problems so similar you know transparent
[29:48] procedures also apply in the case of IND
[29:51] individual decisions so it's a
[29:52] democratic and open process um which uh
[29:56] enables everybody to to fully
[29:59] transparently see what's going on in
[30:01] terms of the development of of Aviation
[30:05] legislation the develop of opinions uh
[30:07] opinions as I said being recommendations
[30:10] for change um
[30:13] byasa uh involve a lot of stakeholders
[30:16] uh there's some of them here on this
[30:18] diagram obviously each of the European
[30:21] Union countries National Aviation
[30:22] authorities Iko
[30:25] itself uh inputs from the objectives of
[30:28] the European Aviation safety plan safety
[30:31] recommendations coming out of any safety
[30:33] studies uh also input
[30:36] from the National Aviation authorities
[30:38] of countries that are not in the
[30:40] European Union and so on so there's uh
[30:43] quite a wide community of stakeholders
[30:46] involved in the development of opinions
[30:47] or
[30:49] regulations this is the process followed
[30:52] this flowchart shows a sequence of
[30:53] actions when heasa adopts a new safety
[30:56] recommendation
[30:58] involving co uh consultation with
[31:00] industry stakeholders so it starts off
[31:02] with the concept of a rul making program
[31:06] initiate the task for the new rules
[31:08] consult various uh stakeholders and
[31:10] bodies in the formulation of that um
[31:13] initial idea uh and develop terms of
[31:17] reference uh and then this is analyzed
[31:19] and turned into an RA which is
[31:22] a a regulatory impact
[31:26] assessment a draft rule R is then uh
[31:29] drafted up and it's
[31:31] circulated amongst the public and the
[31:34] industry for their comments and
[31:36] inputs uh it's circulated as an NPA
[31:40] which is a notice of proposed
[31:42] amendment and that contains explanatory
[31:45] note what impact it will have on the
[31:47] current
[31:48] regulations what the draft proposal is
[31:50] what proposed changes are uh and a check
[31:53] against the uh ik uh high level
[31:56] recommendations as well so it may
[31:59] propose a new rule altogether or
[32:01] amending an existing regulation Andor um
[32:05] perhaps generating a new alter sorry
[32:08] acceptable means of compliance uh and
[32:10] guidance
[32:11] material a crd which is a common
[32:14] response document is
[32:16] the a list or table of all of the
[32:19] answers responses to all of the comments
[32:21] it received during the NPA process so
[32:23] the the industry
[32:25] stakeholders uh provide their put that's
[32:28] all gathered together uh so it's
[32:30] captured in the
[32:32] crd and ultimately this results in the
[32:35] ASA generating from all this information
[32:37] yasa puts together an opinion which is
[32:40] the final proposal to the European
[32:42] commission for implementing rules so at
[32:44] the end of the r making process iasa
[32:47] have developed a rule that reflects uh
[32:49] some serious study and a lot of input
[32:51] from other people um so we've got some
[32:54] Buy in there on the regulation it's not
[32:57] as I said before it's a transparent
[32:59] process which ensures that it's going to
[33:01] work in practice and it's going to be
[33:03] adopted
[33:07] successfully so in the Assa system
[33:10] there's a hierarchy of rules the basic
[33:13] regulation sets the scene which
[33:15] activities are covered who what requires
[33:18] a
[33:19] certificate and contains high level
[33:21] safety objectives which are called
[33:23] essential
[33:25] requirements beneath the essential
[33:27] requirements of the basic regulation
[33:29] there are detailed implementing rules
[33:32] IRS which we just generally call the ASA
[33:34] regulations but technically they're
[33:36] called the implementing rules in
[33:39] addition to this easa is responsible for
[33:41] drawing up um non-binding advisory
[33:44] material the so-called soft
[33:47] law which is it's uh semi- applicable as
[33:51] a law in the sense that if you want to
[33:54] certify your product or get your
[33:55] organization approved uh you really do
[33:58] need to comply with uh you know these
[34:02] acceptable means of compliance or these
[34:03] certification standards
[34:13] CS so this is a simple model of the
[34:17] different regulatory levels starting at
[34:20] the top with you know this hierarchy
[34:22] starting at the top there's the basic
[34:24] regulation which sets the scene which is
[34:26] the parent regulation for all Aviation
[34:28] activity regulation in Europe um the
[34:32] agency opinions are developed for that
[34:34] recommendations coming out of the ASA
[34:37] and they're submitted to the European
[34:40] Parliament and Council turned into a law
[34:42] becomes a binding law uh and then we go
[34:45] down another level where the European
[34:47] commission is responsible for developing
[34:49] the more detailed regulations the
[34:51] implementing rules again with agency
[34:54] opinion or
[34:55] recommendations uh and right underneath
[34:57] that is the soft law I mentioned which
[34:59] is the um the standards to be followed
[35:02] and the guidance material and again um
[35:05] that's called an agency decision because
[35:07] they're responsible for issuing it
[35:09] themselves it's not uh it's non-binding
[35:12] it's not law so the um the agency can
[35:15] actually issue that stuff uh itself
[35:18] without going back to the European
[35:20] legislative
[35:22] system this is a a more detailed
[35:26] illustration of the same thing thing
[35:27] really so we have at the top the basic
[35:30] regulation 1139 2018 the uh the parent
[35:34] law for Aviation basic
[35:36] regulation uh and underneath that
[35:39] there's a number of annexes which
[35:40] contain all of the essential
[35:41] requirements the
[35:43] ERS uh everything we want to achieve in
[35:45] each of the aviation areas in terms of
[35:48] um control and
[35:51] safety um the level below that are the
[35:54] implementing rules uh which are the more
[35:56] detailed Reg regulations again these are
[35:59] binding in law and they specify the
[36:01] actual processes for things like design
[36:04] production Ops and services so we've got
[36:06] the objectives at the high level and
[36:08] we've got the processes and the way
[36:09] you're supposed to do it at at the
[36:11] implementing rule level um implementing
[36:15] rules apply to processes they also apply
[36:17] to
[36:18] organizations uh o here is organization
[36:22] requirements what industry has to do to
[36:25] comply and also the authorities the
[36:28] National Aviation authorities have a set
[36:30] of regulations they've got to follow
[36:32] that's the AR um Authority requirements
[36:36] which relate to their oversight of these
[36:38] organizations in their country um
[36:41] advisory material AMC acceptable means
[36:44] of compliance which is one possible way
[36:46] to comply but it it usually is the only
[36:49] way to comply in practice um
[36:51] certification standards or CS uh which
[36:54] relate to technical design requirements
[36:56] in the main
[36:58] and GM which are guidance material or
[37:01] general explanations of the
[37:03] [Music]
[37:06] regulations so as we said the
[37:08] implementing rules are legally binding
[37:09] on the organizations and on the National
[37:12] Aviation authorities uh and the EU
[37:14] member states can't add any additional
[37:17] requirements now it is possible that
[37:19] operators can operators and design
[37:21] organizations can develop alternate
[37:23] means to comply with the requirements of
[37:26] an implementing a rule apart from the
[37:28] published
[37:30] AMC's so there is a process to do that
[37:32] it's called alternate means of
[37:34] compliance and it would have to be you
[37:37] the organization seeking to comply with
[37:40] the regulation by different means would
[37:42] have to give some pretty good
[37:43] justification why it would provide an
[37:46] equivalent level of safety and control
[37:48] so it's actually quite difficult to do
[37:49] in practice and it's really easier to
[37:52] try and comply with the published
[37:56] AMC's so this is the actual structure of
[37:58] the basic
[38:00] regulation 1139 and it contains the high
[38:03] level Aviation law the nine annexes
[38:06] underneath it contain the essential
[38:08] requirements which must be complied with
[38:10] for each of these specific areas of
[38:12] Aviation
[38:14] regulation other regulations within each
[38:16] Annex contain the detailed implementing
[38:19] rules or more commonly we call them the
[38:21] ASA
[38:22] regulations and as said on the previous
[38:25] slides both ER and are binding and law
[38:28] and you've got to comply with
[38:30] them so there we have it the nine
[38:32] annexes uh in the basic regulation and
[38:35] the covering regulation itself which has
[38:37] six
[38:38] chapters we'll go through those
[38:42] now so structure of the basic regulation
[38:46] chapter one are the principles of of the
[38:49] regulation and objectives which is to
[38:51] improve performance in the aviation
[38:53] sector provide a Level Playing Field in
[38:56] the European market for Aviation promote
[38:59] Fe free trade by air and cost efficiency
[39:02] provide a uniform level of Environmental
[39:04] Protection promote Research into
[39:06] Aviation and to provide a safe Aviation
[39:10] environment also to assist member states
[39:14] in exercising their rights uh in
[39:17] fulfilling their obligations under the
[39:18] Chicago
[39:20] convention uh by ensuring a common
[39:22] interpretation and a uniform and timely
[39:25] imp implementation of its Pro Provisions
[39:27] so the sarps um developed by
[39:31] Iko are interpreted in a single way
[39:36] under the basic
[39:38] regulation uh which prevents individual
[39:41] countries you know interpret them
[39:43] slightly differently and therefore
[39:44] having different Aviation
[39:46] regulations so iasa performs that
[39:49] standardization function of
[39:52] defining the principles of operation and
[39:54] the essential
[39:55] requirements chapter 2 Aviation Safety
[39:58] Management is stems from I's Annex 19
[40:05] requirements and this is the um European
[40:08] and state safety programs each member
[40:10] State uh State shall in consultation
[40:13] with all the relevant stakeholders
[40:15] establish and maintain a state safety
[40:17] program or
[40:18] SSP for the management of civil aviation
[40:21] safety in relation to the aviation
[40:24] activities under its
[40:25] responsibility it's called the the yeah
[40:27] State safety
[40:29] program the state safety program shall
[40:31] include at least the elements related to
[40:34] sa State Safety Management
[40:36] responsibility as described in the ik uh
[40:39] 19 Annex and recommended
[40:43] practices aasa shall also
[40:46] maintain a European plan for Aviation
[40:49] safety as described
[40:50] earlier chapter three is the substantive
[40:54] requirements so these are the detailed
[40:57] or rather top level requirements for the
[40:59] regulation and management of aviation in
[41:01] each of these uh activity areas air
[41:04] worthiness and environment air crew Air
[41:08] Ops AA drones and air traffic management
[41:10] and navigation systems air traffic
[41:13] controllers unmanned aircraft or drones
[41:16] and Third Country
[41:18] operators for example the airworthiness
[41:21] environmental section is where the basic
[41:23] requirements for the certification of
[41:25] aircraft and products and the approval
[41:27] of design and production organizations
[41:30] are
[41:31] stated so in this section the um the
[41:35] certification of aircraft and products
[41:38] is stated including the issue of or the
[41:41] requirement for the issue of a type
[41:42] certificate supported by operational
[41:44] suitability
[41:46] data this chapter also establishes the
[41:50] requirement for design and production
[41:51] organizations to be approved and issued
[41:54] with a
[41:55] certificate the requirement ments for
[41:57] personnel responsible for aircraft
[41:59] maintenance and indeed uh flying
[42:02] aircraft
[42:03] Pilots to be approved and possess a
[42:06] license is also established in this
[42:08] section the detailed essential
[42:10] requirements for Air worthiness are in
[42:13] fact included in Annex 2 of the basic
[42:17] regulation uh and
[42:19] the essential requirements for the other
[42:22] areas of Aviation activity uh are are
[42:25] detailed in other annexes so there's a
[42:27] quite a large number of
[42:33] annexes chapter four is about joint
[42:36] oversight and enforcement is where the
[42:38] basic requirements for delegating the
[42:40] responsibility for managing and
[42:42] overseeing the aviation regulations to
[42:45] the National Airness authorities in each
[42:47] EU member
[42:49] state so these uh the Naas in each state
[42:53] are known as the competent authorities
[42:55] competent in the sense of
[42:58] being uh able to enforce the regulations
[43:01] and have the the knowledge and the
[43:03] oversight to do
[43:05] so uh and this section requires the
[43:07] competent authorities to undertake such
[43:10] responsibilities as managing the
[43:11] certification of Aviation operators uh
[43:14] Airlines and general aviation operators
[43:18] and organizations in their state
[43:20] including maintenance and
[43:23] production their responsibilities also
[43:25] the inspection and auditing of these
[43:27] organizations issuing of licenses and
[43:30] certificates so everything in accordance
[43:32] with the basic uh regulations essential
[43:35] requirements and this will include the
[43:37] oversight of flight Operations Air
[43:39] worthiness ATC and the aerodromes in
[43:42] their
[43:43] countries chapter five is all about aasa
[43:47] these are the high level requirements
[43:48] for iasa what its role and purpose is
[43:51] the tasks that it carries out
[43:53] responsibilities methods and how it's
[43:56] financed from the European
[43:58] Union chapter six uh final Provisions
[44:02] this is the legal statements about the
[44:04] powers delegated by the European
[44:06] Parliament to the European commission uh
[44:08] to enable them to adopt Aviation acts
[44:10] and Implement regulations to ensure that
[44:13] the essential requirements of the basic
[44:14] regulation are both carried out and
[44:21] effective the annexes uh yes it's quite
[44:25] a large number of those there's nine uh
[44:27] each one of those relates to a specific
[44:28] area of Aviation uh
[44:31] activity and as maintainers and
[44:34] designers we are most interested in
[44:36] Annex 2 airworthiness
[44:40] requirements uh a new annex 9 has been
[44:42] introduced in recent years to cover uh
[44:45] uavs or
[44:48] drones so what is the role of AMC's
[44:52] acceptable means of compliance they're
[44:53] non-binding and they're known as soft
[44:55] law because the responsibility to ensure
[44:58] compliance sits with the national
[45:00] competent Authority who have the ability
[45:03] to vary the
[45:05] requirement so the AMC serves as a means
[45:08] by which the requirements contained in
[45:10] the basic regulations and implementing
[45:12] rules can be met so the AMC illustrate a
[45:15] means but but not the only means by
[45:18] which a requirement of an implementing
[45:20] rule can be met so the means of
[45:23] compliance may be by the establishment
[45:25] of management systems and processes
[45:27] by implementing controls quality and
[45:30] oversight systems by provision of
[45:32] operational data or by carrying out a
[45:35] standard test and numerous other methods
[45:37] depending on the nature uh of the
[45:39] activity being carried out and being
[45:44] regulated so satisfactory compliance
[45:48] using anasa published AMC is the way to
[45:52] facilitate certification tasks of the
[45:54] applicant and the competent Authority
[45:56] the n
[45:58] however NAA and the organizations in
[46:01] their states May propose an alternate
[46:04] means of complying with a particular
[46:05] regulation uh they're called alms or
[46:08] alternative means of compliance and they
[46:11] are really proposing an alternative to
[46:14] existing AMC maybe a variation on it or
[46:17] a method of showing compliance by
[46:19] another method other than the process or
[46:22] test required uh in the existing
[46:25] AMC however if you're going to use an
[46:29] alternative means of compliance you've
[46:31] got to justify it and come up with a a
[46:34] very sound and thorough statement as as
[46:36] to why it's as good as the existing AMC
[46:39] so it is quite difficult to do it's
[46:40] quite a challenge but it can be done you
[46:43] know particularly in regard to perhaps
[46:46] new technology where the existing
[46:49] regulations are not able to accommodate
[46:52] a new way of doing things in aviation
[46:55] perhaps things like electric aircraft or
[46:57] composite structures uh drones and so
[47:00] forth uh there may be a need for
[47:02] alternate means of compliance when the
[47:05] the regulations have not quite yet
[47:06] caught up with the uh the technology
[47:11] Evolution what are certification
[47:14] specifications well CS they're
[47:17] non-binding uh technical standards
[47:19] adopted byasa to meet the essential
[47:21] requirements of the basic regulation in
[47:23] regard to design in particular or
[47:26] initial air
[47:27] worthiness so they're the reference
[47:30] technical standards against which a
[47:32] design can be evaluated so the Cs
[47:35] specifications
[47:36] cs25 are for example very similar to the
[47:39] US f25 requirements because they've been
[47:42] harmonized across um across the two
[47:46] authorities so it's mainly concerned
[47:48] with part 21 CS it's concerned with the
[47:52] certification of
[47:55] designs uh I'm what we say is that if
[47:58] all the various aspects of the aircraft
[48:00] affected by the design such as flight
[48:02] loads structural Integrity flammability
[48:05] Interiors electrical power systems
[48:07] safety and so on if they all follow the
[48:09] requirements of the related CS standards
[48:13] a design can be considered airworthy and
[48:16] therefore it can be certified by ASA so
[48:19] the Cs standards have been developed
[48:21] over decades to represent the key things
[48:24] to be taken into account um when you're
[48:27] designing an aircraft or a product and
[48:29] we have basically there's five groups of
[48:33] Cs specs cs27 specs which relate to
[48:36] small helicopters CS 29 large
[48:39] helicopters cs23 general aviation light
[48:42] twin aircraft Etc cs25 large aircraft
[48:46] and airliners uh and another one for
[48:49] drones so they've all got their specific
[48:52] design requirements for different types
[48:53] of aircraft this is an example uh on a
[48:56] of a technical level here um this is an
[49:00] example of a certification standard for
[49:02] the design of an aircraft electrical
[49:04] system CS
[49:07] 25355 um I'm not really going to get too
[49:10] much into electrical design here but
[49:12] just illustrate the principle
[49:15] the this CS defines uh what electrical
[49:19] power distribution system is on an
[49:22] aircraft and it states that for an
[49:24] aircraft that requires two sources of
[49:26] power J generation for his certification
[49:28] which will be the case for any two
[49:30] engined aircraft that if one source of
[49:32] electrical power fails such as a
[49:34] generator then it must be possible to
[49:37] automatically or manually switch to the
[49:39] other generation source so this implies
[49:42] that both the electrical generation
[49:44] systems should be able to feed essential
[49:46] systems via a common bus and you can see
[49:48] that there on that very much simplified
[49:50] aircraft electrical system
[49:55] diagram however the m c uh further
[49:58] clarifies the
[50:00] requirement by stating that in order to
[50:03] achieve proper and reliable Independence
[50:05] of the two electrical power sources the
[50:08] protection and distribution system
[50:09] should be designed in such a way that a
[50:11] single fault such as a short circuit
[50:14] short circuited feeder or bus will not
[50:16] disable the supply from both sources so
[50:20] the AMC is basically an elaboration of
[50:22] the of the cs25
[50:25] requirement um providing guidance as to
[50:27] how the design should be
[50:29] configured so we say yes you must be
[50:32] able to maintain two independent sources
[50:35] of power um but watch out because when
[50:39] you design this you've got to make sure
[50:41] in doing that that there is no one
[50:42] single fault that could cause you to
[50:44] lose the redundancy of having two
[50:47] systems so um really the Cs is a short
[50:51] and simple
[50:52] requirement in its statement it's not
[50:55] it's not a long um design design
[50:57] requirement but if you read the AMC it
[51:00] implies that there is actually more to
[51:02] it and uh you know you're going to need
[51:05] to put in place a fairly complex set of
[51:07] production devices relay circuitry and
[51:10] switching logic in order for this system
[51:13] to meet the the requirement of
[51:14] Independent Electrical Power so that's a
[51:16] typical design type of um CS or they're
[51:19] mostly relate to design but obviously
[51:21] not just electrical power aspects of
[51:23] structure power plants and every part of
[51:26] the air
[51:27] CFT guidance material on the other hand
[51:29] is is a non-binding explanatory
[51:32] interpretation material about how to
[51:34] read the
[51:35] regulations and how to achieve the
[51:37] requirements in those um regulations and
[51:41] also AMC's and CS so it gives uh
[51:44] information and sites some examples uh
[51:47] to assist the user in developing a
[51:49] response to the basic
[51:54] regulation well here's an example of and
[51:56] guidance material this one is regulation
[51:58] 21 La
[52:00] 229 uh which relates to unrepaired
[52:03] damage so what we have here is the the
[52:07] actual regulation says that if any
[52:09] unrepaired damage should be evaluated by
[52:11] a competent design organization to
[52:13] determine whether it has any impact on
[52:17] uh air worthiness and environmental
[52:19] compatibility if that damage is not
[52:22] already covered by uh data that's been
[52:25] put out by I guess by the the aircraft
[52:27] manufacturer so that's clarified in the
[52:30] GM for the same regulation and it says
[52:33] here the process is not intended to
[52:36] supersede the normal maintenance
[52:37] practices defined by the declarant such
[52:39] as carrying out actions to repair the um
[52:43] structural damage but addresses specific
[52:46] cases not covered in the manufacturers
[52:48] documentation so in the blue there 21l
[52:53] 229 is the statement of the requirement
[52:56] actual regulation the GM there in the
[52:58] green is a clarification about what it's
[53:02] intended to do so this is this is the
[53:03] purpose of of guidance
[53:09] material so this is an expansion of the
[53:11] previous diagram um the basic regulation
[53:14] but narrowed down just to the areas
[53:16] dealing with um air
[53:19] worthiness so in respect of air
[53:22] worthiness or for um aircraft we have
[53:25] two sub regulations which sit underneath
[53:28] the basic
[53:29] regulation um within Annex 2 U one of
[53:33] them is 748
[53:35] 2012 and that relates to initial air
[53:38] worthiness or certification what we call
[53:41] part
[53:43] 21 on the other side uh relating to
[53:46] continuous air worthiness uh is
[53:49] regulation
[53:50] 1321
[53:52] 2014 and that contains uh something like
[53:56] about I think there seven annexes there
[53:58] anyway from from Annex Annex one through
[54:00] to
[54:01] 5D so
[54:04] um the ones we're concerned within this
[54:06] series of instructions are Annex one
[54:08] which is part M uh continuous air
[54:11] worthiness management part 145 in Annex
[54:15] 2 to this regulation which is
[54:16] maintenance uh
[54:18] requirements and Annex 5C which relates
[54:21] to the approval of a camo organization
[54:25] continuous worthiness management
[54:27] organization uh it's called part camo
[54:30] and underneath underneath all that uh
[54:33] specific to those regulations they are
[54:35] the
[54:36] AMC's uh acceptable means of compliance
[54:39] and certification standards as we
[54:41] discussed uh just
[54:43] now that's the non-binding
[54:46] law so to finish up um definition of air
[54:50] worthiness is defined in
[54:53] Annex 8 part one and it's important to
[54:57] understand what an airworthy aircraft is
[54:59] it is one which conforms to its type
[55:03] design um which is in a condition for
[55:05] safe operation those two things have to
[55:07] be concurrent before you have an
[55:09] airworthy
[55:15] aircraft the aircraft must conform to
[55:17] its type design so this is considered to
[55:19] be attained when the aircraft
[55:22] configuration is configuration uh being
[55:25] its all its components and
[55:28] elements so this configuration and when
[55:30] the components installed are consistent
[55:33] with the drawings specifications and
[55:35] other data that are part of the type
[55:37] certificate uh which includes any other
[55:40] supplemental type certificate or other
[55:42] approved alteration so we take an
[55:44] aircraft it originally was issued with a
[55:46] type certificate by the manufacturer on
[55:48] top of that there may be some
[55:50] modifications uh embodied as stc's or
[55:53] other alterations and that defines
[55:57] what the configuration of the aircraft
[55:58] should be so there's a there's a lot of
[56:00] drawings and design data related to that
[56:04] so that's the type um conforming to type
[56:09] design the second thing is the aircraft
[56:11] being in the condition for safe
[56:13] operation and that really refers to the
[56:16] fact that the aircraft should not have
[56:17] degraded beyond the point at which it's
[56:19] airworthy for example due to skin
[56:22] corrosion uh any kind of structural
[56:24] cracking window delamination or leaks
[56:27] tire wear this is really the function of
[56:30] aircraft maintenance so those two things
[56:32] together Conformity with the original
[56:35] design all the parts configurations of
[56:38] the aircraft uh are are in line and
[56:41] agree with the original drawings and
[56:43] designs and the condition is maintained
[56:46] so those two things uh give us an
[56:48] airworthy
[56:50] aircraft we're going to go on to look at
[56:52] in more detail at the requirements of
[56:54] initial air worthiness and of continuing
[56:56] airworthiness Management in the next
[56:58] parts of this course meanwhile I thank
[57:01] you for your attention on this
[57:02] particular module thank you
