21.M - Modifications & Repairs

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Transcript 21.M - Modifications & Repairs

Recent Changes to Australian Regulation
Engineering & Design – Parts 21 &39
21.M - Modifications & Repairs
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CASR Subpart 21.M replaced the old CAR
35, 36 & 36A on 27 June 2011
The vast majority of modifications and
repairs are approved by authorised persons
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Modifications & repairs are separate from STCs
STCs are approved by CASA, usually on the
recommendation of an authorised person
21.M - Modifications & Repairs
 Authorised person acts on behalf of CASA to
approve modifications and repairs
 Most authorised persons also design the
modification or repair
 Authorised persons are required to operate to
a Design Approval Procedures Manual
(DAPM), part of which is CASA approved
21.M - Modifications & Repairs
 There are strict limits on what authorised
persons can approve:
 Limits on aircraft complexity (ie, Part 23, 27, 25,
29, etc)
 Limits on engineering speciality (ie, structures,
radio, powerplant, software, etc)
 Fixed wing, rotary wing, analogue, digital
 Any other limitations CASA believes appropriate
21.M - Modifications & Repairs
 Authorised persons do not have a free rein
 must advise CASA of any alteration which is
considered Major and under some other
conditions specified in their DAPM
 Authorised persons must find compliance
with the aircraft’s certification basis
 Need CASA approval to vary the design
standard
 Restricted category
 Equivalent Safety Determinations
21.M - Modifications & Repairs
 Authorised persons must ensure that there
are, where appropriate:
 Instructions for Continuing Airworthiness
 Flight Manual amendments
 The holder of a modification or repair
approval:
 Must provide ICA and Flight Manual amendments
to any operator of an affected aircraft
 Is responsible for continuing airworthiness of the
modification or repair
21.M - Modifications & Repairs
 Authorised persons often become the holder
of the modification or repair that they have
designed and approved.
 21.M aligns with the proposed 21.J
 21.J will replace all reference to “Authorised
Person” with “Approved Design Organisation”
21.J – Approved Design Organisations
 CASR 21.J is currently entitled “Delegation
Option Authorisation Procedures”
 Based on the US FAR 21.J
 No-one in Australia has applied for an
authorisation under the current 21.J
 Poorly understood
 Not suited to Australian Industry
21.J – Approved Design Organisations
 New CASR 21.J is under development and
will replace the existing 21.J
 Based on the EASA Part 21.J, it will introduce
“Approved Design Organisations”
 References in 21.M to “Authorised Persons”
will be changed to “ADOs”
 Many other references in Part 21 will also
change from “Authorised Person” to “ADO”
21.J – Approved Design Organisations
 Regulations are currently in draft form
 Regulations will be made by the middle of
2012, and become effective in March 2013
 There will be a 4 year period for authorised
persons and organisations to transition to
ADOs
CASR 39 - Airworthiness Directives
 In October 2009 CASR 39 changed to recognise
State-of-Design ADs as Australian ADs.
 CASA no longer issues Australian ADs which
repromulgate State-of-Design ADs
 CASA no longer mails out ADs to Registered
Operators
 It is the Registered Operator’s responsibility to find
their own ADs
 CASA does publish State-of-Design ADs on the
CASA web site
CASR 39 - Airworthiness Directives
 CASA can, and does, still issue its own ADs
 Compliance with an Australian AD,
regardless of its origin, is mandatory
 State-of-Design AMOCs against a State-ofDesign AD are automatically acceptable (if
they are applicable).
 CASA still issues its own AMOCs and
Exclusions
QUESTIONS?