Transcript The Future of Design Organisation Approval

Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
The Future of
Maintenance in General Aviation
The perspective from the European
sailplane manufacturers
by
Werner Scholz, Spokesman of the
European Sailplane Manufacturers
EASA Workshop „Future of Maintenance in GA“ - Cologne 1.12.2006
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Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
Contents:
Introduction
Basic comments regarding Part M
Comparison of Part M with old status
Summary and assessment of Part M
EASA Workshop „Future of Maintenance in GA“ - Cologne 1.12.2006
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Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
Introduction
„Who are we - whom do we represent?“
The European sailplane manufacturers are represented by two
associations:
• Verband deutscher Segelflugzeughersteller, Germany
• European Glider Manufacturers and Suppliers association, East Europe
Together they include 13 companies (representing more than 1000
employees) in Austria, Czech Republic, Germany, Lithuania, Slovenia.
Further members of the sailplane “industry”:
• other European sailplane manufacturers
• manufacturers of glider-typical avionics
• manufacturers of trailers and equipment
• glider maintenance facilities
EASA Workshop „Future of Maintenance in GA“ - Cologne 1.12.2006
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Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
Introduction
„Who are we - whom do we represent?“
In total the European sailplane industry represents:
• more than 20 sailplane manufacturers
• more than 30 manufacturers of gliding equipment
• more than 90% of world-wide sailplane production
(over 400 new aircraft per year)
• more than 3000 employees at the manufacturers and associated
companies
EASA Workshop „Future of Maintenance in GA“ - Cologne 1.12.2006
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Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
Introduction
„Who are we - whom do we represent?“
The European sailplane maintenance industry sector represents:
• much more than 100 sailplane maintenance shops
(perhaps even more than 200 - no central association existent)
• certainly hundreds of employees
• several hundred approved inspectors according to national rules
conducting airworthiness reviews on a honorary basis (in their free
time) within the national gliding federations
The European gliding community in Europe includes:
• more than 20.000 registered sailplanes
• more than 70.000 pilots flying gliders and powered sailplanes
EASA Workshop „Future of Maintenance in GA“ - Cologne 1.12.2006
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Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
Introduction
„Who are we - whom do we represent?“
The European sailplane manufacturers do not claim that they can
represent all stakeholders of the gliding community in Europe.
BUT:
• the manufacturers know “their market” (= the operators & the
maintenance sector) very well since more than 50 years
• they know how continuing airworthiness is been handled until now as
some work also as maintenance organisations
• they know as TC holders that there is no general safety problem due to
a lack of proper maintenance
• they know that more complicated regulations will lead towards loss of
much more pilots due to frustration and increased costs
• they already experience the effects of a slowly shrinking “gliding scene”
EASA Workshop „Future of Maintenance in GA“ - Cologne 1.12.2006
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Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
Basic comments regarding Part M
„Motivation of Part M“
Obviously the basic idea of Part M is to have a common regulation for
continuing airworthiness within all EASA member states.
The claimed benefits for stakeholders should be:
• standardised rules valid in all member states
• common safety standards regarding maintenance procedures
• common minimum standards regarding maintenance personnel
• avoidance of duplication at national / European level
• facilitation of a “free movement of goods and services” within Europe
(= to alleviate the selling of aircraft between member states and to
ease cross-border maintenance of aircraft)
• promotion of cost-efficiency in the regulatory process
So how does this all fit to the gliding community? - See later.....
EASA Workshop „Future of Maintenance in GA“ - Cologne 1.12.2006
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Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
Basic comments regarding Part M
„Part M is a very complex regulation“
Part M is by far too complex and difficult to read and understand.
This regulation will be a “must read” at least for all maintenance
organisations & manufacturers & inspectors (= many persons not
having a legal / academic background).
• format with many cross-references within Part M and towards other
regulations
• language with many abbreviations
• partition into regulation and AMC material
This problem is even made worse as the official translations offered by
the authorities are sometimes wrong and/or not directly fitting to the
English original wording.
EASA Workshop „Future of Maintenance in GA“ - Cologne 1.12.2006
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Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
Basic comments regarding Part M
„Part M will not allow simple continuation“
EASA officials have verified that Part M is introduced
• not to cure a pressing safety deficit but to standardise maintenance in
Europe
• with the idea that basically most national maintenance procedures
within light aviation should be possible to be continued.
Nevertheless the competent authorities (= the NAA responsible now to
implement Part M in the member states) have already started to
change rules regarding continuing airworthiness to implement Part M.
This is definitively not a continuation of well established maintenance
procedures!
EASA Workshop „Future of Maintenance in GA“ - Cologne 1.12.2006
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Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
Comparison of Part M with old status
„Basis of the comparison“
Based on the experience in the member states of more than 50 years of
sailplane maintenance, a comparison between the “old status quo” and
the new Part M procedures has been made.
Data for this comparison has been accumulated by
• the European sailplane manufacturers
• the European Gliding Union (EGU) representing the gliding sectors of
the national sporting federations
• by a large number of European maintenance organisations
(traditional repair shops and also federations / clubs conducting glider
maintenance)
This comparison is primary valid for gliding but organisation within light
aviation (e.g. ballooning, small aeroplanes) have already signalled
similar conclusions!
EASA Workshop „Future of Maintenance in GA“ - Cologne 1.12.2006
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Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
Comparison of Part M with old status
„Regular physical survey / issuance of ARC“
The fundamental cornerstone of glider maintenance until now:
A physical survey of the aircraft on a regular basis directly resulting
into issuance of the ARC for continuing flight operations until the next
survey (or a maintenance/repair event).
This might be likened to a basic “maintenance philosophy” similar to the
operation of a private owned car:
• maintenance is been conducted on a “on need basis”
• the showing of “streetworthiness” is only required in certain intervals
and/or after special maintenance/repair events
• operations of the car allowed immediately after completion of the
physical survey without further “registration/certification” by authorities
EASA Workshop „Future of Maintenance in GA“ - Cologne 1.12.2006
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Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
Comparison of Part M with old status
„Regular physical survey / issuance of ARC“
Within Part M this will be in the future:
A physical survey of the aircraft on a regular basis resulting into
issuance of the ARC either by the competent authority or a CAMO+ and
introduction of a certificate of release to service after every
maintenance event.
This certainly stems from the “maintenance philosophy” of the
maintenance and operation of commercial air transport airplanes:
• maintenance is been conducted on a “procedural basis”
• the aircraft “is owned by” the technical/maintenance organisation and
can only operated after a release to service
• maintenance operations only possible with consent of the authorities
based on regulated procedures and approved personnel
EASA Workshop „Future of Maintenance in GA“ - Cologne 1.12.2006
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Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
Comparison of Part M with old status
„Regular physical survey / issuance of ARC“
The introduction of the additional step for the issuance of the ARC by the
competent authority / CAMO+ and the obligatory release to service
certificate will:
• increase the number of administrative “steps” until the glider will be
back in service
• this translates into time delays (remember: more than 20.000 gliders!)
• this also means increased costs for the owners
• this does nothing to improve the actual physical survey
• this does therefore also not increase safety
EASA Workshop „Future of Maintenance in GA“ - Cologne 1.12.2006
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Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
Comparison of Part M with old status
„Airworthiness survey &
introduction of maintenance programs“
Until now the check of the technical documentation for each particular
glider was made parallel to the physical survey and typically included:
• review of the logbook of the glider / engine / propeller
• review of the findings report for this glider before start of the
maintenance
• check against procedures described in the maintenance manual issued
by the manufacturer
• check against existing service bulletins / airworthiness directives
• entry of all findings during the physical review against a check list
provided by the maintenance manual or (if not provided) against a
check list suitable for gliders / motor gliders
All was done together with the inspector during the physical survey.
EASA Workshop „Future of Maintenance in GA“ - Cologne 1.12.2006
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Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
Comparison of Part M with old status
„Airworthiness survey &
introduction of maintenance programs“
Now the check of the technical documentation will be THE central point
for the airworthiness review of each particular glider and is not
necessarily coupled to the physical survey.
Additionally now every individual aircraft needs to have an maintenance
program with an approval of the competent authority.
These maintenance programs will in most cases not give more
information than the already existing information supplied by the
manufacturer as (contrary to commercial air transport) the
maintenance organisations do typically not develop own procedures.
Even this “standard maintenance program” now will need approval!
Issuance of the ARC will be done typically by persons not seeing the
actual aircraft but based on the accompanying paperwork!
EASA Workshop „Future of Maintenance in GA“ - Cologne 1.12.2006
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Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
Comparison of Part M with old status
„Airworthiness survey &
introduction of maintenance programs“
This new system can only work if ALL participating partners
• are familiar with the new administrative procedures (this implies the
need for training thousands of persons)
• have suitable background (excluding the experienced “worker-type”
maintenance people)
• have the additional time for the new additional administrative steps
(making the work for the honorary / free-time inspectors even more
difficult as their time per glider inspection is limited)
Therefore the following results seem to be (again)
• time delays
• cost increase
• loss of maintenance workforce
• with resulting degradation of safety....
EASA Workshop „Future of Maintenance in GA“ - Cologne 1.12.2006
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Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
Comparison of Part M with old status
„Maintenance personnel - certifying staff“
Until now the maintenance personnel in gliding consisted of:
• the owners/operators conducting the lion share of typical regular
maintenance tasks (often referred to as “winter overhaul”)
• the inspectors within the gliding federations conducting the regular
airworthiness reviews on a honorary basis (in their free time) or at
least on a “at cost price”
• the personnel within maintenance organisations and/or the
manufacturers with detailed knowledge for special systems and/or
repairs and major maintenance tasks
Typically some form of approval was required for inspectors - this was
granted under supervision / directly from the NAA.
BUT: Besides the minimum technical expertise required the maintenance
personnel was not excessively regulated.
EASA Workshop „Future of Maintenance in GA“ - Cologne 1.12.2006
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Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
Comparison of Part M with old status
„Maintenance personnel - certifying staff“
Regarding maintenance personnel and inspectors (now identified as
certifying staff) the situation will be more complicated after introduction
of Part M:
• regarding certifying staff Part M refers to Part 66
• Part 66 defines categories of qualifications for aeroplanes and
helicopters and components (excluding gliders)
• for all other aircraft (e.g. sailplanes) Part 66 refers to relevant member
states regulations (resulting into a return to existing systems regarding
maintenance personnel/certifying staff
This raises two questions:
• why this complicated introduction if nothing changes?
• what happens if some NAA will simply delete their national regulation in
favour of Part M / Part 66 thereby “forgetting” gliders?
EASA Workshop „Future of Maintenance in GA“ - Cologne 1.12.2006
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Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
Comparison of Part M with old status
„Maintenance organisations approvals“
Until now a typical maintenance organisation typically had to show:
• compliance to national rules written in the national language and based
on the particular local experience
• some form of certification for the organisation audited by the local
authorities
• some minimum requirements regarding the qualification of the workers
• some approved qualification for the inspectors (issued directly or under
supervision by the NAA)
Normally this meant:
• one single approval for the maintenance organisation
• individual approvals for the inspectors
EASA Workshop „Future of Maintenance in GA“ - Cologne 1.12.2006
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Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
Comparison of Part M with old status
„Maintenance organisations approvals“
Now a typical maintenance organisation needs:
• compliance to EASA rules written in a complicated language
(sometimes not improved by the official translation) plus additional
national rules fitting more or less to Part M
• one certification for the maintenance tasks (Subpart F)
• one certification for the inspections tasks (Subpart G) - now referred to
as Continuing Airworthiness Management Organisation (CAMO)
• compliance - if applicable - with Part 66 / Part 145 if the tasks
performed fall outside the pure glider world / outside of Part M
• still a regular auditing by the competent authority but now based on a
much more complicated regulation system
• introduction of quality assurance systems into their organisations as
the new organisations approvals require
EASA Workshop „Future of Maintenance in GA“ - Cologne 1.12.2006
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Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
Comparison of Part M with old status
„Maintenance organisations approvals“
This already means:
• small maintenance organisations (read: repair shops) do not know if
approval under Subpart F and G will be feasible for them
• some existing maintenance workforce will be lost as they cannot afford
this step towards the new approvals
• air-sport federations acting as maintenance organisations face new and
unfamiliar approval processes (mainly with managers working in their
free time and/or under quite limited working time constrains)
• manufacturers offering maintenance tasks beside their production
process face additional approval processes to continue these
maintenance tasks
• the owner will finally pay for all this application processes without any
safety benefit for his glider and his personal flying....
EASA Workshop „Future of Maintenance in GA“ - Cologne 1.12.2006
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Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
Summary and assessment of Part M
„Motivation of Part M - revisited“
Obviously the basic idea of Part M is to have a common regulation for
continuing airworthiness within all EASA member states.
The claimed benefits for stakeholders should be:
• standardised rules valid in all member states
• common safety standards regarding maintenance procedures
• common minimum standards regarding maintenance personnel
• avoidance of duplication at national / European level
Especially for gliders the rules about maintenance / certifying staff will
still be based on national rules.
This does not necessarily needs to be a disadvantage as those rules
already work very good.
BUT the additionally regulations / administrative procedures as required
by Part M will make maintenance in gliders much more complicated and
expensive .... without discernible safety benefit!
EASA Workshop „Future of Maintenance in GA“ - Cologne 1.12.2006
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Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
Summary and assessment of Part M
„ Motivation of Part M - revisited“
Obviously the basic idea of Part M is to have a common regulation for
continuing airworthiness within all EASA member states.
The claimed benefits for stakeholders should be:
• facilitation of a “free movement of goods and services” within Europe
(= to alleviate the selling of aircraft between member states and to
ease cross-border maintenance of aircraft)
• promotion of cost-efficiency in the regulatory process
The alleviation regarding selling a glider in Europe will only work if the
NAA will be accepting the rules by the other NAA - which was
historically not the case until now - so why should this function now?
Therefore cross-border maintenance still will be difficult.
And within the gliding community no one has been heard to foresee ANY
cost benefit due to the introduction of Part M ......
EASA Workshop „Future of Maintenance in GA“ - Cologne 1.12.2006
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Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
Summary and assessment of Part M
„ Where are we standing now?“
The concept “one regulation that fits all sectors of aviation” is not
working regarding maintenance of gliders.
Either Part M needs some fundamental changes or extensive changes are
needed in the AMC material of Part M / Part 66.
The basic idea of rulemaking task MDM.032 has been claimed to be
“simple regulations for light aviation” - this is of course linked to
Part M and directly influences future of maintenance for GA.
(But ONLY for non-commercial activities!!)
The tasks M.005 (pilot-owner maintenance) and M.017 (review of NPA
7/2005 after Part M regulatory impact assessment) must result into
important changes very fast (in order to stay within the time scale as
EU 2042/2003 gives 28.9.2008 as final introduction date).
EASA Workshop „Future of Maintenance in GA“ - Cologne 1.12.2006
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Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
Summary and assessment of Part M
„ Where to go?“
Today there is no one claiming a basic safety problem regarding
maintenance / continuing airworthiness for gliders
(or for General Aviation).
Therefore: only change when there is a need for change!
If a common regulation is really envisaged then a simpler regulation is
needed than Part M (and Part 66) and then it really must be
standardised in all member states.
If the Agency / EU commission / EU parliament feels national regulation
to be sufficient then make a “mini Part M” only approving existing
national regulations (as existing now) as valid in all member states.
Therefore: a clear decision between European / national rules!
And: Extend the time schedule to avoid “quick fixes” and chaos!
EASA Workshop „Future of Maintenance in GA“ - Cologne 1.12.2006
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Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
Thank you any questions?
EASA Workshop „Future of Maintenance in GA“ - Cologne 1.12.2006
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