Design Organization Approval (DOA)
Part 1 – Obligation to the international requirements to ensure aviation safety
1) ICAO convention under Annex 6 (Operation of Aircraft) Part 1 Chapter 8 (Aeroplane Maintenance) para 8.6 states “ALL MODIFICATIONS AND REPAIRS SHALL COMPLY WITH AIRWORTHINESS REQUIREMENTS ACCEPTABLE TO THE STATE OF REGISTRY. PROCEDURES SHALL BE ESTABLISHED TO ENSURE THAT THE SUBSTANTIATING DATA SUPPORTING COMPLIANCE WITH THE AIRWORTHINESS REQUIREMENTS ARE RETAINED.
2) MCAR Regulation 27 – A certificate of airworthiness issued in respect of an aircraft shall cease to be in force if the aircraft, or such of its equipment as is necessary for the airworthiness of the aircraft, is overhauled, repaired or modified, or if any part of the aircraft or of such equipment is removed or is replaced otherwise than in a manner and with material of a type approved by the Director General either generally or in relation to a class of aircraft or to the particular aircraft.
Part 2 – Design Approval
1) Modification and Repair per ICAO Document 9760
• Modification is “A MODIFICATION TO AN AERONAUTICAL PRODUCT MEANS A CHANGE TO THE TYPE DESIGN WHICH IS NOT A REPAIR”
• Type Design is “DRAWINGS, SPECIFICATIONS NECESSARY TO DEFINE THE CONFIGURATION AND ITS DESIGN FEATURES, REPORTS ON ANALYSIS AND TESTS UNDERTAKEN TO SUBSTANTIATE COMPLIANCE WITH THE APPLICABLE REQUIREMENTS AND INFORMATION, MATERIALS AND PROCESSES USED IN THE CONSTRUCTION”
• Repair is “A DESIGN CHANGE TO AN AERONAUTICAL PRODUCT INTENDED TO RESTORE IT TO AN AIRWORTHY CONDITIONS AND TO ENSURE THAT THE AIRCRAFT CONTINUE TO COMPLY WITH THE DESIGN ASPECTS OF THE AIRWORTHINESS REQUIREMENTS USED FOR THE ISSUANCE OF A TYPE CERTIFICATE FOR THAT AIRCRAFT TYPE AFTER IT HAS BEEN DAMAGED OR SUBJECTED TO WEAR”
• CAR 1996 Regulation 27 para 7 stated aircraft C of A become invalid, if the design change does not comply with the required airworthiness requirements.
2) Design Organization Approval (DOA)
• The local authority i.e. DCA / DGCA is not a Design Organization. Therefore DCA / DGCA cannot accept responsibility for the design.
• DOA is approval for an organization to provide reports and certify that the design of an acft, equipment or any part thereof or modification or repair schemes complies with DCA / DGCA requirements.
• JAR/EASA 21 – SUBPART J (DESIGN ORGANIZATIONS APPROVAL). The principles of both JAR/EASA and BCAR are similar. However, JAR/EASA has been developed more comprehensive than BCAR, i.e. Design Assurance System has been introduced in JAR/EASA.
• Benefit being approved as DOA is being granted privileges with responsibilities and may perform certification and airworthiness activities on behalf of DCA through the following granted privileges:
– Release certification documents without verification by DCA / DGCA
– Classify modifications and repairs
– Approve minor modifications and repairs
– DOA may issue information or instructions stating that the technical content is approved.
– For Modifications undertaken by organisations that are appropriately approved for the task and who have demonstrated a consistent and satisfactory level of competence for the type of work involved, then future similar Modifications may be classified as Minor by the DCA / DGCA.
– Efficient use of industry and DCA / DGCA time, resulting in lower costs.
• DOA shall be headed by an Accountable Manager (Chief Executive or Equivalent) and with full efficient coordination between their units/sections.
• Scope of work – The organization must have
– sufficient personnel with the right qualification, knowledge and experience.
– appropriate tools (Software), equipments (computer) and facility (i.e. office space, lab, flight test center)
3) Design Organization Manual (DOM)
• Policy/procedure of carrying out design activities and management of DOA
– Classification of Major/Minor
– Development of reports/drawings/Test Schedule
– Verification of Design Data
– Inservice difficulty reporting
– Correction action
– Internal Audit
– Retention of designs records
– Design Assurance systems (DAS)
4) Design Assurance System (DAS)
• A DOA shall demonstrate that it has established and is able to maintain a Design Assurance System (DAS) for the control and supervision of the design, and of design changes, of products, parts and appliances covered by the approval.
• The DAS shall be such as to enable the organization;
– To ensure the design of the products, parts and appliances or the design changes thereof, comply with the applicable type certification basis.
– Ensure that its responsibilities are properly discharged.
– Independently monitor the compliance with, and adequacy of, the documented procedures of the system (DOM). The monitoring shall include a feed back system to a person having the responsibilities to ensure corrective actions.
• DAS shall include an independent checking function of the showing of compliance on the basis of which the organization submits compliance statement and associated document to DCA / DGCA.
Part 3 – Certification of Modification/Repair
1) A modification or repair must meet two standards; the acft type certification rules and the performance rules.
2) Data Package is a set of documents required for the justification / accomplishment of the modification such as:
• Standard documents; i.e. Certification plan (for complex modification), Modification documents, SOC, CCD (if applicable) and Manuals amendments (if applicable)
• Type Design documents ; i.e. Drawings, Specifications, Information on dimensions, materials and processes, Airworthiness limitations and any other data necessary to describe the modification.
• Substantiating data; i.e. Test and analysis reports and Justification reports
3) Approved Data is a data which has been investigated and approved by an acceptable authority such as FAA, JAA and UK CAA and divided into two categories:- OEM data and Non OEM data.
• The data packages are only considered as an approved data provided the limitations, including applicability of an approved data are met.
4) FAA Form 8110-3 approved by FAA Designated Engineering Representatives (DER) i.e. OEM DER is accepted as approved data but require DCA installation approval. Consultants DER require review because it has similar status as the Non-OEM STCs.
5) Statement of Compliance (SOC) is a form used as the top-level document for the data package. SOC form shall be signed by a Design Approval signatory or authorized person.