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The airworthiness review of military aircraft MAWC – CY 2012
26 Sep 2012 2
The airworthiness review of military aircraft DIRNAV
Reminder : some airworthiness documents
At the aircraft type level : Type Certificates (TC) :
- Aircraft
- Engine
- Propeller
Supplemental Type Certificates (STC)
For each individual aircraft in service : Certificate of airworthiness (CoA)
Certificate of registration (CoR)
Aircraft TC
Engine TC
Propeller TC
CoA
CoR
26 Sep 2012 3
The airworthiness review of military aircraft DIRNAV
CoA : Issuance (FRA 21 subpart H)
and validity (FRA M subparts G and I)
CoA
T0 T0 + 1 yr T0 + 2 yr T0 + 3 yr T0 + 4 yr
ARC n°1 1st extension
of ARC n°1
2nd extension
of ARC n°1
Renewal
ARC n°2
CAMO Request
for AR
Recommendation
for AR
Recommendation
for AR
Request
for AR
CNMAA
(DSAÉ)
- carry out the AR
- issues the ARC
Extend
the ARC
Extend
the ARC
- carry out the AR
- issues the ARC
CAMO(1)
CNMAA
(DSAÉ)
issues the CoA
& the CoR
(1) FRA M subpart G approved CAMO with privilege to carry out the AR
3 year cycle
26 Sep 2012 4
The airworthiness review of military aircraft DIRNAV
What is an airworthiness review (AR) ?
Objective : To make sure Of the conformity of an aircraft to the type definition approved by the CNMAA
Of the implementation of applicable ADs (Airworthiness Directives) issued by the CNMAA or
issued by a Primary authority recognized by the CNMAA
Of the continuing airworthiness of the aircraft
Content : review of the aircraft records
- Reference documentation (accessibility, integrity, updates…)
- Continuing airworthiness records (quality)
and in parallel
physical inspection of the aircraft
The AR is a photo of the state of the aircraft
an audit :
- Part of a thorough process
- Assessment and recognition of the work performed by the CAMO
- Continuing airworthiness responsibility remains within the CAMO
- The auditor shall be a SQEP (Suitably Qualified and Experienced Personnel)
- The auditor can use sampling techniques based on risk analysis
- Ethics, impartiality, conscientiousness, independence
- Factual assessment based on tangible and verifiable evidences
26 Sep 2012 5
The airworthiness review of military aircraft DIRNAV
Initial Airworthiness Review (AR) :
Legacy aircraft
Annual planning of
Airworthiness Reviews by
the CAMO Planned date
for the AR
1 month AR : 7 to 15 days
End of AR
Request
for AR
Inspection
report Form 153
Rejected
CNMAA
CAMO
Accepted
Confirmation
of the date for
the AR
OK
non OK
AR
report
Management of Level 1
findings
Deadline and
management
OK
ARC Form 15a
Valid 1 year
Management
of Level 2
findings +
observations
Recommendation for the AR
26 Sep 2012 6
The airworthiness review of military aircraft DIRNAV
Form 153 : Inspection report from the CAMO
(compliant with M.A.710 requirement)
a) To satisfy the requirement for an M.A.902 airworthiness review of an aircraft,
a full documented review of the aircraft records shall be carried out by the
approved CAMO in order to be satisfied that: 1. airframe, engine and propeller flying hours and associated flight cycles have been properly
recorded, and;
2. the flight manual is applicable to the aircraft configuration and reflects the latest revision status,
and;
3. all the maintenance due on the aircraft according to the approved maintenance programme has
been carried out, and;
4. all known defects have been corrected or, when applicable, carried forward in a controlled
manner, and;
5. all applicable airworthiness directives have been applied and properly registered, and;
6. all modifications and repairs applied to the aircraft have been registered and are approved
according to FRA 21, and;
7. all service life limited components installed on the aircraft are properly identified, registered and
have not exceeded their approved service life limit, and;
8. all maintenance has been released in accordance with this Part, and;
9. the current mass and balance statement reflects the configuration of the aircraft and is valid, and;
10. the aircraft complies with the latest revision of its type design approved by the CNMAA (DGA
Technical Authority).
26 Sep 2012 7
The airworthiness review of military aircraft DIRNAV
Form 153 : Inspection report from the CAMO
(compliant with M.A.710 requirement)
b) The approved continuing airworthiness management organisation's
airworthiness review staff shall carry out a physical survey of the aircraft.
For this survey, airworthiness review staff not appropriately qualified to FRA 66
shall be assisted by such qualified personnel.
c) Through the physical survey of the aircraft, the airworthiness review staff shall
ensure that: 1. all required markings and placards are properly installed, and;
2. the aircraft complies with its approved flight manual, and;
3. the aircraft configuration complies with the approved documentation, and;
4. no evident defect can be found that has not been addressed according to M.A.404, and;
5. no inconsistencies can be found between the aircraft and the paragraph (a) documented review
of records.
d) By derogation to M.A.902(a) the airworthiness review can be anticipated by a
maximum period of 90 days without loss of continuity of the airworthiness
review pattern, to allow the physical review to take place during a maintenance
check.
26 Sep 2012 8
The airworthiness review of military aircraft DIRNAV
Approved documentation
Data associated with the type certification Type Certificate Data Sheet (TCDS)
For legacy products, an “Airworthiness Reference Data Sheet” listing :
the CNMAA (DGA Technical Authority) decisions related to continued airworthiness
the approved modifications considered as mandatory modifications
Instructions for continuing airworthiness (ICA)
The “Airworthiness Reference Data Sheet” may have to be refined further to the first
airworthiness reviews
ADs and other decisions (limitations, approvals…) issued
by the CNMAA (DGA Technical Authority)
ICA associated with a modification, a repair or an evolution of the data
associated with the type certification
Approved maintenance programme derived from the recommended
maintenance programme issued by the OEM
ICA and SBs from FRA 21 Subpart J approved OEM with relevant privileges
26 Sep 2012 9
The airworthiness review of military aircraft DIRNAV
Form 153 : Inspection report
26 Sep 2012 10
The airworthiness review of military aircraft DIRNAV
Airworthiness review by the CNMAA
The AR is carried out by an airworthiness review staff (ARS) from the CNMAA
(DSAÉ) Review of the records of the aircraft
Physical inspection of the aircraft
The ARS shall have access to the aircraft, along with its documents and
maintenance logbook
The continuing airworthiness file is presented by a CAMO designated responsible
The aircraft, sheltered, with all doors and hatches open, is presented by a
qualified personnel
The inspection is limited to the accessible parts of the aircraft
A check flight may be requested if necessary
The AR should be carried out during a grounding (maintenance check,
configuration change…) but in a representative and flyable configuration
26 Sep 2012 11
The airworthiness review of military aircraft DIRNAV
M.A.905 Findings
a) A level 1 finding is any significant non-compliance with Part M requirements
which lowers the safety standard and hazards seriously the flight safety.
b) A level 2 finding is any non-compliance with the Part M requirements
which could lower the safety standard and possibly hazard the flight safety.
c) After receipt of notification of findings according to point M.B.903,
the person or organisation accountable referred to in point M.A.201 shall
define a corrective action plan and demonstrate corrective action to the
satisfaction of the CNMAA (DSAÉ) within a period agreed with this authority
including appropriate corrective action to prevent reoccurrence of the
finding and its root cause.
26 Sep 2012 12
The airworthiness review of military aircraft DIRNAV
Examples of findings
Level 1 findings : The aircraft is no longer compliant with its TC
Operating conditions not compliant with the approved maintenance programme
Modification or repair solution not approved
AD not implemented
Service limit of an equipment not respected
Release to service not compliant with the regulation (ex : no check flight after a
visit, no maintenance after a serious incident like a lightning…)
Approved maintenance programme not applied
Physical survey of the aircraft not feasible
Level 2 findings : Regulation related to operation and maintenance of the aircraft is not followed
- Documentation issue
- Release to service not compliant with the regulation
Observation : finding for information
There is no
formal decision
making support
table :
decision is
based on
experience
26 Sep 2012 13
The airworthiness review of military aircraft DIRNAV
Initial Airworthiness Review (AR) :
New delivered aircraft
Planned date
of delivery Planned date
for the AR
As short as
possible 1 to 2 days
End of AR
Request
for AR
CNMAA
CAMO
Accepted
Confirmation
of the date for
the AR
non OK
OK
AR
report
Management of Level 1
findings
Deadline and
management
OK
ARC Form 15a
Valid 1 year
CoR Form 5b
CoA Form 25 Permanent
documents
Management
of Level 2
findings +
observations
Certificate
of release to
service Form 53
Aircraft
statement of
conformity Form 52
OEM(1)
Aircraft
acceptance
(1) If DOA with
relevant privileges
No flights, eventually one ferry flight
26 Sep 2012 14
The airworthiness review of military aircraft DIRNAV
FRA 21 Subpart H requirements
FRA 21A.174 Each application for a CoA shall include :
- A statement of conformity Form 52 + Form 53 if applicable (i.e. if maintenance carried out prior to delivery)
- A weight and balance report with a loading schedule
- The flight manual and any other manuals required by the airworthiness Authority of the State of registry
FRA 21A.180 Access to the aircraft for which that airworthiness certificate is applied for shall be granted upon
request by the CNMAA (DSAÉ)
FRA 21A.182 Each applicant for an airworthiness certificate under this Subpart shall demonstrate that its
aircraft is identified in accordance with Subpart Q.
26 Sep 2012 15
The airworthiness review of military aircraft DIRNAV
Form 52 and Form 53
Form 52 : Aircraft statement of conformity Aircraft type + reference of the TC
Aircraft registration
Manufacturer identification
Engine/propeller details
Modifications and/or SBs
ADs
Concessions
Exemptions, waivers or derogations
Airworthiness certificate
Additional requirements
Form 53 : Certificate of release to service Reference of the work order
Brief description of work performed
If the OEM has not the relevant privilege to approve the Form 52, the CNMAA
(DGA Technical Authority) shall validate it by countersignature.
Equivalent documents issued by the OEM are acceptable as long as they contain
the same data and are validated by the CNMAA (DGA Technical Authority)
26 Sep 2012 16
The airworthiness review of military aircraft DIRNAV
Scope of the AR
The AR takes place after the transfer of property to the CAMO (further to the
acceptance) either in the OEM premises if feasible
or generally in the operational unit of the aircraft
after a ferry flight under PtF (Permit to Fly)
issued by the CNMAA (DGA Technical Authority)
The AR is limited to the review of the documentation not covered by Form 52
and Form 53 If the AR takes place several days after the transfer of property, the review shall address :
- The applicable Ads
- The logbook of the aircraft, engine, propeller
- The remaining service limit of equipment
- The compliance of the maintenance applied with the approved maintenance plan
- The verification of the identification of the accessible equipment
26 Sep 2012 17
The airworthiness review of military aircraft DIRNAV
Issues arisen from airworthiness reviews
Airworthiness reviews not well prepared by some CAMO units because of lack of
experience (CAMO units relying on airworthiness reviews to address findings) Requires airworthiness review complements to check corrective actions
Rely on transitional provisions in order not to ground aircraft with level 1 findings
Original schedule based on the assumption that the next 2 extensions of the
airworthiness review certificates are issued by CAMO under FRA M Subpart G
approval privilege : Very few CAMOs are FRA M Subpart G approved
Unexpected additional workload for DSAÉ to fill the gap
unless introducing a new transitional provision :
maximum 3-year validity of the first airworthiness review certificates
until FRA M Subpart G approval
26 Sep 2012 18
The airworthiness review of military aircraft DIRNAV
Issues arisen from airworthiness reviews
Aircraft with equipment unserviceable can no longer be authorized to fly with just
the green light of the chief of operations
Records of such unauthorized configurations in the aircraft logbook may lead to
level 1 findings during the airworthiness reviews
Introduce the civil principle of MMEL/MEL in the regulation MMEL : Master Minimum Equipment List
- Defined by the TCH and approved by DGA Technical Authority during the certification process
MEL : Minimum Equipment List
- Defined by the End User and approved by DSAÉ
- Cannot be less restrictive than MMEL
Already used on civil type certified aircraft, but not addressed on specific military aircraft like fighters
Mandatory for future aircraft types
Introduce also transitional provisions For legacy aircraft, in the absence of MMEL, define and validate
an Operating & Technical Tolerance List (OTTL) based on grandfather law
Until 31.12.2014, ARCs can still be issued and extended in spite of the absence of MEL or OTTL
26 Sep 2012 19
The airworthiness review of military aircraft DIRNAV
Conclusion
The Airworthiness Review constitutes the real job of the oversight of
the regulation enforcement
The Airworthiness Review of a new delivered military aircraft is quite
similar to Airworthiness Review of civil registered aircraft
The Airworthiness Review of a legacy aircraft for which the Type
Certificate was issued after the enforcement of the regulation is quite
challenging in terms of establishing and consolidating the reference
airworthy configuration