1. Continued Airworthiness presentation 2. Regulations (IR21..) 3. Airbus Procedure AP2020 (new A2752)
3.1 COLLECT ENGO: Occurrences from “Design Office” or “Product integrity” MANO: Occurrences from ”Production” or “Flight tests” ISO: Occurrences from “Engineering Support” or “Training & Flight Ops” or “Accident/Incident Investigation” or “Technical Data”
1. Continued Airworthiness presentation 2. Regulations (IR21..) 3. Airbus Procedure AP2020 (new A2752)
3.1 COLLECT ENGO: Occurrences from “Design Office” or “Product integrity” MANO: Occurrences from ”Production” or “Flight tests” ISO: Occurrences from “Engineering Support” or “Training & Flight Ops” or “Accident/Incident Investigation” or “Technical Data”
Basic Airworthiness Training Course - Continued Airworthiness - March 2013
2. Regulatory reference: IR 21
21A.3 Failures, malfunctions and defects .
21A.3B Airworthiness directives
GM 21A.3(a) The system for collection, investigation and analysis of data . GM 21A.3(b) Occurrence reporting . AMC 21A.3(b)(2) Reporting to the Agency . GM 21A.3B(d)(4) Defect correction - Sufficiency of proposed corrective action .. AMC 21A.3B(b) Unsafe condition . GM 21A.3B(b) Determination of an unsafe condition
•EUROPEAN AVIATION SAFETY AGENCY •AGENCE EUROPEENNE DE LA SECURITE AERIENNE
•EUROPAISCHE AGENTUR FUR FLUGSICHERHEIT
•EC Regulation • No. 748/2012
21A.3 Failures, malfunctions and defects (a) System for Collection, Investigation and Analysis of Data. The holder of a type-certificate, restricted type-certificate, supplemental type-certificate,
European Technical Standard Order (ETSO) authorisation, major repair design approval or any other relevant approval deemed to have been issued under this Regulation shall have a system for collecting, investigating and analysing reports of and information related to failures, malfunctions, defects or other occurrences which cause or might cause adverse effects on the continuing airworthiness of the product, part or appliance covered by the type-certificate, restricted type-certificate, supplemental type-certificate, ETSO authorisation, major repair design approval or any other relevant approval deemed to have been issued under this Regulation. Information about this system shall be made available to all known operators of the product, part or appliance and, on request, to any person authorised under other associated implementing Regulations.
(b) Reporting to the Agency. 1. The holder of a type-certificate, restricted type-certificate, supplemental type-certificate, ETSO authorisation, major repair design approval or any other
relevant approval deemed to have been issued under this Regulation shall report to the Agency any failure, malfunction, defect or other occurrence of which it is aware related to a product, part, or appliance covered by the type-certificate, restricted type-certificate, supplemental type-certificate, ETSO authorisation, major repair design approval or any other relevant approval deemed to have been issued under this Regulation, and which has resulted in or may result in an unsafe condition.
2. These reports shall be made in a form and manner established by the Agency, as soon as practicable and in any case dispatched not later than 72 hours after the identification of the possible unsafe condition, unless exceptional circumstances prevent this.
(c) Investigation of Reported Occurrences. 1. When an occurrence reported under paragraph (b), or under 21A.129(f)(2) or 21A.165(f)(2) results from a deficiency in the design, or a manufacturing
deficiency, the holder of the type-certificate, restricted type-certificate, supplemental type-certificate, major repair design approval, ETSO authorisation, or any other relevant approval deemed to have been issued under this Regulation, or the manufacturer as appropriate, shall investigate the reason for the deficiency and report to the Agency the results of its investigation and any action it is taking or proposes to take to correct that deficiency.
2. If the Agency finds that an action is required to correct the deficiency, the holder of the type-certificate, restricted type-certificate, supplemental type-certificate, major repair design approval, ETSO authorisation, or any other relevant approval deemed to have been issued under this Regulation, or the manufacturer as appropriate, shall submit the relevant data to the Agency.
•ANNEX I - PART 21 •21A.3 Failures, malfunctions and defects
Basic Airworthiness Training Course - Continued Airworthiness - March 2013
•EUROPEAN AVIATION SAFETY AGENCY •AGENCE EUROPEENNE DE LA SECURITE AERIENNE
•EUROPAISCHE AGENTUR FUR FLUGSICHERHEIT
•EC Regulation • No. 748/2012
21A.3 Failures, malfunctions and defects (a) System for Collection, Investigation and Analysis of Data. The holder of a type-certificate, restricted type-certificate, supplemental type-certificate,
European Technical Standard Order (ETSO) authorisation, major repair design approval or any other relevant approval deemed to have been issued under this Regulation shall have a system for collecting, investigating and analysing reports of and information related to failures, malfunctions, defects or other occurrences which cause or might cause adverse effects on the continuing airworthiness of the product, part or appliance covered by the type-certificate, restricted type-certificate, supplemental type-certificate, ETSO authorisation, major repair design approval or any other relevant approval deemed to have been issued under this Regulation. Information about this system shall be made available to all known operators of the product, part or appliance and, on request, to any person authorised under other associated implementing Regulations.
(b) Reporting to the Agency. 1. The holder of a type-certificate, restricted type-certificate, supplemental type-certificate, ETSO authorisation, major repair design approval or any other
relevant approval deemed to have been issued under this Regulation shall report to the Agency any failure, malfunction, defect or other occurrence of which it is aware related to a product, part, or appliance covered by the type-certificate, restricted type-certificate, supplemental type-certificate, ETSO authorisation, major repair design approval or any other relevant approval deemed to have been issued under this Regulation, and which has resulted in or may result in an unsafe condition.
2. These reports shall be made in a form and manner established by the Agency, as soon as practicable and in any case dispatched not later than 72 hours after the identification of the possible unsafe condition, unless exceptional circumstances prevent this.
(c) Investigation of Reported Occurrences. 1. When an occurrence reported under paragraph (b), or under 21A.129(f)(2) or 21A.165(f)(2) results from a deficiency in the design, or a manufacturing
deficiency, the holder of the type-certificate, restricted type-certificate, supplemental type-certificate, major repair design approval, ETSO authorisation, or any other relevant approval deemed to have been issued under this Regulation, or the manufacturer as appropriate, shall investigate the reason for the deficiency and report to the Agency the results of its investigation and any action it is taking or proposes to take to correct that deficiency.
2. If the Agency finds that an action is required to correct the deficiency, the holder of the type-certificate, restricted type-certificate, supplemental type-certificate, major repair design approval, ETSO authorisation, or any other relevant approval deemed to have been issued under this Regulation, or the manufacturer as appropriate, shall submit the relevant data to the Agency.
•ANNEX I - PART 21 •21A.3 Failures, malfunctions and defects
Basic Airworthiness Training Course - Continued Airworthiness - March 2013
•System for Collection, Investigation and Analysis of Data
•shall report to the Agency any failure, malfunction, defect or other occurrence
•72 hours after the identification of the possible unsafe condition
1. Continued Airworthiness presentation 2. Regulations (IR21..) 3. Airbus Procedure AP2020 (new A2752)
3.1 COLLECT ENGO: Occurrences from “Design Office” or “Product integrity” MANO: Occurrences from ”Production” or “Flight tests” ISO: Occurrences from “Engineering Support” or “Training & Flight Ops” or “Accident/Incident Investigation” or “Technical Data”
1. Continued Airworthiness presentation 2. Regulations (IR21..) 3. Airbus Procedure AP2020 (new A2752)
3.1 COLLECT ENGO: Occurrences from “Design Office” or “Product integrity” MANO: Occurrences from ”Production” or “Flight tests” ISO: Occurrences from “Engineering Support” or “Training & Flight Ops” or “Accident/Incident Investigation” or “Technical Data”
From In service (ex ISO – AP2750.10) Occurrences from “Engineering Support” Occurrences from “Training & Flight Ops” Occurrences from “Accident/Incident Investigation” Occurrences from “Technical Data”
From Engineering (ex ENGO – AP2750.11) Occurrences from “Design Office” Occurrences from “Product integrity” covering requests from AA
From Manufacturing (ex MANO AP2750.12): Occurrences from ”Production” Occurrences from “Flight tests”
Basic Airworthiness Training Course - Continued Airworthiness - March 2013
3.1 COLLECT - M2807 - Type of Occurrences (PSP/A2752 novelties)
1. Continued Airworthiness presentation 2. Regulations (IR21..) 3. Airbus Procedure AP2020 (new A2752)
3.1 COLLECT ENGO: Occurrences from “Design Office” or “Product integrity” MANO: Occurrences from ”Production” or “Flight tests” ISO: Occurrences from “Engineering Support” or “Training & Flight Ops” or “Accident/Incident Investigation” or “Technical Data”
Basic Airworthiness Training Course - Continued Airworthiness - March 2013
3.2 REPORT Occurrence Reportable Table
A Y G SUBJECTS COMMENTS
X 27 Thrust reversing system – unlock warning or REV press warning
Even in case of spurious warning, will be classified Yellow as for primary lock real failure events
X 28 Total loss of engine parameters
X X 29 Engine self starting A: if consequence on A/C is HAZ to CAT Y: otherwise
92 Electrical installation
X X X 1 Wire chaffing SFAR88 regulation and recommendation need to be considered when such chaffing happened close to potential flammable fluid (leak ) A: HAZ to CAT Y: MAJOR G: minor impact on system (not reported when no high power involved
X X X 2 Significant short circuit A: HAZ to CAT - Close to potential flammable source (fuel, hydraulic ) Y: MAJOR G: minor impact on system
99 Operation of the Aircraft
X X 1 Risk of collision with an aircraft, terrain or other object or an unsafe situation when avoidance action would have been or has been appropriate
A: Airmiss linked to A/C system misbehaviour or AIB procedure G: otherwise but information to AA
As already seen on Change Approval module, CS25 in its relevant interpretative material AMC1309, proposes a classification on the incidents/events considering several point of view:
� Effect on A/C
� Effect on occupant
� Effect on flight crew
Note: Same classification included in FAR/JAR
Basic Airworthiness Training Course - Continued Airworthiness - March 2013
a) If there is factual evidence (from service experience, analysis or tests) that an event may occur that would result in :
1. A large reduction in safety margins or functional capabilities, or 2. Physical distress or excessive workload such that the flight crew cannot be relied upon to perform their tasks
accurately or completely, or 3. Serious or fatal injury to one or more occupants.
unless it is shown that the probability of such an event is within the limit defined by the applicable airworthiness requirements,
Basic Airworthiness Training Course - Continued Airworthiness - March 2013
3.2 REPORT Reportable event / Unsafe Condition
c) Design features intended to minimize the effects of survivable accidents are not performing their intended function.
(Slides, DFDR, PATH MARKING, ELT…..)
OR
Note 1 : Non compliance with applicable airworthiness requirements is generally considered as an unsafe condition, unless it is shown that possible events resulting from this non compliance do not constitute an unsafe condition as defined under a,b,c above.
OR
b) There is an unacceptable risk of serious or fatal injury to persons other than occupants,
Verification tests in AIRBUS-D laboratory have been performed and confirmed the non-conformity for BRUCE Floor Proximity Emergency Escape Path Marking System architecture. The current Bruce - FPEEPMS system architecture does not comply with:
- JAR 25.812 (l)(1) according to A319 / A321 certification basis, - JAR 25.812(k)(1) according to A320 certification basis, as in the event of vertical fuselage segregation forward of door 1, none of the connected FPEEPMS including Exit-Identifiers will illuminate.
A320 - Wiring short circuit in RH raceway Background: One operator has experienced wires short circuit in R/H wing trailing edge raceways, outboard of #3 spoiler on A320 MSN.0018 (Air Safety Report issued by BAW), affected raceway Part Number: D9245005300000 Affected wires are identified as follow: 2824-4551-cf20 2499-4506-cf20 2499-4507-cf20 2499-4707-cf20 3348-4504-qf20 3348-4502-cf22 3348-4500-cf22 3341-4500-cf22 No fire risk due to potential sparks
Basic Airworthiness Training Course - Continued Airworthiness - March 2013
3.2 REPORT - Screening Exercise
Y
G
G
A
ENGINE COMPRESSOR STALL AT LANDING: At landing full reverse engaged, compressor stall was experienced at 50 knots on both engines. Add input: FCOM states that below 80 knots the reverse should be reduced to idle to prevent gas ingestion and subsequent engine stall.
RAT deployment test failed: During ground check, RAT up lock mechanism did not respond to Input from cockpit operation handle.
IFTB DUE TO AFT CARGO SMOKE WARNING IFTB due to aft cargo smoke warning despite both fire extinguisher bottles percussion. On ground, inspection in aft cargo revealed smoke from a parcel containing a chemical product.
IN FLIGHT TURN BACK DUE TO LOSS OF THE SECOND BLEED WITH 1ST BLEED INOP: Shortly after take-off ENG 2 bleed failed and cabin pressurization could not be maintained, flight crew performed an IFTB.
Y AUTOPILOT 2 NOT ABLE TO MAINTAIN THE CRUISE LEVEL: A/C started to climb with increasing vertical speed. Alt alert warned, AP2 disconnected flight level manually recovered. Vertical Speed increased up to +800 ft/mn - Altitude increased + 550 ft
Basic Airworthiness Training Course - Continued Airworthiness - March 2013
3.2 REPORT - Screening Exercise
A320 - Wiring short circuit in RH raceway Background: One operator has experienced wires short circuit in R/H wing trailing edge raceways, outboard of #3 spoiler on A320 MSN.0018 (Air Safety Report issued by BAW), affected raceway Part Number: D9245005300000 Affected wires are identified as follow: 2824-4551-cf20 2499-4506-cf20 2499-4507-cf20 2499-4707-cf20 3348-4504-qf20 3348-4502-cf22 3348-4500-cf22 3341-4500-cf22 Number of similar reports: More than 20
BAW A320 MSN.0018 wiring short circuit in RH raceway AP2020: 92-1 and 999-1 Cable chaffing at raceway junction level. Affected systems/functions for this event: Navigation light, strobe light, low level fuel. Impact on Airworthiness remains MAJOR but must be reported to EASA due to the high number of occurrences and potential adverse trend.
1. Continued Airworthiness presentation 2. Regulations (IR21..) 3. Airbus Procedure AP2020 (new A2752)
3.1 COLLECT ENGO: Occurrences from “Design Office” or “Product integrity” MANO: Occurrences from ”Production” or “Flight tests” ISO: Occurrences from “Engineering Support” or “Training & Flight Ops” or “Accident/Incident Investigation” or “Technical Data”
Basic Airworthiness Training Course - Continued Airworthiness - March 2013
3.3 INVESTIGATE - ARS Structure
Background Short description. Investigation Investigation/analysis of the presented subject. Impact on Airworthiness Safety analysis, to establish if an unsafe condition exists or not Typically: - catastrophic / hazardous / major or - non regulatory compliance or - emergency device related or - structure strength reduction In addition: - Probability of the most realistic worst case - Application of IR 21A.3B(b) giving acceptable reaction time when applicable
Corrective Action Corrective Action(s) identified: - Risk alleviating actions - Short term actions - Long term Actions Identification of the corrective action shall be exhaustive and sufficiently detailed; directly used for writing the AD. Compliance time; directly used for the writing of the AD. Compliance time has to be estimated on Calendar basis. Effectivity Potentially affected aircraft when mandatory measures. Used in AD. Conclusion This paragraph will provide the AIRBUS position and the EASA position. ARS Issue management In order to guarantee a good traceability, a new conclusion will be written for each issue giving the date of the status. Summary An ARS summary can be created. Exportable part of ARS (to foreign AA).
3 ARMs per year (+ special): - Feb/March - June - Oct/Nov ARM ATTENDEES: Æ EASA PCM is the Chairman Æ AIRBUS coordinates the meeting - AA - Panel specialists - OSAC (for EASA AD) - AIRBUS - CAE - CAM - Certification Coordinator (each site) - SSA DCS - Safety Advisor - Customer Service Program - AIRBUS depending on subjects - DCS - Customer Service specialist - CoC specialists Agenda is based on: - AMBER occurrences - Questions from AA - New regulation (SFAR88/92 )
Central Team Task Site team tasks Planning M - Preliminary agenda: Amber Occurrences and EASA requests.
- Follow up action list reminder sent - pre ARM meeting schedule sent
T W T F W-E W-E M T
W T F W-E W-E M T W
PRE ARM meeting (ARS comments, IOA review, Specialist attendance/ARM timing, agenda consolidation)
GM 21A.3B(d)(4) Defect Correction: Different steps to be considered for hazardous to catastrophic failure conditions:
A - Establish all possible alleviating action such as inspections, crew drills, route restrictions, and other limitations B - Identify that part of the fleet, which is exposed to the residual risk C - Using reasonably cautious assumptions, calculate the likely hazardous/catastrophic rate for each aircraft carrying the risk in the affected fleet D - Compare the speed with which any suggested campaign will correct the deficiency with the time suggested E - Also ensure that the expected probability of the catastrophic event during the rectification period on the affected fleet is in accordance with Fleet risk
Note: Where a fleet of aircraft is involved reaction time may be interpreted
as the mean time to rectification and not the time to the last one
Basic Airworthiness Training Course - Continued Airworthiness - March 2013
3.3 INVESTIGATE - Corrective action implementation : Main steps as per regulation
Establish all possible alleviating action such as inspections, crew procedures, route restrictions and other limitations. ATQC (A380/A400M...): Airbus Temporary Quick Change
Basic Airworthiness Training Course - Continued Airworthiness - March 2013
3.3 INVESTIGATE - Corrective action implementation : Risk Alleviation Means
• Depending on the nature of the failure case, different way to manage the retrofit of the corrective actions may be taken � Ageing old A/C to be considered first � Infant new A/C to be considered first � Fatigue as per model result, depending on FC or FH �
• IR 21 provides a guideline tool (GM 21A.3B(d4)) to assist in establishing
rectification campaigns: � It provides tool to quantify acceptable risk exposure. Nevertheless
engineering judgement has to be considered in the same time
� When quantitative criteria cannot be applied, subject event should not be anticipated to occur before corrective action implementation. This is of course leading to use an engineering judgement
Note: IR 21 is not the only way to consider the corrective campaign
Basic Airworthiness Training Course - Continued Airworthiness - March 2013
a) If there is factual evidence (from service experience, analysis or tests) that an event may occur that would result in :
1. A large reduction in safety margins or functional capabilities, or 2. Physical distress or excessive workload such that the flight crew cannot be relied upon to perform their
tasks accurately or completely, or 3. Serious or fatal injury to one or more occupants.
unless it is shown that the probability of such an event is within the limit defined by the applicable airworthiness requirements,
Basic Airworthiness Training Course - Continued Airworthiness - March 2013
b) There is an unacceptable risk of serious or fatal injury to persons other than occupants,
c) Design features intended to minimize the effects of survivable accidents are not performing their intended function.
(Slides, DFDR, PATH MARKING, ELT…..)
OR
Note 1 : Non compliance with applicable airworthiness requirements is generally considered as an unsafe condition, unless it is shown that possible events resulting from this non compliance do not constitute an unsafe condition as defined under a,b,c above.
• GM 21A.3B(d)(4) – 1. This document contains GM of a general nature for use in conjunction with engineering judgement, to aid airworthiness engineers in reaching decisions in the state of technology at the material time.
• GM 21A.3B(d)(4) – 4.3. It must be stressed that the benefit of these guidelines will be to form a datum for what is considered to be the theoretically maximum reaction time. A considerable amount of judgement will still be necessary in establishing many of the input factors and the final decision may still need to be tempered by non-numerical considerations, but the method proposed will at least provide a rational 'departure point' for any exercise of such judgement.
• GM21A.3B(b) – 2. This analysis may be qualitative or quantitative, i.e. formal and quantitative safety analyses may not be available for older or small aircraft. In such cases, the level of analysis should be consistent with that required by the airworthiness requirements and may be based on Engineering judgement supported by service experience data.
Basic Airworthiness Training Course - Continued Airworthiness - March 2013
• Decisions for mandatory actions are made during ARM and recorded in ARS’s
• Airworthiness Directives: � On behalf of EASA, the OSAC performs the EASA AD coordination � Prior to issuance of the EASA AD, draft Project EASA AD (PAD) are
available on the EASA Website for consultation (from 2 up to 4 weeks)
� EASA AD are published with Comment-Response Document (CRD)
• Foreign countries Aviation Authority process: � ICAO Contracting NAA receive all EASA AD’s from EASA � FAA has its own process (NPRM) for which relevant documents are
sent by CAE team
• Airbus informs operators prior to EASA AD issuance via OIT
• Airbus manage ADs data in a specific data base ADCL (EIAS owner)
Basic Airworthiness Training Course - Continued Airworthiness - March 2013
1. Continued Airworthiness presentation 2. Regulations (IR21..) 3. Airbus Procedure AP2020 (new A2752)
3.1 COLLECT ENGO: Occurrences from “Design Office” or “Product integrity” MANO: Occurrences from ”Production” or “Flight tests” ISO: Occurrences from “Engineering Support” or “Training & Flight Ops” or “Accident/Incident Investigation” or “Technical Data”
Basic Airworthiness Training Course - Continued Airworthiness - March 2013 Continued Airworthiness
• AA Aviation Authorities • ACJ Advisory Circular - Joint • AD Airworthiness Directive • AMC Acceptable Means of Compliance • AMOC Alternative Means of Compliance • AOT Alert Operator Transmission • AP AIRBUS Procedure • ARM Airworthiness Review Meeting • ARP Airworthiness Review Process • ARS Airworthiness Review Sheet • ATQC AIRBUS temporary Quick Change • CAE Chief Airworthiness Engineer • CE Chief Engineer • CoC Centre of Competence • DCS Designated Certification Specialist • EASA European Aviation Safety Agency • EP Engineering Panel • EASA AD EASA Airworthiness Directive • FAA Federal Aviation Administration • FC Flight Cycles • FH Flight Hours • FCOM Flight Crew Operating Manual • FOT Flight Operation Transmission • FPEEPMS Floor Proximity Emergency Escape Path Marking System • GM Guidance Material
• OSAC Organisation pour la sécurité de l’Aviation Civile
• ICAO International Civil Aviation Organisation • IR Implementing Rules • ISB Inspection Service Bulletin • ISO In Service Occurrences • MP Maintenance Panel • MOD Modification • MMEL Minimum Master Equipment List • MSN Manufacturer Serial Number • TOP Training and Operational Panel • OEB Operation Engineering Bulletin • OIT Operator Information Telex • ORT Occurrence Reportable Table • PCM Project Certification Manager • PSP Product Safety Policy (AP2750) • RO Reportable Occurrences • SSA System Safety Assessment • SB Service Bulletin • SDM Safety Data Management • SIL Service Information Letter • VSB Vendor Service Bulletin
