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PROPOSED AMENDMENT TO TAMM REG. 3 - AEO LT COL Ir NORDIN BIN ABDUL GHANI RMAF DGTA-AAER
Transcript

PROPOSED AMENDMENT

TO

TAMM REG. 3 - AEO

LT COL Ir NORDIN BIN ABDUL GHANI RMAF

DGTA-AAER

WHERE?

Sect 1 INTRODUCTION - L2 : Overview

Sect 2 REGULATION - L1 : Regulation 1 – Application of Regulation and Procedural Rules - L2 : Regulation 2 – Type Certificate, Service Release

and Design Acceptance - L3 : Regulation 3 - AEO

- L4 : Regulation 4 - AMO - L5 : Regulation 5 - Aircraft Maintenance and

Management Procedures

Sect 3 GUIDANCE (DESIGN)

Sect 4 GUIDANCE (MAINTENANCE)

WHAT?

S2L3 : Regulation 3 - AEO

3.1 - General (General Application)

3.2 - Engineering Authority Certificates

3.3 - General Requirements of Issue

3.4 - Design Control

3.5 - CI Management

3.6 - Operating Requirements

WHY WE NEED TO AMEND? S2L3 : REGULATION 3 - AEO

Realign With The Current Practice.

Introduce New Sub-Regulation/Clause.

Emphasize The Current Requirement.

Prepare For Future Scope of Design/Engineering

Activities..

Facilitate The Understanding of Regulation.

Uphold/Maintain the Aviation Safety/Aircraft

Airworthiness

Regulation Title Remarks

3 Authorised Engineering Organisation To Be Amended

3.1 General No Change (NC)

3.1.1 Applicability NC

3.2 Engineering Authority Certificates To Be Amended

3.2.1 Applicability NC

3.2.2 Certificate Required NC

3.2.3 Sponsor AEO Requirements To Be Amended

3.2.4 Application To Be Amended

3.2.5 Audit NC

3.2.6 Issue of a Certificate To Be Amended

3.2.7 Duration To Be Amended

3.2.8 Engineering Management Plan To Be Amended

3.3 General Requirements of Issue To Be Amended

3.3.1 Definitions NC

3.3.2 Personnel To Be Amended

3.3.3 Design Support Networks NC

3.3.4 Design Control System NC

3.3.5 CI Management System NC

3.3.6 Data NC

3.3.7 Equipment, Tools and Facilities NC

3.3.8 Records To Be Amended

3.3.9 EMS Internal Evaluation System NC

3.3.10 Documentation Control NC

3.3.11 Prescribe, Revise and Interpret Airworthiness Standards New Regulation

3.4 Design Control To Be Amended

3.4.1 Design Control System To Be Amended

3.4.2 Data Control NC

3.4.3 Issue of Design Approval Certification NC

3.4.4 Design Review To Be Amended

3.4.5 Judgement of Significance NC

3.4.6 Design Acceptance NC

Regulation Title Remarks

3.5 CI Management To Be Amended

3.5.1 Applicability NC

3.5.2 Technical Information Review To Be Amended

3.5.3 Maintenance Engineering Analysis NC

3.5.4 Aircraft Structural Integrity Management To Be Amended

3.5.5 Engine Structural Integrity Management To Be Amended

3.5.6 Modifications NC

3.5.7 Substitutions NC

3.5.8 Deviations NC

3.5.9 Aircraft Stores Clearance and Certification NC

3.5.10 Aerial delivery clearances NC

3.5.11 Special Technical Instructions (STIs) To Be Amended

3.5.12 Incorporation Approval NC

3.5.13 Service Release (Minor Changes to TD) NC

3.5.14 Management of Type Design Data NC

3.5.15 Instructions for Continuing Airworthiness To Be Amended

3.5.16 Flight Manuals and aircraft operating instructions NC

3.5.17 Weight and Balance NC

3.5.18 Non Destructive Testing NC

3.5.19 Production NC

3.5.20 Modification Installation NC

3.5.21 Software Integrity Management New Regulation

3.6 Operating Requirements To Be Amended

3.6.1 Continued Compliance NC

3.6.2 Changes to an AEO’s Organisation NC

3.6.3 Inspections and Audits To Be Amended

REG

NO.

EXISTING REGULATION PROPOSED AMENDMENT/REMARKS

3.2.3

Sponsor AEO requirements

c. Sponsor AEOs shall develop,

promulgate and adhere to a structured

compliance assurance program when a

commercial organisation is required to

operate as a commercial AEO, to ensure

that the commercial AEO is monitored for

compliance with the TAR’s regulatory

requirements.

Delete the whole paragraph since the compliance

assurance function is undertaken by DGTA

3.2.4

Application

a. The applicant shall submit an

application for an EAC to the TAR:

(1) By the applicant directly when it is

the SAO organisation.

(2) Through the Sponsor AEO when

the applicant is a commercial

organisation.

a. The applicant shall submit an application for

an EAC to the TAR.

(1) By the applicant directly when it is the

SAO organisation.

(2) Through the Sponsor AEO when the

applicant is a commercial organisation.

REG

NO.

EXISTING REGULATION PROPOSED AMENDMENT/REMARKS

3.2.4 c. For an application from a commercial

organisation, the applicant shall include a

copy of the clauses of the formal

instrument to enforce the regulations in

this regulation.

To cater for an applicant without a contract or

formal instrument)

c. For an application from a commercial

organisation, the applicant shall include a copy of

the clauses of the formal instrument or SAO

sponsor letter to enforce the regulations in this

regulation.

3.2.4 Reg 3.2.4d is not available in the existing

regulation.

To emphasize the requirement.

d. For an application from a commercial

organisation relying substantially upon

subcontractors to perform the engineering

activities listed in the applicant’s EMP, the

application must detail those subcontractors and

the respective scopes of work to be subcontracted.

3.2.6 Issue of a Certificate

a(4) For a commercial AEO, the sponsor

AEO has developed and promulgated a

compliance assurance program as

required by regulation 3.2.3.

Delete the whole paragraph since the compliance

assurance function is undertaken by DGTA

REG

NO.

EXISTING REGULATION PROPOSED AMENDMENT/REMARKS

3.2.7 Duration

Reg 3.2.7c is not available in the existing

regulation.

To cater for AEO without a contract/formal

instrument.

c. An EAC issued to a commercial AEO with SAO

sponsor letter (without formal instrument) is valid

for a period as stated in the sponsor letter or until

the TAR suspends or revokes it.

3.2.8 Engineering Management Plan

Reg 3.2.8a(3)(d) is not available in the

existing regulation.

To introduce new scope of EA for ASR-AEO.

a(3)(d) The airworthiness standards that the ASR

is authorised to prescribe, revise and interpret in

accordance with Regulation 3.3.11.

3.3.2 Personnel

Reg 3.3.2a(2)(g) is not available in the

existing regulation.

To emphasize ASR’s responsibilities as a SDE.

a(2)(g) For ASR only, prescribing, revising and

interpreting airworthiness standards in

accordance with Regulation 3.3.11.

REG EXISTING REGULATION PROPOSED AMENDMENT/REMARKS

3.3.2

(3) For a Sponsor AEO, sufficient Auditor

and Lead Auditor qualified personnel,

meeting all the criteria of Annex G to

this regulation, to conduct

compliance assurance activities

required by regulation 3.2.3.

Delete the whole paragraph since the compliance

assurance function is undertaken by DGTA

3.3.2 e(5) For a Sponsor AEO, the SDE

authorises all Auditor and Lead Auditor

personnel.

Delete the whole paragraph since the compliance

assurance function is undertaken by DGTA

3.3.8

Records

a(2) For commercial organisations, agree

to transfer copies of such records to the

Government of Malaysia (delegated SAO)

upon cessation of the commercial AEO

formal instrument in accordance with

terms to be included in the formal

instrument and endorsed by the TAR.

Delete and endorsed by TAR since the TAR will not

be involved in endorsing the formal instrument.

a(2) For commercial organisations, agree to

transfer copies of such records to the Government

of Malaysia (delegated SAO) upon cessation of the

commercial AEO formal instrument in accordance

with terms to be included in the formal instrument.

and endorsed by the TAR.

REG EXISTING REGULATION PROPOSED AMENDMENT/REMARKS

3.3.11 Reg 3.3.11 is not available in the

existing regulation.

(To introduce new requirement for

ASR-AEO. It is corresponding with the

scope of EA of ASR-AEO (CoE)

Prescribe, Revise and Interpret Airworthiness

Standards

a. Each applicant seeking authority to prescribe, revise

and interpret airworthiness standards, hereinafter

referred to as an Airworthiness Standards

Representative (ASR), must have EMP procedures to

ensure that:

(1) The airworthiness standards that the ASR has

responsibility for are identified in the EMP and are

managed in accordance with Regulation 3.3.10.

(2) There is a pro-active approach to monitoring of

amendments to airworthiness standards.

(3) The competency and on going professional

development requirements for the ASR and those

positions within the AEO deemed to be essential to

an AEO maintaining its COE status, are described in

the EMP and endorsed by the Senior Executive.

REG EXISTING REGULATION PROPOSED AMENDMENT/REMARKS

3.4.1

Design control system

Reg 3.4.1c(5)(d) is not available in the

existing regulation.

To introduce system safety requirement for AEO.

c(5)(d) The application of System Safety.

3.4.4

Design Review

Reg 3.4.4a(6)(b) is not available in the

existing regulation.

To emphasize the requirement for design review

process.

a(6)(b) The requirements of Regulation 3.4.4

a(1)(a) have been satisfied.

a. The procedure for Design Review required by

Regulation 3.4.1 shall ensure:

(1) Certification of design output as a reviewer

is granted by an authorised person only if

satisfied that:

(a) The design assumptions, design reference

data, design conditions and the method and

tools employed in developing the design

output are assessed as appropriate and valid.

3.5.2

Technical Information Review

a(2)(c) Technical Airworthiness Directives

(TADs) issued by the TAR.

To include additional TI for TIR process.

a(2)(c) Technical Airworthiness Directives (TADs)

or Technical Airworthiness Advisory Circular (TAAC)

issued by the TAR.

REG EXISTING REGULATION PROPOSED AMENDMENT/REMARKS

3.5.4

Aircraft Structural Integrity Management

c. The ASI management system shall

ensure that:

(1) For a new aircraft type or major

design change, the ASIMP is issued by

the TAR prior to the Design

Acceptance of the aircraft type or

design change in accordance with

Regulation 2.2.3.

To rationalize the function of TAR/DAR.

c. The ASI management system shall ensure that:

(1) For a new aircraft type or major

design change, the ASIMP is issued by

the TAR/DAR prior to the Design

Acceptance of the aircraft type or

design change in accordance with

Regulation 2.2.3 (Issue of a Design Acceptance

Certificate)

3.5.4

c(6) ASI projects are managed by TAR.

To rationalize the function of TAR/DAR.

c(6) ASI projects are managed by TAR/DAR.

3.5.4 d(3) Ensure the authorised structural

inspection program intervals, structural

life limits, and component retirement

times are not exceeded without TAR

approval.

To rationalize the function of TAR/DAR.

d(3) Ensure the authorised structural inspection

program intervals, structural life limits, and

component retirement times are not exceeded

without TAR/DAR approval.

3.5.4

Reg 3.5.4d(6) is not available in the

existing regulation.

To include additional requirement in ASIMP.

d(6) Clearly identified Principal Structural Elements

(PSE) in ASIMP.

REG EXISTING REGULATION PROPOSED AMENDMENT/REMARKS

3.5.5 Engine Structural Integrity Management

a. Each applicant responsible for the CI

management of an aircraft gas turbine

engine shall establish an Engine

Structural Integrity Management (ESIM)

system to assure the continued

airworthiness of that engine.

b. The ESIM system shall ensure that:

(1) an Engine Structural Integrity

(ESI) Manager is appointed;

(2) critical parts are identified for

each engine;

(3) life limits, inspection and usage

monitoring requirements are

identified for each critical part based

upon the advice of:

(a) the OEM; or (in the absence

of such advice)

(b) a recognised NAA or foreign

military force in accordance with

regulation 2.2.7; or

(c) the TAR;

Engine Structural Integrity Management

a. Each applicant responsible for the CI management

of an aircraft gas turbine engine shall establish and

maintain an Engine Structural Integrity Management

(ESIM) system that ensure:

(1) An Engine Structural Integrity (ESI) Manager is

appointed.

(2) Critical parts are identified for each engine.

(3) Except as otherwise approved by the TAR, life

limits, inspection and Usage Monitoring (UM)

requirements are identified for each critical part

based upon the current advice of:

(a) The OEM.

(b) A recognised NAA or foreign military force as

defined in Regulation 2.2.7.

(c) The ESI Manager are supported by data

provided by an authorized AEO providing ESI

engineering services.

(4) The requirements identified in Regulation

3.5.5.a.(3)are periodically reviewed for applicability

to the SAO configuration, role and environment..

REG EXISTING REGULATION PROPOSED AMENDMENT/REMARKS

3.5.5 (4) a system for engine usage

monitoring is in place to ensure that

engine operating data is recorded to

enable management against the

limits identified at subparagraph (3);

(5) the requirements identified at

subparagraphs (3) and (4) are

assessed for applicability to the SAO

configuration, role and environment;

and

(6) a system for engine condition

monitoring is in place and includes

adequate review to ensure

effectiveness.

c. The ESIM system shall be

documented by an Engine Structural

Integrity Management Plan (ESIMP).

d. The ESIMP shall be reviewed at an

interval of not more than two years.

e. The ESIM system shall be

implemented by procedures that are

sponsored by the applicant.

(5) An effective system for UM is employed to

prevent exceedance of the limits identified in

Regulation 3.5.5.a.(3).

(6) Systems and processes for Condition

Monitoring, used to maintain airworthiness, are

validated and supported.

(7) The ESI management system is documented

in an Engine Structural Integrity Management

Plan (ESIMP).

(8) The ESIMP is reviewed, and revised if

necessary, at intervals not to exceed two years.

(9) The TAR is notified at the earliest opportunity

following:

(a) Receipt of amendments to critical part

life limits, inspection or UM requirements

issued by the applicable organisation in

Regulation 3.5.5.a.(3).

(b) Receipt of any TAAI applicable to the

engine.

(c) A non-recoverable in-flight shut-down of

an engine.

REG EXISTING REGULATION PROPOSED AMENDMENT/ REMARKS

3.5.5 f. TAR approval is to be sought prior to:

(1) deviation or modification to the

life limits and requirements

established at subparagraph b(3)

above; or

(2) issue of a new or amended

ESIMP.

(10) TAR approval is obtained through DAR

recommendation prior to:

(a) Implementing critical part life limits,

inspection or UM requirements that differ

from those specified by the applicable

organisation in Regulation 3.5.5.a.(3).

(b) Significantly modifying the system for UM

required by Regulation 3.5.5.a.(5).

(c) Releasing the initial and all revised

ESIMPs.

REG EXISTING REGULATION PROPOSED AMENDMENT/REMARKS

3.5.11

Special Technical Instructions (STIs)

b(14) The status of released STIs is

promulgated at six monthly intervals for

each STI Series status of either ‘active’ or ‘cancelled’.

b(14) STIs are actively monitored for incorporation

status including:

(a) STIs are cancelled at the earliest

possible opportunity.

(b) STIs found not to be fully incorporated

past their incorporation timeframe are

subject to appropriate action as determined

by the SDE.

(c) The status of released STIs is

promulgated at six monthly intervals for

each STI Series status of either ‘active’ or

‘cancelled’.

3.5.15

Instructions for Continuing

Airworthiness (ICA)

Reg 3.5.15a(4)(d) and a(4)(e) are not

available in the existing regulation.

a(4)(d) The instructions identify all Safety Critical

Items and Systems (SCIS).

a(4)(e) The instructions identify Independent

Maintenance Inspection (IMI) requirements for SCIS.

3.5.15 Reg 3.5.15a(7), a(8) and a(9) are not

available in the existing regulation.

a(7) Validate ICA that identify those maintenance

requirements essential to the airworthiness of

aircraft and associated Cis.

a(8) Collect and analyse data used to validate the

ICA that identify maintenance requirements essential

to the airworthiness of aircraft and CIs.

a(9) Ensure that all maintenance requirements

essential to the airworthiness of aircraft and

associated CIs are reviewed as a result of TIR or

other change initiator.

REG NEW STATEMENT

3.5.21

Software Integrity Management

a. Each applicant responsible for the configuration item management of aviation

software or aviation systems containing software must establish and maintain a

Software Integrity Management System, where aviation software is inclusive of:

(1) On-aircraft software, off-aircraft software with aircraft interface, and off-

aircraft software with no interface but which has airworthiness or safety

implications.

(2) Technologies that resemble software development such as Field

Programmable Gate Arrays(FPGAs) and firmware.

b. The Software Integrity Management System must include:

(1) A Software Management Plan (SMP).

(2) Procedures to assure software integrity of new or modified software.

(3) Procedures to provide continuing assurance of the software integrity of

accepted software.

REG NEW STATEMENT

3.5.21

c. The Software Integrity Management System must ensure that:

(1) The SMP is prepared by the SDE, issued by the DAR and approved by the

TAR.

(2) Any amendment to the SMP been approved by the TAR.

(3) All aviation software Configuration Items being managed by the applicant,

including the associated software assurance level, and worst credible failure

condition are identified in the SMP.

(4) All software tools being used by the applicant, including the tool

categorisation and qualification, are identified in the SMP.

(5) The SMP is reviewed at an interval not exceeding two years.

d. The procedures to assure software integrity of new or modified software must:

(1) Ensure software development of safety-related software is conducted to

satisfy the objectives of either a TAR recognised software assurance standard,

or a Software Assurance Matrix approved by the TAR.

(2) Require a software safety program be established for the development of

all software that is safety-related.

REG NEW STATEMENT

3.5.21

(3) Ensure a Plan for Software Aspects of Certification (PSAC), or equivalent

document, is submitted to and approved by the TAR prior to the

commencement of development.

(4) Provide for DGTA oversight of software for safety-related systems to

permit the DGTA to make software compliance findings.

e. The procedures to provide continuing assurance of the software integrity of

accepted software must:

(1) Implement a framework for software problem reporting, problem

assessment, tracking of problem reports and corrective actions to ensure that

errors, faults and failures are identified and resolved within a timely manner as

Regulation 3.5.2.

(2) Ensure the DAR and TAR is notified of any errors, faults or failures of

aviation software which potentially result in a large reduction in safety

margins.

REG EXISTING REGULATION PROPOSED AMENDMENT/REMARKS

3.6.3

Inspections and audits

d. Except as otherwise authorised by the

TAR, each AEO shall be required to

undergo an external audit at an interval

not to exceed two years and as specified

by the applicable compliance assurance

program as required by regulation 3.2.3.c.

e. The audit team shall include a quantity

of qualified Auditors led by a qualified

Lead Auditor, each meeting the criteria in

Annex G (as applicable) to this regulation.

f. The audit team shall be approved by:

(1) for a Service AEO audit, the TAR.

(2) for a commercial AEO audit, the

SDE of the Sponsor AEO.

g. The Sponsor AEO shall provide to the

TAR a copy of the audit report arising from

an external audit of a commercial AEO.

d. Except as otherwise authorised by the TAR, each

AEO shall be required to undergo an external audit

at an interval not to exceed two years. and as

specified by the applicable compliance assurance

program as required by regulation 3.2.3.c.

e. The audit team shall include a quantity of

qualified Auditors led by a qualified Lead Auditor,

each meeting the criteria in Annex G (as applicable)

to this regulation.

f. The audit team shall be approved by TAR.

(1) for a Service AEO audit, the TAR.

(2) for a commercial AEO audit, the

SDE of the Sponsor AEO.

g. The Sponsor AEO shall provide to the TAR a

copy of the audit report arising from an external

audit of a commercial AEO.

CONCLUSION (S2L3 : REGULATION 3 – AEO)

The propsed amendment could benefit all TAMM Reg. 3

Stakeholders i.e. Regulator, Service AEO, Commercial AEO,

DAR, ASR, and Engineering Organisation.

The proposed amendment shall streamline the current

regulation and upgrade it to a level that could accommodate

the current and future design/engineering activities.

The proposed amendment will not significantly impact the

current design/engineering activities of AEO.

Q & A

THANK YOU


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