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TECHNICAL AIRWORTHINESS MANAGEMENT MANUAL

SECTION 3

LEAFLET 2

GUIDELINES TO MAINTAINING AN AEO

Applicable Regulation:

Regulation 3 Authorised Engineering Organisations

INTRODUCTION

1. To ensure that an AEO remains compliant with the Regulations, each AEO is

required to carry out its duties in accordance with the current approved EMP and referenced

procedures. While Section 3 Chapter 1 provides guidelines on how to establish an AEO, this chapter addresses how organisations are to maintain AEO status.

PURPOSE

2. The purpose of this chapter is to provide guidance to the ongoing maintenance and

improvement of an organisation once it has been granted AEO status.

SCOPE

3. The scope of this chapter is the provision of guidance material that will assist

organisations in understanding the regulations. This chapter focuses on both the SDE and DAR (where applicable) responsibilities and their role in maintaining AEO status. It must be noted that where any conflicts occur between the guidance and the regulations, the regulations take precedence.

FUNDAMENTAL PRINCIPLES

4. SDE. Every applicant for an AEO must nominate an SDE, and it is this appointment

that is primarily responsible for maintaining certification as an AEO. While an AEO may

appoint a number of Deputy SDEs (DSDEs) to undertake SDE functions, it is the SDE that retains the responsibility for the AEOs Engineering Management System (EMS).

5. DAR. For SAO AEOs, the SDE may also be a Design Acceptance Representative

(DAR). (Whereas the SDE is a nominated appointment approved by the TAR, a DAR has a personal delegation from the TAR). DARs are responsible for the Design Acceptance function. Design Acceptance is the process whereby a design or design change (ie an output of the design process) involving aircraft or aircraft-related equipment is determined to be technically acceptable for SAO use. This is based on a determination that the specified requirements and design standards are sufficient and applicable (to the SAO authorised configuration, maintenance policy and procedures, and operations) and that the quality of the design has been proven to the satisfaction of the responsible DAR. Generally, design quality is assured through approval of the design by an AEO against the approved design requirements and standards plus an acceptable basis of design verification. While a DAR is primarily concerned with ensuring technical airworthiness of aircraft and aircraft-related equipment, Director of PUTD, Director of Engineering RMN, Chief of Air Engineering UUBPM, KSS at MLU, Director of Engineering RMAF have an additional (but closely related) responsibility for ensuring ‘fitness for service’, or in other words mission-worthiness.

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6. Level and Scope of EA. The TAR awards AEO to an organisation with a specific level

and scope of organisational Engineering Authority (EA). Level means the degree of approval that may be given for a design, eg. Design Approval certification (for SAO and commercial AEOs) or Design Acceptance certification (for SAO AEOs only). Scope is generally expressed in terms of system scope and design services scope. System scope concerns the equipment covered, and may be limited to particular aircraft components or aircraft-related equipment, or encompasses an entire aircraft type. Design services scope concerns the particular processes, technologies or disciplines that may be applied to the system scope, for instance aircraft stores clearances (a process), composite repairs (a technology), and repair schemes to secondary structure (a discipline).

KEY AREAS FOR MAINTAINING AEO STATUS

7. The focus of Section 3 Chapter 1 ‘Becoming an AEO’ is on meeting the Organisation,

Personnel, Procedure, and Data requirements of the regulations. While the focus of maintaining AEO status is essentially on maintaining these requirements, they can be further broken down into specific groups or activities, which are described in the following paragraphs.

8. Quality System. The SDE is responsible for ensuring that the organisation continues

to hold a valid Quality System certification to ISO 9001 or equivalent, which covers the range of services provided as an AEO.

9. Workforce. The SDE is responsible for assigning internal EA to sufficient staff,

particularly Design Engineers (DEs), to enable the AEO to conduct the full scope and level of engineering activity. However, it is understood that in some instances internal EA cannot be assigned due to staff vacancies, or insufficient competencies of individuals. In the event that staff numbers fall below acceptable levels, for SAO AEOs, the TAR is to be advised, while for a commercial AEO, the DAR of the sponsor AEO should be advised. Should there be a risk to maintaining technical airworthiness caused by insufficient staff, the TAR may decide to temporarily restrict or remove organisational EA from the AEO until the situation improves (see paragraph 27 for further information). Although the SDE does not normally have control over an organisation’s resources (this being the responsibility of the Senior Executive), it is the SDE’s responsibility to monitor engineering staffing levels and competencies, and advising the TAR (for commercial AEOs through the sponsor AEO) when substantial shortfalls exist.

10. Supervision. The SDE is primarily responsible for ensuring that engineering staff

adhere to the EMS, that subordinate personnel are adequately supervised, and that adequate oversight is provided of the design outputs. This does not mean that the SDE should personally review all design outputs. To the contrary, the development and review activity should be assigned to competent personnel and DEs throughout the organisation. Ideally, the SDE will only provide Design Approval certification for those designs judged as significant. The SDE is also responsible for bringing to the attention of the TAR (for a service AEO) or the DAR (for a commercial AEO) any issue that affects the AEO’s ability to comply with the regulations, or any other matter that has the potential to affect technical airworthiness.

11. Internal EA. The SDE is responsible for keeping track of the internal EA awarded to

staff within the AEO. This includes removing EA from staff that resign or are posted, evaluating the competency of new staff for award of EA, and conducting reviews of existing staff for continuation, extension, or reduction of existing EA. The SDE may also decide to review the quality and accuracy of engineering decisions made by his staff as an indicator of

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their performance and competence. In addition, the SDE is responsible for nominating either DSDEs or DEs to perform SDE duties when the SDE is absent.

12. Internal EMS Evaluation System. The SDE is responsible for conducting a series of

internal evaluations or audits of the AEO’s EMS. Note that while the program for these evaluations may be managed by the Quality Manager of the organisation, the activities themselves concern compliance of the EMS against the TAMM, and are quite distinct from compliance of the organisation’s QMS against ISO 9001 or an equivalent standard. They are to be conducted by qualified internal auditors, ideally the SDE’s own technical staff. The results of these internal evaluations should be documented as observations and Corrective Action Reports (CARs), the same as for an external audit by DGTA or the sponsor AEO. They should be reported at management review meetings and have corrective and preventative actions undertaken as for internal quality audits. The internal evaluation system is an important tool for the SDE to ascertain how the EMS is performing, as well as being the best indication of how an AEO will fare at the next surveillance audit. The internal evaluation system is also a useful method for encouraging continual improvement to the EMS and associated procedures.

13. Training Program. A program of continuation training or professional development is

required in order to satisfy the regulatory requirement to maintain the competence of personnel undertaking engineering activities. The training program should be conducted regularly, and records of attendance for each individual kept in order to tailor the training program, as well as for evidence at internal and external audits. Care should be taken in forming the schedule of training, to ensure that the topics covered are directly relevant to the

AEO’s activities. As an example, should the AEO experience an influx of new personnel, the training program should be tailored to cover the more basic principles of the EMS and the AEO’s procedures, these being the highest priority for training of new staff. Further, there is little point conducting lessons on a specific industry or engineering technology if the staffs have a generally poor understanding of the design control system and TIR processes.

14. Design Control System. The SDE is responsible for ensuring that the overall design

control system is compliant with the Design Control Regulation 3.4. Further details can be found in Section 3 Chapter 6 ‘How to produce Approved Designs’. Importantly, within the

design control system the SDE should primarily conduct Design Approval certification for significant designs, whilst providing oversight of other design control processes (such as Design Review) conducted by competent subordinate staff.

15. Management of the Design Support Network. The SDE is responsible for the

periodic review of the DSN as a whole, in order to ensure that it is suitable for the AEO’s activities. This may require the addition of new organisations to the DSN or removal of organisations no longer required in the DSN. New DSN members must not only be evaluated, but it must also be determined what services they are able to provide, when they must be sought for advice or services, and how their services are to be treated by the AEO.

16. Compliance Assurance. As a subset to DSN management, should a SAO AEO

sponsor any commercial AEOs, these organisations must be subject to a compliance assurance program. Similarly, any commercial AEO that has subcontractors performing engineering services on their behalf must also be subject to an audit program. Sponsor AEO responsibilities and compliance assurance programs are covered in Section 3 Chapter 4 ‘Getting Help – Design Support Networks’.

17. Exemptions. Regulation 1.1.4 requires that AEOs who seek to depart from an

applicable regulation must submit a formal exemption request to the TAR. The AEO’s SDE should document in the exemption request the reasons for non-compliance, and what action

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is proposed to compensate for the lack of compliance with the applicable regulation. The SDE should demonstrate that while operating with the exemption, the AEO can still adequately constrain any risk to technical airworthiness. Exemptions may also be applied for candidate DEs, DSDEs or SDE who do not meet the minimum criteria stipulated in Annexes A and B to Regulation 3, as described in Section 3 Chapter 1.

18. EMP and Procedures. The SDE is responsible for coordinating a periodic review of

the EMP and procedures to ensure that they continue to describe the activities of the AEO and that they remain compliant with the regulations. Major changes to the EMP that require

prior written notification to, and acceptance by the TAR are covered by the changes to an AEO’s organisation described at Regulation 3.6.2.

RESPONSIBILITIES OF DESIGN ACCEPTANCE REPRESENTATIVES

19. The individual delegation from the TAR to a Design Acceptance Representative

(DAR) is a key component of the technical airworthiness regulatory framework. As the Design Acceptance function represents corporate governance, a DAR must be a Malaysian Government employee. Eligibility requirements are similar to those for an SDE (Annex A to Regulation 3), however the TAR provides a formal written delegation to DARs. As DARs will normally reside within an AEO, the AEO must have suitable processes and procedures to support the DAR, as required by Regulation 3.4.6.

20. Design Acceptance System. The DAR is a representative of the TAR for Design

Acceptance functions. Design Acceptance means a determination of the technical acceptability of aircraft and aircraft-related equipment for SAO use. As such, the DAR is the ‘custodian’ of the Design Acceptance process for the systems nominated by the TAR, in a

similar manner to which the SDE is responsible for the EMS. The majority of Design Acceptance ‘activities’ should actually be carried out by competent personnel (other than the DAR), under the system defined, controlled and monitored by the DAR. Within Regulation 2 the DAR is the only person authorised by the TAR to issue a Design Acceptance certificate. The issue of a Design Acceptance certificate (for new aircraft types, major changes to Type Design, or minor changes to Type Design) does not require the DAR to personally review all design decisions, calculations, and design outputs. Rather, the Design Acceptance certificate is the method by which the DAR certifies that Design Acceptance functions have been conducted within a compliant Design Acceptance system, hat addresses the requirements of Regulation 2 depending on the classification (ie new aircraft, major change, or minor change).

21. Assumption of Design Acceptance. Regulation 2.5.9 requires that, for commercial

AEOs exercising an Assumption of Design Acceptance certification agreement, a monitoring program be established. The DAR is required to review at least 10% of design changes at least once per year, and document the results of the monitoring program. The purpose of the monitoring program is to confirm that the commercial AEO continues to comply with the regulations, and is exercising the Assumption of Design Acceptance certification within the bounds of the agreement between the DAR and the AEO.

22. Applications to the TAR. The DAR is responsible for applying to the TAR for

endorsement of Statement Of Requirements (SOR) or SOR changes, Type Certification Recommendations, SFP Recommendations, and SAO Release Recommendations for new aircraft or major changes to Type Design. The DAR is required to comply with a number of specific requirements and provide certain documentary evidence to the TAR in each instance, and these are fully described in Regulation 2.

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23. Classification of Type Design Changes. The DAR is responsible for classifying any

changes to Type Design. In general, the DAR may assume a change to Type Design is minor unless the change will introduce a new or substantially varied capability, or will have an appreciable affect on weight, balance, structural strength or operational characteristics. If there is any doubt on the classification of a change to Type Design, the matter is referred to the TAR.

24. Exemptions. Regulation 2 prescribes a number of requirements that must be met in

order for a DAR to issue a Design Acceptance certificate. The requirements vary depending on the level of Design Acceptance activity (new aircraft, major change, or minor change). If a specific requirement cannot be met, or sufficient justification for waiving the requirement exists, the DAR is required to submit a formal exemption request to the TAR in accordance with Regulation 1.1.4. The DAR should document in the exemption request any alternative methods or mitigating factors that demonstrate an equivalent level of technical acceptability exists.

25. Issuing Certificates of Airworthiness. The DAR issues Certificates of Airworthiness for

individual aircraft, confirming compliance to the Type Design. The DAR is also required to suspend or cancel Certificates of Airworthiness in certain circumstances, refer to Regulation

2.6.3.

26.

Notification of Unairworthy Conditions. The DAR is responsible for notifying both the

TAR and the OAA whenever an aircraft type has a condition or defect which is unairworthy in

accordance with the regulations. This includes conditions that although they may not be directly unairworthy, may involve a substantial restriction in operations or operational capability.

WITHDRAWAL OF AEO STATUS

27. The TAR is entitled to suspend or revoke AEO certification, under the provisions of

Regulation 3.2.7, if an AEO fails to meet the conditions for continued compliance (Regulation 3.6.1 refers). Sponsor AEOs are required to notify the TAR in writing with any recommendation to suspend or revoke a commercial AEO certification.

28. For commercial AEOs, the Engineering Authority Certificate (EAC) that represents

AEO certification remains valid only whilst a formal instrument remains in force. Immediately

the formal instrument is cancelled or expires (eg at completion of a contract), the engineering authority provided by the EAC ceases. Note that multiple formal instruments, which are detailed in the Letter of Engineering Authority, may relate to one EAC. The EAC remains valid whilst there is at least one formal instrument in force.

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