Scholarly article on topic 'Development of Production Organization Exposition (POE) to Include Requirements of AS/EN9100, EASA, FAA and DGCA India'

Development of Production Organization Exposition (POE) to Include Requirements of AS/EN9100, EASA, FAA and DGCA India Academic research paper on "Economics and business"

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Abstract of research paper on Economics and business, author of scientific article — Neelesh S. Bhopatkar

Abstract To gain access to new markets and technology resources, as well as low-cost and multi-currency-based sourcing and offset obligations, major Original Equipment Manufacturers (OEMs) are expanding their footprint in Asia. It is mandatory to have EASA/FAA approvals including Civil Aviation Airworthiness approvals by DGCA, India for organizations engaged in manufacture of an aircraft/ component/ item of equipment or part to export products for commercial aircraft applications. Reyaneh Sayafi, Florence Leblond developed a Production Organization Exposition scheme taking into account EN9100 requirements. The objective was to study requirements of AS/EN9100, EASA, FAA and DGCA (India) to harmonize and prepare a concise Production Organization Exposition (POE) that complies with all requirements. This paper includes development of Production Organization Exposition (POE) manual to incorporate requirements of Quality Management Systems- Requirements for Aviation, Space and Defense Organizations (AS/EN 9100), European Aviation Safety Agency (EASA) Part 21 G, Federal Aviation Administration (FAA) CFR 14 Part 21 G and DGCA, India Part 21 Subpart G. A detailed comparison of AS/EN 9100, EASA, FAA and DGCA (India) requirements of Production Organization Exposition (POE) is conducted. A cross reference matrix has been prepared. For each important topic, it covers regulations, similarities and differences and then a harmonization which defines a common structure of procedures of Production Organization Exposition (POE) incorporating AS/EN9100, EASA, FAA and DGCA (India) requirements. Efforts in planning stage will ensure stringent requirements are deployed and enable minimum preparation time required to take up approvals from Civil Aviation Authorities.

Academic research paper on topic "Development of Production Organization Exposition (POE) to Include Requirements of AS/EN9100, EASA, FAA and DGCA India"

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Procedía Engineering 80 (2014) 216 - 223

www.elsevier.com/locate/procedia

3 International Symposium on Aircraft Airworthiness, ISAA 2013

DEVELOPMENT OF PRODUCTION ORGANIZATION EXPOSITION (POE) TO INCLUDE REQUIREMENTS OF AS/EN9100, EASA, FAA AND DGCA INDIA

Neelesh S. Bhopatkar*

Larsen & Toubro Limited, Pune, Maharashtra, India

Abstract

To gain access to new markets and technology resources, as well as low-cost and multi-currency-based sourcing and offset obligations, major Original Equipment Manufacturers (OEMs) are expanding their footprint in Asia. It is mandatory to have EASA/FAA approvals including Civil Aviation Airworthiness approvals by DGCA, India for organizations engaged in manufacture of an aircraft/ component/ item of equipment or part to export products for commercial aircraft applications. Reyaneh Sayafi, Florence Leblond developed a Production Organization Exposition scheme taking into account EN9100 requirements.

The objective was to study requirements of AS/EN9100, EASA, FAA and DGCA (India) to harmonize and prepare a concise Production Organization Exposition (POE) that complies with all requirements. This paper includes development of Production Organization Exposition (POE) manual to incorporate requirements of Quality Management Systems- Requirements for Aviation, Space and Defense Organizations (AS/EN 9100), European Aviation Safety Agency (EASA) Part 21 G, Federal Aviation Administration (FAA) CFR 14 Part 21 G and DGCA, India Part 21 Subpart G.

A detailed comparison of AS/EN 9100, EASA, FAA and DGCA (India) requirements of Production Organization Exposition (POE) is conducted. A cross reference matrix has been prepared. For each important topic, it covers regulations, similarities and differences and then a harmonization which defines a common structure of procedures of Production Organization Exposition (POE) incorporating AS/EN9100, EASA, FAA and DGCA (India) requirements. Efforts in planning stage will ensure stringent requirements are deployed and enable minimum preparation time required to take up approvals from Civil Aviation Authorities.

© 2014 Published by Elsevier Ltd. This is an open access article under the CC BY-NC-ND license (http://creativecommons.Org/licenses/by-nc-nd/3.0/).

Selection and peer-review under responsibility of Airworthiness Technologies Research Center, Beihang University/NLAA. Keywords: Airworthiness; Certification Standard; Quality Management System; Production Organization Exposition

* Mr. Neelesh S. Bhopatkar, Manager, Quality Assurance. Tel.: +91- 02114-669 052; fax: +91—02114-669069. E-mail address: Neelesh.Bhopatkar@larsentoubro.com

1877-7058 © 2014 Published by Elsevier Ltd. This is an open access article under the CC BY-NC-ND license (http://creativecommons.Org/licenses/by-nc-nd/3.0/).

Selection and peer-review under responsibility of Airworthiness Technologies Research Center, Beihang University/NLAA. doi:10.1016/j.proeng.2014.09.076

1. Introduction

The purpose of the Production Organization Exposition (POE) is to set forth in a concise document format the organizational relationships, responsibilities, terms of reference and associated authority, procedures, means and methods of the organization. Reyhaneh Sayafi and Florence Leblond have developed a Production Organization Exposition Scheme taking into account EN9100 Requirements [1]. The objectives were to further study requirements and identify gap areas between AS/EN9100 requirements [2] and EASA [3], FAA [4] and DGCA, India [5] requirements. A detailed comparison of Production Organization Exposition requirements of EASA, FAA and DGCA, India is defined in Table 1. A Production Organization Exposition Structure defined with cross reference matrix of EASA, FAA and DGCA, India requirements clauses and linkage to AS/EN 9100 Quality Management System requirements was provided.

Abbreviations

AS/EN 9100 Quality Management System Requirements for Aviation, Space and Defence Organizations

DGCA Directorate General of Civil Aviation, India

EASA European Aviation Safety Agency

FAA Federal Aviation Agency

OEM Original Equipment Manufacturer

POE Production Organization Exposition

1.1. Gap Analysis of AS/EN9100 and Civil Aviation Requirements

Reyhaneh Sayafi and Florence Leblond have compared requirements of AS/EN 9100 and EASA Production Organization Exposition requirements and grouped them into common and non-common items. Further gap analysis conducted between AS/EN9100 requirements and EASA, FAA and DGCA, India Production Organization Exposition requirements. Major gaps identified are:

• Production Organization Exposition (POE)

• Training on general aviation business and detailed product training for employees who will be involved in Civil Airworthiness Business

• Nomination and certification of test inspectors (certifying staff)

• Additional EASA, FAA and DGCA requirements to be considered in Production Organization Exposition (POE).

1.2. Comparison of EASA, FAA and DGCA Production Organization Approval requirements

A comparison statement was prepared to depict difference of requirements of Civil Aviation Certification for Production Organization Approval (POA) as per Part 21 Subpart G. This comparison will be taken as input to define Production Organization Exposition (POE) structure and clause wise references of EASA, FAA and DGCA, India. AS/EN 9100 Quality procedures reference provided to avoid duplication of procedures.

Table 1. Comparison of EASA, FAA and DGCA Production Organization Approval (POA) Part 21 Subpart G

Commission Regulation (EC) No 1702/2003 of 24 September 2003 Annex Part 21Section A & Subpart G

21A.1 Scope

21A.2 Undertaking by another person than the applicant for, or holder of, a certificate

21A.3 Failures, malfunctions and defects

21A.3B Airworthiness directives

21A.4 Coordination between design and production

Title 14- Aeronautics & Space Part 21 Subpart A and Subpart G

21.1 Applicability and Definitions

21.2 Falsification of applications, reports, or records

21.3 Reporting of failures, malfunctions, and defects

Included in 21.3

CAR 21 Issue II Revision 1 25th Feb, 20 10 Subpart A & Subpart G

21.1 Scope and Definitions

21.2 Undertaking by another person than the applicant for, or holder of, a certificate

21.3A Failures, malfunctions and defects 21.3B Airworthiness directives

21.4 ETOPS reporting requirements

21.5 Airplane or Rotorcraft Flight Manual

21.6 Manufacture of new aircraft, aircraft engines, and propellers

21.7 Continued airworthiness and safety improvements for transport category airplanes.

21.8 Approval of articles.

21.9 Replacement & modification articles

21.131 Applicability

21.132 Eligibility

21.133 Application 21.135 Organization

21.137 Quality system

21.138 Quality manual

21.139 Location of or change to manufacturing facilities.

21.140 Inspections and tests.

21.141 Issuance

21.4 Coordination between design and production

21.131 Scope

21.133 Eligibility

21.134 Application

21.135 Issue of production organization approval

21.139 Quality System

21A.131 Scope

21A.133 Eligibility

21A.134 Application

21A.135 Issue of production organization approval

21A.139 Quality System

EASA FAA DGCA

21.142 Production limitation record

21.143 Duration

21.144 Transferability

21.145 Privileges

21.146 Responsibility of holder

21.147 Amendment of production certificates

21.150 Changes in quality system

21A.143 Exposition

21A.145 Approval requirements

21A.147 Changes to the approved production organization

21A.148 Changes of location

21A.149 Transferability

21A.151 Terms of approval

21A.153 Changes to the terms of approval

21A.157 Investigations 21A.158 Findings

21A.159 Duration and continued validity

21A.163 Privileges

21A.165 Obligations of the holder

EASA Form 50- Application for Part 21 POA

Form FAA 8110-12- Application for Type Certificate, Production Certificate, or Supplemental Type Certificate

21.143 Exposition

21.145 Approval requirements

21.147 Changes to the approved production organization

21.148 Changes of location

21.149 Transferability

21.151 Terms of approval

21.153 Changes to the terms of approval

21.157 Investigations

21.158 Findings

21.159 Duration and continued validity 21.163 Privileges

21.165 Obligations of the holder

CA Form 50- Application for production organization approval under CAR 21, Subpart G

2. Integrated Production Organization Exposition

After comparison of Production Organization requirements it is evident that there are minor differences between EASA, FAA and DGCA, India. It suggested to prepare an Integrated Production Organization Exposition Manual (POE) as defined in Section 3, which caters airworthiness requirements of all agencies supported by AS/EN 9100 Quality Management System requirements.

The benefits envisaged are

• Optimized Production Organization Exposition catering stringent airworthiness requirements,

• Existing AS/EN Quality Management System procedures utilized to avoid duplication of procedures in POE and

• Minimum preparation time for Civil Aviation Airworthiness certifications as clause wise comparison available to identify gap areas.

Figure 1. Integrated Production Organization Exposition (POE)

3. Structure for Integrated POE

An Integrated Production Organization Exposition (POE) structure with AS/EN 9100, EASA, FAA and DGCA, India clause wise references is defined.

Table 2. Integrated Production Organization Structure

Proposed Integrated POE Structure EASA FAA Clause DGCA, India AS/EN

Clause Ref Ref Clause Ref 9100 Clause

SECTION 0 - INTRODUCTION

0.0 Front Page

0.1 Table of Content

0.2 List of Effective Pages

0.3 Revision Details & Issue Status

0.4 Distribution List 21A.143a 21.138 21.143a 4.2.2

0.5 References

0.6 Abbreviations

0.7 Definitions

0.8 Introduction

Proposed Integrated POE Structure EASA Clause Ref FAA Clause Ref DGCA, India Clause Ref AS/EN 9100 Clause

SECTION 1 - MANAGEMENT

1.0 Company Policy 21A.143a 21.138 21.143a 5.3

1.0.1 Corporate Commitment 21A.143a 21.138 21.143a 5.1

1.0.2 Nomination of Accountable Manager 21A.143a &21A.145c 21.135 21.143a & 21.145c --

1.2 Management Personnel 1.3 Duties and Responsibilities of Management Personnel 21A.145c & 21A.143a 21A.145 & 21A.143a 21.135 21.135 21.145c & 21.143a 21.145 & 21.143a 5.5 5.5

1.4 Management Organization Chart 21A.145 & 21A.143a 21.135 21.145 & 21.143a 5.5

1.5 List of Certifying Staff 21A.145 & 21A.143 21.135 21.145 & 21.143 --

1.6 Manpower Resources 21A.143 21.138 21.143 6.2.1

1.7 Description of Facilities 21A.143a 21.138 21.143a 6.3

1.8 Scope of Work and Terms of Approval 21A.151 & 21A.143a 21.138 21.151 & 21.143a --

1.9 Notification Procedure to Civil Aviation Authority of Changes to Organization 21A.147, 21A.148 & 21A.143a 21.150 21.147, 21.148 & 21.143a --

1.10 Amendment Procedure for POE 21A.143 a &b 21.135, 21.146 21.143 a &b --

SECTION 2 - PROCEDURES

2.1 Quality System 21A.139, 21A.143a 21.137 21.139, 21.143a 4.0

2.1.1 Quality Audit of Procedures 21A.139 (xiv) 21.137( l) 21.139 (xiv) 8.2.2

2.1.2 Quality Audit of Products 21A.139 (xiv) 21.137 (l) 21.139 (xiv) 8.2.2

2.1.3 Quality Audit Remedial Action Procedure 2.1.4 Quality Audit Personnel 21A.139 (xiv) 21A.139 (xiv) 21.137 (i) 21.137 (l) 21.139 (xiv) 21A.139 (xiv) 8.2.2 8.2.2

2.1.5 Certifying Staff Qualification, Training, and Procedures 21A.145d2 21A.139 b1 (xi) --- 21.145d2 21.139 b1 (xi) --

2.1.6 Quality Escape -- 21.137 (n) -- 8.3

2.1.7 Audit for Compliance with Part 21 Subpart G 21A.139 b1 (xiv) 21.137 (l) 21.139b1 (xiv) 8.2.2

2.1.8 In-Service Feedback -- 21.137 (m) -- 7.5.1.4

2.1.9 Control of Documents and Records 21A.139 b1(i), (x), 21A.143a 10 21.137 (b), (k) 21.139 (i), (x) 21A.143a 10 4.2.3, 4.2.4,

2.2 Sub-Contract Control 21A.139b & 21.143a 21.137 (c) 21.139b& 21.143a 7.4.1

2.2.1 Supplier/ Sub-Contractor Evaluation Procedure 21A.139 b1 (ii) 21.137 (c) 21.139b1 (ii) 7.4.1

2.2.2 Supplier/ Sub-Contractor List 21A.139 b1(ii) 21.137 (c) 21.139b1 (ii) 7.4.1

Proposed Integrated POE Structure EASA Clause Ref FAA Clause Ref DGCA, India Clause Ref AS/EN 9100 Clause

2.3 Production Control 21A.139a &21A.143a 21.137 (d) 21.139a &21.143a 7.5.1

2.3.1 Acceptance/Inspection of Incoming Materials 21A.139 b1 (iii) 21.138 21.139 b1 (iii) 7.4.3

2.3.2 Stores Procedure 21A.139 b1 (xiii) 21.137 (j) 21.139 b1 (xiii) 7.5.5

2.3.3 Acceptance of Tools & Equipment 21A.143 21.138 21.143 7.5.1.3

2.3.4 Calibration/ Control Procedure 21A.139b1 (vii) 21.137 (f) 21.139 b1 (vii) 7.6

2.3.5 Use of Tools/Equipment by Staff 21A.143 21.138 21.143 --

2.3.6 Production Procedure 21A.139 b1 (v) 21.137 (d) 21.139 b1 (v) 7.5.2

2.3.7 Production Documentation and its Control 21A.143 21.138 21.143 --

2.3.8 Technical Records Control 21A.139 b1 (x) 21.137 (a) 21.139 b 1(x) 4.2.4

2.3.9 Release of Service Procedures EASA Form 1 Form 8130-3 Form 1 --

2.3.10 Control of Computer Records 21A.139 b1 (x) 21.137 (k) 21.139 b1 (x) 4.2.4

2.3.11 Specific Production Procedure 21.139b -- 21.139b --

2.3.12 Airworthiness Coordination with DOA 21A.139b (ix) 21.137 (a) 21.139b (ix) --

2.3.13 Off-Site Working Control Procedures 21A.139b (xv) -- 21.139b (xv) 7.5.1.4

2.3.14 Pre-Delivery Aircraft Maintenance Procedures 21A.139b (xvi) -- 21.139b (xvi) --

2.3.15 Control of Critical Parts 21A.139b 21.137 (k) 21.139b 8.2.4

2.3.16 Inspection and Testing 21A.139b (vi) 21.137 (e) 21.139b (vi) 8.2.4

2.3.17 Quality Escape Procedure -- 21.137 (n) -- 8.3

2.3.18 Control of Nonconforming Product and Article 21A.139 b1(viii) 21.137 (h) 21.139 b1 (viii) 8.3

SECTION 3 - APPENDICES

3.1 Arrangement for Link between DOA and POA 3.2 Release Form 21A.133 b, c EASA Form 1 21.137 (a) Form 8130-3 21.133 b, c Form 1 --

SECTION 4 - ANNEXURE

4.1 Compliance Matrix to EASA Part 21 FO.POA.00015-001 -- --

4.2 List of Management Personnel 4.3 List of Certifying Staff 21A.145c & 21A.143a 21A.145d 21.135 21.145c & 21.143a 21.145d 5.5

4.4 Capability List 21A.143 -- 21A.143 6.4

4.5 Training Program Manual -- -- -- 6.2.2

4.6 Approved Supplier List 21A.139 b1 (ii) 21.146h 21.139 b1 (ii) 7.4.1

4. Conclusion

A gap analysis was carried out to understand difference between EN/AS9100 requirements and EASA, FAA & DGCA, India requirements. FAA and AS/EN 9100 requirements are specifically asking for Inservice feedback and Quality escape while EASA and DGCA, India requirements are silent. EASA and DGCA, India requirements are specific for Certifying Staff, Offsite Working conditions and pre-delivery Aircraft Maintenance Procedures while FAA requirements are silent. There are specific requirements of Production Organization Approval such as Nomination of Accountable Manager, List of Certifying Staff, Scope of Work & Terms of Approval, Notification Procedure for Civil Aviation Authority, Amendment Procedure for changes in POE, Certifying Staff Qualification & Training, Airworthiness coordination with Design Organization Authority and pre-delivery Aircraft Maintenance Procedures while AS/EN 9100 is silent on these requirements.

After studying requirements of EN/AS9100, EASA, FAA and DGCA India, author proposed to prepare a separate Integrated Production Organization Exposition (POE) Manual with cross references of specific requirements of EASA, FAA and DGCA, India clauses and provide linkage/reference to AS9100 Quality Manual procedures. Efforts in planning stage for Production Organization Exposition will cater stringent Civil Aviation Airworthiness requirements in POE. Also references of AS/EN 9100 procedures will avoid duplication of quality procedures in Production Organization Exposition.

Further study need to be conducted to answer - will Civil Aviation Authorities work together to harmonize concise Production Organization Exposition catering all their requirements supported by AS/EN 9100 Quality Management System requirements; standardize and recognize civil airworthiness certification process of respective country to reduce differences and cost of certification without compromising quality and requirements.

Acknowledgements

The author acknowledges the guidance and support provided by Mr. K. Sreekumar, Vice President, Larsen & Toubro Limited, to publish this work. The author acknowledges guidance provided by Mr. Karl Kley, QA Head, CASSIDIAN, to formulate Production Organization Exposition as per EASA requirements.

References

[1] Reyhaneh SAYFI, Florence Leblond. Development of a Production Organization Exposition scheme taking into axcount EN9100 requirements. 25'h International Congress of the Aeronautical Sciences; ICAS2006, p. 1-10.

[2] SAE AS/ EN9100C, Quality Management Systems - Requirements for Aviation, Space and Defence Organizations; SAE Aerospace, 2009-01.

[3] Offcial Journal of the European Union, Commision Regulations (EC) No 1702/2003 of 24 September 2003, laying down Implementating rules for the airworhiness and enviornmental certification of aircraft and related products, parts and Appliances, as well as for certification of design and production organizations.

[4] Federal Aviation Administration, Docket No. FAA-2006-25877, Amdt:21-92, 74 FR 53387, Oct. 16, 2009, Subpart G-Production Certificates; 2009

[5] Directorate General of Civil Aviation ,CAR 21Certification Prodcures for Aircraft and Related Products and Parts; 2010.