Hi All,

Here is my understanding of the DOA, please correct me if i'm wrong and add your info!
I think it would be nice to have a EASA section just as the FAA has one...:)

For a new company wishing to obtain a DOA & TC

Example of differences between the DOA and AS/EN 9100

DOA Design Organisation Approval


The DOA is a "must have"



The DOA does not deal with customer or production issues but mainly design issues in order to obtain a safe product.



Addresses the applicable statutory and regulatory requirements


AS/EN 9100


AS/EN 9100 is a "nice to have"



AS/EN 9100 deals with customer, design, production and applicable statutory and regulatory requirements (but does not address them in detail )

Obtaining a DOA, a TC, when…

The process of obtaining the DOA should be started prior to the process of obtaining a Type Certificate with the Agency. Since the DOA is used to obtain a TC, a TC procedure should be started soon after with the Agency.
A full fledged DOA cannot be obtained from the Agency prior to obtaining a Type Certificate from the Agency.
Why?

Because some of the procedures required for the DOA cannot be audited by the Agency prior to obtaining a TC, these procedures include:



Procedure for the Classification of Major/ Minor Change
Procedure for the Approval of Major Change by the Agency
Procedure for the Approval of Minor under the DOA
…


But a restricted DOA can be issued by the Agency and updated at each audit prior to obtaining a full fledged DOA.

...

Can anyone provide insight on this?

Maybe we can get some more exposure if we move the thread to the FAA page.

Flopal, here is my point of view:

For a new company wishing to obtain a DOA & TC

Example of differences between the DOA and AS/EN 9100

DOA Design Organisation Approval

* The DOA is a "must have" if you want to obtain one of the privileges i.a.w. 21A.263

* The DOA does not deal with customer or production issues but mainly design issues in order to obtain a safe product. I agree, however 21A.4 - connection between DO/PO must be shown

* Addresses the applicable statutory and regulatory requirementsI agree



AS/EN 9100

* AS/EN 9100 is a "nice to have" more or less except if your customers require you to obtain it

* AS/EN 9100 deals with customer, design, production and applicable statutory and regulatory requirements (but does not address them in detail )I agree

Obtaining a DOA, a TC, when…

The process of obtaining the DOA should be started prior to the process of obtaining a Type Certificate with the Agency. Since the DOA is used to obtain a TC, a TC procedure should be started soon after with the Agency.
A full fledged DOA cannot be obtained from the Agency prior to obtaining a Type Certificate from the Agency.
Why?

Because some of the procedures required for the DOA cannot be audited by the Agency prior to obtaining a TC, these procedures include:

* Procedure for the Classification of Major/ Minor Change
* Procedure for the Approval of Major Change by the Agency
* Procedure for the Approval of Minor under the DOA
* …
I assume the Agency requires the TC-holder to do the TC in parallel with the DOA-process to see if the procedures (see above) are adequate for the intended purpose.

But a restricted DOA can be issued by the Agency and updated at each audit prior to obtaining a full fledged DOA.
Yes, the Agency may issue Design Organisation Approvals with limitations to enable the DOA to start working. A DOA may - for example - be limited to minor changes or repairs to TC's/STC's or the privilege to approve editorial changes to the AFM/AFM-Supplement may not be granted and so on. These limitations may be abolished once the Agency has been convinced of the Design Organisation's abilities.

Hope this helps.

Happy New Year!

Angelika

Hello Everyone

I am doing a research on the Economic and Technical perspective of obtaining and maintaining an EASA DOA , for my internship.

I have got the part on the EASA website about the cost of application and what I still need so far is the cost of maintaining the DOA for example the cost of Employing the CVE's, the cost of the Audits and so on.

And should there be any further clarification or additions you think I should include please feel free.

I have been trying to locate the EASA's Internal Certification Working Procedures for the DOA, I have tried the website here but cant locate it.

their website to nor avail

Any clues at all from anyone?

Hi Namviator

As the word "internal" implied, their internal procedure within EASA may not publish. But you can see the expectation required of an applicant DOA under 21B.xxx.

21A.xxx is the applicant required to do.
21B.xxx is the expectation of EASA.

Hope this helps.:)

Hi Star

I thank you very much on that regard

On 25 January 2005 a Decision of the Executive Director - ED Decision 2005/01/CF was taken establishing the Agency's Internal Certification Working Procedures that they be published, and following that decision, they were published on the EASA site, its a pity due to the rules of the chat as am still new, not allowed to post a link but could have done.

I can probably do with a DO handbook example for now.


Thanks

Hi Namviator,

I tried to send you the following answer to your private mail, however, I got an error report, therefore I put my answer for you into this thread.

I very well remember that the Internal Working Procedures were published on the EASA website. At the moment, however, I do not suceed in finding them either. Either they have been removed from the website or they are at a "hidden" place where one would not expect to find them. What did you want to find out by checking these internal EASA working procedures? If it is about the approval procedure of a DOA, I will certainly be able to give you some information since I supported around a dozen companies in obtaining this approval. Just let me know if I can be of any further help to you. Best regards, Angelika

Hello Everyone

I am doing a research on the Economic and Technical perspective of obtaining and maintaining an EASA DOA , for my internship.

I have got the part on the EASA website about the cost of application and what I still need so far is the cost of maintaining the DOA for example the cost of Employing the CVE's, the cost of the Audits and so on.

And should there be any further clarification or additions you think I should include please feel free.

Namviator,

as to your questions above:

the cost for the Agency's surveillance audits are covered by the annual surveillance fees, i.a.w. regulation (EC) 593/2007 ff.

The internal cost of maintaining the DOA are mainly on providing the required ressources e.g.
- management personnel (Head of Design Organisation, Office of Airworthiness, Quality Management/Auditing personnel)
- Design Engineers/Compliance Verification Engineers
- initial and recurrent trainings of any personnel employed by the DO, including any subcontractors (trainings on Part 21, DO-Manual, Certification Specifications etc., as applicable)
- performing internal audits (1 complete system audit within 36 months)
- adequate office rooms, equipment and rooms required for prototyping and tests
- procuring the required airworthiness and environmental requirements (if not published for free on one of the websites of the Aviation Authorities)

and so on.

The real cost in € depend on many items as e.g. your scope of work, the kind of design work you are doing etc.

Hope this helps. If you have any further questions, just ask - if I can help, I will be happy to do so!

Regards,
Angelika

Thanks alot Angelika,

one more question, if I have the Head DOA as the Accountable Manager with four post holders namely: QA Manager, Design Office Manager, Airworthiness Manager and Customer Relations Manager can I have the same person as the Airworthiness Manager if I contracts the CVE? or would there be a conflict of interest?

or would the best option be to have an Acc Manager Independent of the Airworthiness if I want the HDOA to cover the Airworthiness?

having in mind that its just a small Organisation, with only one scope of design (Mechanical)

Thanks alot Angelika,

one more question, if I have the Head DOA as the Accountable Manager with four post holders namely: QA Manager, Design Office Manager, Airworthiness Manager and Customer Relations Manager can I have the same person as the Airworthiness Manager if I contracts the CVE? or would there be a conflict of interest?

or would the best option be to have an Acc Manager Independent of the Airworthiness if I want the HDOA to cover the Airworthiness?

having in mind that its just a small Organisation, with only one scope of design (Mechanical)


Bonjour Namviator,

talking in Part 21, Subpart J terms, there are three management posts (post holders) required:

the Head of Design Organisation
the Office of Airworthiness
the Head of Quality Management

Furthermore, you need Design Engineers and Compliance Verification Engineers to do the Design and Compliance Verification Tasks for each field (in your case only "mechanical").

My experience is that both, the Head of Design Organisation and the Office of Airworthiness, can also undertake the role of the Design Engineers and the Compliance Verification Engineers if the company is very small. The Quality Management must be a position outside of the Design Process, unless there is an independent auditor who can be an external one as well.

If I interprete your situation correctly, you could do with three persons:
The Head of Design Organisation (with two more "hats on" as a Design and Compliance Verification Engineer;
the Office of Airworthiness (also acting as a Design and Compliance Verification Engineer);
the Head of Quality Management/Auditor.

If there is an external Auditor, in the smallest organisation, the Head of Design Organisation could also be the Head of Quality Management. This is my experience, however, needs to be discussed with and reviewed and accepted by the Agency.

It is important that Design and Compliance Verification is done by two independent persons, i.e. 4-eyes-principles.

A customer relations manager is not part of Part 21/Subpart J, so if there is such a person in your company who is competent in design as well, you may employ him in the Design Organisation, too.

I know that it is very difficult to implement Part 21/Subpart J in small organisations but there are many possible solutions.

I hope I have been able to help! If there are any further questions, please let me know!

à la prochaine fois,
Angelika

Bonjour Angelika

It is crystal clear indeed, but... but... the HDOA having two hats as the Acc Mgr and the A/W post holder, that surely means that he prepares the Declaration of Compliance obviously with the help of the CVE but then he signs his own work, where does it leave the "Conflict of Interest" concept. or would it be treated differently should the CVE's be contracted from the outside.

Yes, Design and CVE totally independent.

Regards
Namviator

Bonjour Angelika

It is crystal clear indeed, but... but... the HDOA having two hats as the Acc Mgr and the A/W post holder, that surely means that he prepares the Declaration of Compliance obviously with the help of the CVE but then he signs his own work, where does it leave the "Conflict of Interest" concept. or would it be treated differently should the CVE's be contracted from the outside.

Yes, Design and CVE totally independent.

Regards
Namviator


Bonjour Namviator,

I understand your doubts. Maybe I have catched something wrong in your previous threads?

In all 21, Subpart J companies that I know, the Head of Design Organisation and the Office of Airworthiness are two different persons.

However, both of them can also undertake a role as a Design and/or a Compliance Verification Engineer in the design processes.

Of course, in the end, to a certain extend, they sign their own work.

Striktly speaking, of course, it would be perfect if the Head of Design Organisation and the Office of Airworthiness would be absolutely independent from the design process itself.

However, at the same time this would mean that small organisations would not be able to obtain a 21, Subpart J approval since most of them do not have enough qualified design personell for each individual position.

Therefore, according to my experience, the HoD and the Office of Airworthiness may also undertake the position of the Design and/or the Compliance Verification Engineer (CVE), as long as both tasks are carried out independently from each other.

In order to avoid the managing persons to have two or even three hats on, there is also the possibility to employ external CVE's. That requires specific contracts with them and you need to show how you include them into your Design Assurance System (Part 21 training, DO-Manual trainings including revisions thereof, clear communication lines etc.). Wherever possible, we have avoided to employ external CVE's as long as the companies had the capability (know-how) themselves. It is easier to subcontract the design work than the much more responsible task of the compliance verification.

In any case, the personell situation needs to be individually discussed with the responsible DOA-Teamleader as mentioned in my answer before.

Best regards,
Angelika

Hello Everyone

I am doing a research on the Economic and Technical perspective of obtaining and maintaining an EASA DOA , for my internship.

I have got the part on the EASA website about the cost of application and what I still need so far is the cost of maintaining the DOA for example the cost of Employing the CVE's, the cost of the Audits and so on.

And should there be any further clarification or additions you think I should include please feel free.

I have been trying to locate the EASA's Internal Certification Working Procedures for the DOA, I have tried the website here but cant locate it.

their website to nor avail

Any clues at all from anyone?



Hi Namviator,

when looking for something quite different, I found the Link to the "Internal Working Procedures of the Agency".

Go to www.easa.europa.eu
Learn more
Certification overview
on the right side there is a link "Internal Working Procedures"

Hope this helps!

Regards,
Angelika

Hello Everybody.

I consider this thread as the approriate place to ask my question regarding Part 21J organization approval.

Does it have sense for a new Design Organization to obtain a Design Organization Approval according to Part21J if it's products, at the moment and for the near future, are neither a complete airplane nor a standalone system, just design of structural parts like the Aft Fuselage, acting as a subcontractor in cooperation with a prime contractor?

Is it required the organization to aim to a TC or a RTC or some other certificate according to Part 21(X) in order to has a sense the DOA?

Does anybody require the Part 21J approval in any case, other than the EASA Authority as an intermediate step on the route to obtain a type certificate?

Thank in Advance

Michael

Hello Michael,

in the following you will find my answers:


Does it have sense for a new Design Organization to obtain a Design Organization Approval according to Part21J if it's products, at the moment and for the near future, are neither a complete airplane nor a standalone system, just design of structural parts like the Aft Fuselage, acting as a subcontractor in cooperation with a prime contractor?

If you only act as a subcontractor for another Design Organization, usually there is no need for a Part 21, Subpart J-Design Organization unless your customer requires you to supply your design results with an approval like for example a Supplemental Type Certficate, a Major Repair Design Approval, a Minor Change or a Minor Repair Approval. In many cases, the subcontractors act as Design Subcontractors and their design results are checked, implemented and approved by the customer e.g. by means of a Type Certificate (TC) or a Supplemental Type Certificate. (STC)

Is it required the organization to aim to a TC or a RTC or some other certificate according to Part 21(X) in order to has a sense the DOA?

Yes, any Design Organization that aims to obtain any of the privileges i.a.w. 21A.263 is required to show their abilities by means of an approval i.a.w. Part 21, Subpart J. The same applies to Design Organizations if they want to design minor changes, major changes (STC's), minor repairs or major repairs to products for which they are not the type design holder.

Does anybody require the Part 21J approval in any case, other than the EASA Authority as an intermediate step on the route to obtain a type certificate?

see my answers above.

Hope this helps.

If I can be of any further help, just let me know.

Have a nice week-end!
Best regards,
Angelika

Angelika I thank you for your response.

I thought I had already done so, when some days ago I sent a response, ineffectively .

So you may get a DOA along with a Major Repair Design Approval for example. After that can I suppose that you can retain the DOA even if you dont have active project with EASA?

Actually is it possible for an organization to ask for a DOA wihout aiming to a certificate from EASA that has DOA as a prerequisite? Will EASA accept a request of this type?

Best Regards

Michael

Michael, in the following please find my reply for you:

Angelika I thank you for your response.

I thought I had already done so, when some days ago I sent a response, ineffectively . No problem, we are all busy people, aren't we? :)

So you may get a DOA along with a Major Repair Design Approval for example. After that can I suppose that you can retain the DOA even if you dont have active project with EASA? Yes, as long as your organisation remains in compliance with Part 21 and fulfills its obligations. I don't know if there might be any problems if you do not have any projects for a very long period.

Actually is it possible for an organization to ask for a DOA wihout aiming to a certificate from EASA that has DOA as a prerequisite? Will EASA accept a request of this type?
I am not sure if I have correctly understood your question. My latest status of information is that you do not need to have an active project to apply for a DOA. If you meant something different, please let me know.

Best Regards

Michael

Thank you Angelika once again,

Actually that is the question: "Is it required to have an active project in order to ask for an EASA Part 21 DOA. If yes what types of project can lead you there?". OK I have got the answer from you.

The first information I had was that you shall have an active project, which shall be a complete aircraft design, in order to discuss for a DOA.

It seems however that the DOA is not a standalone situation but a prerequisite to have the EASA approval on a specific product you create.

Best Regards

Michael

Michael, please see my answers below:
Best regards,
Angelika

Thank you Angelika once again,

Actually that is the question: "Is it required to have an active project in order to ask for an EASA Part 21 DOA. If yes what types of project can lead you there?". OK I have got the answer from you.

The first information I had was that you shall have an active project, which shall be a complete aircraft design, in order to discuss for a DOA.

In Germany it used to be a requirement from the national aviation authority to have an active project that accompanied the DO-approval process, however, only within the extent of the requested scope (for example an STC for cabin interior etc.). The Agency recommends such an active project because it facilitates them to assess the competences of the organisation as to their knowledge of airworthiness requirements (Certification Specifications etc.) and design practices. However, as already mentioned, it is not an obligatory requirement by the Agency

It seems however that the DOA is not a standalone situation but a prerequisite to have the EASA approval on a specific product you create.
Yes, that's right"

Best Regards

Michael

Hi everybody.

I have just found this topic by chance, I hope it is still active.

About the positions in the DOA. Angelika, are you sure that the HOD can not be the same person as the Aw Manager? I am not. Actually I knew a DOA where they wanted to distribute positions like that (I don't know if they did it at last). I agree with the independence of Quality department and separation of design and compliance verification, but at first sight I dont see any incompatibility between HOD and AwM. Where did you see it in part21?
I think I understood you know DOAs where the design manager is also CVE, is it right?

And at last, I think there is a sense to obtain DOA for a organisation which will not get any TC or STC: it is easier to work with them as subcontractors for bigger DOAs since its data are directly accepted by EASA, apart from this one I don´t see anymore.

Regards.