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EASA Part 21 Subpart J - Understanding the DOA (Design Organization Approval)
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EASA Part 21 Subpart J - Understanding the DOA (Design Organization Approval)
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  Post Number #9  
Old 18th March 2009, 01:49 PM
Angelika

 
 
Total Posts: 125
Re: EASA Part 21 Subpart J DOA - Here is my understanding of the DOA

Quote:
In Reply to Parent Post by Namviator View Post

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!

la prochaine fois,
Angelika
Thank You to Angelika for your informative Post and/or Attachment!

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  Post Number #10  
Old 19th March 2009, 06:35 AM
Namviator

 
 
Total Posts: 5
Re: EASA Part 21 Subpart J DOA - Here is my understanding of the DOA

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
  Post Number #11  
Old 19th March 2009, 09:26 AM
Angelika

 
 
Total Posts: 125
Re: EASA Part 21 Subpart J DOA - Here is my understanding of the DOA

Quote:
In Reply to Parent Post by Namviator View Post

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
Thank You to Angelika for your informative Post and/or Attachment!
  Post Number #12  
Old 26th March 2009, 10:19 AM
Angelika

 
 
Total Posts: 125
Re: EASA Part 21 Subpart J DOA - Here is my understanding of the DOA

Quote:
In Reply to Parent Post by Namviator View Post

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
Thanks to Angelika for your informative Post and/or Attachment!
  Post Number #13  
Old 8th October 2009, 11:08 AM
Michael_

 
 
Total Posts: 3
Re: EASA Part 21 Subpart J DOA - Here is my understanding of the DOA

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
  Post Number #14  
Old 10th October 2009, 02:29 AM
Angelika

 
 
Total Posts: 125
Re: EASA Part 21 Subpart J DOA - Here is my understanding of the DOA

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
Thank You to Angelika for your informative Post and/or Attachment!
  Post Number #15  
Old 26th October 2009, 05:06 AM
Michael_

 
 
Total Posts: 3
Re: EASA Part 21 Subpart J DOA - Here is my understanding of the DOA

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 (Design Organization Approval) 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
  Post Number #16  
Old 27th October 2009, 02:03 AM
Angelika

 
 
Total Posts: 125
Re: EASA Part 21 Subpart J DOA - Here is my understanding of the DOA

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

Quote:
In Reply to Parent Post by Michael_ View Post

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
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