EASA Part 21 Subpart J - Understanding the DOA (Design Organization Approval)

[flopal]

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.

...

 

[Angelika]

Re: EASA Part21 Subpart J – DOA

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

 

[Namviator]

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?

 

[star_cgh]

Re: EASA Part 21 Subpart J – DOA - Here is my understanding of the DOA

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.

 

[Namviator]

Re: EASA Part 21 Subpart J – DOA - Here is my understanding of the DOA

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

 

[Angelika]

Re: EASA Part 21 Subpart J – DOA - Here is my understanding of the DOA

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

 

[Angelika]

Re: EASA Part 21 Subpart J – DOA - Here is my understanding of the DOA

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

 

[Namviator]

Re: EASA Part 21 Subpart J – DOA - Here is my understanding of the DOA

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)

 

[Angelika]

Re: EASA Part 21 Subpart J – DOA - Here is my understanding of the DOA

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

 

[Namviator]

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