How to become a Repair Design Organisation, part 21 subpart M

[eniram]

Hello everyone!

I would like to thank you for information I've found in this forum. However I have other questions and I hope you could help me.

I am doing a 3-month-internship and the purpose is to study the possibility to create a repair design organisation. It would be a little engineering department which designs repairs for composite material structures for small aircrafts like cessna. The organisation will not apply itself those repairs.

So my questions are :

- If I have correctly understood, to have the approval for design repair, the organisation must already have an approval for design organisation ?

- Must the repair design organisation have a type certification for all the kinds of aircraft for which it designs a repair?

- To reduce the size of the Design Organisation, I consider putting the same person at the head of the compliance with procedures and checking functions, quoted in 21A.239. Is that possible to do? And what is the minimum size of a such organisation (number of person and department, including the design insurance system) ?


- Does the handbook mentioned in 21A243 follow a precise outline?



Looking forward your answer, I thank you in advance! Have a good evening!



Marine

 

[Angelika]

Re: How becoming a Repair Design Organisation, part 21 subpart M

Bon soir, Marine, voilà ma réponse!

Hello everyone! <snip>

Bonne soirée et meilleures salutations,
Angelika

 

[Angelika]

Dear Marine,

I don't know what happened and why my answer to you "disappeared". Sorry for that - in the following I try once again to answer your questions:

1.
If I have correctly understood, to have the approval for design repair, the organisation must already have an approval for design organisation ?

A minor repair to the TC/STC can be applied for by every natural or legal person with the Agency.

For a major repair to the TC/STC you either require an Alternative Design Organisation Approval (there are certain restrictions though) or, if you want to obtain privileges (classification of repair, approvals of minor repairs...) a Design Organisation i.a.w. Part 21, Subpart J.

2. Must the repair design organisation have a type certification for all the kinds of aircraft for which it designs a repair?

I am not sure if I correctly understood your question. The scope of approval of a Design Organisation normally is defined over Certification Specifications (CS-23 small aeroplanes, CS-25 large aeroplanes etc.), the technical fields (electrics, structure, cabin interiors etc) and the type of design work (minor changes, minor repairs, major changes etc.). If you download the application form from the EASA Website, you will see the required details and what possibilities of the Scope of Approval there are.

3. To reduce the size of the Design Organisation, I consider putting the same person at the head of the compliance with procedures and checking functions, quoted in 21A.239. Is that possible to do? And what is the minimum size of a such organisation (number of person and department, including the design insurance system) ?

What do you mean by "the Head of the Compliance"?
There are three management positions required in a Part 21, Subpart J Design Organisation

1. The Head of the Design Organisation
2. The Chief of the Office of Airworthiness
3. The Chief of Independent Monitoring System

There is the possibility to put some persons "several hats" on but the person who is responsible for the independent monitoring system must not be involved in the Design process. If there is no such independent person, there is the possibility to contract an external person to do the audits. Furthermore, the independent checking function in the showing of compliance (a Compliance Verification Engineer must independently check the design work done by the Design Engineer...) is another important aspect of Part 21, Subpart J.
So, theoretically, you could do with 3 to 4 persons, however, of course depending on your scope of approval and the abilitites of those persons.
You should discuss this with the Authority!

4. Does the handbook mentioned in 21A243 follow a precise outline?

There is not a precise outline. You can get some ideas from the AMC/GM but in the end you must show compliance with all applicable Subparts and/or paragraphs.


All this is my knowledge and experience and it does not necessarily have to comply with that of other people though.....

Hope I could help you and hope that this answer won't "disappear" once again!

Kind regards to France,
Angelika

Hello everyone!

I would like to thank you for information I've found in this forum. However I have other questions and I hope you could help me.

I am doing a 3-month-internship and the purpose is to study the possibility to create a repair design organisation. It would be a little engineering department which designs repairs for composite material structures for small aircrafts like cessna. The organisation will not apply itself those repairs.

So my questions are :

- If I have correctly understood, to have the approval for design repair, the organisation must already have an approval for design organisation ?

- Must the repair design organisation have a type certification for all the kinds of aircraft for which it designs a repair?

- To reduce the size of the Design Organisation, I consider putting the same person at the head of the compliance with procedures and checking functions, quoted in 21A.239. Is that possible to do? And what is the minimum size of a such organisation (number of person and department, including the design insurance system) ?


- Does the handbook mentioned in 21A243 follow a precise outline?



Looking forward your answer, I thank you in advance! Have a good evening!



Marine

 

[eniram]

Thank you Angelika for this very quick and sharp answer!

I think I will read again the Part 21 (for the hundredth time! ) with you indications on my mind.

Moreover, to answer to your question and to clear my sentence about the "(Head of) the Compliance with procedure" :

The design assurance system (= the independent monitoring system?) is divided in 2 functions:
- To independently monitor the compliance with, and adequacy of, the documented procedures of the system. This
monitoring shall include a feed-back system to a person or a group of persons having the responsibility to ensure
corrective actions.
- independent checking function of the showings of compliance

It was the first function that I called "Compliance with procedure".

Furthermore, I can't regain the text speaking about the applicable type-certification basis and environmental protection requirements, mentioned in this subsection. Could you please indicate me where I could find it?

Thank you for having quoted the AMC/GM, it seems to be a mine of information.

Vielen Dank für alles,

Marine

 

[Angelika]

Marine, I am sorry for the late answer. I have been very busy over the past weeks... I try to give you a quick answer:



The design assurance system (= the independent monitoring system?) is divided in 2 functions:
- To independently monitor the compliance with, and adequacy of, the documented procedures of the system. This
monitoring shall include a feed-back system to a person or a group of persons having the responsibility to ensure
corrective actions.
- independent checking function of the showings of compliance
That's correct!


It was the first function that I called "Compliance with procedure".
The responsible person for this task is called "Chief of independent system monitoring" (I would call it the Quality Manager but Part 21/AMC/GM uses a different term)
The Chief of independent system monitoring must not be any of the persons doing the independent checking functions of the showing of compliance (those persons are the Compliance Verfication Engineers!). He/she must be independent from the Design and Compliance Verification Process!


Furthermore, I can't regain the text speaking about the applicable type-certification basis and environmental protection requirements, mentioned in this subsection. Could you please indicate me where I could find it?
For Changes to the Aircraft = para 21A.101


Thank you for having quoted the AMC/GM, it seems to be a mine of information.
It's been a pleasure for me to help you!

Regards,
Angelika