UNCONTROLLED IF PRINTED TERHAD

PU 2103

TECHNICAL AIRWORTHINESS MANAGEMENT MANUAL

SECTION 3 LEAFLET 7

DESIGN ACCEPTANCE
Applicable Regulations 2.2.3 Issue of a Design Acceptance certificate for new aircraft or major changes 2.2.4 SAO Statement of Requirements (SOR) for new aircraft of major changes 2.2.5 Airworthiness standards for new aircraft and major changes 2.2.6 Recognition of prior acceptance 2.2.11 Compliance findings 2.5.2 Design Acceptance system for changes to a Type Design 2.5.3 Classification of changes in Type Design 2.5.6 Design Acceptance for minor changes to Type Design 2.5.7 SAO Statement of Requirements for minor changes 2.5.8 Airworthiness standards for minor design changes 2.5.9 Assumption of Design Acceptance certification 3.4.6 Design Acceptance INTRODUCTION 1. Design Acceptance is the cornerstone of the States technical airworthiness regulatory framework and the fundamental reason for the existence of Design Acceptance Representatives (DARs). Design Acceptance means a determination of the technical acceptability of equipment design for Service use. In the technical airworthiness context, the regulations deal primarily with aircraft and aircraft-related equipment design, however the concepts are identical for non-aircraft technical equipment. A DAR is a person with a delegation from the Technical Airworthiness Regulator (TAR) to undertake Design Acceptance functions in accordance with Regulation 2. 2. The basic concepts behind Design Acceptance can be difficult to understand and implement, especially when designs can come in a wide variety of forms with varying degrees of completeness. One of the more difficult aspects of Design Acceptance is trying to balance the autonomy of design and item management agencies to achieve good logistics outcomes with the need to assure technical integrity. In drafting the regulations relating to Design Acceptance, the TAR has sought to facilitate this balance. The intent is that the regulations provide adequate assurance of equipment technical integrity whilst www.dgta.gov.my 3.7 - 1 of 16 TERHAD

UNCONTROLLED IF PRINTED TERHAD

PU 2103

imposing the minimum necessary constraint (and Malaysia Interference) with design or CI management agency engineering decision-making. PURPOSE 3. The purpose of this chapter is to provide guidance on the Design Acceptance process, so that DARs can perform their role more effectively, and AEOs can better understand how the Malaysia accepts their design outputs. SCOPE 4. This chapter covers the Design Acceptance process for new aircraft, and major and minor changes to the Type Design. While this guidance is focussed primarily on aircraft and aircraft-related equipment designs, the concepts are identical for non-aircraft technical equipment. It must be noted that where any conflicts occur between the guidance and the regulations, regulation takes precedence. KEY CONCEPTS OF DESIGN ACCEPTANCE Principle Elements of the Design Acceptance Process 5. The Design Acceptance process embodies four principle elements. These are: a. Specification. There must be a document (or suite of documents) that provide a suitable basis for Design Acceptance in that the Malaysias requirements are sufficiently complete, verifiable and attainable. b. Competency. The design agency must be assessed as having, and must be judged to have applied, the necessary quality systems and competence to complete the design development with acceptable levels of technical risk. c. Verification. The DAR must be satisfied that there is adequate evidence that the design complies with the specification. d. Certification. Design Approval certification is required from the design agency attesting that the e. design meets the specification.

6. In addition, there are a number of key concepts that guide the regulation development process and provide a useful starting point for understanding the regulations. These concepts are: a. Design Acceptance is intrinsically a State function and cannot be contracted out. b. Design Acceptance is a process, not an act. It starts when the RMAF develops a specification, continues as a design agency is selected to perform design activity and ends in Design Acceptance certification. c. Although intrinsically a State function, certain activities within the Design Acceptance process may be undertaken by a number of suitably authorised people other than the DAR, including commercial organisations. d. The Design Acceptance process does not necessarily require the DAR to be personally involved in the design process of any specific design.

www.dgta.gov.my

3.7 - 2 of 16 TERHAD

UNCONTROLLED IF PRINTED TERHAD Design Quality versus Technical Acceptability

PU 2103

7. Generally, design quality is assured through approval of the design by a competent design agency against the approved design requirements and standards plus an acceptable basis of design verification. Thus, it is the design agency that is responsible for the competent execution of the design function (not the DAR), regardless of whether it is a Malaysia or commercial organisation. Competent design agencies are recognised through award of AEO certification, which is maintained through a suitable compliance assurance program. 8. The DAR is a representative of the TAR for Design Acceptance functions, to determine the technical acceptability of aircraft and aircraftrelated equipment for Service use. As such, the DAR is the custodian of the Design Acceptance process for the systems nominated by the TAR, in a similar manner to which the SDE is responsible for the EMS. In accordance with Regulation 3.4.6, Malaysia organisations with Design Acceptance responsibilities for the acquisition or support of the equipment must develop and maintain the skills and quality management systems necessary for: a. the development and approval of adequate technical specifications (the SAO SOR as per regulations 2.2.4 and 2.5.7); b. assessment and ongoing review of design agency competency (the compliance assurance program); c. assessment and management of technical risk; and

d. the review and acceptance of design verification results (compliance findings). Design Acceptance for Changes to Type Design 9. The regulations covering Design Acceptance for a new aircraft acquisition and for a major change to an existing Type Design are fundamentally similar, and are addressed concurrently in this chapter. The regulations covering Design Acceptance for minor changes to an existing Type Design are more flexible, and are covered separately. 10. The Design Acceptance requirements for acquisition of a new aircraft are obvious. For aircraft already in SAO service, however, due to somewhat different requirements, there is a need to classify changes to an existing Type Design as either major or minor. Classification of Changes to the Type Design 11. The first step in the Design Acceptance process for a change to the Type Design is to classify the design as either major or minor. This classification determines whether Design Acceptance is to be conducted under a routine process followed by the aircraft CI manager and controlled by the aircraft DAR, or whether the design requires additional oversight by the TAR and the Airworthiness Board, leading to the issue of either a Supplemental Type Certificate (STC) or a new or amended Malaysian State Type Certificate (MSTC). 12. The basic criteria for classification of a design change are listed at Regulation 2.5.3. The distinction between major and minor may be difficult to define. Conceptually, only the TAR may classify a design. The TAR recognizes that the vast majority of changes to an aircrafts Type Design are minor, and therefore allows the DAR to assume all changes to the Type Design are minor unless they fit the criteria at Regulation 2.5.3. This does not necessarily mean the design will be classified as major, rather that the classification is not clear and requires a determination from the TAR. www.dgta.gov.my 3.7 - 3 of 16 TERHAD

UNCONTROLLED IF PRINTED TERHAD

PU 2103

13. Note that the classification of a design as major or minor is not restricted to its level of technical risk. It is possible for very simple designs to be classified as major and require the full rigour of an STC if the OAR considers the operational implications of that design are of sufficient importance. In fact, it is possible that an STC could be raised and granted in the event of a role change to an aircraft that did not require any changes to the Type Design. Specification 14. All designs, irrespective of classification, require a specification. The specification forms part of the SAO Statement of Requirement (SOR). A specification for design represents a complete and technically rigorous statement of the required design outcomes. The design agency should be able to meet the specification with an acceptable level of technical risk, and it must be possible to verify that the specification has been met. The nature of the specification will depend on the classification of the design. Regulation 2.2.4 contains the specification requirements for major changes to the Type Design, while Regulation 2.5.7 is applicable for minor changes. DESIGN ACCEPTANCE FOR NEW AIRCRAFT AND MAJOR CHANGES TO A TYPE DESIGN 15. Design Acceptance for new aircraft or major changes to a Type Design is covered under Regulation 2.2, Type Certification. Designs of this classification require Type Certification (either an STC, new or amended MSTC) and Service Release, and are generally typified by their large size, duration, and complexity of design activity. Ideally, the DAR performs one act of Design Acceptance certification for the entire design, usually just prior to the application for Type Certification and therefore review by the Airworthiness Board. The certification is based on (usually) large quantities of review and verification activities (generally called compliance finding activities) of each and every facet of the design. Put another way, the DARs single Design Acceptance certification may cover many Design Approval certificates issued by the design agency. Relationship between Design Acceptance and Type Certification 16. There is often considerable confusion over the relationship between Design Acceptance and Type Certification, with the two often being considered either interchangeable, or alternatively one being a subset of the other. In fact, neither is strictly correct, and it is important to understand the relationship between Design Acceptance and Type Certification in the context of the regulations for new aircraft or major changes to Type Design. 17. Design Acceptance is a process that applies to all technical equipment, regardless of the direct impact upon airworthiness. For aircraft and aircraft-related equipment, the determination of technical acceptability of equipment design for Service use applies to more than just airworthiness aspects. The specification for a new aircraft or major change to Type Design will cover many required design outcomes that relate to mission performance or useability, and the Design Acceptance process addresses these. Regulation 2 mandates minimum requirements for Design Acceptance for aircraft and aircraft-related equipment, to ensure adequate assurance of equipment technical integrity.The Design Acceptance process for a new aircraft or major change to Type Design consists of the following steps: a. Compilation of the SAO SOR (Regulation 2.2.4), including the prescription of relevant airworthiness standards for the design activity (2.2.5) and reference to the Statement of Operating Intent (SOI) (2.2.6); b. Compilation of the Design Acceptance strategy (Annex A to Regulation 2), including any applicable planned recognition of prior acceptance (2.2.7); c. Obtaining TAR endorsement of the SAO SOR (2.2.4); and www.dgta.gov.my 3.7 - 4 of 16 TERHAD

UNCONTROLLED IF PRINTED TERHAD d. Issue of the Design Acceptance certificate by the DAR (2.2.3).

PU 2103

18. Type Certification is applied to aircraft only, and represents an additional level of oversight to provide assurance that the Type Design is airworthy. Within the Type Certification process the Type Design conformance with those specifications and standards related to airworthiness are subject to direct oversight by firstly the TAR and OAA, and subject to an independent review by an Airworthiness Board. This additional level of review ensures that the suitability for flight of the Type Design is judged with an appropriate level of rigour. Regulation 2 mandates the minimum requirements for the TAR to be able to make a Type Certification recommendation. The Type Certification process is described more fully in SAO Airworthiness Manual. 19. Note that a Design Acceptance certificate is just one of the requirements for a TAR recommendation for issue of a Type Certificate (STC or MSTC) (2.2.2) and Service Release (2.4). SAO Statement of Requirement (SOR) 20. The SAO Statement of Requirement (SOR) typically comprises the contract Statement of Work (SOW) and Specification. Department of Engineering (DoE) at every SAOs will provide guidance on drafting these documents. The SOW and Specification constitute the complete set of design requirements that the Design Acceptance strategy must address. 21. From an airworthiness regulatory perspective, the TAR requires that the SOR: a. has been developed in accordance with the Design Acceptance strategy;

b. contains appropriate design standards to assure the safe operation of the air vehicle; c. identifies the agency (AEO, third party or SAO COE) responsible for the conduct of the design verification activities to support Type Certification; and d. ensures that the data necessary to show compliance against the design requirements is made available by the design agency to support the Design Acceptance strategy. 22. Technology Advice from DGTA. DGTA staffs are able to assist Project Offices to assure that appropriate airworthiness design requirements are included in SORs. Project Offices should liaise with DGTA seeking this assistance to assure that relevant airworthiness requirements are included as early as possible in the development of the SOR. This assistance constitutes technology advice. 23. Regulatory Review by DGTA. DGTA staffs have the dual responsibilities of providing technology advice and assuring SORs satisfy the SAO airworthiness regulatory framework. The regulatory role involves assessing the complete SOR from an airworthiness perspective. In order for DGTA staff to assess the adequacy of the SOR it needs to be supported by an appropriate Design Acceptance strategy and Statement of Operating Intent (SOI). These documents provide the framework within which the SOR can be assessed for adequacy against regulatory requirements. Airworthiness Design Requirements 24. Airworthiness Design Requirements Manual Section 1 Chapter 1 provides a comprehensive explanation of the application of appropriate airworthiness design requirements for new aircraft and major design changes to existing platforms. Section 2 provides guidance on the design standards to be applied to SAO aerospace projects. www.dgta.gov.my 3.7 - 5 of 16 TERHAD

UNCONTROLLED IF PRINTED TERHAD Design Acceptance Strategy

PU 2103

25. For a new aircraft or a major change to the Type Design, the TAR requires a documented Design Acceptance strategy. The Design Acceptance strategy provides the TAR with evidence that all Design Acceptance activities have been considered, planned, and allocated. The equivalent Design Acceptance strategy for a minor change is the design development plan. 26. The TAR requirements for a Design Acceptance strategy are shown in Regulation 2 Annex A. An example of a completed Design Acceptance strategy is provided at Annex A to this chapter. For major acquisition activities, DoE procedures provide guidance on drafting a Project Design Acceptance Strategy (PDAS), which is a document intended to meet the regulatory requirements of a Design Acceptance strategy as well as acquisition specific requirements. Type Design and Type Record 27. A type record is a summary document that defines the aircraft Type Design at the time of acceptance by the Malaysia, by providing an index (including issue status) of all Type Design data. Design Approval Certificates 28. Regulation 2 requires that the design agency (or agencies) have submitted Design Approval certificates before the DAR can issue a Design Acceptance certificate. This aspect is very important, as it represents one of the four principles upon which Design Acceptance is based. By providing a Design Approval certificate (or certificates), the design agency formally documents compliance of the design to the specified requirements and design standards. Recognition of Prior Acceptance 29. Frequently, a Design Acceptance strategy relies on a certain level of prior acceptance and/or certification by another airworthiness body. Aircraft OEMs are increasingly turning to civil airworthiness standards (such as FAR 25) to either reduce costs, increase potential applications for their aircraft (ie civil as well as military roles), or because of the withdrawal of many US military standards. Regulation 2.2.7 prescribes the TARs minimum requirements where recognition of prior acceptance is proposed as part of the Design Acceptance strategy. 30. The TAR will not necessarily recognise acceptance or Type Certification from any airworthiness organisation. Only the National Airworthiness Authorities (NAAs) or military airworthiness bodies of the countries listed at Regulation 2.2.7 have been reviewed and assessed by the TAR to allow for automatic acceptance. 31. In the event that recognition of prior acceptance is proposed, this should form part of the SAO SOR. Regulation 2.2.4 requires, at the time of the TARs endorsement of the SAO SOR, submission of the documents listed at Regulation 2.2.7.b concerning recognition of prior acceptance. The DAR must submit both the data necessary to compile a Type Record (of the aircraft type that has been previously accepted), as well as evidence of access to the Type Design data of the type previously accepted. 32. Note that the evidence of prior acceptance must be relevant to the SAO configuration, role, and environment. It is further possible that recognition of prior acceptance will be proposed for only part of the Type Design of the aircraft being acquired. For example, the Design Acceptance strategy for a C130 H based Air to Air Refuelling aircraft may seek recognition of prior acceptance for the certification under FAR 25 of the basic C-130H military transport aircraft. Since the basic aircrafts configuration, role and www.dgta.gov.my 3.7 - 6 of 16 TERHAD

UNCONTROLLED IF PRINTED TERHAD

PU 2103

environment are not compatible with the State aircraft, the DAR would also need to propose how the differences, including refuelling system modifications, are to be accepted. These differences may further be based on USAF acceptance of a similar aircraft (as an example). Alternately, if the configuration, role or environment is unique to the SAO, greater in-house verification effort may be required. 33. Note that the TAR may assess any NAA or military airworthiness body not listed at Regulation 2.2.7 to determine if their systems and procedures provide for an equivalent level of safety. These organisations would generally require a physical inspection and audit by TAR staff of the procedures and systems used. Further, this regulation also covers aircraft procured by non-listed countries under a Foreign Military Sales (FMS) agreement with the United Kingdom or the United States of America. In this case, the TAR would accept the prior acceptance conducted by the military airworthiness bodies of the UK and USA before their delivery to the non-listed country. Compliance Findings 34. A compliance finding is the assessment that a design meets a specified design requirement, generally referred to as design verification. Compliance findings can be made by a number of agencies, not necessarily the Malaysia. As such, the design agency, an Independent Verification and Validation (IV&V) agency, an NAA or some other agency deemed acceptable by the DAR can make compliance findings. The Design Acceptance strategy is to detail the agency or agencies responsible for compliance finding, however the Malaysia retains the responsibility for assessing the adequacy of compliance findings (ie a compliance finding review). 35. Compliance Finding Review. A compliance finding review is where the Malaysia assesses that a Certification Basis item has been adequately addressed. This means that: a. the item has been adequately verified by the verification agency;

b. the configuration, role and environment (CRE) verified relates to the RMAF CRE; and c. any open issues have been flagged.

36. The assessment is a judgement made by a competent Malaysian member on the acceptability of the compliance finding activity. Further, it may be assisted by independent third party reporting.

Issue of a Design Acceptance Certificate 37. The actions required of a DAR prior to issue of a Design Acceptance certificate are listed at Regulation 2.2.3. In particular, the following requirements should be noted: a. SAO SOR. The TAR must previously have endorsed the SAO SOR. Any subsequent changes to the SOR must have been approved by the DAR, a relevant ASR, or the TAR, depending on their impact on safety. This regulation is intended to allow the DAR to make minor changes, however any changes that may impact airworthiness standards or safety should be referred to either a relevant ASR, or the TAR. b. Authorised Engineering Organisation (AEO). Note that unlike design changes classified as minor, there is no latitude given for certification of the design agency as an AEO. www.dgta.gov.my 3.7 - 7 of 16 TERHAD

UNCONTROLLED IF PRINTED TERHAD

PU 2103

c. Requirements upon design agency. Regulation 2.2.3.a(5) details specific items that the design agency or agencies must have provided before a Design Acceptance certificate can be issued, including a Type Record and Design Approval certificates. Special Flight Permits 38. Special Flight Permits are also explained in Section 3 Chapter 14. A Special Flight Permit is required to cover operation of an aircraft prior to issue of an MSTC, or operation of a modified aircraft prior to issue of an STC. The requirements for an SFP are streamlined compared with those for Type Certification. In particular, the following should be noted: a. DAR Certification. It is unlikely that all activities required prior to the issue of a Design Acceptance certificate will have been completed at the stage of application for a SFP. Indeed, it is possible that the aircraft operations requested under the SFP are necessary in order to close off the Design Acceptance process. The regulation therefore does not require a Design Acceptance certificate to accompany the SFP application. The regulation does require that the DAR has certified that Design Acceptance activities have been completed as far as possible, for the stage of the designs development and the scope of operations requested at the time of the SFP application. This requirement is intended to balance practicalities with constraining the risk of operations under an SFP as far as possible. b. Summary of Achievements. Similarly, the regulation requires that a document is raised that summarises the achievements made against the Design Acceptance strategy. This document is not necessarily the Accomplishment Summary compiled for an Airworthiness Board, however it may be used to meet the requirements of this regulation. It should be referenced by the DARs certification described in subparagraph a since it describes to what stage Design Acceptance activities have been completed. c. Documenting the Type Design. Since the Type Record may not be complete at the time of SFP, the regulation requires only a document that describes the Type Design at the time of the SFP. It may be in the form of a draft Type Record, as an example. Service Release 39. While Type Certification is focused essentially on the Type Design, Service Release is intended to address all other pertinent technical airworthiness issues once the aircraft is operational. It also provides assurance that various appointments, organisations, and management systems are in place for the in-service support of the aircraft (as opposed to its acquisition). Note that the requirements extend to maintenance as well as engineering. A Design Acceptance certificate is required for Service Release. For further information refer to Section 3 Chapter 14. 40. Certificates of Airworthiness (CofAs). Service Release also requires a system for the issue of Certificates of Airworthiness to successive aircraft produced following the first of the type. Requirements for the issue of Certificates of Airworthiness are covered at Regulation 2.6.3. This regulation does not apply retrospectively to all State aircraft, rather CofAs are to be issued for all new State aircraft requiring a MSTC, and any State aircraft undergoing modification requiring a STC or amended MSTC. In the latter case, the CofA certifies conformance of the aircraft with the updated Type Design covered by the STC, as well as the remaining (unchanged) aspects of the aircraft against the overall Type Design, to the extent that the available data allows.

www.dgta.gov.my

3.7 - 8 of 16 TERHAD

UNCONTROLLED IF PRINTED TERHAD

PU 2103

DESIGN ACCEPTANCE FOR MINOR CHANGES TO THE TYPE DESIGN 41. Design Acceptance for minor changes to the Type Design is covered under Regulation 2.5.6. Designs of this classification are generally typified by their relatively short duration and greater frequency. This is because the AEO performing CI management of the in-service aircraft is frequently required to process design changes to either incrementally improve the capability, or to maintain the current capability. Design changes may become necessary due to items becoming unsupportable, superseded, or to correct manufacturing defects or general wear and tear as a result of operations. Designs may originate from within the DARs own AEO, or from commercial AEOs or other members of the DSN. A significant portion of the DARs workload is generally devoted to supervising the Design Acceptance process, or performing Design Acceptance certification, on these types of designs. 42. Regulation 2.5.2 requires the DAR to establish a Design Acceptance system. This system should comprise a collection of procedures which prescribe how designs are to be specified, design agencies assessed for competency, designs are to be verified as meeting the SAOs requirements and receive Design Approval by the relevant design agency. The AEO that provides support to the DAR is required to develop Design Acceptance procedures, in accordance with Regulation 3.4.6. The following paragraphs describe the requirements for a Design Acceptance system in further detail. Closing the Design Acceptance Process 43. The regulations covering the Design Acceptance process for minor changes to Type Design are subtly different to those for new aircraft and major changes. Nevertheless, these subtle differences are important to understand as they introduce a degree of added flexibility to the process. The Design Acceptance process for minor changes to Type Design is more easily understood by starting with how the process is concluded, and therefore tracing the actions required prior to this step in reverse order back to the start of the process. Further, the application of the intermediate steps is dependent to some extent on how the Design Acceptance process is to be closed off. The regulations allow two ways of closing off the Design Acceptance process for minor changes to Type Design, through either: a. the issue of a Design Acceptance certificate by the DAR (Regulation 2.5.6); or

b. the assumption of Design Acceptance by either the design agency or a member of the DARs staff (Regulation 2.5.9). 44. Design Acceptance Certification. The first method is the simplest method to imagine and implement. It requires the DAR to sign a certificate signifying that the criteria for Design Acceptance under Regulation 2.5.6 have been met. This process does not require the DAR to personally review all the design decisions, calculations and design outputs. Rather, the Design Acceptance certificate is the method by which the DAR certifies that Design Acceptance functions have been conducted within a compliant Design Acceptance system, that addresses the requirements of Regulation 2.5.6. Whilst this method of closure is effective, it can place an unreasonable workload upon the DAR, depending on the number of designs requiring Design Acceptance certification. Ultimately this could impact upon the airworthiness of the aircraft as important design changes are held up awaiting the DARs personal certification. 45. Assumption of Design Acceptance. This method avoids specific DAR certification for each individual change for certain groups of designs. Previous issues of the TAMM allowed the DAR to delegate Design Acceptance for non-significant designs. Since Design Acceptance represented corporate governance on the part of the Malaysia, it was not possible to delegate to anyone other than a Malaysian employee, and hence could not be applied to a commercial AEO. Further, Design Acceptance is more a process that an act, www.dgta.gov.my 3.7 - 9 of 16 TERHAD

UNCONTROLLED IF PRINTED TERHAD

PU 2103

and naturally many people throughout the design change process, from the development of the original specification, through to final sign-off by the DAR, are actually conducting Design Acceptance activities. The DAR controls the overall Design Acceptance process, and under the regulations is the only person who can issue the Design Acceptance certificate. It is this final act that cannot be delegated. (The numerous Design Acceptance activities that have led to that final certification do not require delegation they represent integral components of the Design Acceptance process). 46. Assumption of Design Acceptance enables the DAR to allow an external AEO or individuals within the DARs AEO to assume that the DAR would issue a Design Acceptance certificate, for certain classes of design and under specified conditions. Note that the designs significance is not a factor. The DAR must document the arrangement through an approved procedure (for the DARs AEO staff), or through a formal agreement (for an external AEO), such as a contract or Memorandum of Agreement or Understanding. Specific conditions listed within Regulation 2.5.9 are highlighted as follows: a. The procedures or agreement must reference the interface, airworthiness and other performance requirements to be maintained; b. The design changes or classes of design change applicable (eg all hydraulic systems, substitutions only); c. The method of recording of the assumption of Design Acceptance certification shall: (1). include certification that the conditions for Design Acceptance have been satisfied, (2). require that the person recording is at least authorised to certify Design Approval for the design,and (3). reference the agreement or procedure that allows for the Assumption of Design Acceptance. d. Commercial AEOs must: (1). make all records available for the DARs review (minimum 10% no less than once per year); and (2). be monitored for their performance under the assumption of Design Acceptance agreement, and have that authorisation revoked if performance is less than adequate. 47. There are some decisions which cannot be expedited and which will require individual endorsement by the DAR (and perhaps the TAR) prior to their incorporation irrespective of the application of the Design Acceptance process (Regulation 2.5.9.c). These include those designs: a. introducing a new (or markedly enhanced) capability (since the existing specification will not be relevant, this effectively means designs classified as major); b. resulting in a reduction (or suspected reduction) in safety standards, or mission capability (the TAR recognises that this requires the exercise of considerable judgement); c. requiring changes in the technical interface with other systems and human/machine interfaces; and d. involving rejection of mandatory or safety related OEM advice. www.dgta.gov.my 3.7 - 10 of 16 TERHAD

UNCONTROLLED IF PRINTED TERHAD

PU 2103

48. It must be noted that the above restrictions represent the TARs minimum level of constraint that will be imposed on design agencies. DARs are not necessarily expected to permit all design agencies this level of autonomy and may wish to add further restrictions based on the: a. b. c. d. e. Specification 49. Regulation 2.5.6 requires that a Design Acceptance certificate is only issued for a design if the DAR is satisfied that the design complies with the relevant SAO Statement of Requirement (SOR) and airworthiness standards. The DAR is to approve all SAO SORs for minor design changes, while an SDE may be authorised to approve SAO SORs within the scope of an assumption of Design Acceptance agreement. These regulations contribute to satisfy the first of the four principal elements of the Design Acceptance process identified at paragraph 5, ie. The design must satisfy a specification that states all the Malaysias requirements, is verifiable and attainable. 50. Design changes under an SAO SOR (via the specification) should ensure the original basis for certification is not compromised, and that the new work either complies with the original airworthiness requirements, or with equally comprehensive updates requirements. Regulation 2.5.7a describes the SAO SOR requirements for minor changes that conform to the existing aircraft specification. Regulation 2.5.7.c describes the requirement to seek TAR endorsement (by submission of the listed documents) for instances when the SAO SOR for a minor change does not conform to the existing aircraft specification. 51. What Constitutes a Specification? A specification is a complete and technically rigorous statement of a design outcome. Many designs, such as minor structural repairs or technical substitutions, would appear to have no distinct specification. Rather, their only requirement is that they restore or maintain whatever integrity or performance the original structure or component possessed. Another common problem is that often service bulletins and other Technical Information (TI), which recommend a design change, dont contain any of the rationale or requirements for the design (ie no specification). 52. In these cases, the AEO could overcome the difficulty of raising a specification for each and every design change by instituting procedures to ensure the essential elements of the SOR regulation are satisfied. For example, an AEO could have a generic procedure for substitutions which contains the specification for substitutions. One requirement might be that all new components shall maintain the technical integrity and functionality of the component being replaced and would reference the appropriate high-level specifications. Such a procedure, if approved by the DAR, would satisfy the regulations. Alternatively, the record created from evaluation of the TI after registration can act as the specification for any design change contained in that TI. The evaluation of any TI requires a judgement as to whether the TI is applicable and requires action. The record of these judgements form the basis of the specification of a design change. All that is required is a procedure to ensure the correct information is entered into the TI evaluation record and that the organisations procedures make it plain that the TI evaluation has this dual role. 53. When is the Specification approved? The regulations do not specify when the DAR must approve a specification during the Design Acceptance process. They simply www.dgta.gov.my 3.7 - 11 of 16 TERHAD confidence in performance; the quality of specification and design data available; depth of engineering expertise available; involvement of contractors or subcontractors (as applicable); and design change significance.

UNCONTROLLED IF PRINTED TERHAD

PU 2103

require that such approval must be given prior to the award of a Design Acceptance certificate. The obvious time to approve most specifications is prior to design development. Such a strategy minimises risk that the specification, and consequently the design, does not meet the SAOs requirements. However, there will be occasions where the specification will only be drafted after the design is developed. The example of the TI evaluation serving as an SAO specification referred to above is just one example. 54. The primary method by which design agency competency is determined is through certification as an AEO. Whereas this is an essential requirement for Design Acceptance certification for a new aircraft or major change, other options are available to the DAR for a minor change to Type Design. Should the design agency be not certified as an AEO, or if the AEO certification scope is not relevant to the design under consideration, then firstly the design must be applicable to the SAOs configuration, roles and environment. Further, the following criteria apply (Regulation 2.5.6): a. Recognition of prior acceptance. Using the same criteria under Regulation 2.2.7, the DAR may perform Design Acceptance certification for a design previously accepted by a recognised NAA or military airworthiness body. b. Other. In the absence of a relevant AEO certification, or prior acceptance, the following caveats apply: (1). The design must comply with airworthiness standards prescribed in the specification; (2). The design agency must be assessed by the DAR to be of acceptable quality and reliability (this should be already documented within the DSN); (3). The original end-user (customer) of the design must be known; and

(4). The design must be approved by either the relevant OEM, or an engineering organisation of acceptable quality (based on the DARs professional judgement). Verification 55. The DAR must verify that the design meets the SAOs requirements. The degree and amount of verification activity required varies for each design. Some designs require independent testing, desktop analysis of test reports, or a physical demonstration. It is not practical to verify each aspect of each minor design change to an aircraft throughout its life, nor is it in keeping with the quality management process approach to Design Acceptance. The regulations therefore do not impose a minimum level of verification activity. DARs are expected to identify the issues that are important to the maintenance of the technical integrity of the aircraft and ensure, via procedures in their Design Acceptance system, that these issues are verified using a satisfactory method. Certification 56. Design Approval certification by the design agency is that organisations assurance that the design complies with specification requirements. The requirements for Design Approval certification are covered at Regulation 3.4.3 and explained within Section 3 Chapter 6. Design Approval certification is the final of the four principal elements of Design Acceptance at paragraph 5. For minor changes to Type Design there can be many forms of document or TI that represent Design Approval certification from a design agency. For example an OEM service bulletin may fulfil this requirement, and it is therefore important for the TI and DSN processes of an AEO to disclose those items of TI that may be treated as an approved design, ie. include a Design Approval certification from the design agency. www.dgta.gov.my 3.7 - 12 of 16 TERHAD

UNCONTROLLED IF PRINTED TERHAD

PU 2103

DESIGN ACCEPTANCE FOR NON-AIRCRAFT TECHNICAL EQUIPMENT 57. Regulation 2 provides the TARs minimum requirements for the Design Acceptance of aircraft and aircraft related equipment. Hence, many of the specific requirements do not apply for Design Acceptance of non-aircraft technical equipment. In addition, non-aircraft technical equipment is not subject to a formal Type Certification process. Consequently, Design Acceptance for non-aircraft technical equipment can be greatly simplified. This section provides guidance from the TAR on the minimum requirements. 58. Non-aircraft technical equipment can take many forms, ranging from commercial-offthe-shelf computers hosting aircraft maintenance tools, through aircraft supporting GSE, to Air Traffic Control and Air Defence systems and ground based navigation aids. Some of the items used to support SAO aviation activities are required to conform with the technical regulatory framework of another environment Technical Regulatory Authority (TRA). For example, the Land TRA will manage aircraft refuelling vehicles. Other items will represent an integral component of an aircraft weapons system, for example aircraft type specific GSE, and yet are not required to be managed with the full rigour of the TAMM regulations. The TAR requires that the TAMM regulations be used as a management guide only for these systems, refer to Section 1 Chapter 5. The TAR does not wish to constrain the flexibility available to organisations for supporting non-aircraft technical equipment. Accordingly, the only constraints that the TAR mandates for non-aircraft technical equipment are detailed in the following are as follows: a. Specification. The Malaysia must approve a document (or suite of documents) that provide a suitable basis for Design Acceptance, in that the design requirements are sufficiently complete, verifiable and attainable. There is no requirement for TAR or TAR staff involvement in development or approval of the SOR. b. Competency. The design agency (or agencies) must be assessed as having, and must be judged to have applied, the necessary quality systems and competencies to complete the design development with acceptable levels of technical risk. The TAR has no requirement for design agencies to be accredited as AEOs. All that is required is for the Malaysia to have established a level of confidence in the organisation, with the level of review and audit dependent upon the complexity (and hence risk) of design activity. c. Verification. The TAR requires that there is adequate evidence that the design complies with the specification. Independent compliance finding activity may not be necessary, depending on the level of technical risk. d. Certification. The TAR requires that the design agency provides a certification attesting that the design meets the specification. Strict compliance with all of the Regulation 3.4 (Design Control) requirements is not mandatory. 59. No other TAR requirements for the Design Acceptance of non-aircraft technical equipment should be assumed or inferred. Annex: A. Example of a Design Acceptance Strategy

www.dgta.gov.my

3.7 - 13 of 16 TERHAD

UNCONTROLLED IF PRINTED TERHAD

PU 2103 Annex A to. Sect 3 Chap 7

EXAMPLE OF A DESIGN ACCEPTANCE STRATEGY

PROJECT AIR 5678 DODOL AVIONICS UPGRADE Introduction 1. This Design Acceptance strategy (DAS) is raised to document the strategy for Design Acceptance of PA5678 Dodol Avionics Upgrade project. This DAS is a living document, and a current and approved version will be submitted prior to: a. TAR endorsement of the PA5678 Dodol Avionics Upgrade SOR (ie Specification and Statement of Work); b. TAR recommendation for issue of a Special Flight Permit (SFP) to cover test flying requirements; and c. TAR recommendation for issue of a Supplementary Type Certificate (STC) covering the upgraded Dodol aircraft avionics configuration. 2. PA5678 Dodol Avionics Upgrade project aims to replace ageing and unreliable flight station avionics equipment. The project is based on the installation of equipment and systems common to civil commuter aircraft variants operating in the USA under FAA certification, with the exception of the avionics computer, which is sourced from the UK. 3. Design Change Classification. This DAS is required since the design change incorporating the upgraded avionics equipment is classified as a Major change to the Type Design in accordance with Regulation 2.5.3. The design change classification was agreed during a meeting between DGTA and project executives on 14 Feb 2000. Airworthiness Design Standards 4. The airworthiness design standards have been compiled in accordance with the Maritime Patrol Group Statement of Operating Intent (SOI) for the Dodol aircraft. Existing equipment and systems identified as unsupportable beyond 2005 were identified during the Dodol aircraft Weapon System Management Committee meeting in Jul 1999 based on analysis performed by MLU staff. 5. In accordance with Regulation 2.2.5, airworthiness design standards for the replacement equipment are largely based on FAR Part 25 Amendment H, including all current and relevant Advisory Circulars (ACs). The upgraded avionics computer complies with DEF STAN 00-55 and 00-56, which have been assessed by DGTA staff as approved alternate standards to FAR 25.1301 and 25.1309 and the objectives of RTCA/DO178B. 6. Airworthiness design standards are listed as part of the Certification Basis, within PA 5678 Dodol Avionics Upgrade Specification. In accordance with Regulation 2.2.4.c(3), the Air 5678 Project Office (PO) has engaged DGTA staff on a regular basis prior to release of the Air 5678 Request For Tender (RFT) in order to compile the project Specification. Further, the TAR endorsed the project SOR as per TUDM/2548/2/2/Tech Pt 6 (58) of 19 Jan 2000. 7. Recognition of Prior Acceptance. As described above, all equipment and systems to be fitted, with the exception of the avionics computer and interface software, are covered by an FAA issued STC for the aircraft type. Copies of the relevant FAA STCs issued may be found at Appendices 1 to 5 inclusive. Director of Engineering TUDM proposed to accept the FAA issued STCs as recognition of prior acceptance without performing any additional www.dgta.gov.my 3.7 - 14 of 16 TERHAD

UNCONTROLLED IF PRINTED TERHAD

PU 2103

compliance finding activities on the equipment covered under these STCs. This proposal formed part of the SOR that was endorsed by the TAR as indicated at paragraph 6 above. Design Agency Details 8. The overall design for the installation of the upgraded avionics equipment and systems will be subject to Design Review and Approval by Upgrades R Us Pty Ltd, 132 Lorimer St, Fishermans Bend VIC 3009. Upgrades R Us is certified to ISO9001:2000 and is certified as an Authorised Engineering Organisation (AEO) vide certificate DGTA069 for the design and installation of Dodol surveillance equipment under a separate contract. The Upgrades R Us Letter of Engineering Authority (LEA) has recently been extended in scope to cover the flight station avionics equipment covered by this DAS. 9. Upgrades R Us intend to involve one subcontractor, Fatal Exception Software Pty Ltd, in software development activity required for the integration of the avionics computer. Design Acceptance System Description 10. Engineering Authority. The Senior Design Engineer (SDE) of Upgrades R Us, Mr. B. Modworld, has assigned Engineering Authority (EA) to competent Design Engineers (DEs) within his organisation to undertake Design Approval activities. The design is to receive Design Approval by Mr. Ahmad Jedad and then forwarded to Mejar Ariff Chong DSDE AV project office, who will perform Design Acceptance Review in accordance with Bhg Kejuruteraan TUDM PU-2xxx before passing to KSS MLU for Design Acceptance certification. 11. Compliance Finding Agencies. Compliance finding agencies are authorised to perform the following elements of the compliance finding activity: a. FAA compliance findings with respect to STCs at Appendices 1 to 5 (retrospective); b. Mr. Sandy Springfield of Software Certification Services Inc. (delegated DER by the FAA) with respect to avionics computer software designed and developed by Fatal Exception Software (under contract and on behalf of the Malaysia); c. d. SSR I DU with respect to flight testing aspects; and DGTA with respect to Electromagnetic Environmental Effects (E3).

12. Compliance finding agencies will undertake compliance finding activities in accordance with Regulation 2.2.11. In particular, compliance finding agencies will ensure that the data being used for compliance finding activities is applicable and current. 13. Certification Basis. The Certification Basis resides within the PA 5678 Dodol Avionics Upgrade Specification, and is the responsibility of DSDE AV PO to maintain and update in accordance with State Airworthiness Management. (If the CBD is to be managed as a stand alone document then it must be adequately referenced at this point.) 14. Compliance Assurance. XXMaPO are the Sponsor AEO for Upgrades R Us under a separate contract for support of the M-XX Rus fighter aircraft. MLU has a Memorandum of Agreement (MOA) XXMaPO/4078/25/10/Tech Pt 4 (57) of 25 Apr 2006 that addresses MLU participation in surveillance and auditing activities for Upgrades R Us. Upgrades R Us was last subject to a full compliance audit in Jan 2007 with 3 CARs raised and a satisfactory overall result. 15. Amendments to SOR. There have been no significant amendments to the SOR as at the date of this latest version of the DAS. Any future significant amendments to either www.dgta.gov.my 3.7 - 15 of 16 TERHAD

UNCONTROLLED IF PRINTED TERHAD

PU 2103

document are to be submitted to the TAR for endorsement. Any minor amendments will receive approval by the KSS MLU. 16. Review of SOI. There have been no significant amendments made to the DODOL SOI by Maritime Patrol Group. KSS MLU as a member of the Maritime Weapon System Management Committee will be involved with any future changes to the SOI. 17. Special Flight Permit (SFP). This DAS relies on a programme of flight testing activity to be conducted by No 1 DU to verify that the upgraded avionics configuration meets the performance and functional requirements of the Specification. SDE AV PO will coordinate the CAESE submission to the TAR recommending the issue of a SFP covering this activity based on submission of the following documents: a. Certification by the KSS MLU that Design Acceptance activities have been completed as far as practicable at the time that the SFP is sought; b. c. d. A draft Type Record supplement provided by Upgrades R Us; A current version of this DAS; Evidence of accomplishments made against the DAS;

e. The proposed SFP in draft format, limited to the flight test envelope recommended by CAESE as suitable for the test flying activity; f. Certification from Mr. Ahmad Jedad at Upgrades R Us (as per the contract) of the following: (1). An interim Design Approval certificate has been provided for the design in its current state; (2). temporary maintenance and logistics support is ready to support the test flying activity; and (3). sufficient personnel have been assigned EA to support on-going airworthiness and safety of flight evaluation during the test flying activity. 18. Issue of a Design Acceptance certificate. At the completion of all compliance finding activities, as well as the successful resolution of any issues arising from the compliance finding activities, KSS MLU will issue a Design Acceptance certificate in accordance with BBSPO SI(LOG) 2-12. Appendices: 1. FAA STC ST01234SC Rockwell Collins AN/ARC210 Radio System 2. FAA STC ST56789SE Honeywell GBU24 Combined GPS/INS Navigation System 3. FAA STC ST09876SE Sony CRT450E Digital Flight Instrument Display System 4. FAA STC ST54321SW Telstra AUS6666 Interphone Communication System (ICS) 5. FAA STC ST22334SC Antanov RK-8713 Digital Flight Control System

www.dgta.gov.my

3.7 - 16 of 16 TERHAD