Certification – An Introduction for the Operator
When we launched the blog, we invited suggestions from, you the readership on future topics, we also sought to invite guest contributors with expertise outside the scope of Mackenzie Morgan’s knowledge. The article below on modification certification has been produced for us by Rowan Geddes of SpanAerospace Ltd, there is a biography, and contact details for Rowan at the end of the article.
The world of certification can be, well bewildering to say the least! In this article we will look briefly at certification from the end users point of view. We will avoid the nitty-gritty and have a quick overview of the process involved in adding equipment to the aircraft.
For all aircraft (and rotorcraft) in the UK and the EU, EASA is the certifying authority. They stipulate and enforce all aviation regulation for EU member states. The CAA is no longer the certifying authority for modifications repairs etc, unless it is a ‘state’ aircraft, for example police. They do however, represent EASA in the UK and act on their behalf to enforce the regulations.
So how does this affect you the operator who wants to modify or upgrade their aircraft? Well almost without fail, ANYTHING you do to modify, change, upgrade or repair your aircraft will need to be certified in order to maintain your certificate of airworthiness. Installing factory approved changes is the easy way out. In EASA speak, modifications are referred to as changes, and repairs are, well repairs.
EASA, and their approved design offices, Part 21J design organisations, are the authority to certify these changes. The system is set up such that the easiest way is for you to follow the following procedure:
- Decide what it is you want to do to your aircraft, eg GNS 430 upgrade to a GNS 530W, a new interior, install an entertainment system;
- Approach a Part 21J Approved design organisation with your proposal and obtain a quote;
- The design organisation, find one via your maintainer is the best way, will then work with you to design the change, produce the mountain of paperwork required to certify the change, approve or obtain approval under their authority depending on the change classification and;
- Work with the installation organisation to install your change as per the approved design.
It is worth noting that there are two categories for modifications or changes in EASA speak, Major or Minor. From the end user point of view, the difference is in the cost and time taken to approve the change. Examples of major changes can include changes to instrument layouts, addition of antennas, cabin reconfigurations and installation of external equipment. Minor changes might be the GNS upgrade described above, simple repairs, addition of cabin trim, addition of a simple in-flight entertainment system, i-pod or mp3 player. The EASA website has lists of what constitutes a major or minor change. A minor change may take anything from a few days to weeks to approve. A major change will take up to 12 weeks or more to make it through the certification process. Plan your modification ahead, and don’t be afraid to ask for help or guidance. Most design organisations are willing to offer advice, and EASA and the CAA are full of people who are paid to do just that. Otherwise you can contact a certification expert who can help give you guidance on what the probable classification of your modification may be, and any potential pitfall you may want to keep an eye out for.
Within reason, almost anything can be done to modify your aircraft- usually the only limit is the depth of your pockets… Anything that plugs permanently into the aircraft’s electrical system will require a change. That new GPS unit you want to stick to the instrument panel – it will require an approved change to install it. Don’t invalidate your insurance – get the modification installed properly!
Next time we will look deeper into the regulations and start to understand where the costs are, and why it can take so long to get a change certified.
Till then, safe flying!
Rowan Geddes.
Rowan Geddes is a professional Aerospace engineer with more than 12 years experience in the industry across two hemispheres. Since relocating to the UK in 2007 and starting his own business, SpanAerospace Ltd, he has provided contract end-to-end design and certification support to high profile customers including the UK subsidiary of Europe’s leading helicopter manufacturer, and the design office of one of the UK’s leading charter, retrofit and maintenance companies. Working in Part 21J design offices, he has helped to certify dozens of Minor, and Major changes certified to either EASA or CAA requirements as required. This includes developing and conducting aerodynamic flight tests with EASA and the CAA to qualify external equipment for service and generate the relevant performance data for flight manual supplements. Rowan is currently working with several organizations to develop software aimed at simplifying the certification paperwork process for Part 21J Design Organisations.
rowan.geddes@spanaerospace.co.uk
