Sounds like bad news for New Part 23
Performance is still the measure
The AinOnline headline may have caused irregular heartbeats among the certification mavens at the FAA, GAMA and US aerospace executives/engineers. The world, including EASA, spent massive amounts of time and regulatory chips to agree to a performance-based standard for Pat 23 aircraft. Moving from the old prescriptive, check list approach to this new regime “loosened” (in a positive sense) the process by minimizing ill-fitting criteria and establishing more relevant criteria.
The headline references Product Certification being tightened; specifically the 1st sentence further states “[p]ossible safety risks linked to “too much room” for interpretation of the EASA Part 21 product and parts certification regulation.” [BREAK OUT THE AED.]
Next sentence terminates the state-of-emergency:
“It proposes to amend Part 21 to clarify that instructions for continued airworthiness (ICA) are part of the type certificate, and to develop the related acceptable means of compliance and guidance material. The NPA also merges the requirements related to record keeping, manuals, and ICA now in various subparts into a single requirement for each.”
NPA 2018-01 states in more careful, less shocking terms:
The objective of this Notice of Proposed Amendment (NPA) is to mitigate the risks linked to the uncertainty of the status of instructions for continued airworthiness (ICA) and therefore to avoid there being too much room for interpretation in the rules and standards, leading to differences and possible safety risks. This NPA proposes to amend Annex I (Part 21) of Regulation (EU) No 748/2012 to clarify that ICA are part of the type certificate (TC), and to develop the related acceptable means of compliance (AMC) and guidance material (GM). It also merges the requirements related to record keeping, manuals and ICA in the various subparts into a single requirement for each of these aspects in Subpart A (new points 21.A.5, 6 and 7). The proposed changes are expected to improve the harmonisation of ICA among the design approval holders (DAHs) in relation to the identification, approval, formatting and availability of ICA to the end users.
Headlines can be misleading and fortunately, the EASA press release lost something in the translation.
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