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TECHNICAL AIRWORTHINESS MANAGEMENT MANUAL
SECTION 1 LEAFLET 4

THE APPLICATION OF THE REGULATIONS TO DESIGNS NOT AFFECTING TECHNICAL AIRWORTHINESS
INTRODUCTION 1. As part of the TAR’s responsibilities, DGTA on behalf of TAA is required to put in place a regulatory framework for all engineering activities pertaining to aircraft related equipment. This related equipment includes such diverse elements as Ground Support Equipment, aircraft simulators, software development environments, air defence radars and air traffic control equipment. 2. Rather than develop a separate regulatory framework for designs not affecting airworthiness, DGTA has directed that all such designs will comply with the intent of the regulations promulgated by this manual. It is recognised, however, that many of the regulations in Section 2 are aircraft and airworthiness-specific, and therefore need reinterpretation if they are to apply to other classes of design, and relaxation where they may be overly prescriptive. PURPOSE 3. The purpose of this chapter is to provide direction as to how the regulations are to be applied to designs and design changes of, or affecting, State equipment but not necessarily impacting upon technical airworthiness. SCOPE 4. This Instruction applies to all organisations responsible for the conduct and/or management of engineering applied to State aircraft and aircraft related equipment. DEFINITIONS 5. There are no unique definitions applicable to this chapter. CLASSES OF DESIGN 6. For organisations managing the design of aircraft, compliance with the regulations is clear; however, the situation is less clear for organisations managing the design of other technical equipment. To resolve this difficulty, the regulatory framework currently identifies the following two fundamental issues. 7. The Equipment to be designed/modified. This has been defined as comprising three broad groups of equipment: a. on-aircraft items, 1.4 - 1 of 5 TERHAD Rev 1 July 2013

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Note, the interface referred to can be either a physical interface (like support equipment) or a functional interface (such as SPKB, simulators and ATC/ADC equipment).

8. The Effect of the Design/Modification. This has been defined as comprising three broad groups of design: a. b. c. designs affecting airworthiness, designs affecting air or personnel safety, and designs affecting capability or efficiency.

9. Each organisation performing design activities on behalf of the State must consider the classes of design decision they will be making and create their Engineering Management System accordingly. A possible matrix of equipment and design effects is shown at Table 5– 1. Note; this matrix is intended only to give a very rough overview of how some decisions on some equipment may be classified and that often the same equipment may appear in several classes. For example, some designs for role equipment could affect the airworthiness of an aircraft (such as internal fuel bladders carried in cargo areas). On the other hand, other designs will have no impact upon airworthiness, or even capability, and merely provide an efficiency gain for the SAO (such as redesign of a stretcher to ease its use inside aircraft). Table 5–1 Example of the Classification of Design Activities
On-Aircraft items Technical Airworthiness Engine, airframe, avionics, flight control, maximum lives, damage tolerances, some role equipment (fuel bladders etc), fuels/lubricants and most stores. Most changes to life support equipment, ejection seats, some role equipment (parachutes), most stores, cargo, passengers Most changes to radar, ESM, FLIR, EW, etc and some role equipment, stores, cargo, passengers. Off-aircraft – with interface Some GSE, ATE and mission planners etc that effect the operation of the aircraft in flight. Some groundbased IT systems. Most GSE, ATC radars, ILS beacons etc. Flight training simulators. Off-aircraft – no interface Not Applicable

Safety

Anything that goes fast, uses high powers or contains nasty chemicals etc. Ground-based communications and IT systems, especially those for command and control purposes

Capability and efficiency

Most air defence systems and data communications. Some ground-based IT systems.

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A complete description of each of the design classifications is contained at Annex A.

Use of Professional Judgement in Classifying Designs 11. The classification of a design is not a straightforward application of a series of clearly defined steps in a flowchart. Ultimately, the classification of a design (or a collection of designs) is an exercise in professional judgement by an engineer. Given the virtually unlimited number of scenarios for design in the aviation field, it is not possible for DGTA to make these judgements in advance. Thus, the initial classification in most cases will be made by engineers in the relevant design agencies. DGTA requires that design agencies document both the classification of their design activities and the rationale for that classification in their application for Engineering Authority. APPLICATION OF REGULATIONS TO CLASSES OF DESIGNS 12. Having determined the classes of design likely to be made in an organisation it is then necessary to determine how the Section 2 regulations will apply to that organisation. In tailoring the regulations organisations performing design on behalf of the SAOs are to conform to the application guide included in Table 5–2. Table 5–2 Determining the Application of the Regulations to Design Activities On-Aircraft Off-aircraft – with interface Some Tailoring (Annex B) Some Tailoring (Annex B) Management Guide (Annex C) Off-aircraft – no interface N/A

Technical Airworthiness Safety

Full

Full

Management Guide (Annex C) Management Guide (Annex C)

Capability

Some Tailoring (Annex B)

Core Regulatory Concepts to Be Applied In All Design Classes 13. Irrespective of the guidance provided at the relevant annexes there are a limited number of concepts embodied by the regulations that apply to all classes of design. These are listed below. 14. The Classification of A Design Is an Airworthiness Decision. To use Table 5–2 to determine the applicability of the regulations, an organisation must classify the design activities it performs. It must be recognized that this classification of a design is itself an airworthiness decision. In most cases this decision will only need to be made once, with the classification (and rationale for that classification) of routine design activities being recorded in the organisation’s EMP. www.dgta.gov.my 1.4 - 3 of 5 TERHAD Rev 1 July 2013

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15. All Organisations performing design activities must apply for and be granted Authority. DGTA requires that all organisations apply for, and receive Engineering Authority prior to undertaking any engineering activities with respect to State aircraft or related equipment. The scope and level of Engineering Authority, and the method by which it is provided, is based upon an assessment of the applicant's anticipated scope and level of engineering activities and the equipment upon which they will be conducted. Similarly, the level of compliance assurance for organisations will vary considerably depending on the classification of engineering decisions routinely made by the organisation. For example, organisations seeking to make airworthiness decisions on State aircraft would probably be certified as an AEO and be subject to a rigorous compliance assurance program, including external audits. Conversely, organisations performing design aimed at increasing the efficiency of logistics management software may be awarded EA via a minute from the TAR, based on a brief desktop audit of their documentation, and may not be subject to any compliance assurance program at all. 16. The four key pillars of design (development, review, approval and acceptance) apply to all designs, no matter how simple. It is self evident that all designs must be developed, however the latter steps are equally essential. All designs must be subject to independent review. All designs must be approved, i.e. all designs must be certified by the relevant design agency as satisfying the specification. Finally, all designs must be subject to a Design Acceptance process to ensure that the design is applicable to the SAO’s requirements and suitable for use. The qualifications and experience of the people involved in these processes and the rigour applied to each will vary considerably, but each of these processes will exist, in some form, for all designs undertaken with respect to State aircraft and related equipment. 17. The design reviewer must always be independent from the developer. No matter how simple (replacement of O-ring xyz with O-ring xyz-1) or complex (an AEW&C weapon system) a design may be, all design outputs comprising that design shall be subject to independent review. 18. The design agency must hold a third party ISO 9001 quality certification or equivalent. It is a general requirement that organisations seeking to contract with the Government are required to possess a third party certified quality system. DJTA has determined that this requirement will be included in the core requirements of any organisation (contractor or Service) seeking to undertake design for the SAO as this provides an assurance that the numerous administrative processes such as record keeping, documentation control etc will be adequately documented and properly functioning. Organisations Making Decisions in Multiple Classes 19. Many (possibly most) organisations will be required to perform design activities in a number of the classes identified above. Organisations making decisions in multiple classes are only required to demonstrate the necessary compliance with the regulations as applicable to each decision class. However, in order to minimise the risk of more critical designs being treated inappropriately, and for the sake of efficiency and standardisation, DGTA expects that such organisations will establish a single compliant management system for all activities and equipment types, rather than attempting to manage some designs by exception. Note, whilst DGTA does not direct that organisations have a single EMS accommodating the most rigorous design activities undertaken by the organisation, DGTA must be certain that where an organisation seeks to establish parallel systems that there is very little risk of designs being handled inappropriately. www.dgta.gov.my 1.4 - 4 of 5 Rev 1 TERHAD July 2013

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20. There will be cases where an organisation will deal with more critical designs very rarely or where the more (or less) critical designs are easily separated from the remainder. Under these circumstances, the organisation may seek to establish multiple systems for dealing with the exemptions. Examples of where this may be done include: 21. A unit managing EW software and performing a range of design tasks falling into a number of classes would normally have a single management system compliant for all of these designs. However, that organisation may elect to establish a second, less rigorous, system to deal with very minor design changes implemented on deployments away from the home base. 22. A unit managing support equipment may be able to separate those items with airworthiness implications from those without and restructure their organisation such that this division is clearly supported by the organisational structure. In such a case it may be viable for the organisation to impose different engineering management systems tailored to each type of design. Annexes: A. B. C. Classification of Designs. Some Tailoring of Regulations. Use of the Regulations as a Management Guide.

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