July 20, 2016

Denver, CO
Delegation and Organization Procedures Branch
AIR-160

General Session Presentation Printout

Section 508 Compliant

Section 508 requires that when federal agencies develop,

procure, maintain, or use electronic and information technology
(EIT), individuals with disabilities have access to and use of
information and data that is comparable to the access and use
by individuals without disabilities. For more information
visit: Section508.gov.

Use of the information provided in this document is for general reference only. This
document can be superseded at any time by the next revision or expiration of the
referenced information.

Renewal Requirements

FAA22000002 DER Recurrent General Session

FAA Order 8100.8D paragraph 803.g. states: "DERs must attend a recurrent seminar every 2 calendar
years to maintain their knowledge of the regulations and policies and as a condition for renewal. DERs
may satisfy the 2 year requirement by attending a DER seminar in the calendar year it is due.

Contact EDR Training

If you have any questions or comments concerning the content of this document, send an email to
the Engineering Designee Recurrent Training Branch.

For Program Information visit our website:

Engineering Designee Recurrent Training Information
Table of Contents

Renewal Requirements

Contact EDR Training

Agenda

List of Acronyms

Engineering Designee Training Overview Tony Jopling (AIR-160)

Stump the Regulator All AIR-160

What’s New? ..... Jon Mowery (AIR-160)

1. Recent Policies
2. Defense of the Designee Systems
3. Update to Designee Management System (DMS) schedule
4. Repairs and Repair Specifications
5. Additive Manufacturing
6. Updates to the DER Handbook (8110.37)
7. § 23 Rewrite

Level of FAA Project Involvement Kevin Kendall (AIR-160)

AM Checklist
 2016 Engineering Designee Recurrent Seminar
General Session

8:00 – 8:15 .................Intro/Logistics/Announcements Tony Jopling (AIR-160)

8:15 – 8:30 .................Welcome TBD / Kevin Kendall (AIR-160)

8:30 – 9:00 .................Engineering Designee Training Overview Tony Jopling (AIR-160)

9:00 – 9:30 .................Stump the Regulator All AIR-160

9:30 – 10:00 ...............Break

10:00 – 12:00 .............What’s New? Jon Mowery (AIR-160)

12:00 – 1:30 Lunch

1:30 – 2:30 .................Level of FAA Project Involvement Kevin Kendall (AIR-160)

2:30 – 3:00 General Questions / Learning Assessment

 AIR-160 Engineering Designee Recurrent Seminar
List of Acronyms

Acronym/Symbol Definition
§ Section
14 CFR Title 14 of the Code of Federal Regulations
AC Advisory Circular
ACE Small Airplane Directorate (SAD)
ACO Aircraft Certification Office
AD Airworthiness Directive
ADO Approved Design Organization
AEG Aircraft Evaluation Group
AIA Aerospace Industries Association
AIR Aircraft Certification Service
AIR-1 Director, Aircraft Certification Service
AIR-100 Design, Manufacturing & Airworthiness Division
AIR-110 Certification Procedures Branch
AIR-120 Technical & Administrative Support Staff Branch
AIR-130 Systems & Equipment Standards Branch
AIR-140 Operational Oversight Policy Branch
AIR-150 System Performance and Development Branch
AIR-160 Delegation and Organization Procedures Branch
ASTC Amended Supplemental Type Certificate
ASW Rotorcraft Directorate
ATC Amended Type Certificate
ASTM American Society for Testing and Materials
AVS Aviation Safety

C of A Certificate of Airworthiness
CA Certificating Authority (a.k.a. exporting authority)
CBT Computer Based Training
CDO Certified Design Organization
CDPO Certified Design Production Organization
CFR Code of Federal Regulations
CLOA Certificate Letter of Authorization
CMACO Certificate Management ACO
COA Certificate of Authority
COS Continued Operational Safety
CP Certification Plan
CPN Certification Project Notification

DAH Design Approval Holder

DAR Designated Airworthiness Representative
DBR Delegation by Regulation
DER Designated Engineering Representative
DIN Designee Information Network
DMS Designee Management System
DOT Department of Transportation
DRS Designee Registration System

Page 1 of 3
Last updated: March 21, 2016
 AIR-160 Engineering Designee Recurrent Seminar
List of Acronyms

E&PD Engine and Propeller Directorate

ECO Engine Certification Office
EDR Engineering Designee Recurrent
EMI Electro-Magnetic Interference

F Fahrenheit
F&R Function and Reliability
F/A Flight Attendant
FAA Federal Aviation Administration
FAATC Federal Aviation Administration Technical Center
FADEC Full Authority Digital Engine Control
FANS Future Aeronautical Navigation System
FAQ Frequently Asked Questions
FAR Federal Aviation Regulation
FCAA Foreign Certification Airworthiness Authority
FSDO Flight Standards District Office

GA General Aviation
GAMA General Aviation Manufacturers Association
GAO General Accounting Office

HQ Headquarters

ICA Instructions for Continued Airworthiness

LOPI Level of Project Involvement

MARPA Modification and Replacement Parts Association

MOC Method of Compliance
MOU Memorandum of Understanding

NACIP National Automated Conformity Inspection Process

NAS National Airspace System
NPRM Notice of Proposed Rulemaking
NTSB National Transportation Safety Board

ODA Organization Designation Authorization

ODAR Organizational Designated Airworthiness Representative
OIG Office of the Inspector General
OMT Organization Management Team

PACO Project Aircraft Certification Office

PMA Parts Manufacturer Approval
PNL Program Notification Letter
POA Production Organization Approval
POC Point of Contact
PSCP Project Specific Certification Plan
PSP Partnership for Safety Plan

Page 2 of 3
Last updated: March 21, 2016
 AIR-160 Engineering Designee Recurrent Seminar
List of Acronyms

PTRS Program Tracking and Reporting Subsystem

R&A Repairs and Alterations

RBDM Risk Based Decision Making
RBRT Risk Based Resource Targeting
RFC Request for Conformity
RGL Regulatory and Guidance Library

SAD Small Airplane Directorate

SAIB Special Airworthiness Information Bulletin
SAR Selection, Appointment, and Renewal
SFAR Special Federal Aviation Regulation
SME Subject Matter Experts
SMS Safety Management System
SOP Standard Operating Procedure
SRM Safety Risk Management
STC Supplemental Type Certificate

TAD Transport Airplane Directorate

TBD To Be Determined
TC Type Certificate
TCDS Type Certificate Data sheet
TSO Technical Standard Order
TSOA Technical Standard Order Authorization

UM Unit Member

Page 3 of 3
Last updated: March 21, 2016
 Federal Aviation
Administration
Engineering
Designee Training
Overview

Presented to: 2016 Engineering Designee

Recurrent Seminar

Federal Aviation 1
Administration
 Seminar Program Overview
• Online Website & Updates
• Course Fees
• Recurrent General Session
• Renewal Requirements
• Seminar Locations
• Recurrent Technical Sessions
• New Courses
• Course Certificate and Instructions
• Future Improvements
• Feedback
• Contact Us

Federal Aviation 2
Administration
 Designee Training Program
Website

• http://www.faa.gov/other_visit/aviation_industry/designees_delegatio
ns/training/DER_Recurrent/

• Best Place for Most Up to Date Information

– General Session Schedule
– ODA Training Information
– Technical Session Updates
– Deviation Memos
– etc.

Federal Aviation 3
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 Course Fees
• Necessary to begin to return course fees to normal level
• This means all courses will see some sort of increase in tuition
• Some new courses will see the fee structure change
• Changes will occur over the next calendar year

Federal Aviation 4
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 Recurrent Seminar General Session
• Focus on material applicable to all (or most)
attendees such as:
- Changes in Designee Management
- Changes in TC/STC Process
- Changes in TSO/PMA
• ½ to 1 day in-person (face to face)
• Same Locations as Previous Years
- Every Year: Atlanta, Seattle, Los Angeles, Ft. Worth, Wichita
- Every 2 Years (Alternating): New York, Denver, Chicago,
Boston, Anchorage
• Renewal Requirements

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 Renewal Requirements
• The requirements for DER Recurrent training are contained in
Para 803 (g) of FAA Order 8100.8D. The online training has NOT
changed that requirement. For example, if you last completed
recurrent training anytime in 2014 then you must complete
recurrent training during 2016, i.e. before January 1, 2017.

• FAA Order 8100.8D paragraph 803.g. states: "DERs must attend a

recurrent seminar every 2 calendar years to maintain their
knowledge of the regulations and policies and as a condition for
renewal. DERs may satisfy the 2 year requirement by attending a
DER seminar in the calendar year it is due."

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 Seminar Locations
DER & ODA Location Rotation (Tentative Schedule)
Last Updated: 3/9/2016

Month 2015 2016 2017 2018

March Wichita Wichita Wichita Wichita
April Wichita Fort Worth Fort Worth Fort Worth
Fort Worth

May Boston New York Boston New York

June Anchorage Fort Worth - ODA Anchorage
July Atlanta Denver Chicago Denver
August Seattle Seattle Seattle Seattle
Los Angeles
Boston - ODA
September Chicago Los Angeles Los Angeles Los
Angeles
October Los Angeles Atlanta Atlanta Atlanta

November Chicago (Blank) (Blank) (Blank)

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 Recurrent Seminar Technical Sessions

• Entirely web based

– Electrical Systems and Structures completed in June
and July 2012 (respectively)
– Flight Test, Mechanical Systems and Propulsion
released in April 2013
• Response to online courses has thus far
been very positive
– Most designees appreciate the ability to complete
training on own time in own location

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 Development of New Courses
• Training Cycles – Phase approach
– Up to now all topics (General Session and all
Technical Sessions) changed every two years
– Topics will continue to change every two years
• Note: Some topics are continued past two years, but they
have have updated content.
– Course development:
• Electrical and Structures cycle - available on even years
• Flight Test, Mechanical Systems, and Propulsion -
available on odd years (See Table)\
– Changes on the Horizon
• Individual Courses released as available
• Designees able to pick from list of coursesFederal Aviation
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Administration
• Yearly or Bi-Annual Training Tuition (flat rate)
 Course Certificate
• Course Certificate: Issued after up to 4
hours after successful completion.
– If you do not receive a course certificate:
• Grade not recorded: System error, browser, etc.
• User did not meet the course requirements:
– For example, user completed 4 of 6 topics. Requirements are
provided at registration (DRS), in the course and course
printout.
– Do not wait until Jan after the course expires to
figure this out
– You may retrieve your current and past certificates
from DRS (see FAQ webpage)
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 Course Instructions
• Course Instructions are provided to help you successfully
complete a course. Instructions are provided on
– Blackboard Designee Tab
– Course Menu of each course
– “How to use this course” overview
– New courses will have system requirements on the 1st page.
• ‘Next’ button not available – read user navigation instructions
on the lower left hand corner of course page. Examples
include:
– Click on the FAA Expert icon to learn more. Then click on the Next arrow to
continue.
– Click on the graphic to view the video. Then click on the Next arrow to
continue.

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 Further Improvements Coming
• We hope to be able to create a system that provides more
individualized training
• Current Plan:
– Designees would complete “Core Courses” based upon their specific
authorization
– Other topics within that discipline will be identified as “Specialty” Courses
– Designees will be required to complete all “Core” Courses within their
discipline
– Designees may be required to take a certain number of “elective”
courses that they will be able to choose
– This will significantly reduce the designees completing material that does
not apply to their actual authority

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 We Need Your Help!
• Feedback:
– Engineering Designee Seminar Program is YOUR
program
– Most topics come from field suggestions
(Designees, ACOs, Directorates, etc.)
– Future changes/improvements will include input from
our designees
– There are many ways YOU can provide input
• End of course Survey
• Website: Contact us Email: [email protected]
• Each course provides a Contact Us button

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 Contact Us
Please allow time to look into your problem and respond. The program is growing and
we are doing our best to respond to all inquiries in a timely manner.

1. For content specific questions each course will now have contact information for the Subject Matter
Expert (SME) for that course. Please contact the SME for content related questions.

2. Preferred Method: Email: 9-AMC-EDR [email protected]. Each course has a Contact Us Menu Item.
Provide as much information as possible:

• Be sure to include the following information:

• Course Number and title for example: (27200106) Electrical: Electronic Flight Bag
• Page Number: Page 5 of 25
• Explain the error found
• Provide a screen shot if possible

3. If you decide to call and leave a Message:

• a. Clearly Provide your full name. Not a nick name -- name as it appears in DRS.
• b. Course #, Lesson and problem: We can troubleshoot and perhaps correct the issue if we have the
details before we contact you by email or returning your call.

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Questions

Federal Aviation 15
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 Federal Aviation
Administration

Stump the
Regulator

Presented to: 2016 Engineering Recurrent Seminar

 Stump the Regulator

• Open Q&A session with everyone from FAA

Headquarters on stage
• We reserve the right to tap into local FAA
knowledge
• Any question relating to delegation of any
kind is fair game
• Prize to those who manage to stump us
Note: Not liking our answer is not stumping us

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 Sample questions

• Question:
– As a DER I last took the general session training in
Sept of 2014. My renewal is in Aug of 2016. Can I
be renewed or do I have to take the training before?
• Answer:
– Yes, you can. The training requirement is once
every 2 calendar years, which means you have until
Dec 31st of 2016 to take the training in this scenario.

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 Sample questions

• Question:
– Can a Repair Specification be created for minor
repairs?
• Answer:
– No, Repair Specification approvals are for major
repairs ONLY. Minor repairs only require
acceptable data not approved data and therefore no
8110-3 or 8100-9 is required.
Ref 8110.37E and 14CFR 43

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 Sample questions

• Question:
– I see there is something called a “vintage DER” Do I
have to have that before I can work on Vintage
Airplanes?

• Answer:
– No, a vintage DER is a DER who did not meet all the
qualifications of a DER but who has demonstrated
expertise in a certain type of vintage aircraft.
Ref 8110.37E

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Questions before
we begin?

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Ok, then let’s see if you can
STUMP THE REGULATORS

Federal Aviation 7
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 Federal Aviation
Administration

What’s New ?

Presented to: 2016 DER Recurrent Seminar

What’s New?

• History
• Concept
• Feedback

Federal Aviation 2
Administration
What’s New? Topics List
• Recent Policies
• Defense of the Designee System
• Update to Designee Management System
(DMS) schedule
• Repairs and Repair Specifications
• Additive Manufacturing
• Updates to the DER Handbook (8110.37)
• §23 Re write

Federal Aviation 3
Administration
Recent Policies

• Where can Policy information be found?

• http://rgl.faa.gov/Regulatory_and_Guidance
_Library/rgPolicy.nsf/
• This site contains Policy that has yet to be
incorporated in FAA guidance

Federal Aviation 4
Administration
Recent Policies

• As an example, we recently published a

memo allowing for the delegation of
Emissions findings
• Policy number AIR100-14-140-GM13
• This policy allows ACO’s to delegate to
qualified individuals findings of compliance
to 14 CFR part 34
• It also provides for the delegation to ODA’s

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Questions?

Federal Aviation 6
Administration
 Federal Aviation
Administration

Defense of the
Designee System

Presented to: 2016 DER Recurrent Seminar

Defense of the Designee System

• Why do we make the changes we do?

• Why are we tracking and documenting

more?

Federal Aviation 8
Administration
Defense of the Designee System

• Congress instructs the FAA on what to do

– How do they make sure we are doing what they told
us to? They audit us
– The Government Accountability Office or Office of
the Inspector General conduct audits of the FAA
• Additionally, other Countries, when
deciding whether or not to accept FAA
findings conduct audits of our system

Federal Aviation 9
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Defense of the Designee System

• Designees are a large part of our system

• Naturally audits of our system spend a large
portion of time focusing on how we manage
the designee system

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Defense of the Designee System

• We need to be able to answer, with data, the

following types of questions:
– How are the FAA designees:
• Trained?
• Appointed?
• Terminated if needed?
– How does the FAA ensure:
• Findings made by designees are correct?
• Initiate corrective action on designees?
– How does the FAA determine what to delegate?

Federal Aviation 11
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Defense of the Designee System

• The first, best defense of our system is our

accident rate, and we use that
• But we also need to be able to point to
documented processes that answer
those questions
• This is what drives a lot of the changes you
see in our orders and things like our new
DMS tool

Federal Aviation 12
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Questions?

Federal Aviation 13
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 Federal Aviation
Administration

Designee
Management
System (DMS)

Presented to: 2016 DER Recurrent Seminar

What is DMS?

• DMS is a web based tool for the FAA to

use in managing its designees
• Created in Response to a Government
Accountability Office (GAO) audit of
the FAA

Federal Aviation 15
Administration
 What will DMS do?
• It will roll up
– Appointment
– Renewal
– Terminate
as well as provide for the management of the delegation
• Link with NACIP, our conformity delegation
program

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Current Deployment Schedule

• DMS is up and running for Manufacturing

Designees, and Aeromedical
• AFS is next
• DERs are last and should be transferred in
the Fall of 2017

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Electronic 8110-3

• One of the major changes

• Short of a system failure, will be the only
way to file a 8110-3
• Will be a series of questions, then program
generated form for authorization
• Will be able to use past forms to generate
new ones
• Will no longer have to submit forms to ACO

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Questions?

Federal Aviation 19
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 Federal Aviation
Administration

Repairs, Alterations,
and Repair
Specifications

Presented to: 2016 DER Recurrent Seminar

Repairs & Alterations

8110.37E defines a repair as:

A repair is the restoration of a damaged product or article
accomplished in such a manner and using material of
such quality that its restored condition will be at least
equal to its original or properly altered condition (with
regard to aerodynamic function, structural strength,
resistance to vibration and deterioration, and other
qualities affecting airworthiness)

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Administration
Repairs & Alterations

8110.37E defines an alteration as:

An alteration is the modification of an aircraft from
one sound state to another sound state; the
aircraft meets the applicable airworthiness
standards both before and after the modification.

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Repairs & Alterations

Q: When can a DER be involved?

A: When data must be approved

Q: When does data have to be approved?

A: Only for a major repair or major alteration

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Administration
Repairs & Alterations

• It is not the DERs responsibility to

determine whether or not the repair or
alterations in major or minor
• It is the responsibility of the entity (IA,
Repair Station, etc.) returning the aircraft to
service to determine the type of data
(acceptable or approved).
• Ref AC 43-210 301(b)

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Administration
Repairs & Alterations

• The requirement for approved data vs

acceptable data is a combination of 14 CFR
Part 43 which tells you that all maintenance
tasks must be done with data acceptable to
the FAA. It also specifies who can perform
maintenance tasks.
• Then, the operational rules i.e. 65, 145, 121,
135, etc. contain the requirement for FAA
approved technical data for major repairs
and alterations
Federal Aviation 25
Administration
Repairs & Alterations

§43.13 Performance rules (general).

(a) Each person performing maintenance,
alteration, or preventive maintenance on an
aircraft, engine, propeller, or appliance shall
use…methods, techniques, and practices
acceptable to the Administrator…”

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Repairs & Alterations

• §65.95 Inspection authorization: Privileges

and limitations
(a) The holder of an inspection authorization may—
(1) Inspect and approve for return to service any aircraft
or related part or appliance (except any aircraft
maintained in accordance with a continuous airworthiness
program under part 121 of this chapter) after a major
repair or major alteration to it in accordance with part 43
[New] of this chapter, if the work was done in accordance
with technical data approved by the Administrator

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Administration
Repairs & Alterations

§121.379 Authority to perform and approve

maintenance, preventive maintenance, and
alterations.
(b) A certificate holder may approve any aircraft, airframe,
aircraft engine, propeller, or appliance for return to service
after maintenance, preventive maintenance, or alterations
that are performed under paragraph (a) of this section.
However, in the case of a major repair or major alteration,
the work must have been done in accordance with
technical data approved by the Administrator.

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Repairs & Alterations

§135.437 Authority to perform and approve

maintenance, preventive maintenance, and
alterations.
(b) A certificate holder may approve any airframe, aircraft
engine, propeller, rotor, or appliance for return to service
after maintenance, preventive maintenance, or alterations
that are performed under paragraph (a) of this section.
However, in the case of a major repair or alteration, the
work must have been done in accordance with technical
data approved by the Administrator.

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Repairs & Alterations

§145.201 Privileges and limitations of

certificate.
(c) A certificated repair station may not approve
for return to service
(2) Any article after a major repair or major alteration
unless the major repair or major alteration was
performed in accordance with applicable approved
technical data;

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Administration
Repairs & Alterations

• What does all that mean?

• Basically all repairs and alterations need to
be done in accordance with data acceptable
to the FAA, the exception is that all major
repairs and alterations must be done in
accordance with technical data approved by
the FAA

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Administration
Repairs & Alterations

This is explicitly spelled out in Order 8110.37

4-12 (a) and (b)
Major alterations and major repairs must be
accomplished in accordance with technical data
approved by the Administrator
Minor repairs and minor alterations do not require
FAA engineering approval. As such, DERs
cannot approve minor repairs or alterations.

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Repairs & Alterations

• Yet, we are still seeing repair and alteration

approvals via 8110-3s for what are clearly
minor repairs and alterations
• While the determination of whether or not a
repair or alteration in major is not the
responsibility of the DER, we do expect you
to follow the order and NOT approve data
for what is clearly a minor repair/alteration

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Repairs & Alterations
• Not following our system for return to
service after a repair or alteration causes
confusion on the part of mechanics
and inspectors
• If they always see an 8110-3 approving data,
even when it’s not necessary, they expect to
always see one
• This results in hardship for those that follow
the system where they have to explain one
is not needed

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Repair Specifications

• Have been required for all multiple non

serial number specific, non DAH repairs
since 2012
• Generally working well but there are some
issues

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Repair Specifications

• This first is what we just talked about for

single repairs.
• Repair Specifications are only for
major repairs
• Second are issues with using Repair
Specifications as a means to circumvent PMA
• Third using them to repair TSO articles with
no certification basis established

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Administration
Repair Specifications

• Example of issues 1 and 2

• A repair specification came in to ACO as
recommend approval for a fuel probe clamp
• The only data associated was a drawing
showing how to cut and bend a piece of
sheet metal to fabricate the clamp
• Basically they were using a DAH
maintenance procedure but wanted to
manufacture the clamp

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Administration
Repair Specifications

• NOT a major repair

• There are acceptable methods to fabricate a
part during maintenance where the next
higher assembly level is returned to service
but they require a quality system
• A repair specification is not the correct path

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Administration
Repair Specifications
• We are currently working on an INFO for seat belts
specifically
• Seats belts are a good example since for the case
of dynamic seat requirements the fact the seat belt
as repaired meets the TSO may not be sufficient to
allow it to function properly with dynamic seats.
• This makes it necessary to know the certification
basis in order to determine if the as repaired part
can meet the required regulations

Federal Aviation 39
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Repair Specifications
• General Guidelines for Repairs to TSO articles
– A repair to a TSO article is the same as a repair to any other
aircraft part you must:
• Know the certification basis in order to determine which
regulations apply and need to be found in compliance
• Identify if the data you are approving is not the complete data
set required
• The ONLY difference is that in the case of a TSO
article being repaired you must evaluate whether
it still meets the TSO and if not mark out the
TSO marking

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Questions?

Federal Aviation 41
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 Federal Aviation
Administration

Additive
Manufacturing

Presented to: 2016 DER Recurrent Seminar

Additive Manufacturing

• Definition
• Existing Policy
• Expectations of Designees

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Administration
Additive Manufacturing

• Additive Manufacturing (AM) also known as

“3D Printing” refers to a range of fabrication
methods, both metallic and nonmetallic,
where basic material forms (such as
metallic powders, wire, resin, etc.) are
processed in a machine to produce near-net
shape parts

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Additive Manufacturing

• Link to recent memo to ACO’s regarding AM

• http://rgl.faa.gov/Regulatory_and_Guidance
_Library/rgPolicy.nsf/0/6AB4787EF524BF07
86257F0700597E6B?OpenDocument
• Or just search rgl.faa.gov under “Policy” by
issue date and look for June 3, 2015
• Requests certain information about projects
involving AM to the FAA AM National
Team, AMNT

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Administration
Additive Manufacturing
• The list of information requested is as
follows
– Company name
– Type of application (e.g., TC/ATC/STC, PMA)
– Product type (e.g., engine, aircraft part)
– Make, model, component or part
– Part criticality
– Specify the AM manufacture methodology (e.g., polymer,
metal, etc.).
– ACO point of contact (e.g., project engineer)
– DER involvement: Yes or No.
• If yes, what regulations are/were used for showing compliance?

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Additive Manufacturing
• At this site you’ll see that the Transport
Airplane Directorate lays out the need for an
Issue paper if AM is to be used
• https://www.faa.gov/aircraft/air_cert/design_
approvals/transport/media/rptTAIListForPub
licWeb.PDF
– You may need an issue paper to establish a means
of compliance with §§ 25.603, 25.605 and 25.613 to
develop appropriate design values for additive
manufactured materials that account for variability in
materials, geometry and manufacturing processes

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Additive Manufacturing

• What does this all mean for the designee?

• Basically AM is a new fabrication method
and the FAA would like to make sure we
understand how it’s being used
• To that effect we may require information
from you and even Issue Papers if warranted

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Additive Manufacturing

• If you are involved in projects or activities

that use AM please contact your advisor for
the latest FAA policy
• In the CD and in your booklet you’ll find a
copy of a checklist put together by the
Transport Airplane Directorate that will
provide a starting point of basic questions

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Questions?

Federal Aviation 50
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 Federal Aviation
Administration

Rev F to Order
8110.37

Presented to: 2016 DER Recurrent Seminar

What’s planned for in 8110.37F

• 8110.37F is not out yet, but is projected to be

out for comment by summer of 2016
• Here are some of the changes planned
– Remember nothing is final or required until the order
is published

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What’s planned for in 8110.37F

• No more DER Candidates

– anyone who fit the previous description will now be
a DER with authority limited to Recommend
Approval only
• A note will be added to address the removal
of Administrative and Management DERs
– Management function will now be a special authority
similar to Repair Specification
• Added a section on rescinding an 8110-3
after it’s been issued
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What’s planned for in 8110.37F

• Adding a section on repair of TSO products

– Cannot just repair a part that was produced under a
TSOA to the TSO
– Must address the certification basis of the product
upon which the repaired part will be installed on

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Questions?

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 Federal Aviation
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14 CFR Part 23
Rewrite

Presented to: 2016 DER Recurrent Seminar

14 CFR Part 23 rewrite

• The entire part 23 has been rewritten

• It will be less prescriptive
• The philosophy will be to have the WHAT
we want to happen in the rule (e.g. keep
occupants from severe injury during a
crash) and put the HOW into Method Of
Compliance (MOC) documents

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14 CFR Part 23 rewrite
• The rule and the MOC documents will be
used together to show compliance
• Initially the new form (Rule and MOC
documents) will look very similar to the
current 14 CFR Part 23 at amendment 62
because that was our starting point for the
ASTM documents
• As time goes by changes to the ASTM
MOC’s and other accepted MOC documents
will result in a more streamlined process
for applicants
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14 CFR Part 23 rewrite

• This is a rather dramatic departure from

the past
• The comment period has closed and the
comments are currently being evaluated

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Questions?

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 Federal Aviation
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Level of FAA Project

Involvement

Presented to: 2016 DER Recurrent Seminar

What is Level of Project Involvement
(LOPI)?

• How much or how little the FAA participates on each

project
• FAA participation includes employees and designees
• Applicant’s actions may or may not be affected.

Examples:
– Accept test data that shows compliance
– Require test to be performed with designee involvement
– Require test with ACO engineer involvement

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How does FAA determine LOPI?

• Part of Compliance Planning

• Required vs optional (discretionary)
• Where does involvement derive the most benefit?
– Decisions or events critical to safety
– Based on project team member experience
– How complex is the requirement?
– Confidence in applicant
– Applicant’s experience
– Internal processes
– Proposed designees

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Why is FAA allowed to vary LOPI?
• FAA has Limited resources
• Applicant is responsible for compliance
• Applicant’s must make a certifying statement
of compliance
– Statement required prior to receiving design
approvals.
– Based on certification activities that show compliance
and how compliance was managed (via a compliance
listing, for example)
The applicant ALWAYS has to show
compliance FAA has discretion in how we
determine Compliance

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FAA Discretion
• FAA has discretion to determine how much or
how little of an applicant’s showing to review
(Designees don’t have this discretion)

• FAA makes the level of involvement

determination based on risk

• Risk determination has been made subjectively

in the past

• Risk Based Decision Making (RBDM) tools can

assist in these determinations
– 14 CFR part prioritization
– Risk Based Resource Targeting
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How does Risk equate to Level of
Involvement?

• Project areas have various risks associated with

them, but the LOPI decision focuses mainly on safety
risk of a noncompliance
• This risk is made up of the severity (consequences)
of a noncompliance combined with the likelihood of
the noncompliance occurring
• Contributors are
– Relative risk rating of each rule section
– Applicant experience
– Designee experience
– Safety record

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Where and how is the FAA involved based
on risk “Levels”

• The outcome of the safety risk process is relatively

simple, resulting in it either being High, Medium, or
Low
– High suggests direct FAA involvement
– Medium suggests FAA involvement through
designees
– Low suggests that FAA resources aren’t
necessary and the FAA can rely on applicant’s
submittal without review (“applicant showing
only”)

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Why “Applicant Showing Only” is a benefit

• FAA uses delegation to leverage its workforce, doing

what ACO staff would otherwise do
– Managing delegation requires applicant and FAA resources
– Applicant capability contributes to delegation decisions
• Applicant capability may also reduce resources needed
– Example: Compliance demonstration without FAA/designee involved
provides applicant more control of cost and schedule
– May still rely on DER workforce directly or indirectly
• Robust applicant capability is the foundation of Safety
Management System (SMS) approach to certification
– Approved Design Organization (ADO)
– Certified Design Production Organization (CDPO)

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Applicant Showing
• Reflected in policy
– Streamlined PMA Order 8110.119 (11/30/12)
– Guidance for Recognition and Use of Applicant Showings on
Standard Certification Projects AIR100-15-150-PM16 (9/30/15)
• Future
– 8110.4D Type Certification
• Promotes applicant responsibility and ability for FAA to adjust
involvement based discretion
– 8100.15C ODA Procedures
• Applicant capability is largely established as a prerequisite to
ODA
• FAA involvement decision is largely made as part of the ODA
authorization
– FAA LOPI Order

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Implementing an efficient LOPI decision
process
• Depends on partnerships working toward a common goal
– Define what FAA and applicant want the future to look like
– What will it take to get there?
• Pursue applicant showing without FAA involvement
– Largely untapped resource
– Follow AIR Policy Memo which allows it for Low Risk
– Start simple: conformity, witnessing, and low risk testing/findings
– Future: More complex for data analysis and testing and may depend on
• People
• Processes
• Auditing

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FAA Level of Involvement and DERs

• A DER is an FAA compliance finder

• A DER was previously a compliance showing expert

• FAA LOI depends on applicant’s compliance

showing expertise

• What FAA LOI means to you

– Defines what you’ll do on FAA’s behalf
– Possibly results in what you’ll do on the applicant’s behalf
– Could increase your value to the applicant

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Summary
• FAA level of involvement should be determined by
risk level
• Applicant always has to show compliance and
provide method that they used to do so
• FAA has discretion and can reduce resources by
limiting involvement where appropriate
• FAA has already reduced FAA resources by
using designees
• Further reduction possible by recognizing applicant
showing and focusing designee resources
• Applicant capability foundation of future SMS approach

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Additive-Manufacturing Sample Checklist

Introduction:
The introduction of additive-manufacturing (AM) in the production of commercial
aviation parts presents a unique challenge for certification. The term additive-
manufacturing does not describe one manufacturing method, but a wide range of
methods, each with its own set of concerns and requirements. The checklist provided
herein is not intended to be comprehensive list of all the questions that need to be
addressed to accomplish certification of an AM part, but to provide a basic list of initial
questions.

The compliance plan for a given AM part will be affected by:

• Component Design Requirements:
o Part classification (e.g., safety critical, durability critical, non-critical)
o Materials substitution (are you changing the material system? From what to
what?)
Note: Material chemistry alone does not dictate material properties. Using the
same material with additive-manufacturing may not yield the same properties.
o Extent of available technical data for the component’s requirements
• Component Geometry Requirements:
o Part size (total envelope and volume)
o Part complexity (surface area-volume ratio, fraction envelope solid, symmetry)
o Dimensional conformance requirements
o Surface finish requirements (including internal features where applicable)

Taking into consideration the above factors, an assessment of regulatory compliance

needs to address the following:

Basic Materials Requirements: (§25.603)

• What is the applicant’s experience with the AM material being proposed?
• Are the constituent materials to be used in the AM process being purchased per a
recognized industry specification, or an internal proprietary material
specification?
o If using an industry specification, is it from an FAA recognized source
and are there any additional controls being applied to ensure the applicant
is receiving the correct material?
o If using an internal specification, how is FAA approval being sought?
• What testing was conducted to validate that the material selected is suitable for
the applicants intended application?
• How has the applicant taken into account the operational environment in
selecting the material?
• Has the applicant generated mechanical property curves for the material from test
samples produced via additive-manufacturing using parameters representative of
parameters to be used to make parts?
Basic Process Requirements: (§ 25.605)
• What AM process is being proposed?
• What is the experience of the applicant with this process for manufacturing parts?
• How were the key process parameters identified and what controls were
established?
• How is the applicant proposing gaining FAA approval of their process
specification?
• What AM machine process is the applicant using to qualify it to that process
specification? (If multiple machines will be used, is each machine qualified
independently?)
• How are key process parameters being monitored for quality control?
• What testing was conducted by the applicant (or being proposed) to verify that the
AM process proposed provide a stable and repeatable product?
• What inspections are being used to verify that the final product has been
manufactured correctly?

Inspection Methods:
• What are the possible defects in the final parts for which final part inspections
will be conducted?
• What are the defect limit sizes and how were they established?
• What NDI inspection methods are being proposed to detect the defects during
production?
• How were these NDI methods validated?

Development of Strength and Design Values: (§25.613)

• Are the AM manufactured articles from which test specimens are being extracted
representative of actual production parts?
• What sampling plan is being used to capture the variability of the material being
purchased and the AM process being used to manufacture parts?
o How a material batch being defined, and how many batches are being
tested as part of the design values program?
o How a production lot being defined, and how many lots are being tested as
part of the design values program?
o Is the material used more than once (e.g. recycling powder bed material)?
• How is the expected operational environment of the part being accounted for in
the design values test program?
Application of Special Factors: (§ 25.619)
• Was the testing conducted to derive design values required by § 25.613 sufficient
to capture the variability of part being fabricated?
o Were the specimens used to derive design values extracted from
representative production parts, or individually produced? (If specimens
were individually fabricated they may not capture the variability of what is
actually being produced.)
o Are specimens are being extracted from representative parts but, because
of part geometry, specimens can’t be obtained from all key grain
directions?
o Did the test program encompass all the variables in the AM process,
machine, and material stock?