ED Decision 2020/012/R
QUALITATIVE SAFETY ASSESSMENT — CONSEQUENCES OF THE PROPOSED MMEL DISPATCH CONFIGURATION
(a) Operational consequences of the proposed dispatch configuration (including any limitations and/or procedures) evaluated according to the criteria of CS MMEL.140 (a) and (b), classified as no safety effect or minor as per the associated type-certification basis of the aircraft definitions, are considered to be acceptable.
(b) The classification of failure conditions established in the safety assessment process through the aircraft and system FHAs should be used carefully, as the mitigation means associated with the proposed MMEL item may lead to a reduction in the severity that was identified for type certification purposes.
For example, the failure of one item during a particular flight phase may be considered to be major due to a temporary loss of function until the flight crew performs a manual reconfiguration during the flight. But when this item is known to have failed on the ground, prior to the departure, the consequence may be less critical for the crew, and the application of the associated dispatch conditions can allow the classification to be reduced to an acceptable level.
(c) Conversely, some severities that were set up for the purpose of type certification may need to be complemented or increased. In particular, the effects on the crew workload and potential fatigue need to be carefully assessed. Indeed, the severity of a failure that may have been assessed as having minor effects as an in-flight failure during the type certification may be considered to have more than minor repercussions due to operating for several flights in some operational conditions. Some aggravating factors (e.g. the number of flights of the exposure, the flight duration, flight rules, special operations) will sometimes need to be mitigated by limitations that would normally not apply for a full-up aircraft configuration (e.g. day VFR only, instead of Day & Night VFR, types of operations).
GM5 MMEL.145(c) requires qualitative safety assessment of MMEL dispatch consequences, accepting no safety effect or minor classifications, while carefully adjusting severities for crew workload and fatigue.
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