GM 21.A.91 Classification of changes to a type certificate (TC)

1.       PURPOSE OF CLASSIFICATION

Classification of changes to a type certificate (TC) into MAJOR or MINOR is to determine the approval route to be followed in Part-21 Subpart D, i.e., either 21.A.95 or 21.A.97, or alternatively whether application and approval has to be made in accordance with Part-21 Subpart E.

2.       INTRODUCTION

2.1     21.A.91 proposes criteria for the classification of changes to a TC as minor or major.

(a)     This GM is intended to provide guidance on the term ‘appreciable effect’ affecting the airworthiness of the product or affecting any of the other characteristics mentioned in 21.A.91, where ‘airworthiness’ is interpreted in the context of a product in conformity with type design and in condition for safe operation. It provides complementary guidelines to assess a change to the TC in order to fulfil the requirements of 21.A.91 and 21.A.117 where classification is the first step of a procedure.

Note: For classification of Repairs see GM 21.A.435(a).

(b)     Although this GM provides guidance on the classification of major changes, as opposed to minor changes as defined in 21.A.91, the GM and 21.A.91 are deemed entirely compatible.

2.2     For an ETSO authorisation, 21.A.611 gives specific requirements for design changes to ETSO articles.

         For APU, this GM 21.A.91 should be used.

3.       ASSESSMENT OF A CHANGE FOR CLASSIFICATION

3.1     Changes to the TC

21.A.91 addresses all changes to any of the aspects of a TC. This includes changes to a type design, as defined in 21.A.31, as well as to the other constituents of a TC, as defined in 21.A.41.

3.2     Reserved

3.3     Classification process (see also the flow chart ‘Classification process’ in Appendix A to GM 21.A.91)

21.A.91 requires all changes to be classified as either major or minor, using the criteria of 21.A.91.

         Wherever there is doubt as to the classification of a change, EASA should be consulted for clarification.

When the strict application of the paragraph 3.4 criteria results in a major classification, the applicant may request reclassification, if justified, and EASA could take the responsibility for reclassifying the change.

A simple design change planned to be mandated by an airworthiness directive may be reclassified as minor due to the involvement of EASA in the continued airworthiness process when this is agreed between EASA and the DOA holder.

The reasons for a classification decision should be recorded.

3.4     Complementary guidance for classification of changes

A change to the TC is judged to have an ‘appreciable effect on the mass, balance, structural strength, reliability, operational characteristics, noise, fuel venting, exhaust emission, operational suitability or other characteristics affecting the airworthiness, environmental protection or operational suitability of the product’ and, therefore, should be classified as major, in particular but not only, when one or more of the following conditions are met:

(a)     where the change requires an adjustment of the type-certification basis or the OSD certification basis (special conditions or equivalent safety findings) other than elect to comply with later certification specifications;

(b)     where the applicant proposes a new interpretation of the certification specifications used for the type certification basis or the OSD certification basis that has not been published as AMC material or otherwise agreed with the Agency;

(c)      where the demonstration of compliance uses methods that have not been previously accepted as appropriate for the nature of the change;

(d)     where the extent of new substantiation data necessary to comply with the applicable certification specifications and the degree to which the original substantiation data has to be re-assessed and re-evaluated is considerable;

(e)     where the change alters the airworthiness limitations or the operating limitations;

(f)      where the change is made mandatory by an airworthiness directive or the change is the terminating action of an airworthiness directive (ref. 21.A.3B), see Note 1; and

(g)     where the design change introduces or affects functions where the failure effect is classified as catastrophic or hazardous.

Note 1: A change previously classified as minor and approved prior to the airworthiness directive issuance decision needs no reclassification. However, EASA retains the right to review the change and reclassify/reapprove it if found necessary.

Note 2: The conditions listed in (a) through (g) above are an explanation of the criteria noted in 21.A.91.

For an understanding of how to apply the above conditions, it is useful to take note of the examples given in Appendix A to GM 21.A.91

3.5     Complementary guidance on the classification of changes to OSD

This paragraph provides firstly general guidance on minor OSD change classification, and secondly additional guidance specific to each OSD constituent.

Changes to OSD are considered minor when they:

—    incorporate optional information (representing improvements/enhancements);

—    provide clarifications, interpretations, definitions or advisory text; or

—    do not change the intent of the OSD document, e.g. changes to:

—    titles, numbering, formatting, applicability;

—    order, sequence, pagination; or

—    sketches, figures, units of measurement, and correction of editorial mistakes such as:

—    spelling; or

—    reference numbers.

Given the structure and individual intent of the separate OSD constituents, the interpretation of ‘appreciable’ is also affected by the specific nature of the applicable certification specifications (CS) for that constituent. Therefore, specific guidance on each of the OSD constituents is provided hereafter.

(a)     Master minimum equipment list (MMEL)

(1)     A change to the MMEL is judged to have an ‘appreciable effect on the operational suitability of the aircraft’ and, therefore, should be classified as major, in particular but not only when one or more of the following conditions are met:

(i)      where the change requires an adjustment of the OSD certification basis;

(ii)      where the applicant proposes changes to the means of compliance with the requirements used for the OSD certification basis (i.e. MMEL safety methodology);

(iii)     where the extent of substantiation data and the degree to which the substantiation data has to be assessed and evaluated is considerable, in particular but not only when:

(A)     the substantiation data involving the review of failure conditions that are classified as hazardous or catastrophic has to be evaluated;

(B)     the assessment of the failure effects (including next worst failure/event effects) on crew workload and the applicable crew procedures has to be evaluated; or

(C)     the capability of the aircraft to perform types of operation (e.g. extended-range twin operations (ETOPS), instrument flight rules (IFR)) under MMEL is extended.

(2)     A change to the MMEL is judged not to have an ‘appreciable effect on the operational suitability of the aircraft’ and, therefore, should be classified as minor, in particular but not only when one or more of the following conditions are met:

Modifications to an existing item when:

(i)      the change only corresponds to the applicability of an item for configuration management purposes;

(ii)      the change corresponds to the removal of an item;

(iii)     the change corresponds to the increase in the number of items required for dispatch; and

(iv)     the change corresponds to a reduction in the rectification interval of an item.

Addition of a new item when:

(v)      it is considered as non-safety-related (refer to CS‑MMEL, GM2 MMEL.110); or

(vi)     it is indicated as eligible for minor change classification in 1 to GM1 CS‑MMEL‑145.

(b)     Flight crew data (FCD)

(1)     FCD change related to change to the type design

When classifying the FCD change as minor or major, the method of CS‑FCD, Subpart D should be used.

(i)      An analysis should be performed to assess the change impact on the FCD through the allocation of difference levels realised with operator difference requirement (ODR) tables as per CS FCD.400. In this case, the base aircraft is the aircraft without the type design change, whereas the candidate aircraft is the aircraft which includes the type design change.

(A)     If a no more than level B difference is assigned for training, checking and currency for the candidate aircraft, the related FCD change should be classified as minor.

(B)     If a difference level C, D or E for training, checking and currency is assigned to the candidate aircraft, the related FCD change should be classified as major.

(ii)      Notwithstanding the above, the change to FCD should be classified as major when a T1 or T2 test is found necessary by the applicant to confirm that the aircraft with the type design change is not a new type for pilot type rating.

(2)     Stand-alone changes to FCD are not related to any type design changes. They may be triggered for example by in-service experience or by the introduction of data at the request of the applicant after type certification.

(i)      Introduction of credits in training, checking or currency should be classified as major. Example: addition of further-differences training, common take-off and landing credits, etc.

(ii)      Stand-alone changes to FCD that correspond to a change of the intent of a data should be classified as major. Example: addition of a training area of special emphasis (TASE) or prerequisite, expansion of a TASE.

(c)      Cabin crew data (CCD)

(1)     OSD change related to change to the type design

When classifying the OSD CCD change as minor or major, the method from CS‑CCD, Subpart B should be used.

(i)      An analysis should be performed to assess the change impact on the OSD CCD through the identification of the difference and its impact on operation in the aircraft difference table (ADT) as per CS CCD.200. In this case, the base aircraft is the aircraft without the type design change, whereas the candidate aircraft is the aircraft which includes the type design change.

(A)     If the difference has no impact on the operation of an element of the ADT for the candidate aircraft, the related OSD CCD change should be classified as minor.

(B)     If the difference has an impact on the operation of an element of the ADT for the candidate aircraft, the related OSD CCD change should be classified as major.

(ii)      Notwithstanding the above, the change to OSD CCD should be classified as major when an ADT analysis is found necessary by the applicant to confirm that the aircraft with the type design change is not a new type for cabin crew.

(2)     Stand-alone changes to OSD CCD are not related to any type design changes. They may be triggered for example by in-service experience or by the introduction of data at the request of the applicant after type certification.

(i)      Stand-alone changes to cabin aspects of special emphasis (CASE) should be classified as major. Example: addition of further CASE, expansion of CASE.

(ii)      When classifying stand-alone changes to type-specific data for cabin crew the method from CS‑CCD, Subpart B should be used. An analysis should be performed to assess the change impact on the type-specific data through the identification of the difference and its impact on operation in the ADT as per CS CCD.200.

(A)     If the change does not concern a determination element of CS CCD.205, the stand-alone change should be classified as minor.

(B)     If the change has no impact on the operation of an element of the ADT, the stand-alone change should be classified as minor.

(C)     If the change has an impact on the operation of an element of the ADT, the stand-alone change should be classified as major.

(d)     Simulator data (SIMD)

The OSD constituent ‘simulator data’ does not include the data package that is necessary to build the simulator. It includes only the definition of the scope of validation source data to support the objective qualification of a simulator. So, when this guidance discusses changes to ‘simulator data’, this concerns only changes to the ‘definition of scope of validation source data’ and not changes to the data package.

(1)     A change to the SIMD should be classified as major, in particular but not only when one or more of the following conditions are met:

(i)      when a change to the SIMD introduces validation source data from an engineering platform where the process to derive such data has not been audited by the Agency in the initial SIMD approval; or

(ii)      when the process to derive validation source data from an engineering platform is changed.

(2)     A change to the SIMD could be classified as minor, in particular but not only when one or more of the following conditions are met:

(i)      changes to engineering validation data independent of the aircraft due to improvements or corrections in simulation modelling (e.g. aerodynamics, propulsion);

(ii)      configuration changes to the aircraft where the process to derive validation source data from an engineering platform is unchanged;

(iii)     changes to validation source data by using better, more applicable flight test data; or

(iv)     editorial changes to the validation data roadmap (VDR).

(e)     Maintenance certifying staff data (MCSD)

[Reserved]

3.6     Complementary guidance for the classification of changes to aircraft flight manuals (AFMs)

The following changes to the AFM are deemed to be minor:

(a)     revisions to the AFM associated with changes to the type design that are classified as minor in accordance with point 21.A.91;

(b)     revisions to the AFM that are not associated with changes to the type design (also identified as stand-alone revisions) which fall into one of the following categories:

(1)     changes to limitations or procedures that remain within already certified limits (e.g. weight, structural data, noise, etc.);

(2)     consolidation of two or more previously approved and compatible AFMs into one, or the compilation of different parts taken from previously approved and compatible AFMs that are directly applicable to the individual aircraft (customisation); and

(3)     the introduction into a given AFM of compatible and previously approved AFM amendments, revisions, appendices or supplements; and

(c)      administrative revisions to the AFM, defined as follows:

(1)     for the AFMs issued by the TC holder:

(i)       editorial revisions or corrections to the AFM;

(ii)      changes to parts of the AFM that do not require approval by EASA;

(iii)     conversions of previously Federal Aviation Administration (FAA)- or EASA-approved combinations of units of measurement added to the AFM in a previously approved manner;

(iv)     the addition of aircraft serial numbers to an existing AFM where the aircraft configuration, as related to the AFM, is identical to the configuration of aircraft already covered by that AFM;

(v)      the removal of references to aircraft serial numbers no longer applicable to that AFM; and

(vi)     the translation of an EASA-approved AFM into the language of the State of design or State of registration;

(2)     for AFM supplements issued by STC holders:

(i)       editorial revisions or corrections to the AFM supplement;

(ii)      changes to parts of the AFM supplement that are not required to be approved by EASA;

(iii)     conversions of previously FAA- or EASA-approved combinations of units of measurement added to the AFM supplement in a previously approved manner;

(iv)     the addition of aircraft serial numbers to an existing AFM supplement where the aircraft configuration, as related to the AFM supplement, is identical to that of the aircraft already in that AFM supplement; ‘identical’ means here that all the aircraft have to belong to the same type and model/variant;

(v)      the addition of a new STC to an existing AFM supplement, when this supplement is fully applicable to the new STC;

(vi)     the removal of references to aircraft serial numbers that are no longer applicable to that AFM supplement;

(vii)    the translation of an EASA-approved AFM supplement into the language of the State of design or the State of registration.

3.7     Complementary guidance for classification of changes to environmental protection characteristics See Section 8 of Appendix A to GM 21.A.91.