BCAR A8-21 Audit

BCAR A8-21 Internal Audit

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Personnel

Audit A8-21

Scope (Part 21A.131 and .231)

This requirement applies only to aircraft and associated parts, that are not required to comply with European Regulation (EC) No. 216/2008, i.e. Non-EASA Aircraft. It establishes the procedure for the approval of Non-EASA Aircraft production and/or design organisations and rules governing the rights and obligations of applicants for, and holders of, such approvals. Any organisation involved with the design or production
of EASA Aircraft and/or associated parts, should refer to the appropriate European regulations, see Note 1 below.
NOTE: The European Aviation Safety Agency (EASA) as established in European Regulation (EC) No. 216/2008 commenced operation on 28 September 2003 and at the same time European Commission Regulation (EC) No. 1702/2003, laying down implementing rules for the airworthiness and certification of aircraft, entered into force. For ease of reference, aircraft that are required to comply with Regulation (EC) No. 216/2008 are commonly described as “EASA Aircraft”.
NOTE: BCAR A8-21 was derived from Part 21 and references the corresponding Part 21 paragraph after each subtitle. Part 21 is an annex to European Commission Regulation (EC) No. 748/2012 which has replaced Regulation (EC) No. 1702/2003.
NOTE: A list of Non-EASA aircraft can be found in the CAA publication, CAP 747, ‘Mandatory Requirements for Airworthiness'

Eligibility (Part 21A.133 and .233)

Any natural or legal person (‘organisation’) shall be eligible as an applicant for an approval under this Requirement. For design organisation approval the applicant shall hold or have applied for: a) a type certificate or equivalent, or approval of a major change to the type design or type certificate; or b) a supplemental type certificate or equivalent; or c) a major repair design approval; or d) privileges to approve design changes or repairs; or e) privileges to submit reports to the CAA. For production organisation approval the applicant shall: a) justify that, for a defined scope of work, an approval under this Requirement is appropriate for the purpose of showing conformity with a specific design (see Chapter A8–21 Appendix 1); and b) hold or have applied for an approval of that specific design; or c) have ensured, through an appropriate arrangement with the applicant for, or holder of, an approval of that specific design, satisfactory coordination between production and design

Application (Part 21A.134 and .234)

Each application for a design or production organisation approval shall be made in a form and manner established by the CAA and shall include an outline of the terms of approval and associated privileges requested

Issue of approval (Part 21A.135 and .235)

An organisation shall be entitled to have a design or production organisation approval issued by the CAA when it has demonstrated compliance with the applicable requirements under this Requirement.

Extent of Approval

Design

For design organisation approval the applicant shall hold or have applied for: a) a type certificate or equivalent, or approval of a major change to the type design or type certificate; or b) a supplemental type certificate or equivalent; or c) a major repair design approval; or d) privileges to approve design changes or repairs; or e) privileges to submit reports to the CAA.

Production

For production organisation approval the applicant shall: a) justify that, for a defined scope of work, an approval under this Requirement is appropriate for the purpose of showing conformity with a specific design (see Chapter A8–21 Appendix 1); and b) hold or have applied for an approval of that specific design; or c) have ensured, through an appropriate arrangement with the applicant for, or holder of, an approval of that specific design, satisfactory coordination between production and design.

Exposition (Part 21A.143 and .243)

The organisation shall submit to the CAA an exposition
The exposition shall be amended as necessary to remain an up-to-date description of the organisation, and copies of any amendments shall be supplied to the CAA.
providing the following information
A statement signed by the accountable manager confirming that the exposition and any associated manuals which define the approved organisation’s compliance with this Requirement will be complied with at all times;
The title(s) and names of nominated managers accepted by the CAA
The duties and responsibilities of the manager(s) including matters on which they may deal directly with the CAA on behalf of the organisation
An organisational chart showing associated chains of responsibility of the managers
A list of certifying staff
A general description of man-power resources
A general description of the facilities located at each address specified in the organisation’s certificate of approval
A general description of the scope of work relevant to the terms of approval
The procedure for the notification of organisational changes to the CAA
The amendment procedure for the exposition
A description of the quality system and/or design assurance system and associated procedures
A list of partners and significant subcontractor

Personnel Requirements

Management and staff:
A manager has been nominated by the organisation, and is accountable to the CAA. His or her responsibility within the organisation shall consist of ensuring that all design and production is performed to the required standards and that the organisation is continuously in compliance with the data and procedures identified in the exposition
a person or group of persons have been nominated to ensure that the organisation is in compliance with these Requirements, and are identified, together with the extent of their authority. Such person(s) shall act under the direct authority of the accountable manager referred to in subparagraph i). The persons nominated shall be able to show the appropriate knowledge, background, and experience to discharge their responsibilities.
Staff at all levels have been given appropriate authority to be able to discharge their allocated responsibilities and that there is full and effective coordination within the organisation in respect of airworthiness, noise, fuel venting and exhaust emission data matters.
With regard to certifying staff, authorised by the organisation to sign the documents issued under the privileges of this approval: The knowledge, background (including other functions in the organisation), and experience of the certifying staff is appropriate to discharge their allocated responsibilities
The organisation maintains a record of all certifying staff which shall include details of the scope of their authorisation
Certifying staff are provided with evidence of the scope of their authorisation.

Privileges of the Organisation

Design Privileges (Part21A.263)

16.1 The holder of a design organisation approval shall be entitled to perform design activities within its scope of approval.
16.2 Compliance documents submitted by the holder of a design organisation approval for the purpose of obtaining: a) a type certificate, type approval or approval of a major change; or b) a supplemental type certificate; or c) an APU equipment approval authorisation; or d) a major repair design approval. may be accepted by the CAA without further verification.
16.3 The holder of a design organisation approval shall be entitled,within its terms of approval and under the relevant procedures of the design assurance system: a) to classify changes to the type design or type certificate and repairs as ‘major’ or ‘minor’ (see Chapter A8–21 Appendix 2). b) to approve minor changes to the type design or type certificate and minor repairs. c) to approve minor revisions to the aircraft flight manual and supplements, and issue such revisions containing the following statement: ‘Revision No [YY] to AFM (or supplement) ref. [ZZ] is approved under the authority of the UK CAA design organisation approval reference: [x/y/z]’. d) to approve the design of major repairs to products or Auxiliary Power Units for which it holds the type-certificate or the supplemental type-certificate or ETSO authorisation. e) to issue information or instructions containing the following statement: ‘The technical content of this document is approved under the authority of the UK CAA design organisation approval reference: [x/y/z].’. f) to submit reports to the CAA. NOTE: Paragraph (b) may also be interpreted to include declaration of compliance with the applicable type certification basis for minor changes to the type design, or type certificate, and minor repairs for aircraft operating under the policy framework set out for CAA Oversight of Military Registered Aircraft.

Production Privileges (Part 21A.163)

Pursuant to the terms of approval issued under these requirements the holder of a production organisation approval may: a) perform production activities under theserequirements. b) in the case of complete aircraft and upon presentation of a UK CAA Aircraft Statement of Conformity, obtain an aircraft certificate of airworthiness or permit to fly and, if appropriate, a noise certificate without further showing (see Chapter A8–21 Supplement 2). c) in the case of other products, parts, or appliances issue UK CAA Approved Certificates without further showing (see Chapter A8–21 Supplement 1). d) maintain a new aircraft that it has produced and issue a Certificate of Release to Service in respect of that maintenance (see Chapter A8–21 Supplement 3).

Changes to the Approved Organisation

After the issue of the organisation approval, each change to the organisation, particularly changes to the design assurance or quality system, that is significant to the showing of compliance, conformity or to the airworthiness and environmental protection of the product, part or appliance, shall be approved by the CAA
An application for approval shall be submitted to the CAA and before implementation of the change the organisation shall demonstrate that it will continue to comply with these Requirements after implementation
A change of the location of the facilities of the approved organisation is deemed a change of significance and therefore necessitates application to the CAA

Duration and Continued Validity (Part 21A.159 and .259)

15.1 An organisation approval shall be issued for an unlimited duration. It shall remain valid unless: a) the organisation fails to demonstrate compliance with theapplicable requirements or b) the CAA is prevented by the approved organisation, or any of its partners or subcontractors, from performing its investigations; or c) there is evidence that the organisation cannot maintain satisfactory control of the design or manufacture of products, parts, or appliances under the approval; or d) the organisation no longer meets the eligibility requirements forthis approval; or e) the certificate has been surrenderedor revoked.
15.2 Upon surrender or revocation, the certificate shall be returned to the CAA.

Findings (Part 21A.158 and .258)

14.1 When objective evidence is found showing non-compliance of the holder of an organisation approval with the applicable requirements, the finding shall be classified as follows: a) A level one finding is any non-compliance with these Requirements which could lead to uncontrolled non-compliances with applicable requirements and which could affect the safety of the aircraft. b) A level two finding is any non-compliance with these Requirements which is not classified as level one. c) A level three finding is any item where it has been identified, by objective evidence, to contain potential problems that could lead to a non-compliance of the holder of an organisation approval with the applicable requirements.
14.2 After receipt of notification of findings: a) In case of a level one finding, the holder of the organisation approval shall demonstrate corrective action to the satisfaction of the CAA within a period of no more than 21 working days after written confirmation of the finding. b) In case of level two findings, the corrective action period granted by the CAA shall be appropriate to the nature of the finding but in any case, initially shall not be more than six months. In certain circumstances and subject to the nature of the finding the CAA may extend the six-month period subject to a satisfactory corrective action plan. c) A level three finding shall not require immediate action by the holder of the organisation approval.
14.3 In case of level one or level two findings, the organisation approval may be subject to a partial or full suspension or revocation. The holder of the organisation approval shall provide confirmation of receipt of the notice of suspension or revocation of the organisation approval in a timely manner.

Design

Facilities

Verify office accommodation and test facilities are provided for the management of all planned work

Design Assurance System

The design organisation shall demonstrate that it has established and is able to maintain a design assurance system for the control and supervision of the design, and of design changes, of products, parts and appliances covered by the approval

This design assurance system shall be such as to enable the organisation

To ensure that the design of the products, parts and appliances or the design change thereof, comply with the applicable type certification basis and environmental protection requirements
And ensure that its responsibilities are properly discharged in accordance with the appropriate provisions of the requirement & the terms of approval issued under this requirement
To independently monitor the compliance with, and adequacy of, the documented procedures of the system. This monitoring shall include a feed-back system to a person or a group of persons having the responsibility to ensure corrective actions

Design Compliance Verification (CVE)

The design assurance system shall include an independent checking function of the showings of compliance
The design organisation shall specify the manner in which the design assurance system accounts for the acceptability of the parts or appliances designed or the tasks performed by partners or subcontractor according to methods which are the subject of written procedures

Design Approval

To classify changes to the type design or type certificate and repairs as ‘major’ or ‘minor’ (see Chapter A8–21 Appendix 2)
To approve minor changes to the type design or type certificate and minor repairs
To approve minor revisions to the aircraft flight manual and supplements, and issue such revisions containing the following statement: ‘Revision No [YY] to AFM (or such revisions containing the following statement: ‘Revision No [YY] to AFM (or supplement) ref. [ZZ] is approved under the authority of the UK CAA design organisation approval reference: [x/y/z]
To approve the design of major repairs to products or Auxiliary Power Units for which it holds the type-certificate or the supplemental type-certificate or ETSO authorisation. NOTE: RTA would not work with APU's under STC or ETSO authorisation. Not written in the scope of approval
To submit reports to the CAA.

Components, Tools & Equipment

With regard to general approval requirements, facilities, working conditions, equipment and tools, processes and associated materials are adequate to discharge the organisation's obligations under this Requirement.

Approved Data

Does the organization have a defined design process that ensures compliance, including the use of approved design data and procedures for addressing changes or deviations in coordination with the design approval holder

Works Orders & Contracts

Does the work order and/or contract clearly define the scope of work
Is a work order generated or contract review undertaken?

Design Performance

Is there a documented process to ensure that the design meets all performance requirements as specified in BCAR A8-21, and are these validated through appropriate testing and analysis in coordination with the design approval holder?

Component Maintenance (Design)

Maintain a new aircraft that it has produced and issue a Certificate of Release to Service in respect of that maintenance (see Chapter A8–21 Supplement 3).

Component Release to Service (Design)

UK CAA Aircraft Statement of conformity i.a.w. Supplement 2 of BCAR A8-21

Design Records

Record all details of work carried out

Approval Obigation

The holder of an organisation approval shall, as applicable:
Ensure that the exposition and the documents to which it refers, are used as basic working documents within the organisation
Maintain the organisation in conformity with the data and procedures approved for the organisation approval
Determine that the design of products, or changes or repairs thereof, as applicable, comply with applicable requirements and have no unsafe feature
Except for minor changes or repairs approved under the privileges of the design organisation approval, provide to the CAA statements and associated documentation confirming compliance
Ensure that required manuals or instructions for continued airworthiness, or changes thereof, are reviewed and approved either by the organisation or the CAA as appropriate and are provided to each known owner of aircraft affected
Provide to the CAA information or instructions related to Airworthiness Directives and Mandatory Permit Directives
Determine that each completed aircraft conforms to the type design and is in condition for safe operation prior to submitting a UK CAA Aircraft Statement of Conformity
Determine that other products, parts or appliances are complete and conform to the approved design data and are in condition for safe operation before issuing a UK CAA Approved Certificate to certify airworthiness, and additionally in case of engines, determine according to data provided by the engine type approval holder that each completed engine is in compliance with the applicable emissions requirements, current at the date of manufacture of the engine, to certify emissions compliance; or determine that other products, parts or appliances conform to the applicable data before issuing UK CAA Approved Certificate as a conformity certificate
Record all details of work carried out
Establish and maintain an internal occurrence reporting system in the interest of safety, to enable the collection and assessment of occurrence reports in order to identify adverse trends or to address deficiencies, and to extract reportable occurrences. This system shall include evaluation of relevant information relating to occurrences and the promulgation of related information
Report to the holder of the type approval or design approval, all cases where products, parts or appliances have been released by the production organisation and subsequently identified to have possible deviations from the applicable design data, and investigate with the holder of the type approval or design approval in order to identify those deviations which could lead to an unsafe condition
Report to the CAA the deviations which could lead to an unsafe condition identified according to subparagraph i). Such reports shall be made in a form and manner established by the CAA
Where the holder of the production organisation approval is acting as a supplier to another production organisation, report also to that other organisation all cases where it has released products, parts or appliances to that organisation and subsequently identified them to have possible deviations from the applicable design data
Provide assistance to the holder of the type approval or design approval in dealing with any continuing airworthiness actions that are related to the products parts or appliances that have been produced
Establish an archiving system incorporating requirements imposed on its partners, suppliers and subcontractors ensuring conservation of the data used to justify conformity of the products, parts or appliances. Such data shall be held at the disposal of the CAA and be retained in order to provide the information necessary to ensure the continuing airworthiness of the products, parts or appliances
Where, under its terms of approval, the holder issues a Certificate of Release to Service, determine that each completed aircraft has been subjected to necessary maintenance and is in condition for safe operation, prior to issuing the certificate.

Production

Facilities

Verify office accommodation and test facilities are provided for the management of all planned work

Production Quality System

The production organisation shall demonstrate that it has established and is able to maintain a documented quality system. This quality system shall be such as to enable the organisation to ensure that each product, part or appliance produced by the organisation or by its partners, or supplied from or subcontracted to outside parties, conforms to the applicable design data and is in condition for safe operation, and thus exercise the privileges granted under this Requirement
The quality system shall contain as applicable within the scope of approval, control procedures for
Document issue, approval, or change
Vendor and subcontractor assessment audit and control
Verification that incoming products, parts, materials, and equipment, including items supplied new or used by buyers of products, are as specified in the applicable design data
Identification and traceability
Manufacturing processes
Inspection and testing, including production flight test
Calibration of tools, jigs, and test equipment
Non conforming item control
Airworthiness co-ordination with the applicant for, or holder of, the design approval
Records completion and retention
Personnel competence and qualification
Issue of airworthiness release documents
Handling, storage and packing
Internal quality audits and resulting corrective actions
Work within the terms of approval performed at any location other than the approved facilities
Work carried out after completion of production but prior to delivery, to maintain the aircraft in a condition for safe operation
The control procedures need to include specific provisions for any critical parts
an independent quality assurance function to monitor compliance with, and adequacy of, the documented procedures of the quality system. This monitoring shall include a feedback system to the person or group of persons referred to in sub-paragraph 8.1 c) ii) and ultimately to the manager referred to in sub-paragraph 8.1 c) i) to ensure, as necessary, corrective action

Production Certificate of Release to Service

Determine that other products, parts or appliances conform to the applicable data before issuing UK CAA Approved Certificate as a conformity certificate

Component Maintenance (Production)

Maintain a new component that it has produced & issue a Certificate of Release to Service in respect of that maintenance

Component Release to Service (Production)

Certificate of Release to Service on new parts i.a.w Supplement 1 of BCAR A8-21 (Approved Certificate)

Production Records

Are production records, (PJC's, Production Job Card), maintained to demonstrate conformity with approved design data, and do they provide traceability for materials, processes, and personnel involved?
Has the organization established an archiving system that ensures the conservation of data used to justify conformity of products, parts, or appliances, including requirements imposed on partners, suppliers, and subcontractors? Is this data readily available to the CAA and retained for ensuring the continuing airworthiness of the products, parts, or appliances

Quality Assurance & Auditing

Has a documented program of internal audits been implemented, and are audits conducted regularly to ensure compliance with regulatory and organizational quality standards?
Are suitably qualified and competent personnel appointed, and have they been granted the authority and resources necessary to perform quality assurance tasks effectively?
Does the quality department maintain effective communication and reporting with the Civil Aviation Authority (CAA) to ensure ongoing compliance with BCAR A8-21 requirements?
Are processes in place for identifying, recording, and resolving non-conformances, and is there evidence that corrective actions are implemented and monitored for effectiveness?
Does the quality department have sufficient independence and authority within the organization to identify and address non-conformances without external pressure?