EASA definition of Major Mod - where?

[IO540]

In FAA land, it is FAR 43 Appendix A.

Does EASA have a similar definition?

I have seen some spectacular cases lately where a mod on a Euro-reg plane got turned down by EASA, but the proper way to have approached that job would have been to check whether it is a Major Mod at all; if not, the paperwork should be doable locally. One should not invent major mods unless the proposed work is explicitly on some major mod list.

[L-Band]

No EASA make up they own laws, and are becoming a pain in the rear end.
You do not know if your mod is a Major or a Minor one until you put the paperwork into them. I have had a mod to a Helicopter to install an encoder to the Transponder and EASA say this mod is a Major Mod as you are modifying the static system and deemed as hazardous and dangerous as the R22 is certified IFR night and Day!! And that is one of many.
All we are trying to do is comply with the law regarding carriage of mode c.
No such list exists.
L

[IO540]

So, every mod, no matter how small, has to go to EASA?

They must have massive manpower to deal with it all.

[Islander2]

So, every mod, no matter how small, has to go to EASA?Yes, in order to get a project number allocated.

They must have massive manpower to deal with it all.No, having issued the project number I believe they delegate a lot back to the national aviation authorities.

[smitn05]

As others have said its entirely down to EASA. The process is:

Form 32 goes to EASA detailing the mod.

Easa decide MINOR or MAJOR (note any mandatory Flight Manual Supplements will almost certainly be MAJOR - apart from the FMS for IFR approval of the GNS series of Garmins GPS's for which there is an exemption)

EASA provide a project number to CAA / NAA.

If MAJOR - Part 21 Design Org

If MINOR, datapack produced locally and sent to CAA / NAA for approval.

Once approved, an exemption can be requested from CAA/NAA to allow realease back to service pending EASA technical visa.

CAA/NAA send approval details to EASA who issue the Technical Visa.

From experience on avionics I can say that you can push the boundaries quite far in certain areas (we have mods on file for 1 x audio panel, 2 x NAV/COM/GPS, 1 x ADF, 1x DME, 1X XPDR, TCAS and stormscope all under a MINOR), but on the other hand try and get a GTX330 Mode S transponder through with a FMS telling the pilot not all DAPS are available on the aircraft and it will be MAJOR

It also comes down to how you word the title and description of the mod. Failing to put a simple statement in when applying may easily turn an simple MINOR into a MAJOR. You get to know the wording that keeps em happy once you have had enough kicked back at ya!!!

[JOE-FBS]

Minor mod's by an EASA part 21J Design Organisation do not go to EASA. If you don't have access to someone with a DOA then yes, the mod' goes to EASA (or NAA) for a Technical Visa.

The definitions of minor and major are well covered in the part 21 regulations and guidance material.

Organisation Approvals | Design Organisations Approvals (http://www.easa.eu.int/ws_prod/c/c_orgapprodoa_doa.php)

(it's not a rivetting read!)

There is a list of DOA holders here:

http://www.easa.eu.int/ws_prod/c/doc/Org_Appro/easa_doa.pdf

You might find what you need here. If you are really lucky, you'll find one who already has approved the mod; you require.

List of EASA STCs here. I do not know of any central list of minor mod's because, I have said, EASA does not see them.

http://www.easa.europa.eu/ws_prod/c/doc/Design_Appro/STCs/Web%20STC%20list%2008%20October%202008.pdf

I have to say that I don't get all this EASA bashing. I have worked under EASA DOA for the best part of 5 years and find the processes entirely viable and the people entirely helpful.

Sadly, I cannot help with GA aircraft electronics, my EASA recognised skills are in large aircraft interiors.

[IO540]

Thank you Joe.

Can you please tell me where the major mod definitions are?

It is really bad that minor mods need a design authority. Under FAA (whose safety record is as good as the best anywhere else) a minor mod can be done in the field - so long as each part used comes with approved data e.g. TSOd, PMAd, aviation grade part, etc.

EASA is going to continue to pay a price for this - either by people being on foreign registers to avoid silly charges for silly-simple stuff, or by work being done undeclared (which always went on anyway, but you had to have good "contacts").

[wigglyamp]

Joe wasn't saying that all minors require a design authority. Anyone can apply to EASA for a minor mod, just as in the UK, they used to apply to the CAA regional office. Now, if EASA agree it's a minor, they normally task it back to the NAA (UK CAA etc) for technical assessment. There is more paperwork involved than under the old CAA minor route, and the cost is a bit more - the current fee is EU250 for a minor on a light aircraft under 2000kg.

For more information on classification, you can look in the AMC and GM to Part 21 at Agency Measures | Acceptable Means of Compliance and Guidance Material (http://www.easa.europa.eu/ws_prod/g/rg_amcgm.php)
There are some tables in AMC21A-91 which guide you through the decision making process.

If you need a Major mod approved, you can only do this through a Part 21J DOA (Ok - EASA have Alternate Procedures, which are used alot in France as there are very few DOA's, but EASA don't like to use them and will positively attempt to dissuade applicants).
For the priviledge of holding a DOA, you have yearly audits - ours are done directly from Cologne, and we pay surveillance fees of EU2800 per year. (Our speciality is avionics). For minor changes, we are left alone to classify, write and approve our own mods. For majors, EASA may keep the task in-house or delegate it back to an NAA (and this may not necessarily be your own NAA!) Unfortunately EASA fees for Majors are quite a bit higher than we used to pay the CAA - EU1000 for a simple STC such as clearing the AFM supplement for EHS Mode S on a single turboprop such as a PA46.

The system is certainly more onerous than the old CAA minor and major route, but if you stick to the rules, it does seem to work OK.

Regards

[JOE-FBS]

IO540, I think wigglyamp has pointed you in the right direction for where to look in the AMC / GM.

On your point about the FAA, a PMA is in some ways similar to a minor mod (in a previous job, we used minor mod's, done internally with no reference to EASA, to certify after-market foams and covers for airlines, which is sort of how PMA is used in the US). A TSO is a parts approval independent of an aeroplane (or it is for seats anyway). So, if you are fitting parts with PMA or TSO then someone somewhere has already done a lot of approval work with the FAA and is recovering the associated costs in the piece price. No difference from EASA that I can see.

EASA has an exactly parallel system of ETSOs. To apply for one of those, you need Alternative DOA procedures approved by EASA. I have just done that where I work now and it is not onerous or expensive. Bizarrely, a DOA does not allow applications for ETSO so my organisation now has both DOA (for minor mod's) and ADOA (for ETSO). We don't do STCs.

One does not need a minor mod' for every individual aircraft, if Bloggs DOA has written a minor mod' to fit a Scruggs ABC transponder to all TinyCo 123 aeroplanes then you can use that mod' more than once. The difficulty is identifying who, if anyone, has already written a mod' to fit the kit you want to the aeroplane you want. The only way I know to do that is identitfy all the DOAs with relevant privileges and ask them if they have what you want which is a bit of a faff!

[IO540]

Yes, the other way is to write to the manufacturer of the item and ask them if they have sold any to European customers, and if they have, who were these, and then follow the trail. Usually it leads to an avionics shop, and they can vary from being welcoming to reluctant because they are looking to recover the work they put into the mod. So one has to give them some money. But all one actually needs is the local CAA's file reference. It's a real shame there is no central mod database. The UK CAA has its AANs online but I know for a fact that many mods are not on there because they were done either unofficially, or in the mistaken belief that an FAA STC is good enough by itself because of the FAA-CAA treaty.

The whole thing gets a bit more complicated because there is a whole raft of treaties between various EU member states, and the FAA, for mutual certification recognition. However I think that the bottom line with these treaties is that the local CAA still issues its own covering paperwork (like the UK CAA's AAN). Whereas a few (Australia is one I know of) just accept FAA STCs directly, with no local examination.

[wigglyamp]

It's not correct to say that all you need is the CAA's file reference for a minor mod in order to incorporate the same mod to another aircraft. The CAA reference merely states the approval of a data package, but does not include that data. You need the actual data package from the original applicant in order to do the work, so you ensure the work actually complies with what was approved. That's why the avionic shop that produced the original data expects to get paid for it.
As an example, a CAA minor mod could have approved a transponder installation - say a Garmin GTX330 into a TB20. The CAA AD261 approval document (prior to EASA) or EASA Tech visa, would say just that. It wouldn't tell you were or how to mount the antenna, altitude encoder etc, or provide the wiring diagram, instructions for continued airworthiness etc. You only get this data from the owner of the approved data.

It's no different in the US system. You can't copy a 337 from one aircraft and use it again on another - you must submit more data - (it could be identical), to the FAA FSDO, or to an FAA DER, and get the inspector to approve it. If you use an FAA STC, you have to have a permission letter issued by the STC holder allowing you to use their data against a particular aircraft.

[IO540]

Wigglyamp -

You need the actual data package from the original applicant in order to do the work, so you ensure the work actually complies with what was approved

Can one not get the package from the national CAA? They must have a copy of it, to have approved it in the first place?

Partly, what I was getting at is that one needs both the paperwork pack, and the file reference from the national CAA. The latter is needed in case the job was done off the logbooks, so to speak.

[JOE-FBS]

Why should the NAA release the data pack? The applicant has spent time, money and expertise getting the approval, it is in effect their product to sell.

[IO540]

Joe, no disagreement there, but at least the process could be formalised in the form of an STC, and go onto a database where others can find it.

It is a little silly to keep copyright on something which nobody can find.

The FAA 337s are easier to dig out. I recall one can even search by aircraft tail number.

[wigglyamp]

Whilst you can search for FAA 337's against a particular aircraft registration through the FAA in Oklahoma, you can't do a general search to see, for example, if a particular type of equipment has been installed in a particular type of aircraft. FAA 337's have to be filed with the FAA to record that a mod has been installed on that particular aircraft.

You can do a search for STC's with both the FAA and EASA, as well as AAN's with the UK CAA, EMZ approvals with the German LBA etc, but as mentioned previously, once you find who has/owns the STC, you have to pay for the package and rights to use it.

It's becoming more prevalent now for some equipment manufacturers to generate FAA AML STC's - these are Approved Model List STC's which may list hundreds of aircraft types. Garmin have the G600 EFIS on this type of approval, so if you buy the system from Garmin, you get automatic rights to use the STC when installing it. Even in EASA land, there are some AML modifications availabe - Becker have such a minor mod package for their Mode S transponders. Getting an AML STC in Europe is a different proposition, and time will tell if EASA will allow it.

Some STC holders provide a stipulation that the approval is only valid for new equipment - you can't use if for second-hand parts. This is their right as owners of the intellectual property rights. It's no different for the owner of a minor modification package. To create a database of approved minor changes would be huge. My own organisation has well over 1000 approved mods, including STC's and minor changes.