8900.1 CHG 504



Section 3  Safety Assurance System: Phase 3—Design Assessment (SAS Business Process Modules 2, 3, and 4)

2-1216    GENERAL. The Design Assessment (DA) phase is the part of the certification process when the applicant’s manuals and other documents are reviewed indepth to ensure compliance with applicable regulations and conformity to safe operating practices.

NOTE:  These documents may include paper representation or electronic format. Advisory Circular (AC) 145‑9, Guide of Developing and Evaluating Repair Station and Quality Control Manuals, provides guidance to develop a Repair Station Manual (RSM) and Quality Control Manual (QCM). AC 145‑10, Repair Station Training Program, provides guidance to develop a training program.

A.    Organization. An important responsibility of the certification project manager (CPM) is to organize the certification team’s efforts to promptly review the applicant’s manuals and other documents. The Schedule of Events (SOE) determines what will be examined and when. The previously agreed‑upon SOE will determine the priority of items to be reviewed and any additional inspector support or other Federal Aviation Administration (FAA) resources that will be needed beyond the composition of the basic certification team. The DA phase is an intensive process and will most likely require additional resources to accomplish necessary tasks in a timely manner. The certificate‑holding district office (CHDO) certification team may be augmented by other FAA resources.

Indicates new/changed information.

B.    Plan for Review. The plan for review should ensure that each of the required manuals or documents submitted by the applicant will be reviewed in accordance with procedures and criteria outlined in the other volumes of this order. Ensure that the Comprehensive Assessment Plan (CAP) has been developed to complete all elements. Principal inspector (PI) instructions for each DA will include at least the following: “Name of Inspector” conducting the inspection; indication of who is designated as “team coordinator (TC)” and/or “team member;” and the proposed completion date. Any additional Custom Data Collection Tool (C DCT) created by the CPM during initial certification will annotate “initial certification” in the National/Local/Field block when creating the C DCT. The compliance statement directs the inspector to the location in the applicant’s manuals where a compliance procedure is described.

C.    Resource Management. The CPM will provide input to the Front Line Managers (FLM) to help them identify team resources to complete each Element Design Data Collection Tool (ED DCT). The FLMs will determine resource availability and assign TCs and team members to support the plan. The FLM will concur with the CAP.

2-1217    REVIEW OF APPLICANT’S SUBMISSIONS. During this phase, members of the certification team evaluate and approve or accept the applicant’s manuals and any other required documents. Review of the applicant’s submissions should be accomplished by simultaneous reference to Title 14 of the Code of Federal Regulations (14 CFR), the compliance statement, and the appropriate manual or document. The following are examples of typical submissions from applicants during the DA phase. This list is not all‑inclusive, and certain items may not be applicable to a particular type of operation.

    Supervisory personnel résumés outlining proposed supervisory qualifications and compliance histories.

    Applicant submitted ED DCTs or a Custom ED DCT.


    QCM (may be combined with the RSM).

    Training program/manual (may be combined with the RSM or QCM; however, the training program must be approved).

    Exemption requests.

    Letter stating compliance with 14 CFR part 145, § 145.53(c) or (d).

    Hazardous materials (hazmat) program.

    Letter of compliance that all applicable regulatory requirements are addressed.

    Proposed operations specifications (OpSpecs).

2-1218    THE COMPLIANCE STATEMENT. Compliance statement purposes:

A.    Applicable Regulatory Requirements. It ensures that the applicant has adequately addressed all regulatory requirements applicable to the proposed operation.

B.    Intent to Comply with Regulatory Requirements. It aids the certification team in determining where the regulatory requirements have been addressed in the applicant’s manuals, programs, and procedures. In evaluating the applicant’s compliance statement, the certification team may find it helpful to compare (in a side‑by‑side manner) the regulations, the applicant’s manuals, and the compliance statement. The compliance statement documents how the applicant intends to comply with each applicable regulation.

2-1219    OPSPECS. The CPM will coordinate with the applicant and draft OpSpecs in the Web‑based Operations Safety System (WebOPSS).

2-1220    DATA COLLECTION (Module 4A).

A.    Accuracy Verification and Data Analysis. The Certification Project Team (CPT) will verify accuracy of the applicant-completed ED DCTs or Custom ED DCTs and complete their assigned ED DCTs or Custom ED DCTs. The CPT will collect and analyze the data by conducting a data analysis meeting. If the current submission is not of sufficient quality and/or when additional data is necessary, notify the applicant with a written explanation of concerns identified during the data analysis meeting. If a subsequent submission contains minimal concerns which will allow the PI to approve or accept the program with mitigation, schedule and conduct a meeting with applicable members of the CPT and the applicant to discuss and correct the remaining discrepancies.

B.    Letter to the Applicant. The letter must advise the applicant that they must return the next revision as an entire submission accompanied by revised applicant-completed ED DCTs. The applicant will label all documents in the revised submission in sequential order (e.g., Revision B, Revision C). Also, the applicant will use their manual revision process when revising their manuals (e.g., change bars).

NOTE:  The certification team should remember that it is the applicant’s responsibility to develop manuals and procedures that ensure safe operating practices and compliance with the rules.

2-1221    DATA REPORTING (Module 4B). Each team member will then enter their responses into the Safety Assurance System (SAS). Enter “Initial Cert.” in the “Local/Regional/National” field on the “Common Data” screen. Save data by clicking “Submit”.

NOTE:  If an inspector observes any finding(s) not related to their assigned element, or he or she cannot capture it in their assigned element, document the finding(s) in a Dynamic Observation Report (DOR) and notify the inspector(s) working that element.

2-1222    DATA REVIEW (Module 4C). The data reviewer will ensure that data meets the data quality guidelines (DQG) and submit to Analysis, Assessment, and Action (AAA).

2-1223    ANALYSIS AND ASSESSMENT (Module 5A). Along with the identified members of the CPT, the CPM conducts an Element Design Assessment (EDA) meeting to analyze ED DCT collected data by element. The CPM will make a bottom‑line assessment and document it in AAA.

2-1224    ACTION (Module 5B). Follow the Module 5 business process to determine the appropriate course of action for each element.

NOTE:  The applicant must maintain an active project. The CHDO must evaluate an inactive period that exceeds 90 days. Inactivity of greater than 90 days may be cause to terminate the certification process, or you may terminate the process when it is clear that continuing the process will not result in approval or acceptance (i.e., multiple failures of the applicant’s submissions).

RESERVED. Paragraphs 2-1225 through 2-1229.