[Peetwo]

KC on Part 21 realignment and future BASAs - 

Via emails:

To all members.

CASA has a major hurdle to learn how to adopt foreign regulations as was done when CASA adopted FAR Part 21.
CASR Part 21 is way out step with FAR Part 21 that no longer supports the BASA with the United States.

AMROBA has applied the same principles to making CASR Part 21 to Realign CASR Part 21 with FAR Part 21 – we don’t suggest that no additional work will be required to change the numbering system to meet Australian regulatory numbering standards and fine tune with a government personnel review. This is also a task for legislative drafters.

We have also suggested that CASA Engineering management be trained by the FAA in Part 21 certification procedure for products and articles.

AMROBA has added some unique Australian Part 21 requirements – e.g. Limited (ex-military) category aircraft, amateur-built under a ABAA, intermediate category, etc.

We also adjusted Subpart J to align with EASA CS 21, subpart J.

If you are in the design and manufacturing sectors you should review.

The FAA used a 12 months post making the Part for industry to update – this was mainly so quality systems could be implemented.
Many Australian companies already include a quality system and may need little adjustment.

• Out goes Class I, II & III items
  
• All manufacturers , PAH, PMA, ATSO meet one quality system standards
  
• More responsibilities on industry designers and manufacturers.
  
• No Fabrication system – included in manufacturing quality system.
  
• Linked FAR provisions that need adopting also added to rear of Part 21
  
• Noise Part needs adopting so CASA certifications can be accepted globally.
  
• Continuing airworthiness items in FAR Part 26 need to be included in CASR Part 90.
  
• Note – EASA also has a CS 26 with continuing airworthiness items – Part 90 must stay globally aligned.
  

What we do with this proposal if supported by members is give it to government and its department to see if we can get this regulatory change started so we can at least have a regulatory system for Australian manufacturer products and articles for sale globally.

The Department and Foreign Affairs, possibly Department of Trade will all be involved in obtaining BAAs with other countries hopefully, based on this realigned Part 21

Please feel free to pass it on to non-members

Regards

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Ref: https://amroba.org.au/wp-content/uploads...ticles.pdf

MTF...P2