Use Of Previously Appoved Data

Use of PreviouslyApproved DataPresented to:ACO OutreachBy:Sue McCormickAIR-6C1Date:May 2018Federal AviationAdministration

Reusing Technical DataCommon QuestionsHow do you knowthe data that wasgenerated is stillvalid?At what point in the project isthe data approved?What evidence does theapplicant need to reusethe data?Are there specialconsiderations fordata approved viaa foreignauthority?Using Previous Approved DataFederal AviationAdministration2

Technical DataDescriptive DataSubstantiation Data Drawings and specificationsnecessary to define theconfiguration and the designfeatures; Information on dimensions,materials, and processes; Airworthiness limitations, ifapplicable; and Documents such asinstructions for continuedairworthiness (ICA) andairplane or rotorcraft flightmanuals, if applicable Test results Computations, and Other information necessaryto show that the descriptivedata meets the applicablerequirementsReference §§ 21.29 and 21.31Using Previous Approved DataFederal AviationAdministration3

ApprovedUnless used with reference to another person,means approved by the FAA or any person towhom the FAA has delegated its authority inthe matter concerns, or approved under theprovisions of a bilateral agreement betweenthe US and a foreign country or jurisdictionReference 14 CFR § 1.1Using Previous Approved DataFederal AviationAdministration4

How is Data Approved? Technical data are approved under part 21 usuallywhen the FAA issues a design approval–––––Type Certificate (TC)Supplemental Type Certificate (STC)Parts Manufacturer Approvals (PMA)Technical Standard Orders (TSO)Other methods, i.e. § 21.8(d) Technical data can also be approved in support ofrepairs and alterations such as field approval(block 3 of FAA Form 337) and by using FAA forms8110-3 or 8100-9 Data associated with Part 39 AirworthinessDirectives (e.g., service bulletin or AMOC)Using Previous Approved DataFederal AviationAdministration5

Evidence of Approval FAA or FCAA Documentation– Letter– Stamp– Traceability to Design Approval Designee Approval (DER orODA)– FAA Forms 8110-3 or 8100-9Using Previous Approved DataFederal AviationAdministration6

ReferencesFAA Order 8110.4, 2-6(a)(2) Applicant wants to reuse part from TC design in newdesign Data generated for the first TC is still valid FAA data Use of the part in a new application requires a newshowing of compliance Previously generated data may or may not be adequate(or applicable) to make the new showing of compliance Showing includes activities – like writing compliancereports – in which the applicant presents the variousdata in a logical order with explanations of how the dataprove complianceUsing Previous Approved DataFederal AviationAdministration7

ReferencesFAA Order 8110.51, “Acceptability of PreviouslyApproved Certification Compliance Data from ForeignSources”, Section 4 Current regulations and policy do not specifyacceptable sources of compliance data or themethod of acquiring the data, whether generated bya foreign or domestic applicant Basic principles for accepting data are the same asfor U.S. applicant-generated data. Using and accepting any data to demonstratecompliance must be based on the FAA’s ability toestablish the applicability and validity of the dataUsing Previous Approved DataFederal AviationAdministration8

Determining if data is validThe FAA verifies data is valid by confirming thesteps of the original data acceptance. Typically: Approval of the applicant's test plan, Confirming the conformity of a test article and testsetup, Verifying the qualifications of personnel involved inthe setup, Witnessing and approving the test data, and Ensuring approved test procedures were usedUsing Previous Approved DataFederal AviationAdministration9

Determining if data is applicable Is the data appropriate for an FAAcertification project? We evaluate if the design data approved fora certain use can be appropriately applied toanother use The applicant's showing of identicality,providing rationale for non-interference withany design features of the new model, etc.Using Previous Approved DataFederal AviationAdministration10

Applicant ResponsibilitiesApplicant is still responsible for submitting asufficient data package to the ACO (asrequired by § 21.21(b)) that is necessary toshow that the product meets the applicablerequirements of the Federal AviationRegulationsUsing Previous Approved DataFederal AviationAdministration11

Contact InformationSue McCormickAerospace EngineerDesign Certification Procedures sing Previous Approved DataFederal AviationAdministration12

Approved Data. Approved data means data approved by the FAA. The term “approved” is based on § 1.1, which states: “Approved, u\൮less used with reference to another person, means approved by the FAA or any person to whom the FAA has delegated its authority對 in the matter concerned, or approved under the provisions of a bilateral