AMC No 1 to 21.B.100(b) Level of involvement (LoI) in projects for minor changes and minor repairs

CAA ORS9 Decision No. 1

In contrast to 21.B.100(a), the assessment of the LoI for minor repair designs and minor changes is performed by the CAA at the level of the certification project.

The CAA reviews the information provided by the applicant in accordance with point 21.A.93(b) for novel or unusual features, the complexity of the design and/or the compliance demonstration, as well as the criticality of the design or technology.

An application for the CAA’s approval of a minor change implies that the applicant either does not hold a design organisation approval (DOA) or that the change is outside the DOA holder’s terms of approval. However, the CAA takes into account the performance and experience of the applicant with similar design changes, for which data may be already available at the CAA. The applicant may be also requested to present its experience with similar design changes if insufficient information is available at the CAA.

By definition (see point 21.A.91), a minor change has no appreciable effect on the airworthiness of the product. Therefore, the potential impact of a non-compliance with part of the certification basis regarding the airworthiness or environmental protection aspects of the product should, in most cases, be non-critical.

This facilitates the assessment of the likelihood of an unidentified non-compliance.

A process similar to the one described in AMC 21.B.100(a) and 21.A.15(b)(6) should be used to justify and document the CAA’s LoI.

Following a first assessment of the criticality of the described design or technology, the CAA evaluates the existence of any novel or unusual features, as well as the complexity of the design and/or the compliance demonstration.

Depending on the results of this evaluation, and based on the table below, the CAA determines its LoI as follows:

		Risk class
Non-critical	Non-novel and non-complex	Class A	Class A
	Novel and/or complex	Class B	Class C
Critical	All cases	Class C	Class C
		Level of experience: high or medium	Level of experience: low or unknown

1. Class A: the CAA’s involvement is limited to the review of the information that summarises the main results of the compliance demonstration, without any participation in compliance activities (witnessing of tests, audits, etc.).

2. Class B: in addition to the LoI defined for risk Class A, the CAA’s involvement is limited to the review of those compliance elements that are related to the identified novel or unusual features, complexity of the design and/or compliance demonstration. The CAA may exceptionally participate in the related compliance activities (by witnessing tests, audits, etc.).

3. Class C: the CAA’s involvement is limited to the review of all the compliance documents that are related to the identified criticality of the design or technology, if applicable, or to the identified novel or unusual features. The CAA may participate in the related compliance activities (by witnessing tests, audits, etc.).