Aerospace / Aeronautical Engineering Competency Required for Potential Professional Engineers

Aircraft operators and owners are responsible for ensuring their aircraft is airworthy. Aircraft airworthiness is defined in ICAO Annex 8 - Aircraft Airworthiness. The ICAO Annex 8, the Standards and Recommended Practices (SARPs), was published in association with the Chicago Convention 1944 Articles 31 “Certificate of Airworthiness.”

The ICAO Annex 8 also publishes the minimum standards for designing aircraft, engines, and propellers. The aircraft, engines, and propellers must comply with those airworthiness standards. The states that have aircraft design and manufacturing) i.e., the USA and EU published their national airworthiness standards, which are widely accepted by most ICAO member states.

Any changes (modification) and repairs of the aircraft registered and operated in the states are the responsibility of the state’s aviation authority. The ICAO recommended that the states carry out these changes through a Design Organization, particularly for minor changes and repairs. Some will directly to get the Type Certificate Holders (TCH) approval.

However, many states follow the ICAO Annex 8 recommendation, and the states approve these changes through a Design Organization. These Design Organizations must have competent engineers. Competency means having a formal, qualified engineering degree, skills in specific analysis (i.e., structure stress analysis), and experience (particular years in structure analysis work with a DOA).

The engineering work will be according to the airworthiness standards (i.e., FAA FAR Part / EASA CS 25 - Large Airplane, FAA FAR Part /EASA CS 29 - Large Helicopter, FAA FAR Part /EASA CS 27 - Small Helicopter, FAA FAR Part /EASA CS? 23 Small Aeroplane, CS VLA - Very Light Aircraft, CS VLR - Very Light Aircraft, CS UAS - Unmanned Aircraft System). The ICAO Annex 8 has been Amended to include the Remote Pilot Aircraft System (RPAS) to be issued with a Type Certificate (TC) and to qualify for a Certificate of Airworthiness (C of A) for operations in manned aircraft airspace.

The engineering design area will be commonly on those FAR Parts or CS subparts;

1. Subpart B - Flight (flight performance, maneuvers, control, stability, and flight test)

2. Subpart C - Structure (loads, strength, etc.)

3. Subpart D - Design and Construction (materials, protection of structure, cabin airworthiness, etc.)

4. Subpart E - Powerplant (Engine control systems, fuels, oils, etc.)

5. Subpart F - Equipment (electrical, avionics, etc.)

6. Subpart G - Information and Limitation (manuals)

Each subpart contains paragraphs of design requirements, showing engineering works must comply with nine means of compliance codes.

An example of the paragraph is Subpart C, paragraph 25.303. The safety factor: “Unless otherwise specified, a factor of safety of 1.5 must be applied to the prescribed limit load, which is considered an external load on the structure. When a loading condition is prescribed for ultimate loads, a safety factor need not be applied unless otherwise specified”. To do this analysis, we need to establish the limit load of the structure. The limit loads will be found through Subpart B - flights.?

The nine means of compliance are divided into four types: Engineering evaluation, tests, inspections, and equipment qualification.

1. Engineering evaluation (MoC 0-03) covers the determination of compliance, making references to design change documents, the election of methods, determination factors, and determination of definitions (MoC 0). This MoC produces the Type Design Documents or recorded compliance statements in the Compliance Checklist Documents (CCD) or Compliance Checklist (CCL). Under engineering evaluation, MoC 01 is a Design review, which will produce descriptions and drawings of the aeronautical products and their parts and components. The MoC 02 will be calculated and analyzed, producing substantiation reports, such as load, stress, electrical loads analysis, system functioning, etc. The MoC 03 is about conducting a safety Assessment and preparing the Safety Analysis report.

2. Tests (MoC 04-08) cover laboratory tests (MoC 04), Ground Tests (MoC 05), Flight Tests (MoC - 06), and Simulation (MoC 08). These MoCs will produce Test Programmes, Test Reports, and Test Interpretations. Typically, the authorities will approve the test plan or schedule, witness the test program, and finally approve the test reports. These are essential parts of the Type Investigation (TIA) process.

3. Inspection (MoC 7) is a design inspection, for example, for the cabin interior modification, where the justification is requiring the seated passengers to see all emergency signage. Typically, we will do the “Cabin Walk” to verify the design and installation of the cabin interiors. The compliance documents prepared are Inspection or conformity reports.

4. Equipment Qualification (MoC 09) is used when the equipment does not have TSO components certification. Therefore, they must be certified together with the Aircraft or aircraft systems. Thus, the previous MoC may be included.

To conduct the engineering works, the engineers must be competent.

1st competency component is formal knowledge of engineering by having a degree in engineering.

2nd component of competence is having the skill to conduct analysis, test, and simulation, and

3rd component of competency is years of experience in engineering work activities.?

Under the Design approved organization (Part 21 Subpart J), these engineers were moved to the senior level as Show Compliance Engineer (SCE), later to Compliance Verification Engineer (CVE), and finally as the Head of Design Organization (HODO). The SCE is the company's internal approval, CVE is a CAAM-approved signatory, and HODO is the CAAM-nominated post holder (NPH).?

These works are under the law, and noncompliance will be heavily penalized up to lengthy jail terms, which is higher than the penalty under the Engineers Act.

This article was written after the authors received complaints about why most approved design organizations have not accepted Engineering Technology Graduates. The authors also received a request for Mentoring non-engineering graduates, which is very confusing. I hope this article clarifies the engineering work in approved design organizations (Part 21 Subpart J - DOA).

Note: This is only the author's view; the author is Abu Hanifah Haji Abdullah, PEng PC, PTech, who has been in the aerospace industry for more than 30 years and was qualified as a PEng with BEM since 1998. He has the C130 Design Approval from USAF ALC-WR with Airod Sdn Bhd and was the Project Manager for the Eagle Aircraft 150B recertification on stall speed issues. He was with the authority until his early retirement in 2009, and with the authority, he was part of the team for the Malaysian Type Certificate for Eagle 150B and SME-MD3-160. He was also in the team for Mi-171, and Dhruv Helicopter Type Validation, and Type Acceptance for the A320, A330, A340, A380 (early part), Helicopter Superpuma, and Agusta. The Ministry of Transport also appointed him as an investigator for MH-370 and the Helicopter tragedy involving Tan Seri JJ.

He is still active in academics, consultant engineering services, and training for short courses. He is the author of four books in aviation.