(Reserved)
5.2.1.1 This section describes the hierarchy of policy and guidance within the Defence Aviation Safety Program.
5.2.2.1 The DASP Manual is the central policy and guidance document within the DASP. It is issued by the Defence AA in three volumes:
Volume 1 Requirements for the DASP expands on Joint Directive 21/2021 to establish requirements for the implementation of the DASP; in particular:
legal and governance arrangements
independent safety assurance
the Defence Aviation Safety Regulation
the independent investigation of accidents and incidents
independent reviews of Aviation Safety.
Volume 2 Defence Aviation Safety Regulation establishes all requirements and provisions for the management of Aviation Safety by commanders and managers.
Volume 3 DASP Guidance provides an overview of the DASP and how its various elements collectively achieve the required safety objectives. Volume 3 also provides supporting information to promote understanding of concepts and processes spanning multiple requirements or provisions established through Volumes 1 and 2.
5.2.3.1 The DASR are contained within DASP Manual Volume 2. Their structure and naming convention are based on those applied by CASA and EASA.
5.2.3.2 The DASR comprise:
General Requirements, which define the scope and applicability of the DASR parts as well as establish requirements and provisions that are applicable to a significant proportion of regulated entities.
DASR parts, which are outcome based and specify requirements for each of the specifically regulated Aviation Safety topics. They may include associated supporting information in the form of Acceptable Means of Compliance (AMC) and Guidance Material (GM).
5.2.4.1 The AMC and GM embedded within the DASR are part of a broader range of supporting information published by DASA to promote understanding of, and compliance with, the regulations. All such supporting information is authoritative and does not mandate any action but may address regulatory requirements and provisions established elsewhere.
5.2.4.2 Acceptable Means of Compliance. AMC provides a generic and widely applicable approach to meeting the respective DASR requirements. DASA publishes AMC to provide certainty as to how the required safety outcomes may be achieved. Choosing to implement an AMC relieves the regulated entity of the burden of proving that the means of compliance achieves the intended safety outcome. The regulated entity demonstrates compliance with the DASR by appropriately implementing AMC. Regulated entities are free to propose Alternative Means of Compliance (AltMoC); however, the nature of Aviation Safety regulation means that the use of AltMoC may not be suitable in every instance.
5.2.4.3 Guidance Material. GM helps to illustrate the meaning of a requirement or provision in the DASR. It may provide relevant background, context or an explanation of the policy intent underpinning the respective regulation.
5.2.4.4 Advisory Circulars. Advisory Circulars (ACs) are typically issued to bring an issue to the attention of the target audience or to address a complex topic. ACs may be used to identify acceptable ways to achieve regulatory compliance, either as a temporary transition arrangement or in advance of promulgation as AMC in the DASR. Examples include information regarding emerging Aviation Safety matters, information that enhances compliance understanding for existing regulation, or policy guidance for aviation issues that are not yet regulated but require further understanding.
5.2.4.5 Factsheets. Factsheets are typically issued to provide concise information that may assist those interested in a particular topic.
5.2.5.1 Volume 1 of the DASP Manual requires DASA to ‘issue standards, inclusive of airworthiness codes, as required for the implementation of the DASR’. DASA fulfils this responsibility through prescribing and interpreting the minimum requirements for the design of Defence aircraft, engines, propellers, and other aircraft-related systems and equipment that have an effect on aviation safety.
Prescribing design requirements
5.2.5.2 DASA employs three foundational principles when prescribing design requirements for aviation safety:
DASA recognises the design requirements prescribed by several CAAs and MAAs as providing a sound foundation for the safe design of Defence aircraft and aircraft-related systems and equipment
DASA may prescribe supplementation to these design requirements, where an aspect of a requirement is judged deficient or to support application to Defence’s unique role and operating environment
DASA requires the conduct of a system safety program, to provide a robust means for identifying and analysing aviation hazards during the design process, and for eliminating or minimising the resultant risks so far as is reasonably practicable.
5.2.5.3 To provide assurance that safe flight is achieved through aircraft design, many CAAs/MAAs prescribe airworthiness design requirements, which are usually documented in an ‘Airworthiness Code’ (DASR 21.A.16A refers). An Airworthiness Code is a complete and consistent suite of design requirements that define those attributes of aircraft systems or equipment that underpin safe flight. As the development and maintenance of an Airworthiness Code is a substantial undertaking, rather than define and publish its own Code, DASA recognises Airworthiness Codes prescribed by other CAAs/MAAs (i.e. DASA accepts that these Codes provide a safe foundation for aircraft and aircraft-related systems design).
5.2.5.4 DASA may recognise an Airworthiness Code when the Code as a minimum:
is prescribed by a recognised CAA/MAA
has demonstrated a sound safety record
prescribes a complete and consistent suite of airworthiness design requirements
is supported by associated guidance on how to achieve compliance with the airworthiness design requirements
is accessible, i.e. published by the CAA/MAA in a consolidated and easily accessed format.
5.2.5.5 While aircraft and aircraft-related systems/equipment designs developed to a DASA recognised Airworthiness Code should substantially meet the level of safety expected by Defence, supplementary airworthiness design requirements may need to be prescribed by DASA as a result of:
known inadequacies in the Code
novel features included in the proposed design that are not accommodated by the Code
proposed Defence-unique roles and/or operating environments that are outside the scope of the Code and/or
Defence policies or Australian legislated requirements not being covered by the Code.
5.2.5.6 Compliance with DASA-recognised Codes and prescribed supplementation is the principal means by which safe design of an aircraft and aircraft-related systems/equipment is achieved. However, in isolation, a standards-based approach may not provide a complete basis for certification of an aircraft, or approval of aircraft-related systems/equipment having an effect on aviation safety. Many standards are inherently stove-piped, and therefore further analytical effort is required to identify and control system-level hazards. Further, standards are often written with ‘vanilla’ applications in mind; novel aircraft or systems design features are likely to pose novel hazards, which are not catered for within the standard. As a result, in addition to compliance with design standards, DASA requires the conduct of a system safety program for aircraft designs.
5.2.5.7 System safety is an engineering discipline that embraces safety as a core aspect of any given system design (or design change). System safety programs employ a suite of engineering tools and techniques to identify and analyse aviation safety hazards during the design process, and provide a management framework to evaluate and control the resultant risks. When applied well, a system safety program is an essential adjunct to a standards-based design approach.
5.2.5.8 DASA prescribes supplementation to recognised Codes within a framework of ‘essential’ and ‘recommended’ design requirements. While essential airworthiness design requirements define the level of safety that must be achieved by a design, they are not immutable. DASA, in consultation with the relevant capability manager where applicable, may approve an alternative design requirement in the following circumstances:
where analysis confirms the alternative design requirement achieves an equivalent level of safety
where analysis shows the alternative design requirement, supplemented by operational risk treatments, should achieve an equivalent level of safety or
where enforcing the Essential design requirement would have a marked negative effect on capability or cost, and an alternative (but less safe) design requirement is in Defence’s best interests.
Interpreting design requirements
5.2.5.9 Like other MAAs, DASA accepts that tailoring of design requirements may be necessary to achieve essential military capability. Provided DASA concludes the proposed tailoring is judicious (i.e. that the tailoring represents good judgement or sense) in the ADF operational context, DASA may approve tailoring to the prescribed requirement. Certification or approval against the tailored requirement(s) would then be pursued by the applicant. Any proposed tailoring of design requirements by an applicant for type certification and/or design approval from DASA, which results in changes to prescribed safety criteria, must be supported by documented rationale that includes:
the capability manager's confirmation that a clear (well-defined) and documented capability imperative for the proposed tailoring exists
the applicant's confirmation that compliance with the prescribed standard impedes that capability imperative
the applicant's characterisation of the delta between the prescribed standard and the tailored standard
the applicant's, with the assistance of the capability manager (or delegate), characterisation of the risk due to this delta and
the capability manager's (or delegate's) formal conclusion that the tailored safety criteria presents a credible and defensible level of safety for that Defence aircraft or aircraft-related system/equipment, contextualised for ADF operations.
5.2.5.10 Agreed tailoring, including any essential risk controls to achieve the defined level of safety, will usually be documented in a Military Certification Review Item (MCRI) or equivalent approved by DASA. Detailed MCRI guidance is contained in Section 7.2 Certification.
5.2.5.11 DASA may have two separate roles in the above process. First, as the repository of standards and certification expertise, DASA may advise the capability manager and applicant on how to wisely complete each step. Secondly, DASA needs to gain sufficient confidence in the conduct of the process to assure the Defence AA that the tailoring is indeed judicious. If this second role cannot be achieved, the tailoring of the prescribed requirement(s) cannot be approved and consequently certification or approval of the design would be precluded.
5.2.5.12 DASA also provides interpretation advice and direction on the intent and meaning of airworthiness design requirements, often but not exclusively related to:
the approval of tailored means of compliance for a design requirement
advice on the relevance of proposed design requirements to the design under consideration
advice on pragmatic tailoring of design requirements/standards.
5.2.5.13 The prescription and interpretation of design requirements and standards may be delegated to a Standards-Delegate of the Safety Authority (Standards-DoSA). The functions and responsibilities of DoSAs are detailed in Section 4.3.
Design requirements and WHS
5.2.5.14 Defence aircraft and aircraft-related systems/equipment can present a hazard to aircrew, other aircraft occupants, other airspace users, persons near or under the aircraft flight path, and maintenance and other ground personnel. The Australian Work Health and Safety Act and the Work Health and Safety Regulations (collectively, WHS Legislation) apply to Defence aviation, and therefore Defence has a legal obligation to ensure the health and safety of these persons. The design of the Defence aircraft can, in part, contribute to Defence satisfying this legal obligation, for example:
the aircraft design can promote a safe airborne workplace for aircrew and other occupants through:
reducing the likelihood of a catastrophic in-flight mishap
improving crash survivability for aircraft occupants
implementing design controls for in-aircraft hazards that might injure aircraft occupants
implementing design controls for in-aircraft hazards that might affect the future (post-flight) health of aircraft occupants
the aircraft design can promote the safety of persons near or under the aircraft flight path through:
reducing the likelihood of a catastrophic in-flight mishap
reducing the ground impact energy (mainly relevant to uncrewed aircraft)
the aircraft design can promote the safety of persons in close proximity to a stationary aircraft through:
implementing design controls for aircraft hazards that might injure ground personnel
implementing design controls for aircraft hazards that might affect the future health of ground personnel
incorporating aircraft maintenance instructions that identify reasonably foreseeable hazards to maintenance personnel and present safe maintenance practices.
5.2.5.15 Importantly, DASA approval of prescribed design requirements for a Defence aircraft or aircraft-related systems/equipment, and proposed tailoring, does not constitute endorsement/agreement of the determination that risk has been eliminated or otherwise minimised SFARP. Rather, this must remain a decision for the capability manager (or delegate), as does the enduring management of the residual risk due to the tailoring/alternative standard.
Defence Aviation Safety Design Requirements Manual
5.2.5.16 The Defence Aviation Safety Design Requirements Manual (DASDRM) is DASA’s repository for recognised Codes, and associated prescribed supplementary design requirements, with respect to Defence aircraft and aviation support systems/equipment design.
5.2.5.17 The DASDRM prescribes design requirements for aircraft systems and functions, and aircraft support systems and equipment that have an effect on aviation safety, that are necessary to achieve safe flight in Defence’s proposed Configuration, Role and Environment (CRE). It also prescribes additional design requirements that may further improve the level of safety, and that should be implemented where reasonably practicable. In each case, the DASDRM identifies the hazard(s) that the design requirement is intended to treat, to provide a basis for informed risk management where an aircraft design fails to meet the design requirement.
5.2.5.18 While capability and interoperability is not a specific consideration when establishing that an aircraft is capable of safe flight, robust design for capability and interoperability contributes to mission success, and therefore the safety of the crew. Consequently, while capability and interoperability design requirements are not a primary focus of the DASDRM, design requirements that support capability and interoperability outcomes are included where appropriate.
5.2.5.19 The DASDRM comprises the following six sections:
Section 1 – Application of Airworthiness Design Requirements. This section defines the purpose and scope of the DASDRM and defines the Airworthiness Codes that have been recognised by the Authority as providing a sound foundation for the design of Defence aircraft. It also describes the extent to which airworthiness design requirements contribute to Defence meeting its WHS Legislation obligations. Finally, Section 1 describes the application of capability and interoperability standards to aircraft designs.
Section 2 – Integrated Design Requirements. This section prescribes airworthiness design requirements for those engineering disciplines that pervade most aspects of aircraft systems design or affect multiple systems such as system safety, electromagnetic environmental effects and crash protection.
Section 3 – Aircraft System Design Requirements. This section prescribes airworthiness design requirements for aircraft systems such as communications, navigation, structures (fixed and rotary wing) and propulsion. The only systems included in this section are those where the Authority recognised Airworthiness Codes do not provide satisfactory coverage for Defence aircraft designs.
Section 4 – Uncrewed Aircraft Design Requirements. This section prescribes airworthiness design requirements for UAS.
Section 5 – Aircraft Support Systems. This section prescribes design requirements for non-aircraft systems and ground based equipment, where the systems/equipment have a direct effect on safe flight or aviation safety, such as aeronautical life support equipment, mission planning systems and aerial delivery.
Section 6 - Aerodrome Design Requirements. This section prescribes airworthiness design requirements for Defence aerodromes and heliports.
Introduction
5.2.6.1 DASA may provide formal regulatory advice on any Defence Aviation Safety policy within its remit in order to assist with understanding and compliance. This section provides guidance on seeking such advice. Other queries, such as those concerning DASA business matters, availability of training, staff duties, contact details and updates to ongoing activities do not warrant a formal process and may be addressed through normal lines of communication.
When to make a formal request
5.2.6.2 Only certain types of queries warrant the application of a formal process. Such queries fall into the following broad categories:
requesting interpretation of DASR or other policy:
where the intent is unclear
relating to a situation not explicitly covered by existing policy.
requesting advice regarding implementation of DASR or other policy, such as:
whether a particular approach is compliant
applicability of policy to a particular activity.
Before making a formal request
5.2.6.3 DASA publishes a number of educational and promotional artefacts, which may answer a query without the need to request advice. See Section 5.2.4 Regulatory supporting information and the Education and Promotion page on the DASA web site.
5.2.6.4 The DASP Policy and Guidance Portal (PGP) contains a functional search engine that may assist in searching for specific terminology or phrases. Tips for navigation and searching are contained within the PGP User Guide.
How to make a formal request
5.2.6.5 If formal regulatory advice is required, the preferred method to request advice is via a DASR Query Form (DQF). In the case of uncertainty as to whether a DQF is suitable, email dasa.dasr@defence.gov.au.
5.2.6.6 While an email or phone call directly to a desk officer may seem more efficient, it does not always result in appropriate DASA registration and oversight. Registration informs DASA which areas of policy may require review or additional educational material and builds traceability for future updates. Oversight of queries is important for managing and prioritising DASA workload and ensures that advice follows an appropriate approval process before release. Therefore, DASA reserves the right to redirect any query to written form.
Turnaround Times
5.2.6.7 DASA will negotiate and agree upon a turnaround time with the query initiator as the first action following receipt of a query. DASA will communicate any subsequent changes to that timeline to all involved parties when they become apparent.
5.3.1.1 The DASR make provision for DASA to issue a range of ‘authorisations’ if assured that the regulated community has met, and continues to meet, the requirements and constraints of the DASR. These authorisations may be in the form of certificates, permits, approvals or licenses.
5.3.1.2 This chapter presents an overview of each common aviation safety authorisation.
5.3.2.1 DASA-issued authorisations can broadly be characterised as pertaining to organisations, products and/or personnel. These authorisations are as follows:
organisational authorisations:
Military Air Operator (MAO)
Aerodrome Operator (ADOPR)
Air Cargo Delivery Service Provider (ACDSP)
Air Navigation Service Provider (ANSP)
Air Battle Management Operator (ABMO)
Military Design Organisation (MDO)
Military Production Organisation (MPO)
Approved Maintenance Organisation (AMO)
Continuing Airworthiness Management Organisation (CAMO)
Maintenance Training Organisation (MTO)
Military Type Certificate Holder (MTCH) (currently an implicit approval)
product authorisations:
Military Type Certificate (MTC)
Military Restricted Type Certificate (MRTC)
Military Supplemental Type Certificate (MSTC)
Military Permit to Fly (MPTF)
Military Certificate of Airworthiness (CoA)
Military Restricted Certificate of Airworthiness (RCoA)
Australian Military Technical Standard Order (AUSMTSO)
Approval of Repair Design
Airworthiness Directive (AD)
Aircraft Maintenance Programme (AMP)
Uncrewed Aircraft System Operating Permit (UASOP)
Aerodrome Certificate (ADC)
Other11
personnel authorisations:
Military Aircraft Maintenance Licence (MAML)
Note: DASA directly authorises certain management personnel within approved organisations. These are commonly referred to as ‘Form 4 authorisations’, since they are approved on DASA Form 4, Acceptance of Nominated Management Personnel. In the context of this chapter, those authorisations are considered to be part of the organisational approval process, so they are not listed separately here.
5.3.2.2 The type and scope of authorisations needed for a particular aircraft, aerodrome or air navigation service will depend on a range of factors, for example the involvement of other civil or military Aviation Authorities, the support arrangements implemented by Defence, and so on. These issues are explored elsewhere in this Manual.
5.3.2.3 Annexes A to X individually examine the authorisations listed in paragraph 3. Each annex explains the purpose of the authorisation, the relevant DASR requirements, applying for the authorisation, the responsibilities of the authorisation holder, and DASA’s approach to compliance assurance.
Air Cargo Delivery Service Provider (To be issued)
Air Navigation Service Provider (To be issued)
Military Production Organisation
Approved Maintenance Organisation
Continuing Airworthiness Management Organisation
Maintenance Training Organisation
Military Type Certificate Holder
Military Restricted Type Certificate (To be issued)
Military Supplemental Type Certificate
Military Certificate of Airworthiness
Military Restricted Certificate of Airworthiness (To be issued)
Australian Military Technical Standard Order
Airworthiness Directive (To be issued)
Aircraft Maintenance Programme
Uncrewed Aircraft System Operating Permit
Military Aircraft Maintenance Licence
Air Battle Management Operator (To be issued)
5.4.1.1 This section expands on the Oversight and Enforcement (O&E) policy described in section 4.1.4. Specifically, it explains how regulated entities can expect to be engaged by DASA in assessing initial and ongoing compliance.
5.4.1.2 Regulated entity. The term ‘regulated entity’ is used to describe the different organisations and personnel within the Aviation Safety community that are regulated under DASR, and who are subsequently oversighted by DASA. These entities are typically awarded DASA-issued authorisations, as listed in section DASPMAN Vol 3 Chapter 5.3.2 Aviation Safety Authorisations.
5.4.2.1 The DASA regulatory facing directorates accountable for O&E functions are DAVNOPS, DIA and DCA. The remit of each is detailed below:
DAVNOPS. DAVNOPS responsibilities include:
conducting regulatory compliance assessments of organisations to enable the issuing of:
a Military Air Operator Certificate (MAOC) and corresponding Operational Specification (OpSpec) under DASR.ARO
an Air Navigation Service Provider Certificate (ANSPC) and Service Provision Conditions (SPC) under DASR.ANSP
an Aerodrome Operator Certificate (ADOPRC) and Aerodrome Operator Specification (ADOpSpec) under DASR 139
an Air Cargo Delivery Service Provider Certificate (ACDSPC) and Air Cargo Delivery Operational Specification (ACDOpSpec) under DASR ACD
an Air Battle Management Operator Certificate (ABMOC) and Operational Specification (OpSpec) under DASR ABM
conducting oversight to allow the retention of existing organisation authorisations.
DIA. DIA responsibilities include:
conducting regulatory compliance assessments of organisations and nominated management personnel, to enable the issuing of:
a Military Type Certificate Holder (MTCH) organisation approval and the corresponding platform Type Certificate under DASR Part 21 Subpart B
a Design Organisation Approval (DOA) for engineering design services under DASR Part 21 Subpart J.
a Design Production Organisation Approval (POA) for parts production services under DASR Part 21 Subpart G or DASR Part 21 Subpart F.
conducting oversight to allow the retention of existing organisation and approval holder authorisations, both within the ADF and those contracted to Defence.
DCA. DCA responsibilities include:
conducting regulatory compliance assessments of organisations and nominated management personnel, to enable the issuing of:
DASR Part M Continuing Airworthiness Management Organisations (CAMO) authorisations
DASR Part 145 Maintenance Organisation (DASR 145 MO) authorisations
DASR Part 147 Aircraft Maintenance Training Organisation (DASR 145 AMTO) authorisations
DASR Part 66 Military Aircraft Maintenance Licences (DASR 66 MAML)
conducting oversight to allow the retention of existing organisation and approval holder authorisations, both within the ADF and those contracted to Defence.
5.4.3.1 To gain an initial authorisation, the applicant:
organisation must demonstrate:
a Defence need for the award of the authorisation
a local documented management system that complies with DASR requirements for the proposed scope and level of activities, as defined by their organisation approval basis (ie the set of documents which provides the objective quality evidence necessary to prove compliance with the relevant DASR)
Nominated Management Personnel must demonstrate:
a Defence need for the award of the authorisation
compliance with specific qualification, training and experience requirements.
5.4.3.2 Application. An application for initial authorisation is made on the relevant DASR form, in a manner established by DASA within the respective DASR. Each form describes the information to be included to demonstrate compliance, how the form is to be submitted and who to. Where the DASR does not prescribe a format or manner for the application, the applicant should contact the relevant DASA Directorate for guidance.
5.4.3.3 Initial DASA assessment. The process by which DASA assesses applications varies between organisations and Nominated Management Personnel. For organisations, the assessment process begins with a desk top audit of the organisation’s relevant documentation (i.e. evidence which demonstrates the proposed DASR compliance means are ‘Present’ and ‘Suitable’—see below). For Nominated Management Personnel, DASA assesses compliance with specific qualification, training, and experience requirements.
5.4.3.4 If the applicant is found to be deficient in required content or non-compliant with any relevant DASR requirement, DASA will endeavour to request additional information where practicable. Post assessment the outcome of the application will be notified to the organisation as:
progressed to the next stage
rejected, providing reasons
conditionally progressed, with actions taken by DASA and the applicant to ensure non-compliances are resolved.
5.4.3.5 On-site DASA assessment. An on-site assessment is not an essential part of the initial authorisation process for any DASR authorisation and will be dependent on the nature of the request. DASA will determine if there is a need to conduct an on-site assessment, based on the outcome of the initial assessment, and the scope, level, and complexity of the application. Where conducted, the on-site assessment may include inspection of physical facilities and additional documents, and further face-to-face discussion with applicant staff (for additional ‘Present’, ‘Suitable’ and ‘Operating’ evidence—see below).
5.4.3.6 DASA Organisational Approval. Following the initial assessment and, if conducted, on-site assessment, the DASA team will provide a recommendation for authorisation to the DASA assessment lead. Where appropriate, an authorisation package will be compiled for DG DASA approval. Once approved, authorisation artefacts are dispatched to the applicant at which point the applicant may utilise privileges granted, noting any limitations.
5.4.3.7 Timeline. DASA timelines for the assessment and approval of authorisation applications will depend on the scope and complexity of the authorisation sought, and the level of DASA involvement to support the applicant through the process. DASA will endeavour to collaborate with applicants and action authorisation requests in a timely manner. Approvals may be expedited based on operational or safety imperatives and negotiated accordingly.
5.4.3.8 Post approval. The organisation and Nominated Management Personnel transition from the ‘initial authorisation’ phase to ongoing DASA oversight to retain their authorisation. The applicant is responsible for maintaining ongoing compliance with the relevant DASR and rectifying any future internally identified non-compliances through their own Quality Management System.
5.4.4.1 Changes to authorisations. Should a regulated entity identify a need for authorisation scope/limitations/privilege changes, the entity must apply to DASA (except where otherwise permitted by DASR). Applications for changes to authorisations are made on a form and in a manner established by DASA within the respective DASR, as per their initial authorisation. In actioning the application, DASA will follow the same process as for initial authorisations, adjusting the scope and extent of the assessment to suit the nature of the change. The organisation and Nominated Management Personnel must not implement the proposed change until DASA has issued updated authorisations (except where otherwise permitted by DASR and previously agreed by DASA).
5.4.4.2 Retention of authorisation. DASA authorisations remain extant provided regulated entities retain a Defence need and continue to comply with respective DASR. Once the initial authorisation is awarded, ongoing DASA surveillance and oversight of authorisation holders commences. A key component of an effective regulatory framework is ensuring that regulated organisations have a clear understanding of when, why and how DASA will review ongoing compliance. DASA assures the validity of authorisations by applying an oversight cycle commensurate with the perceived risk to Aviation Safety (generally every 24 months). DASA’s risk-based approach continually reviews safety intelligence collected from active and passive surveillance activities. Based on collected safety intelligence, DASA conducts oversight of authorisation holders, adjusting frequency and scope of oversight to suit the perceived risk.
5.4.5.1 The DASP O&E policy is documented in section 4.1.4, and supports compliance with the DASR through application of a consistent O&E operating model. This section provides Defence tailoring of the civil PSOE model for broader DASR application; noting the PSOE model developed for ICAO Annex 19 is heavily oriented towards Management System maturity assessment vice broader regulation compliance. When considering the Defence aviation context it is important to understand the hazard-based nature of DASR and the regulated community’s SFARP obligation in achieving an acceptable level of safety through a baseline level of compliance.
5.4.5.2 Within this context, DASA will execute oversight activities of a regulated entity using the following Defence-tailored PSOE definitions:
‘Present’ (P). There is evidence that the process, behavior and technology indicators required for DASR compliance are clearly visible and documented within the organisation’s systems.
‘Suitable’ (S). There is evidence the process, behavior and technology indicators are suitable (i.e. regulatory compliant) for the size, nature, context, complexity of the organisation and its services, and the Aviation Safety hazard expected to be mitigated (including consideration of industry expectation for standards, codes, guidance etc).
‘Operating’ (O). There is evidence that the process, behavior and technology indicators are in use and an output is being produced.
‘Effective’ (E). There is evidence that the process outputs , behavior and technology indicators are effective in achieving the desired DASR Aviation Safety hazard control outcome.
Note, effectiveness assessments represent an evolution in compliance methodology, beyond traditional compliance/conformance assessments. In executing an effectiveness assessment, a thorough understanding of the applicable regulation’s aviation safety hazard is required, to ascertain if the process outputs are effectively preventing realisation of that hazard (based on evidence collected during an oversight activity).
5.4.5.3 Where non-compliances or potential problems are identified through PSOE application enforcement action will be taken against the organisation.
5.4.6.1 Findings are issued to highlight an actual or potential non-compliance against DASR. All findings are supported by objective quality evidence and contain adequate detail to support the finding.
5.4.6.2 A Finding will only be issued to remedy an identified non-compliance to a specific regulatory outcome. Once Findings are issued, the regulated entity is responsible for identifying immediate actions, root causes, developing a corrective action plan and implementing corrective actions to address the non-compliance.
5.4.6.3 Finding levels. DASA issues Level 1, 2 and 3 findings, as follows:
Level 1. Any non-compliance with DASR requirements which lowers the safety standard and seriously hazards flight safety.
Level 2. Any non-compliance with DASR requirements which lowers the safety standard and possibly hazards flight safety.
Level 3. Any non-compliance with DASR requirements, or potential problem, that could lower the safety standard and possibly hazards flight safety.
5.4.6.4 DASA Level 1 and 2 Findings. Once a DASA Finding is issued to an organisation, DASA will monitor that actions required to address non-compliances or potential non-compliances are managed and tracked until closure of the Finding. The DASA Level 1 and 2 Findings lifecycle has six distinct stages for regulated organisations, defined on DASR Form 1299 as follows:
Organisational acceptance of Finding. Organisations accept the Finding based on a DASA assessment of the evidence, and respond with proposed dates for the completion of their Immediate Actions and development of their Corrective Action Plan. DASA will assess the response and agree to timeframes, or consult for revised dates.
Where organisations does not agree with the DASA Findings issued, they must formally write to DASA, providing objective evidence as to why the Finding is inappropriate. DASA will assess the additional evidence and respond.
Implementation of Immediate Actions. Organisations implement short-term solutions to contain the non-compliance and manage the associated risk mitigated SFARP. DASA will use DASR Form 1299 to assess the organisation’s actions and document acceptance, or request rework as appropriate.
Root cause analysis. Organisations assess the root causes of the non-compliance. Multiple root cause analysis tools are available to organisations, including the ‘5-Whys’, Bow Tie, Ishikawa diagrams, Apollo Reality Charting, and Tree Diagram. Importantly, there is never just one root cause to a non-compliance, and ‘human error’ is never a valid conclusion.
DASR Form 1299 provides (as a non-compulsory use tool) a ‘5-Whys’ template against which a root cause analysis can be conducted. DASA will use DASR Form 1299 to assess the organisation’s analysis and document acceptance, or request rework as appropriate.
Development of the Corrective Action Plan. Organisations identify a corrective action for each root cause identified, to prevent recurrence. For each corrective action, the organisation defines:
a means by which the effectiveness of the corrective action to prevent reoccurrence will be assessed
the objective quality evidence required to substantiate corrective action effectiveness
a lead person for its implementation, and for reporting implementation and substantiation status
the due date for corrective action completion, cognisant of the need to validate the effectiveness of the corrective action prior to closure
any justification supporting the completion date choice (e.g. time to collect validation evidence, or co-dependency/secondary effects).
DASR Form 1299 provides a Corrective Action Plan template. DASA will use the form to assess the organisation’s plan and document acceptance, or request rework as appropriate.
Implementation of Corrective Actions. Organisations implement the DASA-agreed corrective actions, progressively submitting each completed Corrective Action to DASA for consideration on DASR Form 1299. DASA will track and manage the progress of approved Corrective Action Plans so that a Finding will not fall overdue unless an individual Corrective Action due date has passed.
DASA will use the DASR Form 1299 to assess the organisation’s assessment and document acceptance, or request rework as appropriate.
Finding closure. Once DASA is satisfied that the organisation has implemented and validated the effectiveness of all actions that address the non-compliance, DASA will close the Finding and notify the organisation.
5.4.6.5 Findings Requiring Re-work. Where DASA assesses issues with the quality of the response provided by an organisation in developing/implementing Immediate Actions, Root Cause Analysis, Corrective Action Plan or Corrective Actions it will be returned to the organisation for re-work. In doing so, DASA will provide the necessary details of the cause for re-work for further organisational consideration and action. As part of the re-work process the organisation will generally be required to consider if a Finding Extension is required based upon the impact of the quality issue relative to the extant hazard retention. Where extension to originally agreed submission timelines is necessary the criteria under 5.4.6.6 will be required.
5.4.6.6 DASA Level 3 Findings. Level 3 Findings are notified to the organisation through DASA correspondence (usually an initial authorisation notification or an oversight report). Level 3 Findings are expected to be managed to closure under the organisation’s QMS. DASA will review Level 3 Finding progress during subsequent O&E activities. Inaction against a Level 3 finding does not automatically equate to a Level 2 Finding being issued. However, it may serve as evidence that, when coupled with other safety intelligence, may lead to issue of a Level 2 Finding.
5.4.6.7 DASA Findings extensions. An organisation can request an extension (usually through email to the respective Desk Officer) at any stage in the Findings management process. However, as the organisation owns the Aviation Safety risk associated with the Finding until DASA Finding closure, DASA will only consider these requests based on an assessment of the Finding’s residual risk being mitigated SFARP. Evidence expected to be provided in an extension request should include:
the reason further time is required to complete actions,
details of what has already been completed against Findings root causes and agreed Corrective Actions,
what outstanding Corrective Actions remain and their revised dates for completion, and
justification of how residual aviation safety risk will be controlled SFARP until Corrective Action completion.
5.4.6.8 DASA assesses all extension requests in accordance with the DASA Enforcement Principles at section 4.1.4 and notifies organisations of the outcome. However, organisations should not assume automatic extension approval.
(Reserved)