21.A.130 Statement of conformity

This GM provides technical guidance on the use of remote ICT to support the issuance of an ‘EASA Form 1’ for prototype and newly produced parts, appliances and products other than complete aircraft. It is the responsibility of the production organisation to assess whether the use of remote ICT constitutes a suitable alternative to the physical inspection of the part, appliance or product in accordance with the applicable requirements. The production organisation that intends to use the remote ICT for such purposes should first discuss the feasibility aspects with its competent authority.

(a)Terminology In the context of this GM, the following terminology is used: ‘issue of an EASA Form 1’ means the issuance of an EASA Form 1 under Part 21 Subpart G by a certifying staff, raise an EASA Form 1 under Part 21 Subpart F by an authorised person, and the validation of an EASA Form 1 under Part 21 Subpart F by a competent authority inspector, except in the case of issuance of an EASA Form 1 for the correction of error(s) on a previously issued certificate and for the recertification of an item from ‘prototype’ to ‘new’ provided that the design data has not changed; ‘authorised staff’ means certifying staff as defined in Part 21 Subpart G, and ‘authorised person’ and ‘competent authority inspector’ as defined in Part 21 Subpart F; ‘item’ means any part, appliance or product other than a complete aircraft; ‘applicable design data’ means non-approved design data for a prototype item and approved design data for a newly produced item; ‘task’ means any inspection, test and/or verification, as described in a documented procedure, which is needed to be performed by an authorised staff before signing an EASA Form 1; ‘remote ICT’ means any real-time video and audio communication tools using information and communication technologies (ICT) whose aim is to enable the performance of the task(s) by the authorised staff from a location different from that where the item is located (on-site).

(b)Regulatory context The following entities may issue an EASA Form 1 for produced items in order to certify their conformity to the applicable design data and, for new items, their condition for safe operation: the holder of a letter of agreement (LoA) that is issued in accordance with Part 21 Subpart F (refer to point 21.A.130(a)); the competent authority in the context of Part 21 Subpart F (refer to point 21.A.130(d)); the holder of a production organisation approval (POA) in accordance with Part 21 Subpart G (refer to point 21.A.163(c)). An EASA Form 1 has to be issued by appropriately qualified authorised staff. Part 21 does not require authorised staff to be on-site when issuing an EASA Form 1, nor how the production organisation and the competent authority shall determine whether the part/appliance/product other than a complete aircraft conforms to the applicable design data and, for a new item, is in a condition for safe operation. These should be detailed in a documented procedure accepted by the competent authority. Part 21 requires: in point 21.A.130(d) that the competent authority validate the EASA Form 1 following inspections performed in accordance with 21.B.135(b) if it finds after the inspection that the product, part or appliance conforms to the applicable design data and is in condition for safe operation; in point 21.A.165(c) that the POA holder has to determine that: other products, parts or appliances are complete and conform to the approved design data and are in a condition for safe operation before issuing an EASA Form 1; other products, parts or appliances conform to the applicable data before issuing an EASA Form 1. Typically, compliance with these requirements is ensured through the on-site presence of the authorised staff in order to guarantee they have appropriate access to the item, as needed. However, compliance with these requirements may be also ensured in certain circumstances, determined as per the considerations described in point (c) below, by remotely conducting the tasks which are needed before the issuance of an EASA Form 1 by the use of remote ICT. The following considerations should be used as guidelines when the on-site presence of the authorised staff is to be replaced by virtual presence, using remote ICT.

(c)The use of remote ICT to support the issuance of an EASA Form 1 Remote ICT may have limitations that could render it unsuitable for some applications. Accordingly, careful consideration and risk management should be applied when determining when to use remote ICT. These considerations, listed below, are however not exhaustive and should not be treated as a checklist.

(1)General considerations As an overarching principle, it needs to be determined whether the nature of the tasks to be performed by the authorised staff allows the use of remote ICT. The facility where the item is located: should be referred to in EASA Form 65 or EASA Form 55, directly or indirectly by reference to the corresponding section of the manual or production organisation exposition (POE); or for a POA, should be a facility from where a POE procedure related to point 21.A.139(b)(1)(xv) authorises the issuance of an EASA Form 1. The complexity, novelty and safety criticality of the item to be released with the EASA Form 1 should be taken into account. The level of competence and experience of the personnel in the use of the particular procedures and equipment that will be used to perform the tasks before issuing EASA Form 1. Previous experience of the organisation / confidence in the organisation’s inspection system / quality system / management system. The appropriateness of the inspection and test instruments and/or equipment, especially if used to evaluate qualitative aspects of a product, part or appliance.

(2)Equipment and set-up considerations The suitability of video resolution, fidelity, and field of view for the task being performed. The need for multiple cameras, imaging systems or microphones, and whether the person that performs or witnesses the tasks can switch between them, or direct them to be switched, and has the possibility to stop the process, ask a question, move the equipment, etc. The controllability of viewing direction, zoom, and lighting. The appropriateness of audio fidelity for the evaluation being conducted. Whether real-time, uninterrupted communication between the person(s) authorised to remotely witness the activity (authorised staff) and the personnel performing it exists at the location where the item is located. The need for unique testing devices or equipment (for example, fast-frame cameras, special lighting conditions, sensitive listening devices, mobile phones with cameras for HD video calls). Whether personnel have been adequately trained in the proper set-up, validation and use of the technology, tools and/or equipment to be used. The need for the recording of audio and video data, as well for its retention or for the retention of other information.

(3)Cybersecurity considerations There are cases where the facilities where the tasks have to be performed are subject to strict security limitations. When using remote ICT for the tasks needed before issuing an EASA Form 1, it is the responsibility of the organisation to provide an equivalent level of security, therefore the person that is responsible for IT security within the organisation should concur to the ICT technology before proceeding.

(4)Documenting the use of the remote ICT The documented processes (procedures) developed by the holder of a letter of agreement (LoA) or a POA should be accepted by the competent authority, and should describe the following: the risk assessment process required to determine the appropriateness of the remote ICT taking into account the above-mentioned considerations; the tasks to be performed, including preparation activities, inspections, tests, verifications to be done, personnel involved in the remote ICT activities and their level of competence; that it is necessary to guarantee that authorised staff have access to all necessary data (e.g. drawings, schematics, datasheets, etc.) they require in order to determine that the item conforms to the applicable design data, and how this can be ensured; how remote ICT will be used in real time (not pre-recorded) so that authorised staff may direct the performance of the tasks as if it were conducted in-person, on-site, with the aid of the equipment or the personnel supporting the activity at the remote location; the procedures for conducting a reinspection in case the equipment malfunctions or the process fails to yield acceptable results; a reinspection using remote ICT may be accomplished after correcting the malfunction or process, or by an actual on-site inspection; how authorised staff should record and communicate any difficulties or concerns regarding the process so that the organisation can improve its programme; how the use of the remote ICT will be documented in the required records; and how the organisation’s IT security is ensured throughout the remote ICT process (data protection and intellectual property of the organisation also need to be safeguarded).

A. INTRODUCTION This AMC relates specifically to the use of the EASA Form 1 for manufacturing purposes under Part 21 Subpart F. It can be used as a supplement to the completion instructions in Part 21, Appendix I which covers the use of the EASA Form 1.

1.PURPOSE AND USE The EASA Form 1 is prepared and signed by the manufacturer. For production under Part 21 Subpart F it is presented for validation by the competent authority. Under Subpart F the certificate may only be issued by the competent authority. A mixture of items released under Subpart G and under Subpart F of Part 21 is not permitted on the same certificate.

2.GENERAL FORMAT Refer to Part 21 Appendix I.

3.COPIES Refer to Part 21 Appendix I. The Part 21 Subpart F originator must retain a copy of the certificate in a form that allows verification of original data.

4.ERROR(S) ON THE CERTIFICATE If an end user finds an error(s) on a certificate, they must identify it/them in writing to the originator. The originator may prepare and sign a new certificate for validation by the competent authority if they can verify and correct the error(s). The new certificate must have a new tracking number, signature and date. The request for a new certificate may be honoured without re-verification of the item(s) condition. The new certificate is not a statement of current condition and should refer to the previous certificate in block 12 by the following statement: ‘This certificate corrects the error(s) in block(s) [enter block(s) corrected] of the certificate [enter original tracking number] dated [enter original issuance date] and does not cover conformity/condition/release to service.’ Both certificates should be retained according to the retention period associated with the first.

5.COMPLETION OF THE CERTIFICATE BY THE ORIGINATOR Refer to Part 21 Appendix I for completion of the certificate. Specific Part 21 Subpart F instructions that differ from the Part 21 Appendix I are provided below. Block 1 – Approving competent authority/Country State the name and country of the competent authority under whose jurisdiction this certificate is issued. When the competent authority is the Agency, ‘EASA’ must be stated. Block 12 – Remarks Examples of conditions which would necessitate statements in Block 12 are: a) When the certificate is used for prototype purposes, the following statement must be entered at the beginning of Block 12: ‘NOT ELIGIBLE FOR INSTALLATION ON IN-SERVICE TYPE-CERTIFICATED AIRCRAFT’. b) Re-certification of items from ‘prototype’ (conformity only to non-approved data) to ‘new’ (conformity to approved data and in a condition for safe operation) once the applicable design data is approved. The following statement must be entered in Block 12: RE-CERTIFICATION OF ITEMS FROM ‘PROTOTYPE’ TO ‘NEW’: THIS DOCUMENT CERTIFIES THE APPROVAL OF THE DESIGN DATA [insert TC/STC number, revision level], DATED [insert date if necessary for identification of revision status], TO WHICH THIS ITEM (THESE ITEMS) WAS (WERE) MANUFACTURED. c) When a new certificate is issued to correct error(s), the following statement must be entered in Block 12: ‘THIS CERTIFICATE CORRECTS THE ERROR(S) IN BLOCK(S) [enter block(s) corrected] OF THE CERTIFICATE [enter original tracking number] DATED [enter original issuance date] AND DOES NOT COVER CONFORMITY/CONDITION/RELEASE TO SERVICE’. d) In case of an engine, when the competent authority has granted an exemption from the environmental protection requirements, the following statement must be entered in block 12: ‘ENGINE EXEMPTED FROM [REFERENCE TO THE TYPE OF EMISSION] EMISSIONS ENVIRONMENTAL PROTECTION REQUIREMENT’ Additionally, for production under Subpart F, this block must include the Statement of Conformity by the manufacturer under 21.A.130. For this purpose, the appropriate Block 13a statement must be included in the block 12 and not referenced in a separate document. The statement may be pre-printed, computer generated or stamped, and must be followed by the signature of the manufacturer’s authorised person under 21.A.130(a), the name and the position/identification of such person and the date of the signature. Block 13b – Authorised Signature This space shall be completed with the signature of the competent authority representative validating the Block 12 manufacturer Statement of Conformity, under 21.A.130(d). To aid recognition, a unique number identifying the representative may be added. Block 13c – Approval/Authorisation Number Enter the authorisation number reference. This number or reference is given by the competent authority to the manufacturer working under Part 21 Subpart F.

APPLICABLE ENGINE EXHAUST EMISSIONS REQUIREMENTS This determination is made according to the data provided by the engine type-certificate holder. It should be noted that the competent authority has the possibility to grant exemptions from these requirements as noted in Chapter 2, paragraph 2.1.1 and Chapter 4, paragraph 4.1.1 of Part III of Volume II of Annex 16 to the Chicago Convention. When such an exemption is granted, the competent authority: takes into account the number of exempted engines that will be produced and their impact on the environment; considers imposing a time limit on the production of such engines; and issues an exemption document. ICAO Doc 9501 ‘Environmental Technical Manual’ Volume II provides guidance on the issuing of exemptions.

DEFINITIONS OF ENGINE TYPE CERTIFICATION DATE AND PRODUCTION DATE Volume II of Annex 16 to the Chicago Convention contains three different references to applicability dates:

1.the ‘date of manufacture for the first individual production model’, which refers to the date when the type certificate is issued for the engine type or model;

2.the ‘date of application for a type certificate’, which refers to the application date to the certificating authority of the State of Design of the engine type certification; and

3.the ‘date of manufacture for the individual engine’, which refers to the production date of a specific engine serial number (date of EASA Form 1). Point 1 refers to the date of the first engine EASA Form 1 issued after the completion of the engine production pass-off test. Point 3 refers to the date used in the application of the engine emissions production cut-off requirement, on or after which all in-production engine models must meet a certain emissions standard. 21.A.130(b)(4)(i) includes the applicable production requirements for aircraft engine emissions. ICAO Doc 9501 ‘Environmental Technical Manual’ Volume II provides guidance on these applicability dates.

APPLICABLE AEROPLANE CO2 EMISSIONS REQUIREMENTS This determination is made according to the data provided by the aeroplane type-certificate holder. This data should allow the determination of whether the aeroplane complies with the CO2 emissions applicability requirements in Chapter 2, paragraph 2.1.1 of Part II of Volume III of Annex 16 to the Chicago Convention. It should be noted that the competent authority has the possibility to grant exemptions as noted in Chapter 1, paragraph 1.11 and Chapter 2, paragraph 2.1.3 of Part II of Volume III of Annex 16 to the Chicago Convention,. When such an exemption is granted, the competent authority: takes into account the number of exempted aeroplanes that will be produced and their impact on the environment; and issues an exemption document. ICAO Doc 9501 ‘Environmental Technical Manual’ Volume III provides guidance on the issuing of exemptions.

It is the responsibility of the applicant to ensure that each and every product, part and appliance conforms to the applicable design data and is in condition for safe operation before issuing and signing the relevant statement of conformity. During manufacture, the applicant is expected to use such facilities, systems, processes and procedures as are described in the Manual and have been previously agreed with the competent authority. The competent authority must then make such inspection and investigation of records and product, part or appliance as are necessary to determine that the agreed facilities, systems, processes and procedures have been used, and that the statement of conformity may be regarded as a valid document. To enable timely inspection and investigation by the competent authority, the statement of conformity must be prepared and submitted to the competent authority immediately upon satisfactory completion of final production inspection and test.

Upon transfer of ownership: a) For a complete aircraft, whether or not an application for a certificate of airworthiness is to be made, an EASA Form 52 must be completed and submitted to the competent authority for validation. b) For anything other than a complete aircraft an EASA Form 52 is inappropriate, and an EASA Form 1 must be completed and submitted to the competent authority for validation. NOTE: If there is any significant delay between the last production task and presentation of the EASA Form 52 or EASA Form 1 to the competent authority, then additional evidence relating to the storage, preservation and maintenance of the item since its production must be presented to the competent authority.

This GM provides technical guidance on the use of remote ICT to support the issuance of an ‘EASA Form 1’ for prototype and newly produced parts, appliances and products other than complete aircraft. It is the responsibility of the production organisation to assess whether the use of remote ICT constitutes a suitable alternative to the physical inspection of the part, appliance or product in accordance with the applicable requirements. The production organisation that intends to use the remote ICT for such purposes should first discuss the feasibility aspects with its competent authority.

(a)Terminology In the context of this GM, the following terminology is used: ‘issue of an EASA Form 1’ means the issuance of an EASA Form 1 under Part 21 Subpart G by a certifying staff, raise an EASA Form 1 under Part 21 Subpart F by an authorised person, and the validation of an EASA Form 1 under Part 21 Subpart F by a competent authority inspector, except in the case of issuance of an EASA Form 1 for the correction of error(s) on a previously issued certificate and for the recertification of an item from ‘prototype’ to ‘new’ provided that the design data has not changed; ‘authorised staff’ means certifying staff as defined in Part 21 Subpart G, and ‘authorised person’ and ‘competent authority inspector’ as defined in Part 21 Subpart F; ‘item’ means any part, appliance or product other than a complete aircraft; ‘applicable design data’ means non-approved design data for a prototype item and approved design data for a newly produced item; ‘task’ means any inspection, test and/or verification, as described in a documented procedure, which is needed to be performed by an authorised staff before signing an EASA Form 1; ‘remote ICT’ means any real-time video and audio communication tools using information and communication technologies (ICT) whose aim is to enable the performance of the task(s) by the authorised staff from a location different from that where the item is located (on-site).

(b)Regulatory context The following entities may issue an EASA Form 1 for produced items in order to certify their conformity to the applicable design data and, for new items, their condition for safe operation: the holder of a letter of agreement (LoA) that is issued in accordance with Part 21 Subpart F (refer to point 21.A.130(a)); the competent authority in the context of Part 21 Subpart F (refer to point 21.A.130(d)); the holder of a production organisation approval (POA) in accordance with Part 21 Subpart G (refer to point 21.A.163(c)). An EASA Form 1 has to be issued by appropriately qualified authorised staff. Part 21 does not require authorised staff to be on-site when issuing an EASA Form 1, nor how the production organisation and the competent authority shall determine whether the part/appliance/product other than a complete aircraft conforms to the applicable design data and, for a new item, is in a condition for safe operation. These should be detailed in a documented procedure accepted by the competent authority. Part 21 requires: in point 21.A.130(d) that the competent authority validate the EASA Form 1 following inspections performed in accordance with 21.B.135(b) if it finds after the inspection that the product, part or appliance conforms to the applicable design data and is in condition for safe operation; in point 21.A.165(c) that the POA holder has to determine that: other products, parts or appliances are complete and conform to the approved design data and are in a condition for safe operation before issuing an EASA Form 1; other products, parts or appliances conform to the applicable data before issuing an EASA Form 1. Typically, compliance with these requirements is ensured through the on-site presence of the authorised staff in order to guarantee they have appropriate access to the item, as needed. However, compliance with these requirements may be also ensured in certain circumstances, determined as per the considerations described in point (c) below, by remotely conducting the tasks which are needed before the issuance of an EASA Form 1 by the use of remote ICT. The following considerations should be used as guidelines when the on-site presence of the authorised staff is to be replaced by virtual presence, using remote ICT.

(c)The use of remote ICT to support the issuance of an EASA Form 1 Remote ICT may have limitations that could render it unsuitable for some applications. Accordingly, careful consideration and risk management should be applied when determining when to use remote ICT. These considerations, listed below, are however not exhaustive and should not be treated as a checklist.

(1)General considerations As an overarching principle, it needs to be determined whether the nature of the tasks to be performed by the authorised staff allows the use of remote ICT. The facility where the item is located: should be referred to in EASA Form 65 or EASA Form 55, directly or indirectly by reference to the corresponding section of the manual or production organisation exposition (POE); or for a POA, should be a facility from where a POE procedure related to point 21.A.139(b)(1)(xv) authorises the issuance of an EASA Form 1. The complexity, novelty and safety criticality of the item to be released with the EASA Form 1 should be taken into account. The level of competence and experience of the personnel in the use of the particular procedures and equipment that will be used to perform the tasks before issuing EASA Form 1. Previous experience of the organisation / confidence in the organisation’s inspection system / quality system / management system. The appropriateness of the inspection and test instruments and/or equipment, especially if used to evaluate qualitative aspects of a product, part or appliance.

(2)Equipment and set-up considerations The suitability of video resolution, fidelity, and field of view for the task being performed. The need for multiple cameras, imaging systems or microphones, and whether the person that performs or witnesses the tasks can switch between them, or direct them to be switched, and has the possibility to stop the process, ask a question, move the equipment, etc. The controllability of viewing direction, zoom, and lighting. The appropriateness of audio fidelity for the evaluation being conducted. Whether real-time, uninterrupted communication between the person(s) authorised to remotely witness the activity (authorised staff) and the personnel performing it exists at the location where the item is located. The need for unique testing devices or equipment (for example, fast-frame cameras, special lighting conditions, sensitive listening devices, mobile phones with cameras for HD video calls). Whether personnel have been adequately trained in the proper set-up, validation and use of the technology, tools and/or equipment to be used. The need for the recording of audio and video data, as well for its retention or for the retention of other information.

(3)Cybersecurity considerations There are cases where the facilities where the tasks have to be performed are subject to strict security limitations. When using remote ICT for the tasks needed before issuing an EASA Form 1, it is the responsibility of the organisation to provide an equivalent level of security, therefore the person that is responsible for IT security within the organisation should concur to the ICT technology before proceeding.

(4)Documenting the use of the remote ICT The documented processes (procedures) developed by the holder of a letter of agreement (LoA) or a POA should be accepted by the competent authority, and should describe the following: the risk assessment process required to determine the appropriateness of the remote ICT taking into account the above-mentioned considerations; the tasks to be performed, including preparation activities, inspections, tests, verifications to be done, personnel involved in the remote ICT activities and their level of competence; that it is necessary to guarantee that authorised staff have access to all necessary data (e.g. drawings, schematics, datasheets, etc.) they require in order to determine that the item conforms to the applicable design data, and how this can be ensured; how remote ICT will be used in real time (not pre-recorded) so that authorised staff may direct the performance of the tasks as if it were conducted in-person, on-site, with the aid of the equipment or the personnel supporting the activity at the remote location; the procedures for conducting a reinspection in case the equipment malfunctions or the process fails to yield acceptable results; a reinspection using remote ICT may be accomplished after correcting the malfunction or process, or by an actual on-site inspection; how authorised staff should record and communicate any difficulties or concerns regarding the process so that the organisation can improve its programme; how the use of the remote ICT will be documented in the required records; and how the organisation’s IT security is ensured throughout the remote ICT process (data protection and intellectual property of the organisation also need to be safeguarded).

This GM provides technical guidance on the use of remote ICT to support the issuance of an ‘EASA Form 1’ for prototype and newly produced parts, appliances and products other than complete aircraft. It is the responsibility of the production organisation to assess whether the use of remote ICT constitutes a suitable alternative to the physical inspection of the part, appliance or product in accordance with the applicable requirements. The production organisation that intends to use the remote ICT for such purposes should first discuss the feasibility aspects with its competent authority.

(a)Terminology In the context of this GM, the following terminology is used: ‘issue of an EASA Form 1’ means the issuance of an EASA Form 1 under Part 21 Subpart G by a certifying staff, raise an EASA Form 1 under Part 21 Subpart F by an authorised person, and the validation of an EASA Form 1 under Part 21 Subpart F by a competent authority inspector, except in the case of issuance of an EASA Form 1 for the correction of error(s) on a previously issued certificate and for the recertification of an item from ‘prototype’ to ‘new’ provided that the design data has not changed; ‘authorised staff’ means certifying staff as defined in Part 21 Subpart G, and ‘authorised person’ and ‘competent authority inspector’ as defined in Part 21 Subpart F; ‘item’ means any part, appliance or product other than a complete aircraft; ‘applicable design data’ means non-approved design data for a prototype item and approved design data for a newly produced item; ‘task’ means any inspection, test and/or verification, as described in a documented procedure, which is needed to be performed by an authorised staff before signing an EASA Form 1; ‘remote ICT’ means any real-time video and audio communication tools using information and communication technologies (ICT) whose aim is to enable the performance of the task(s) by the authorised staff from a location different from that where the item is located (on-site).

(b)Regulatory context The following entities may issue an EASA Form 1 for produced items in order to certify their conformity to the applicable design data and, for new items, their condition for safe operation: the holder of a letter of agreement (LoA) that is issued in accordance with Part 21 Subpart F (refer to point 21.A.130(a)); the competent authority in the context of Part 21 Subpart F (refer to point 21.A.130(d)); the holder of a production organisation approval (POA) in accordance with Part 21 Subpart G (refer to point 21.A.163(c)). An EASA Form 1 has to be issued by appropriately qualified authorised staff. Part 21 does not require authorised staff to be on-site when issuing an EASA Form 1, nor how the production organisation and the competent authority shall determine whether the part/appliance/product other than a complete aircraft conforms to the applicable design data and, for a new item, is in a condition for safe operation. These should be detailed in a documented procedure accepted by the competent authority. Part 21 requires: in point 21.A.130(d) that the competent authority validate the EASA Form 1 following inspections performed in accordance with 21.B.135(b) if it finds after the inspection that the product, part or appliance conforms to the applicable design data and is in condition for safe operation; in point 21.A.165(c) that the POA holder has to determine that: other products, parts or appliances are complete and conform to the approved design data and are in a condition for safe operation before issuing an EASA Form 1; other products, parts or appliances conform to the applicable data before issuing an EASA Form 1. Typically, compliance with these requirements is ensured through the on-site presence of the authorised staff in order to guarantee they have appropriate access to the item, as needed. However, compliance with these requirements may be also ensured in certain circumstances, determined as per the considerations described in point (c) below, by remotely conducting the tasks which are needed before the issuance of an EASA Form 1 by the use of remote ICT. The following considerations should be used as guidelines when the on-site presence of the authorised staff is to be replaced by virtual presence, using remote ICT.

(c)The use of remote ICT to support the issuance of an EASA Form 1 Remote ICT may have limitations that could render it unsuitable for some applications. Accordingly, careful consideration and risk management should be applied when determining when to use remote ICT. These considerations, listed below, are however not exhaustive and should not be treated as a checklist.

(1)General considerations As an overarching principle, it needs to be determined whether the nature of the tasks to be performed by the authorised staff allows the use of remote ICT. The facility where the item is located: should be referred to in EASA Form 65 or EASA Form 55, directly or indirectly by reference to the corresponding section of the manual or production organisation exposition (POE); or for a POA, should be a facility from where a POE procedure related to point 21.A.139(b)(1)(xv) authorises the issuance of an EASA Form 1. The complexity, novelty and safety criticality of the item to be released with the EASA Form 1 should be taken into account. The level of competence and experience of the personnel in the use of the particular procedures and equipment that will be used to perform the tasks before issuing EASA Form 1. Previous experience of the organisation / confidence in the organisation’s inspection system / quality system / management system. The appropriateness of the inspection and test instruments and/or equipment, especially if used to evaluate qualitative aspects of a product, part or appliance.

(2)Equipment and set-up considerations The suitability of video resolution, fidelity, and field of view for the task being performed. The need for multiple cameras, imaging systems or microphones, and whether the person that performs or witnesses the tasks can switch between them, or direct them to be switched, and has the possibility to stop the process, ask a question, move the equipment, etc. The controllability of viewing direction, zoom, and lighting. The appropriateness of audio fidelity for the evaluation being conducted. Whether real-time, uninterrupted communication between the person(s) authorised to remotely witness the activity (authorised staff) and the personnel performing it exists at the location where the item is located. The need for unique testing devices or equipment (for example, fast-frame cameras, special lighting conditions, sensitive listening devices, mobile phones with cameras for HD video calls). Whether personnel have been adequately trained in the proper set-up, validation and use of the technology, tools and/or equipment to be used. The need for the recording of audio and video data, as well for its retention or for the retention of other information.

(3)Cybersecurity considerations There are cases where the facilities where the tasks have to be performed are subject to strict security limitations. When using remote ICT for the tasks needed before issuing an EASA Form 1, it is the responsibility of the organisation to provide an equivalent level of security, therefore the person that is responsible for IT security within the organisation should concur to the ICT technology before proceeding.

(4)Documenting the use of the remote ICT The documented processes (procedures) developed by the holder of a letter of agreement (LoA) or a POA should be accepted by the competent authority, and should describe the following: the risk assessment process required to determine the appropriateness of the remote ICT taking into account the above-mentioned considerations; the tasks to be performed, including preparation activities, inspections, tests, verifications to be done, personnel involved in the remote ICT activities and their level of competence; that it is necessary to guarantee that authorised staff have access to all necessary data (e.g. drawings, schematics, datasheets, etc.) they require in order to determine that the item conforms to the applicable design data, and how this can be ensured; how remote ICT will be used in real time (not pre-recorded) so that authorised staff may direct the performance of the tasks as if it were conducted in-person, on-site, with the aid of the equipment or the personnel supporting the activity at the remote location; the procedures for conducting a reinspection in case the equipment malfunctions or the process fails to yield acceptable results; a reinspection using remote ICT may be accomplished after correcting the malfunction or process, or by an actual on-site inspection; how authorised staff should record and communicate any difficulties or concerns regarding the process so that the organisation can improve its programme; how the use of the remote ICT will be documented in the required records; and how the organisation’s IT security is ensured throughout the remote ICT process (data protection and intellectual property of the organisation also need to be safeguarded).