(a)Applicability of point 21L.A.67 Point 21L.A.67 should be complied with by applicants for the approval of a minor change to a type certificate (TC), and by design organisation approval (DOA) holders that approve minor changes under their own privileges. Point 21L.A.67(c), however, only applies to projects for which an application is submitted to EASA. For DOA holders that approve minor changes under their privileges, the justification of compliance and the declaration of compliance required by point 21L.A.67(b) should be produced but do not need to be submitted to EASA. They should be, however, kept on record and submitted to EASA on request during its DOA continued surveillance process.
(b)The approval process The approval process comprises the following steps: Note: Steps 1, 2 and 4 should be followed only by applicants for minor changes approved by EASA. DOA holders that approve minor changes under their privileges should refer to AMC No 1 to 21.A.263(c)(2) or AMC No 2 to 21.A.263(c)(2), as applicable to their approval process.
(1)Application When the minor change is approved by EASA, an application should be submitted to EASA as described in point 21L.A.65 and in AMC 21L.A.65.
(2)Certification basis
(3)Justification of compliance
(4)Declaration of compliance
(c)Certification basis The certification basis for a minor change consists of a subset of the elements of the product’s certification basis ‘incorporated by reference in the type certificate’. The certification basis ‘incorporated by reference in the type certificate’ is the certification basis for the product as recorded in the type certificate data sheet (TCDS) for the product type/model in the applicable configuration(s). The certification basis contains the applicable airworthiness and environmental protection requirements specified by reference to their amendment level, as complemented by special conditions, equivalent safety findings, deviations, a proposed ‘elect to comply’, etc., as applicable. By way of derogation from the above, CSs that became applicable after those incorporated by reference in the TC may be used for the approval of a minor change (see the guidance below on certification specifications that became applicable after those ‘incorporated by reference in the type certificate’). If other changes are required for the embodiment of the minor change, the certification basis corresponding to the product modified by these other changes should also be considered when determining the certification basis for the minor change.
(d)Justification of compliance required by point 21L.A.67(c) The applicant should justify compliance with the certification basis under point 21L.A.67(a) for all areas that are either physically changed or functionally affected by the minor change.
(1)Means of compliance: the applicant should define and record the means (calculation, test or analysis, etc.) by which compliance is demonstrated. Appendix A to AMC1 21L.A.24(b) may be used to describe how compliance is demonstrated.
(2)Compliance documents: the compliance demonstration should be recorded in compliance documents. For minor changes, one comprehensive compliance document may be sufficient, provided that it contains evidence of all aspects of the compliance demonstration. See also the additional guidance in point (e) below.
(3)Aircraft manuals: where applicable, supplements to manuals (e.g. aircraft flight manual (AFM), aircraft maintenance manual (AMM), etc.) may be issued. See also additional guidance in point (f) below on embodiment/installation instructions.
(e)Definition of the change to the type certificate The change to the type certificate should be defined in accordance with GM 21L.A.61.
(f)Embodiment/installation instructions The instructions for the embodiment/installation of the change (e.g. service bulletin, modification bulletin, production work order, etc.) should be defined. This may include the installation procedure, the required material, etc.
(g)Certification specifications that are applicable to the product on the date of the application for the change
(1)Minor changes are those changes that do not affect the airworthiness of the product. This means that the certification basis for the minor change may consist of the items of the certification basis incorporated by reference in the TCDS of the product type/model, and normally it should not be necessary for a minor change to use certification specifications that became applicable after those that are incorporated by reference in the type certificate.
(2)On the other hand, the applicant may elect to use the certification specifications that are applicable to the product on the date of the application for the change for the compliance demonstration. This does not affect the classification of the change.
(h)Feature or characteristic that affects the airworthiness or environmental compatibility of the changed product The term ‘no feature or characteristic’ applies to a minor change, in which case the effect of the change on the product safety or environmental compatibility is quite low. Minor changes should not be approved if either the design organisation approval (DOA) holder approving minor changes under its privileges or EASA is aware of a feature or characteristic that may make the changed product unsafe or environmentally incompatible for the uses for which the approval is requested.