Europe - Comment Response Document for the Amendment of EC1702/2003 to Introduce Operational Suitability Data (OSD)

REFERENCE: The CRD to NPA 2009-01 has been issued and is open for feedback and comments. The document can be found here.

SUMMARY: The document is the proposal for the Amendment of EC 1702/2003 and the related Annex - Part 21 to amend the need for an operational suitability data as part of the type certification process when the aircraft is operated in Europe. The goal for the OSD is to close the gap between certification, operations and maintenance processes.

When implemented, the new OSD as proposed will contain:

  • Minimum training syllabi for pilot type rating training, maintenance type rating training, and cabin crew training.
  • Simulator data.
  • Master minimum equipment list.

The new rule not only will apply to TC applicants and holders, but also to STC applicants if the change implemented requires an amendment to the OSD.

The second topic of the proposal is the introduction of a Safety Directive. The purpose of a SD is to impose a change to a design or limitation to users of an aircraft type with or without the involvement of the TC holder. For example, in case of general safety problems, such as fuel tank safety or EWIS.

The new process would require developing further regulations and material identified as Part-26, CS-26 and AMC-26.

Comments to this CRD 2009-01 Part I should be received by the agency not later than 13 July 2011.

AEA COMMENTARY: The involvement of stakeholders at this stage of the rulemaking is an important opportunity for AEA members to make sure their voice is being heard. Association members are encouraged to provide suggestions and/or comments to the agency via the EASA Comment Response Tool. Please email a copy of your comments to Ric Peri at as soon as possible and prior to the comment closing date.

Contact Ric Peri, AEA vice president of government and industry affairs, by email at or by phone at 202-589-1144.