EASA's New OSD Requirement Explained

Compiled by Jesus Bedriñana
15/01/2018 OSD - OPERATIONAL SUITABILITY DATA 1

OPERATIONAL SUITABILITY DATA (OSD)
• The European Commission has published on 27 January 2014
a new requirement in certification –“Operational Suitability
Data” (OSD)– mandating that aircraft manufacturers,
including those building helicopters, to submit data EASA
considers important for safe operations.
• OSD covers pilot training, maintenance staff and simulator

qualification; the master minimum equipment list (MMEL);
and possibly other areas, depending on the aircraft’s systems.

• The process begins when the aircraft manufacturer proposes
what data EASA will evaluate against the new rule for
approval.
• OSD is approved as part of the type certificate like the

airplane flight manual.
• Since the holder of the type certificate is the owner of OSD,

the manufacturer has to keep the data current.

• Users affected by the new rule (operators and training
organizations) will find that OSD has both mandatory and
recommended elements and national aviation authorities will
determine whether users must comply with a
recommendation.
• Pilot qualification is at the heart of OSD.
• It defines a minimum syllabus for a type rating, as well as

training areas of special emphasis.

• The EASA has provided a transition period for the industry to
comply with the new requirement.
• MMELs for in-production models, for example, must be

approved by 18/12/2015, or before the aircraft is operated by
an EU operator, whichever is the latest.
• The mandatory OSD succeeds the voluntary Operational

Evaluation Board (OEB) process.

• OSD = Type related data, necessary for safe operation
• Five 5(6) elements → 21.A.15:

– Syllabus of pilot type rating training (FCD)
– Reference data for simulators (SIMD)
– Syllabus of maintenance certifying staff type rating training
(MCSD)
– Type specific data for cabin crew (CCD)
– Master Minimum Equipment List (MMEL)
– (other type-related OS elements)

OSD INTRODUCTION – CHANGE OF CONCEPT
• Before OSD Regulations → OEB process:
• Voluntary process with involvement of manufactures,

operators, NAAs, Agency ….
– Unclear responsibilities;
– Result not binding;
– Maintenance training not included.

OSD INTRODUCTION – CHANGE OF CONCEPT
• With the new OSD Regulations…..
• OSD approved by the Agency for aircraft type in the TC:
• Using EASA CSs;

– Mandatory approval;
– TC Holder responsible;
– Result (partly) mandatory for operators / training
organisations;
– OSD owned by TC holder and made available to operators
and NAAs.

OSD OVERVIEW
• All OSD is property of TC Holder;
• EASA Does Not Publish Data;
• The References are in TCDS;

– E.g. type rating, variants are in TCDS (EASA will publish
consolidated lists);
• Existing Voluntary OEB transfer to OSD;
• TC holder to indicate mandatory / non-mandatory;
• Eventually OEB report is superseded.

THE OSD RULE PACKAGE:
• Initial airworthiness, Part 21: Regulation (EU) 69/2014;
• AMC/GM to Part 21: ED 2014/007/R;
• CS-FCD; CS-MMEL; CS-GEN-MMEL; CS-CCD;
• CS-SIMD; CS-MCSD (not published yet);
• Air Operations: 71/2014;
• Aircrew: 70/2014;
• Continued airworthiness: not published yet.

OSD REGULATORY FRAMEWORK – PART-21
21.A.15 APPLICATION
(d) An application for a type-certificate or restricted type-certificate for an aircraft shall
include, or be supplemented after the initial application to include the application for
approval of operational suitability data, consisting of, as applicable:
1. the minimum syllabus of pilot type rating training, including determination of
type rating;
2. the definition of scope of the aircraft validation source data to support the
objective qualification of simulator(s) associated to the pilot type rating training, or
provisional data to support their interim qualification;
3. the minimum syllabus of maintenance certifying staff type rating training,
including determination of type rating;
4. determination of type or variant for cabin crew and type specific data for cabin
crew;
5. the master minimum equipment list; and
6. other type-related operational suitability elements.
OSD FC – APPLICABILITY
Operational Suitability Data

consist of contituents which must
be by the manufacturer and of
elements which may be provided

EASA OSD BOXES CONCEPT

OSD REGULATORY FRAMEWORK – PART-21
21.A.62 – Availability of operational suitability data
The holder of the type-certificate or restricted type-certificate shall make
available:
(a) at least one set of complete operational suitability data prepared in
accordance with the applicable operational suitability certification basis, to all
known EU operators of the aircraft, before the operational suitability data must
be used by a training organisation or a EU operator; and
(b) any change to the operational suitability data to all known Union operators
of the aircraft; and
(c) on request, the relevant data in (a) and (b) above, to:
1. the competent authority responsible for verifying conformity with one or
more elements of this set of operational suitability data; and
2. any person required to comply with one or more elements of this set of
operational suitability data.
OSD CERTIFICATION SPECIFICATIONS
CSs ALREADY PUBLISHED:
• CS MMEL (Annex to ED Decision 2014/004/R)
• CS-GEN-MMEL (Annex to ED Decision 2014/005/R)
• CS-CCD (Annex to ED Decision 2014/006/R)
• CS-FCD (Annex to ED Decision 2014/008/R)
• CS-SIMD (Annex to ED Decision 2014/033/R)
• CSS STILL IN PROGRESS
• CS-MCSD (RMT.0106, NPA 1st quarter 2016 – interim period

to be covered through CM-MCSD-001)

OSD REGULATORY FRAMEWORK - OVERALL

OSD FCD – APPLICABILITY
• Certain data must be provided for each aircraft examples are
– Aircraft type designation and license endorsement
– Initial type rating syllabus
• Certain data may be provided by the manufacturer examples are
– Aircraft type designation and license endorsement
– Initial type rating syllabus examples are
– Variant determination and associated differences training
syllabus
– Flight crew requirements for the operation of optional
equipment (HUD, EVS, etc.) or the performance of optional
procedures (RNP AR, LVO, Steep Approaches, etc.)
– Credits for Mixed Fleet Flying; Common Take-Off and Landing
Credits (CTLC)

OSD HISTORY AND BACKGROUND

OSD FCD: OEB – OSD EVOLUTION / HARMONIZATION

OSD FCD: OEB – OSD EVOLUTION / HARMONIZATION

OSD FCD – INTEGRATION INTO PART 21
• Operational Evaluations for OSD Flight Crew follow the Part-21
process for aircraft certification
• The certification basis for Operational Suitability Data Flight Crew

consists of the CS-FCD, unless the Agency accepts other means; and
of any special conditions as described in Part-21
• Certification Review Items (CRI) are raised to address specific items,

if required former (J)OEB Operational Review Items (ORI) / Issue
Papers (IP)
• OSD FCD evaluations are performed by a dedicated certification

panel (Panel 2), managed by the Product Certification Manager
(PCM) in collaboration with the OSD CEx & SenEx -

OSD FCD – INTEGRATION INTO PART 21
• EASA PCM
– Manages overall process
– issues OSD related CRIs, CAIs, etc. (drafted by Panel 2)
– includes OSD reference in TCDS (when finalized)
• Panel 2 (OSD Flight Crew Data)
– Performs technical management
✓ Team composition, operational evaluation, establishment o
– Operational suitability data
– Collaborates with the participating authorities (e.G. FAA, TCCA,
etc)
– Provides evaluation updates to PCM
– Includes OSD data in EASA type rating list (when finalized)

OSD - FCD: Illustration of challenges

OSD FCD – APPLICABILITY

OSD FCD – REFERENCE

OSD FCD – REFERENCE

OSD FCD – TRANSITION ARRANGEMENTS
TRANSITION / GRANDFATHERING

OSD - FCD
• Step 1: Identify the deliverables
– Minimum syllabus of pilot type rating training
– Determination of type rating
• Step 2: identify required procedures
– The specific training requirements are identified or
confirmed through the evaluation process and evaluation
descriptions as described in CS FCD.425.

OSD FCD – TCDS CONTENT

OSD FC – Operational Suitability Data (OSD) Approval

OSD MMEL
• Why an OSD certification basis?
• OSD MMEL development process
• OSD impact on MMEL end-users
• Conclusion

…..WHY AN MMEL CERT BASIS?
• Before 2000, No standard requirement
• 2000-2014 JAR-MMEL Requirement…..
• The MMEL [..]maintain[s] an acceptable level of safety as

intended in the applicable JAR or equivalent Requirement
– Subjective “acceptable” not defined
– Authority judgement required (shared responsibility)
– Wide variety of TCH MMEL methodology
– No MMEL guidance comparable to FAA MMEL Policy
Letters or TCCA guidance book

WHY AN MMEL CERT BASIS? (CS-MMEL OBJECTIVES)
• Maintain consistency with JOEB process
– The JAR-MMEL content is integrated
– CS-MMEL Section 1 Subpart A General
– CS-MMEL Section 1 Subpart B MMEL
• Provide necessary requirements/criteria for compliance
finding in a Type Certification framework
• The SUBPART C “Level of safety and justifications of MMEL
items” is created
– Criteria for acceptability based on HAZ/CAT (FC
Classification)
– Account for different TCH MMEL practices

OSD MMEL DEVELOPMENT PROCESS

OSD IMPACT ON MMEL END-USERS
ORO.MLR.105 (A) REQUIRES EU OPERATORS TO:
• Base their new MELs on OSD MMEL available directly from

the Type Certificate Holder.
– Note: The MMELs status will no longer be published on the
EASA website. Data has to be made available by (S)TC
Holders as per 21.A.62/108/120B
• Update their MEL as per OSD MMEL at the earliest
opportunity and not later than 18 December 2017 or 2 years
after the OSD was approved, whichever is the latest.

OSD IMPACT ON MMEL END-USERS
Under AIR-OPS regulations, operators:
• Shall have an MEL (ORO.MLR.105) if conducting:

– Commercial air transport operations (CAT);
– Commercial specialized operations;
– Non-commercial operations with complex motor-powered
aircraft;
– Non-commercial specialized operations with complex
motor-powered aircraft.
• May have an MEL (NCO.GEN.155), if conducting:
– Non-commercial operations with non-complex motor-
powered aircraft.

MMEL IN OSD - CONCLUSION
With MMEL in OSD we have now:
• Approval process comparable to Type Design Certification
• Clearer sharing of duties and responsibilities between Agency

and (S)TC Holders
• Requirements for MMEL necessary changes
• A tool for adapting EASA level of involvement
• Additional privileges for DOA holders for MMEL minor

changes approval

SIMULATOR DATA – ONE CONSTITUANT OF OSD
OBJECTIVE:
• Provision of data to be used to validate by objective

comparison that simulators used for type-rating represent the
type of aircraft.

SIMULATOR DATA – ONE CONSTITUANT OF OSD
• Is CS-SIMD something completely new ?
• Most of the elements of CS-SIMD were already part of CS-

FSTD to be applied for the evaluation of Flight Simulation
Training Devices (FSTD).
• It was always essential to demonstrate that simulators are

representative of the aircraft type concerned.

CS-SIMD OVERVIEW
• Why has CS-SIMD been drafted as a separate document
under OSD Part-21 ?
• New:
– Area of responsibility for an OEM becomes more clear
– From a voluntary OEB process, to mandatory OSD process
– To provide all source data required for validation (sim vs.
a/c) before EIS of the aircraft
– the provision of source data will be done by an authority-
approved ‘definition of scope of validation source data
(VSD)’

IMPLEMENTATION OF OSD-MCS
• No CS-MCSD already exists for the time being…
• Rulemaking Task RMT.106 is in progress to develop the CS-

MCSD (expected in 2018).
• To cover the transition phase, the Certification Memorandum

CM-MCSD-001 provides specific guidance in preparation of
the Special Condition (SC) as per Part 21.A.16B which will be
included in the OSD certification basis to address the MCSD.
• The SC is conveyed through a Certification Review Item (CRI

A-MCSD).
• CM-MCSD-001 gathers the outputs of the RMT.106.

MASE - MAINTENANCE AREA OF SPECIAL EMPHASIS

MASE - MAINTENANCE AREA OF SPECIAL EMPHASIS

OSD REGULATORY FRAMEWORK - OVERALL

CC OSD Regulatory Framework - Aircrew

Air Operations: Part-ORO – Subpart CC (Cabin Crew)

BRIEF INTRODUCTION TO CCD
CS CCD.100 Applicability
• These Certification Specifications are applicable to:
• (a) aircraft with a maximum passenger seating configuration

capacity of more than 19 seats; and
• (b) aircraft with a passenger seating capacity of 19 seats or

less required to carry cabin crew; and
• (c) any other aircraft with a maximum passenger seating

configuration capacity of 19 seats or less if voluntarily elected
by the applicant to facilitate operations with cabin crew.

BRIEF INTRODUCTION TO CCD
DELIVERABLES:
• CS CCD. 400 – Cabin Aspects of Special Emphasis (CASE) - as a

stand-alone document ….
– if necessary at the time of the Initial TC, or,
– Included in the Type Specific Data of the respective new
type or variant;
• CS CCD. 310 – Type Specific Data for the new type rvariant;
• CS CCD. 215 – Aircraft Difference Table for variant.

EASA REFERENCES
• PR.CERT.00001-001 Airworthiness of Type design Ed.2013+
• UG.CERT.00002-004 Certification handbook

OSD SUMMARY
• Based on Basic Regulation and Part 21
• Required for the OEMs
• Mandatory for the end user (Operators, MRO, etc)
• Scope includes 5 (+1) OSD
• Constituents

OSD VS OEB - THE EFFORT AND THE CHALLENGE
• Deeper involvement of EASA TC holders in the development
and approval of OSD
• Links created within Training and OPS requirements
• Streamlining of the OSD in the certification/validation

processes
• Need to establish a certification basis
• Need for DOAs to integrate the OSD process
• Data owned and maintained by the TC holder
• Inclusion in bilateral agreements with EASA Partners

OSD – APPLICABILITY
• Part 21: Applicable to all aircraft Categories.
• CS: non-complex a/c largely excluded:

– FCD: only when type rating;
– MCSD: only when type rating;
– CCD: only when Pax. > 19 (exceptions apply);
– SIMD: only when SIM is used in type training;

OSD MMEL – APPLICABILITY
• Complex aeroplanes: Required;
• Non-complex aeroplanes:
– Generic MMEL in CS
– TC Holder can confirm this generic MMEL is adequate;
• VLA, LSA, VLR, sailplanes, powered sailplane, balloons and
ELA2 airships can use concept o “Required Equipment”.
– No need for formal MMEL.

OSD - DOA consequences
• 2 year implementation (18 Dec 2015);
• New “fields of expertise” to be taken into account for

investigations and surveillance
– Competences;
– Procedures;
– CVE role.
• Form 82 application required;
• Update of TOA;

CRI A-1 OSD Applicable Requirements
• CRI A-01 shall also record the applicable OSD requirements,
including the relevant Certification Specifications Data (CS-
FCD, CS-MMEL/CS-GEN-MMEL, CS-SIMD, CS-CCD, CS-MCSD).
• Since the application for OSD elements may come later than
the application for TC, the OSD certification basis may be
recorded together with the airworthiness requirements, or
alternatively in a distinct appendix of the CRI A-01, at the
discretion of the PCM.

OSD CONCEPT SUMMARY

EASA's New OSD Requirement Explained

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Compiled by Jesus Bedriñana

15/01/2018 OSD - OPERATIONAL SUITABILITY DATA 1

• OSD covers pilot training, maintenance staff and simulator

15/01/2018 OSD - OPERATIONAL SUITABILITY DATA 4

• OSD is approved as part of the type certificate like the

• Since the holder of the type certificate is the owner of OSD,

15/01/2018 OSD - OPERATIONAL SUITABILITY DATA 5

• Pilot qualification is at the heart of OSD.

• It defines a minimum syllabus for a type rating, as well as

15/01/2018 OSD - OPERATIONAL SUITABILITY DATA 6

• MMELs for in-production models, for example, must be

• The mandatory OSD succeeds the voluntary Operational

15/01/2018 OSD - OPERATIONAL SUITABILITY DATA 7

• Five 5(6) elements → 21.A.15:

15/01/2018 OSD - OPERATIONAL SUITABILITY DATA 8

• Voluntary process with involvement of manufactures,

15/01/2018 OSD - OPERATIONAL SUITABILITY DATA 9

• OSD approved by the Agency for aircraft type in the TC:

• Using EASA CSs;

15/01/2018 OSD - OPERATIONAL SUITABILITY DATA 10

• EASA Does Not Publish Data;

• The References are in TCDS;

• TC holder to indicate mandatory / non-mandatory;

• Eventually OEB report is superseded.

15/01/2018 OSD - OPERATIONAL SUITABILITY DATA 11

• AMC/GM to Part 21: ED 2014/007/R;

• CS-FCD; CS-MMEL; CS-GEN-MMEL; CS-CCD;

• CS-SIMD; CS-MCSD (not published yet);

• Air Operations: 71/2014;

• Continued airworthiness: not published yet.

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Operational Suitability Data

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• CS MMEL (Annex to ED Decision 2014/004/R)

• CS-GEN-MMEL (Annex to ED Decision 2014/005/R)

• CS-CCD (Annex to ED Decision 2014/006/R)

• CS-FCD (Annex to ED Decision 2014/008/R)

• CS-SIMD (Annex to ED Decision 2014/033/R)

• CSS STILL IN PROGRESS

• CS-MCSD (RMT.0106, NPA 1st quarter 2016 – interim period

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• The certification basis for Operational Suitability Data Flight Crew

• Certification Review Items (CRI) are raised to address specific items,

• OSD FCD evaluations are performed by a dedicated certification

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• Why an OSD certification basis?

• OSD MMEL development process