Compliance Workflow — Issue Paper vs CRI
Section 13: Jurisdiction Mapping Sets
Definition
Formal mechanisms used by certification authorities to document and track specific certification issues, concerns, or special conditions that arise during a certification project and require resolution between the applicant and the authority. These instruments capture the authority's position on a compliance matter, the agreed means of compliance, and the resolution.
Where This Shows Up
During any significant certification project, questions arise about the interpretation of regulations, the adequacy of proposed compliance methods, or the need for special conditions not covered by existing rules. The authority uses formal documentation instruments to record these questions and their resolutions, creating a traceable record of the certification basis and compliance path. These instruments are project-specific and are managed as part of the certification programme.
Primary Sources
Type Certification — describes the FAA Issue Paper process used during type certification projects.
EASA certification programme management procedures define the CRI process.
Across Jurisdictions
FAA Order 8110.4C
An Issue Paper is the FAA's formal instrument for documenting a certification issue, the proposed resolution, and the agreed means of compliance. Issue Papers are categorized as Type A (novel or unusual design features), Type B (exemptions), Type C (equivalent safety findings), or Type D (special conditions). The Issue Paper process involves drafting by the ACO engineer, review within the FAA, coordination with the applicant, and eventual closure upon demonstration of compliance. Issue Papers become part of the type certification data package.
EASA Certification Programme Procedures
A CRI is EASA's formal instrument for documenting and resolving certification issues within a certification programme. CRIs may address interpretive issues, special conditions, equivalent safety findings, or deviations from published AMC. Each CRI specifies the issue, the proposed means of compliance, and the EASA position. CRIs are managed within EASA's certification programme tracking system and are closed upon satisfactory compliance demonstration. The CRI process involves EASA certification engineers, the applicant, and may involve the EASA advisory bodies.
While functionally similar to FAA Issue Papers, CRIs are integrated into EASA's structured certification programme management framework. EASA CRIs may also be used to impose additional conditions beyond the published CS/AMC.
TCCA Airworthiness Manual
TCCA documents certification issues and resolutions through the certification project process, using issue tracking within the certification plan. The specific format may vary by project but serves the same function as FAA Issue Papers and EASA CRIs.
TCCA's process is less formally structured than the FAA IP or EASA CRI system but achieves the same objective of documenting and resolving certification questions.
Related Terms
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