The Australian Defence Force engaged Baines Simmons to help prepare for the transition to adopting the European Military Airworthiness Requirements (EMARs) within its Defence Aviation Safety Regulations (DASRs) by 2018. Baines Simmons provided training to over 50 Defence staff to aid understanding of EMAR 21 and differences from the European Aviation Safety Agency requirements. They also assisted the Directorate General Technical Airworthiness with customizing EMAR 21 implementation and supported defence organizations to develop documentation required for approval under the new regulations. Initial training phases helped stakeholders better understand principles of the regulations and their application in the military domain.

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Defence Aviation Case Study 53
Regulatory Consulting – EMARs
Australian Defence Force - Technical Airworthiness
Adoption of EMAR 21 by the Australian
Government Department of Defence
Baines Simmons is a long-standing partner to the European Defence Agency
(EDA) and during 2014-2015 provided technical guidance, advice and expertise
to assist with the drafting of the new European Military Airworthiness
Requirements (EMARs) – specifically helping to set the standards for the
management of Continuing Airworthiness for military aircraft across the
EDA’s 27 participating member states.
During 2015/16, the Australian Defence Force used our expertise to help them
prepare for the transition to EMARs which are being adopted into Defence
Aviation Safety Regulations (DASRs) during 2016-2018. This engagement
focused on both Initial and Continuing Airworthiness. After our initial training,
the ADF used our materials to generate their own internal Continuing
Airworthiness training programme but used our services to assist further with
Initial Airworthiness training – which is the focus of this case study.
Background
In 2015, the Australian Directorate General Technical Airworthiness (DGTA) published the
well-researched ‘10 Ways to Better Aviation Regulation’. As part of this process, the DGTA
investigated various regulatory models and decided to adopt the European Defence Agency’s
(EDA) approach as promulgated in the European Military Airworthiness Requirements
(EMARs). Specifically, EMAR 21 addresses the certification of (1) aircraft and related products,
parts and appliances, and (2) of Design and Production Organisations. These requirements
will be adopted into Australia’s Defence Aviation Safety Regulations (DASRs) under a phased
approach during 2016-2018:
 Jan 2016: Draft DASR released for consultation
 Sept 2016: DASR 21 to be promulgated with a transition period to the next milestone
 Dec 2018: Current Australian Defence Aviation Safety regulations no longer supported
The Challenge
With our practical exprerience in the Initial Airworthiness domain, and due to our
partnership with the EDA on setting and maintaining the Defence Standard for Continuing
Airworthiness across Europe with the EMAR requirements, Baines Simmons was approached
by the DGTA to help the Australian military and industry prepare for the transition to DASRs
within a short timeframe, and specifically with:
 Aiding their understanding of the EASA framework from which EMAR 21 originates
 The militarisation of the regulation and preparation of supporting guidance material
The Solution
Baines Simmons approached this challenge with a 4-phase solution:
 Phase 1: During October 2015, we trained more than 50 DGTA and other Defence staff
members to prepare them for the transition. The training was focused on a)
understanding the intent behind the EDA and the EMAR 21 requirements; b) the
differences between EASA Part 21 and EMAR 21 and c) areas where EMAR 21 will most
probably be updated in the near future. As with all our courses, the focus was not
“Excellent job for a difficult topic.
Well done!”
“Great breadth and depth of
coverage in Part 21.”
“Good mix of instruction and
interaction.”
Very dynamic. Duane was able
to tailor the course to suit the
audience requirements.”
Feedback from DGTA delegates,
April 2016

2. Managing Organisational
Safety Performance
An organisation’s Regulatory
Compliance Management System
enables it to know how
effectively it is meeting its legal
and regulatory obligations. It sits
at the heart of the Baines
Simmons SMARRT MAP™
model, which shows the nine
essential components – four
management systems and five
human- and system-centric
enablers needed for the ‘effective
management of safety’.
Defence Aviation Case Study
Regulatory Consulting – EMAR
Australian Defence Force -Technical Airworthiness
just on the technical details but also on the intent behind the regulation, emphasising what
it is trying to achieve and how this can be implemented in a real-world environment. This
event was repeated with two major defence sub-contractors to prepare them for the
transition and also to enable them to comment constructively on the draft DASRs.
 Phase 2: During April 2016, we conducted training for ADF personnel who currently
reside either within the authority or within regulated organisations to help prepare them
for forthcoming change. Training material was adapted to cater for lessons learned since
October 2015 with a mapping exercise against the current version of the DASR. A key
area of focus was DGTA’s need for an indigenous Military Type Certificate Holder
(MTCH) which is in neither the EASA Part 21 nor the EMAR 21 constructs, nor sits
comfortably within Subpart B. Three solutions were proposed to DGTA, all of which
were designed to help prevent industry confusion and clearly delineate the role of (and
interface with) the MTCH. In addition, we provided advice and expertise to help some key
industry partners with the compilation and content of their Design Organisation
Expositions (DOEs) along with the supporting Design Assurance System (DAS)
requirements. A key area of focus was on organisational structures, where boundaries
might need to be redrawn to cater for the distinct EMAR organisation approval constructs
(i.e. DOA, POA, CAMO & 145).
 Phase 3: Althought a summary of all Subparts in EMAR/DASR 21 was presented in
phases 1 and 2, the emphasis was placed on the requirements relating to organisational
approvals (i.e. POA in Subpart G and DOA in Subpart J). During this third phase, we will
support the ADF and industry by:
o Providing additional training, as required, in support of any other DASR Subparts
o Assisting the DGTA with the customisation of DASR 1, especially if detail from the
existing Technical Airworthiness Manual (TAM) might be usefully incorporated as
additional guidance material
o Preparing the regulator for their surveilance duties and providing Q&A support
during the DOA and POA award process
o Assisting industry members with the compilation of their Expositions and
supporting processes
 Phase 4: During this final phase we will provide assistance to the regulator and to
industry to exploit the technical, operational and financial benefts of moving beyond
minimum compliance to performance using our proprietary framework for managing
organisational safety performance – the SMARRT MAP™ - which helps you understand
not just if your organisation is compliant, but how well your organisation complies with the
regulations. Based on a comprehensive understanding of regulatory content and intent, the
Regulatory Compliance Management System (illustrated left) applies both a compliance-
and performance-based oversight approach across the management system.
The Outcomes (to date of Phases 1&2)
 DGTA having a better understanding of the principles of the implementation of EMAR 21,
resulting in a slight revision to their approach to cater for the unique challenges inherent
in the adoption of what is essentialy a civil approach to certification in the military domain.
 DGTA having a better understanding of how the Part 21 output integrates with the
Continuing Airworthiness requirements already developed to support through-life aircraft
safety and airworthiness.
 DGTA having a clearer focus on the advantages of gaining organisation and design
performance within the Part 21 sectors.