What are the benefits of using a CATA Worklist Item (CWI)?
If an applicant follows the compliance methodology documented in a closed CWI, and their certificating authority endorses that methodology for a certification project, the other three CMT authorities will accept that compliance methodology for validation.
How should an applicant inform the certifying authority and validating authorities that the applicant has used one or more CWIs?
The applicant can indicate where CWIs have been used by referencing the CWIs in their certification plan and in other relevant certification documentation (e.g. validation work plans, compliance substantiation reports, etc.).
Are applicants required to use CWI?
No, CWIs are non-binding. An applicant may choose to follow the compliance methodology in a closed CWI or use an alternative approach.
What happens if an applicant does not elect to follow a CWI?
An applicant may use an alternative compliance approach by using existing guidance or agree to a new method by using the certifying authority’s existing issue resolution process. However, this approach might not be harmonized among the four authorities, which could result in additional time and effort in validation projects.
Can Industry submit a proposal for a CWI? If so, what is the process?
Yes, Industry can submit a proposal for a CWI to the CATA Chair through the Industry Lead. The CATA will discuss the proposal and decide how to proceed. The CATA Chair may also contact Industry with a request for additional information, if needed. The CATA Chair will inform Industry of CATA’s decision whether to move forward with a new proposed CWI that will be submitted for CMTS approval.
Can Industry comment when a CWI is initiated?
No. However, Industry may submit a CWI proposal to the CATA Chair as discussed above.
Does CATA, through the CATA Chair, request comments from Industry on new CWI proposals?
CATA would like industry to be aware of new, CMTS-approved CWIs that CATA is undertaking. CATA is not requesting industry comments on new CWI proposals, but Industry may provide comments if desired. Since CATA already has CMTS approval to work on the CWI as it has been defined, the Industry comments would not be able to influence whether CATA will undertake the project nor change the scope of the project.
Does the CATA process give Industry the opportunity to comment on active CWIs before the CMTS approves the CWI final decision for publication?
No. Industry does not have the opportunity to comment on active CWIs that are in work internally in CATA. The CMTS-approved CATA Charter emphasizes the authority-only focus of CWI projects.
Does Industry have an opportunity to comment on closed CWIs? Will CATA revise a closed CWI based on Industry comments?
After the CMTS approves the CWI final decision for publication, CATA publishes the final decision and the CWI is considered closed. Industry may review closed CWI and provide comments to the CATA Chair via the Industry Lead. CATA will review the comments and decide whether further action is necessary. The CATA Chair will acknowledge receipt of the comments and provide an update to the Industry lead once a decision has been made. It is unlikely that industry comments will lead CATA to revise a closed CWI.
Can a non-Industry member of the public provide comments on a closed CWI? If so, what is the process for submitting comments?
A member of the public may comment on a closed CWI by sending comments to the CATA contact provided on the CATA main page. CATA will review the comments and decide whether further action is necessary. The CATA Chair will acknowledge receipt of the comments and provide an update to the commenter once a decision has been made.
What happens if CATA has a need for Industry data in the course of an active CWI?
The CATA chair will request the information by contacting the Industry Lead.
How is Industry data protected?
An Industry member does not need to submit data to CATA through the Industry lead; instead, the data can be submitted directly to the CATA CWI lead or their CATA representative. CATA will share the data only with the CATA representatives and subject matter experts (SMEs) from each authority that are working on the CWI. The data will not be shared with other Industry members.
What data and guidance material do subject matter experts (SMEs) consider when they develop a CWI position?
Typically, the SMEs consider authority and applicant positions in closed Issue Papers (IP) and Certification Review Items (CRI) and authority guidance in final/published advisory circulars (AC), acceptable means of compliance (AMC), and policy documents. The SMEs may also consider draft guidance documents (e.g. AC, AMC, and policy documents) and recommendation reports from advisory committees such as Aviation Rulemaking Committees (ARCs) and Aviation Rulemaking Advisory Committees (ARACs). In addition, the SMEs may be able to consider the authority and applicant positions from IP and CRI that are currently open, provided that each applicant agrees to share its position and associated data with the SMEs from the other authorities to use in the CATA project. Note that the SMEs will not debate the merits of open IP/CRIs that apply to on-going validation projects, as this is outside the scope of CATA’s authority.