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Delegate Newsletter Volume 6, Number 1
Delayed Implementation of the Changed Product Rule
During the May 23, 2001 meeting of the CARAC Aircraft Certification Technical Committee, it was proposed briefed that our introduction of the Changed Product Rule (CPR) into the Canadian Aviation Regulations was undergoing legal review by the Department of Justice. The intent to implement CPR in Canada on the same implementation dates that as the United States' Federal Aviation Administration (FAA) and Europe's Joint Aviation Authorities (JAA) has already been established, as follows;
- December 10, 2001, for Part 25 products, and
- December 9, 2002, for other aeronautical products
Recent activities in training and policy development, however, have prompted the industry to express concerns over certain implementation issues that may need further resolution and agreement by other civil aviation authorities. A common concern is the treatment of design changes that are regarded as being "not significant", and how CPR may be imposing extraordinary administrative and technical burdens on the treatment of such design changes. Manufacturers of type certificated aeronautical products claim that the burden added by CPR for dealing with "not significant" changes will only serve to delay or lengthen the certification process, unless civil aviation authorities consider some form of flexibility or delegation of the CPR process.
The concerns expressed so far by both industry and authorities on several implementation issues warrant resolution if CPR is to be applied in a consistent manner internationally. Given the remaining time before CPR becomes mandatory, Transport Canada Civil Aviation (TCCA), the FAA, and the JAA recognized that the best way to proceed is to allow more time for all concerned authorities to work together in resolving these issues, or concerns, and complete all the necessary tasks for achieving consistency of implementation. The consistency of implementation will require changes to, the current training materials, the current advisory materials, and the development of harmonized policies and procedures.
Accordingly, it has been agreed upon by TCCA, FAA and JAA to delay the two (2) CPR implementation dates of CPR to a new single date of June 10, 2003. The new date represents a delay of 18 months in the application of CPR for Part 25 products, and of 6 months for the rest of the aeronautical products. The FAA and JAA will have to make similar announcements to their industry of the joint decision to delay CPR.
We remain committed to implementing CPR in Canada. The move to a new single date of June 10, 2003, although a delay, represents additional opportunity to work with the FAA and JAA in achieving an equitable application of CPR internationally.
