European Aviation Safety Agency (EASA) - Maintenance Annex Guidance
Approval process for Canadian Based Approved Maintenance Organisations
This Guidance details how TCCA will implement the Bilateral Agreement and Annex B between the European Union and Canada for CAR 573 Maintenance Organizations located in Canada.
I. Initial Approval Process
1. TCCA actions
Upon receipt of a request for supplement approval in accordance with this Agreement, TCCA shall ensure that the applicant has access to the most current revision of the MAG and the EASA Form 17.
2. Applicant actions
To apply for approval under the provisions of the Agreement Annex B, an applicant AMO must:
- Be located in Canada and
- Hold a TCCA CAR 573 approval
The applicant shall:
- Complete the EASA Form 17 and
- Establish an EASA Supplement to their Maintenance Policy Manual in accordance with the supplement guidance material (see Appendix 1).
The EASA Form 17 plus the proposed EASA Supplement shall be sent to the supervising TCCA region at least 90 days prior to the date initial approval is required.
Note: The above documents shall not be sent to EASA by the applicant.
3. TCCA/EASA actions
- The TCCA regional office shall send the EASA Form 17 to TCCA HQ
- TCCA HQ shall forward a copy of the EASA Form 17 to EASA. EASA shall invoice the organisation based on the EASA Fees and Charges Regulation, as amended. The current EASA Fees and Charges Regulation can be found at the EASA website at: European Aviation Safety Agency
- Once EASA has received the applicant’s payment, it shall notify TCCA that the process can continue and identify (on the application Form 17) the EASA approval number to be used in the process.
- TCCA shall review the EASA Supplement for compliance with Appendix 1.
- Where the supplement is found satisfactory, TCCA shall issue a letter quoting the EASA approval number to the AMO and attesting that the EASA supplement is approved. The letter shall specify that the scope of ratings and limitations shall not exceed that which is specified in the organizations CAR 573 certificate and limitations record.
- Once approved, the EASA supplement and the privileges associated with it shall remain in force until surrendered, suspended or cancelled by TCCA or EASA.
- TCCA will ensure that activities conducted in accordance with the supplement are part of their oversight of the organization.
- TCCA shall forward a copy of the supplement approval letter to EASA.
- EASA will publish the list of Approved Maintenance Organizations located in Canada on its website:
II. Continuation Process
1. TCCA Action
TCCA ensures every 24 months that the conditions for approval continue to be met. Where the conditions are not met, TCCA shall take appropriate action and notify EASA.
2. Applicant actions
The applicant shall submit the following to TCCA;
- A Completed EASA Form 17 indicating continuation and/or change in Block 5 as required, and
- A current copy of their EASA MPM Supplement (only if the continuation is submitted together with a change)
3. TCCA/EASA actions
- TCCA Regional office will review the submitted Form 17 for completeness and legibility.
- The TCCA Regional office will review the supplement for compliance to Appendix 1(if submitted).
- The TCCA Regional office will issue a new supplement approval letter when the supplement is found acceptable (if submitted).
- The TCCA Regional office will forward the EASA Form 17 and Supplement approval letter (if issued) to TCCA HQ.
- The TCCA HQ will forward the completed Form 17 and supplement approval letter (if issued) to EASA.
4. EASA actions
- EASA shall invoice the organisation based on the EASA Fees and Charges Regulation, as amended. The current EASA Fees and Charges Regulation can be found at the EASA website at: European Aviation Safety Agency. In accordance with EASA Fees and Charges Regulation the applicable fee will be invoiced on an annual basis.
- EASA shall notify TCCA if the applicant has failed to make the fee payment within 90 days from invoice date.
- If the applicant fails to pay the applicable continuation fee EASA shall ask TCCA to revoke the supplement approval letter.
- Where EASA has reason to recommend to TCCA not to continue the approval, EASA should immediately inform TCCA who will take appropriate action.
- Late Applications-The applicant is expected to apply 60 days prior to their continuation due date. TCCA will accept late applications up to 30 days beyond the due date. If the applicant fails to apply for continuation within the above specified time frame, their approval cannot be continued, it shall be rendered invalid and an initial application must be initiated by the applicant.
5. Surrender of approval
Where a company surrenders its approval, TCCA will notify EASA to remove the company from the list of approved companies on its website. TCCA will also remove the company from its website.
III Amendment process
1. Applicant actions
The following changes to an organisation require the submission of an EASA Form 17 and associated amended supplement to TCCA regional office:
- Change of Address.
- Change of Accountable Manager.
- Change of Organisation Name and/or Approval Number.
2. TCCA actions
- TCCA Regional office will review the submitted Form 17 for completeness and legibility.
- The TCCA Regional office will review the supplement for compliance to Appendix 1.
- The TCCA Regional office will issue a new supplement approval letter when the supplement is found acceptable.
- The TCCA Regional office will forward the EASA Form 17 and Supplement approval letter to TCCA HQ.
- The TCCA HQ will forward the completed Form 17 and supplement approval letter to EASA.
3. EASA Actions
EASA will update the list of approved companies on its website.
IV Suspension or Revocation
Suspension of the CAR 573 AMO certificate will automatically render the EASA Part 145 supplement approval letter invalid for the duration of the suspension. As a consequence of this suspension the AMO cannot exercise the privileges of their EASA Part 145 approval in accordance with the Agreement.
Revocation of the CAR 573 AMO certificate will automatically render the EASA Part 145 supplement approval letter invalid. As a consequence of this revocation all privileges of their EASA Part 145 approval are permanently removed and cannot be re-instated.
3. EASA Actions
Where EASA has reason to request the TCCA to revoke the supplement approval letter, TCCA should take immediate action.
Each party shall immediately notify the other party of any activities related to the aforementioned certificate action.
Appendix 1: EASA Supplement Contents
In accordance with the Agreement on Aviation Safety between the European Union and Canada, each AMO maintaining aircraft registered in an EU Member State or components intended for installation thereon, shall include in its Maintenance Policy Manual a supplement in accordance with Annex B Appendix B1.
Appendix 2: Example EASA Supplement
EASA SUPPLEMENT REFERENCE NO. ..........
TO CAR 573 AMO MAINTENANCE POLICY MANUAL REF ..........
Company Name and Facility Address:
TCCA APPROVED MAINTENANCE ORGANISATION NUMBER
EASA Part 145 Approval Number:
Compliance with the EASA approved Supplement together with the TCCA Approved Maintenance Policy Manual forms the basis by which an AMO can exercise the maintenance privileges under the Agreement.
The Approved Maintenance Organisation (AMO) must always retain at its principal place of business a current copy of this EASA Supplement in English and provide it to EASA upon request.
The cover page of the EASA Supplement should include the intent of the above statement
Note: This example EASA Supplement gives guidance on the subjects, which need to be addressed and translated into working procedures to ensure compliance with the Specific Regulatory Requirements. The supplement must therefore be customised to satisfy the specific approved maintenance organisation procedures.
1. LIST OF EFFECTIVE PAGES
2. AMENDMENT PROCEDURE
Self explanatory, but this paragraph should identify by title, the person within the AMO is responsible for amendment action. Procedures to ensure that revisions to the approved supplement are submitted to the appropriate authority (TCCA) for review and approval prior to change implementation
A TCCA CAR 573 Approved Maintenance Organization can be EASA Part 145 approved when the CAR 573 Maintenance Organization complies with the maintenance specific regulatory requirements set forth in this supplement in addition to complying with TCCA CAR 573.
This supplement is therefore intended to identify the means to comply with the agreement when performing maintenance on EU registered aircraft or components intended for installation there on.
4. ACCOUNTABLE MANAGER'S COMMITMENT STATEMENT
This paragraph represents the agreement by the Accountable Manager that the AMO will comply with the conditions specified in the Supplement.
The Accountable Manager is usually the AMO's Chief Executive Officer (CEO), Accountable Executive or President but can, in the largest organisation be the Vice President (Engineering) so long as he/she is on the corporate Board and has full financial authority.
An acceptable statement for this paragraph could be:
"This Supplement defines in conjunction with the TCCA Approved Maintenance Policy Manual, the organisation and procedures upon which the EASA Part 145 approval is based.
These procedures are approved by the undersigned, and must be adhered to, as applicable, when maintenance is performed under the conditions of the EASA Part-145 supplement approval letter.
It is accepted that the organisation's procedures do not override the necessity of complying with any additional requirements formally published by EASA and notified to this organisation from time to time.
It is further understood that EASA reserves the right to suspend or revoke the approval if procedures are not followed or standards are not upheld.
Signed by the Accountable Manager (Signature, printed name and date)
For and on behalf of the AMO"
Please note that whenever the Accountable Manager is replaced, the new Accountable Manager must sign the statement.
5. APPROVAL BASIS AND LIMITATION
The EASA Part-145 supplement approval is based upon compliance with CAR 573 in addition to the specific regulatory requirements found in the Agreement and associated MAG.
The approval of maintenance is limited to the scope of work permitted under the current Certificate issued by TCCA to the AMO in accordance with CAR 573.
6. ACCESS BY EASA AND TCCA
Identify the fact that EASA staff should be allowed access to the repair station for the purpose of ascertaining compliance with procedures and standards and to investigate specific problems. The paragraph should also specify that TCCA staff may access the repair station to investigate on behalf of the EASA.
7. WORK ORDERS / CONTRACTS
The organization must ensure that work orders/contracts are in place to define the maintenance to be accomplished on the Aircrafts/Components under the jurisdiction of an EU Member State and that this contract is understood and agreed by both parties.
An acceptable statement for this paragraph could be:
Prior to undertaking work on Aircrafts/Components under the jurisdiction of an EU Member State, a work order/contract defining the maintenance to be performed will be established between the organization and the EU customer. The work order/contract will specify the inspections, repairs, modification, overhauls to be accomplished, the airworthiness directives to be complied with and components to be replaced.
The EU customer remains responsible for specifying any AD compliance required during maintenance through the work order but the AMO should always remind the customer of the need.
8. REPAIRS AND MODIFICATIONS
The AMO should establish that the customer has obtained or is in the process of obtaining any necessary approvals from EASA. The AMO should request the operator to provide such written proof from EASA.
9. RELEASE OF COMPONENTS AFTER MAINTENANCE
Release to service of components up to and including complete power plants should be carried out in accordance with CAR 571 except that paragraphs 7 and 8 of this supplement should be taken into account and the Authorised Release Certificate (TCCA Form One) should be issued.
A maintenance release made in accordance with this supplement constitutes a corporate release on behalf of the AMO as well as being a standard CAR 571.10 release.
For an EU customer the TCCA Form One should always include the EASA approval number in block 12 and specify any overhaul, repairs, modifications, Airworthiness Directives, replacement parts and quote the issue of the approved data used.
The supplement should contain a copy of a completed example of a TCCA Form One used by the AMO and instructions for completion by staff.
The instructions should include the information that:
The TCCA Form One document should be signed by a person authorised to return the component to service on behalf of the organisation. EASA requires a “corporate release” therefore a maintenance release made in accordance with this supplement constitutes a corporate release on behalf of the AMO as well as being a standard CAR 571.10 release. Block 14c must in all cases bear the TCCA number. Block 14d should include the personal identification of the individual signing.
Block 3 of the TCCA Form One Authorised Release Certificate should contain a unique number for each certificate for traceability purposes. (Not the TCCA Approval Number)
It is also an advantage from the point of view of company liability, in that the company knows exactly how many forms have been issued and the details of each release.
Block 11 of the form should show the status of the component e.g. repaired, overhauled etc.
Block 12 should contain details of the approved data used to perform the maintenance and reference to any ADs or SB's embodied during the maintenance e.g. overhauled in accordance with CMM xxx Section yy issue 3, AD xxxx96 and SB xxx Rev x embodied. Full details held on work order XYZ.
Block 12 should also include the EASA Part-145 Approval number e.g. "EASA Approval No.: EASA.145.XXXX."
Block 14a of the TCCA Form one will display a checkmark in the "Other regulation specified in block 12" Check Box. In the case where the particular maintenance was only EASA approved and not TCCA approved the "CAR 571.10 Maintenance Release" checkbox should not be checked. Example: an EASA AD not approved by TCCA.
The organisation must retain a copy of each form issued.
The AMO should also identify in the MPM/roster those staff that are authorised to issue the TCCA Form One on behalf of the AMO.
Note: The supplement should include information regarding the acceptability of components authorised for use during maintenance, which should meet the intent of the following:
- Component means any component part of an aircraft up to and including a complete powerplant and any operational or emergency equipment.
- Only the following new and used components may be fitted during maintenance:
3. New Components
3.1 New components should be traceable to the Original Equipment Manufacturer (OEM) as specified in the Type Certificate (TC) holders Parts Catalogue and be in a satisfactory condition for fitment. The new component should be accompanied by a release document issued by the OEM or Production Certificate (PC) holder. The release document should clearly state that it is issued under the approval of the relevant NAA under whose regulatory control the OEM or PC holder works.
3.2 For USA OEMs and PC holders release should be on the FAA Form 8130-3 as a new part.
3.3 For all EU States OEMs and PC holders release should be in accordance with EASA Part-21 (EASA Form 1).
3.4 For Canadian OEMs and PC holders release should be on the TCCA Form One as a new part.
3.5 Standard parts are exempt from the forgoing provisions, except that such parts should be accompanied by a conformity statement and be in a satisfactory condition for fitment.
3.6 Production Manufacturing Approval (PMA) parts may only be accepted as detailed in EASA Part-21 or any EU/US bilateral agreement.
4. Used Components
4.1 Used components should be traceable to maintenance organisations and repair stations approved by the Authority who certified the previous maintenance and/or in the case of life limited parts certified the life used. The used component should be in a satisfactory condition for fitment and be eligible for fitment as stated in the TC holders Parts Catalogue.
4.2 Used components from EASA approved USA repair stations should be accompanied by an FAA Form 8130-3 issued as a maintenance release (DUAL RELEASE).
4.3 Used components from a USA repair station not EASA approved should not be used even if accompanied by an FAA Form 8130-3
4.4 Used components from EASA Part-145 approved maintenance organisations should be accompanied by an EASA Form 1 issued as a maintenance release.
4.5 Used components from a Canadian AMO with an EASA approved supplement should be accompanied by a TCCA Form One issued as a maintenance release (dual release)
4.6 Used components from a Canadian AMO that does not have an EASA approved supplement should not be used even if accompanied by a TCCA Form One
4.7 Used components that have been issued a triple release (i.e. certifying compliance with FAA, EASA, TCCA requirements) on an EASA Form 1 as a maintenance release are acceptable
10. CERTIFICATE OF AIRWORTHINESS (C of A) VALIDITY
Whilst EC Operators’ aircraft have indefinite C of A’s, the C of A’s validity period is verified by means of an “airworthiness review certificate” (ARC). The EC Operator or owner is responsible for ensuring the C of A remains valid but the repair station should ensure that the C of A is valid from the expiry date as detailed on the ARC before issue of a release to service. If the ARC has expired the customer should be informed before issue of a release to service.
This paragraph is only applicable to AMOs with airframe/aircraft rating.
11. RELEASE OF AIRCRAFT AFTER MAINTENANCE
Release to service of aircraft after maintenance shall be carried out in accordance with CAR 571 except that paragraphs 7, 8 and 10 of this EASA Supplement shall also be taken into account and specify the aircraft maintenance check plus any repairs, modifications, Airworthiness Directives, replacement parts together with the issue of approved data used.
At the completion of maintenance the following certification should be made in the aircraft maintenance record.
Maintenance Release in Accordance with CAR 571.10:
"Certifies that” except as otherwise specified, the described maintenance has been performed in accordance with the applicable airworthiness requirements and in respect to that work the aircraft is ready for release to service."
The sub-clause "except as otherwise specified" is intended for use with two types of deviation as follows:
- The case where not all of the required maintenance was carried out as agreed by the customer. The maintenance not carried out should be listed on the release.
The case where the particular maintenance was only EASA approved and not TCCA approved.
Example: an EASA AD not approved by TCCA.
Where the EC Operator requires his/her own paperwork to be used and signed the following certification can be made:
Release to Service in accordance with EASA Part-145.A.50:
"Certifies that the work specified except as otherwise specified was carried out in accordance with EASA Part-145 and in respect to that work the aircraft is considered ready for release to service."
or “Release to Service in accordance with EASA Part-145.50.”
12 QUALITY MONITORING SYSTEM (QMS)
The primary objective of the QMS is to enable the organisation to satisfy itself that it can deliver a safe product and that it remains in compliance with CARs and the Specific Regulatory Requirements.
A Quality Assurance Program under CAR 573.09 is found to be equivalent to the EASA Part 145.A.65 Quality Assurance System when the following additional items are included.
- The organisation must perform an internal audit within the first year of the EASA supplement approval
- A product audit on one of the organisations main product lines must be performed on a yearly basis.
- Except for the product audit referenced in (2) the internal audit cycle may be extended to 2 years
A product line audit means sample checking all the procedures and requirements associated with the specific product example to ensure that the end result is an airworthy product. A product line example for an aircraft rated AMO, would be a check process that is carried out for example an A check, 100 hour check, C check. Product line inspections will be carried out at each facility carrying out maintenance activities.
A product line example for an engine, avionics or component rated AMO would be conducted at each facility, work shop, base, carrying out maintenance activities.
An example of a product line for an avionics AMO could be the shop that performs maintenance on radios, for a component AMO could be the shop that performs maintenance on hydraulic pumps. If the component shop was performing maintenance on hydraulic pumps at two different facilities, they would be required to perform product line audits at both locations annually.
The above principle applies to all primary product lines.
The quality department will include a list of each product line to be audited on an annual basis in their audit plan.
13. REPORTING OF UNAIRWORTHY CONDITIONS
When serious defects are found in EC operated aircraft or aircraft components then such fact must be reported to EASA and the customer within 3 days of discovery. When reporting to EASA the identity of the customer must be included to allow follow up action. The existing TCCA Service Difficulty Report (SDR) form should be used.
This paragraph should address this issue.
14. LINE STATIONS
Each CAR 573 line station subject to the terms of this agreement should be listed giving its location and the basic maintenance capability at each location.
Line stations are accepted at locations that are identified in the relevant Approval/Manual and are subject to the oversight of TCCA. Line stations located in the EU Member states are not accepted under the Agreement i.e. you cannot exercise the privileges received under the Agreement in the EU member states.
Appendix 3: Application form (EASA Form 17)
European Aviation Safety Agency
Canadian AMO application for initial / continuation of a Maintenance Approval in accordance with the Bilateral Agreement between the European Union and Canada on Civil Aviation Safety.
EASA Form 17
Page 1 of 2
For the Applicant:
1. CAR 573 AMO name: CAR 573 certificate number:
2. Address of AMO:
3. Mailing Address (if different from 2 above):
4. Tel: Fax: Main Contact E-mail:
5. Please select the type of application and complete the section 6 of the Form 17
a. Initial [ ] b. Continuation [ ] c. Change [ ]
(in case of continuation and or change) EASA Part 145 approval number: EASA.145.______
I wish to apply on behalf of this AMO for an approval to perform maintenance on EU products in accordance with the Agreement concluded between the European Union and Canada on Civil Aviation Safety.
I understand that a maintenance approval granted under the terms and conditions of the bilateral agreement between the European Union and Canada is subject to the fees described in the European Commission Regulation (CE) No 593/2007(1) and that failure to demonstrate continued compliance to Fees and Charges regulation may result in the invalidity of an initial application or in the revocation of an existing maintenance approval.
I additionally understand that no technical investigation in relation with an initial application to a maintenance approval will be carried out until payment of applicable fees has been honoured (2).
Name & Signature of the AMO Accountable Executive:
Note: This application form shall be addressed to the AMO's TCCA Principal Maintenance Inspector, together with documents supporting the application, and in particular the EASA Supplement to the AMO Maintenance Policy Manual.
|For TCCA Inspector: Please process this application in accordance with SI 573-002|
European Aviation Safety Agency
Canadian AMO application for initial / continuation of a Maintenance Approval in accordance with the Bilateral Agreement between the European Community and Canada on Civil Aviation Safety.
EASA Form 17
Page 2 of 2
8. For EASA:
8a. Initial Application
EASA hereby confirms that the applicant: TCCA AMO #___________, has paid the fees in relation with the above described application, and therefore EASA authorises the granting by TCCA of the EASA Part 145 approval:
to perform maintenance on EU products once it has been satisfied compliance of the AMO to applicable regulatory requirements.
EASA hereby grants continuation/accepts the change (strike through as required) submitted by TCCA AMO #___________/ EASA.145.XXXX.
Please forward this acknowledgement to:
Transport Canada Civil Aviation
9. To be filled by EASA in case of non-compliance
EASA hereby informs TCCA that the applicant has failed to demonstrate compliance with the fees and charges and that the application/ continuation of the EASA Approval is rendered invalid.
(This information is to be forwarded to Transport Canada at the above mentioned address)
Note on fees and charges
- Date modified: