European Aviation Safety Agency (EASA) - Maintenance Annex Guidance

Section C:
Approval process for EU Based Maintenance Organizations

  1. Initial Approval Process
    1. NAA Action
    2. Applicant Action
    3. NAA/TCCA Actions
  2. Continuation Process
    1. NAA Actions
    2. Applicant Actions
    3. NAA/TCCA actions
    4. TCCA actions
    5. Late Applications
    6. Surrender of approval
  3. Amendment process
    1. Applicant actions
    2. NAA actions
    3. TCCA Actions
  4. Suspension or Revocation
    1. Suspension
    2. Revocation
    3. TCCA Actions
    4. Communication
  5. Appendices
  6. Appendix 1: TCCA Supplement Contents
  7. Appendix 2: Example TCCA Supplement
  8. Appendix 3: Application Form (Transport Canada Form 24-0093)

Introduction

This Guidance details how EASA and NAA’s will implement the Bilateral Agreement and Annex B between the European Union and Canada for EASA Part 145 Approved Maintenance Organisations located in the European Union.

I Initial Approval Process

1. NAA Action

Upon receipt of a request for supplement approval in accordance with this Agreement, NAA shall ensure that the applicant has access to the most current revision of the MAG and the TCCA Application Form 24-0093.

2. Applicant Action

To apply for approval under the provisions of the Agreement Annex B, an applicant AMO must:

  1. Be located in the one of the EU Member States and
  2. Hold an EASA Part-145 approval.

The applicant shall:

  1. Complete the TCCA Application Form 24-0093 and
  2. Establish a TCCA Supplement to the Maintenance Organisation Exposition in accordance with the supplement guidance material (see Appendix 1).

The TCCA Application Form 24-0093 plus the proposed TCCA Supplement should be sent to the NAA at least 90 days prior to the date initial approval is required.

Note: The above documents shall not be sent to TCCA by the applicant.

3. NAA/TCCA Actions

  1. The NAA shall send the TCCA Form 24-0093 to TCCA HQ.
  2. TCCA shall invoice the organization based on the current Fee Regulations which can be found in Canadian Aviation Regulation Part 1, Sub Part 4.
  3. Once TCCA has received the applicant’s payment, it shall notify the NAA that the process can continue and identify (on the TCCA Form 24-0093) the TCCA approval number to be used in the process.
  4. The NAA shall review the TCCA Supplement for compliance with Appendix 1.
  5. Where the supplement is found satisfactory, the NAA shall issue a letter quoting the TCCA Approval Number to the AMO and attesting that the TCCA supplement is approved. The letter shall specify that the scope of ratings and limitations shall not exceed that which is specified in the organizations Part 145 certificate and scope of approval.
  6. Once approved, the TCCA supplement and the privileges associated with it shall remain in force until surrendered, suspended or cancelled by the NAA or TCCA.
  7. The NAA will ensure that activities conducted in accordance with the supplement are part of their oversight of the organization.
  8. The NAA shall forward a copy of the supplement approval letter to TCCA.
  9. TCCA in turn will publish the approval on the TCCA website.

II Continuation Process

1. NAA Actions

The NAA ensures every 24 months that the conditions for approval continue to be met. Where the conditions are not met, the NAA shall take appropriate action and notify TCCA with copy to EASA Standardisation Department.

2. Applicant Actions

The applicant shall submit the following to the NAA;

  1. A completed the TCCA Application Form 24-0093 indicating continuation and/or change in Block 5 as required, and
  2. A current copy of their EASA MOE supplement (only if the continuation is submitted together with a change).

3. NAA/TCCA actions

  1. The NAA will review the submitted TCCA Form 24-0093 for completeness and legibility.
  2. The NAA will review the supplement for compliance to Appendix 1(if submitted).
  3. The NAA will issue a new supplement approval letter when the supplement is found acceptable (if submitted).
  4. The NAA will forward the TCCA Form 24-0093 and Supplement approval letter (if issued) to TCCA HQ.

4. TCCA actions

  1. TCCA shall invoice the organization based on the current Fee Regulations which can be found in Canadian Aviation Regulation Part I, Subpart 4. The applicable CAR 104 fee will be invoiced upon application for continuation.
  2. TCCA shall notify the NAA if the applicant has failed to make the fee payment within 90 days from invoice date.
  3. If the applicant fails to pay the applicable continuation fee TCCA shall ask NAA to revoke the supplement approval letter.
  4. Where TCCA has reason to recommend to NAA not to continue the approval, TCCA should immediately inform EASA Standardisation department and the NAA who will take appropriate action.

5. Late Applications

The applicant is expected to apply 60 days prior to their continuation due date. The NAA 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.

6. Surrender of approval

Where a company surrenders its approval, the NAA will notify TCCA to remove the company from the list of approved companies on its website.

III Amendment process

1. Applicant actions

The following changes to an organisation require the submission of a TCCA Form 24-0093 and associated amended supplement to the NAA:

  1. Change of Address.
  2. Change of Accountable Manager.
  3. Change of Organisation Name and/or Approval Number.

2. NAA actions

  1. The NAA will review the submitted TCCA Form 24-0093 for completeness and legibility.
  2. The NAA will review the supplement for compliance to Appendix 1.
  3. The NAA will issue a new supplement approval letter when the supplement is found acceptable.
  4. The NAA will forward the TCCA Form 24-0093 and Supplement approval letter to TCCA HQ.

3. TCCA Actions

TCCA will update the list of approved companies on its website.

IV Suspension or Revocation

1. Suspension

Suspension of the EASA Part 145 Approval will automatically render the Canadian CAR 573 supplement approval letter invalid for the duration of the suspension. As a consequence of this suspension the AMO cannot exercise the privileges of their CAR 573 approval in accordance with the Agreement.

2. Revocation

Revocation of the EASA Part 145 Approval will automatically render the Canadian CAR 573 supplement approval letter invalid. As a consequence of this revocation the AMO all privileges of their CAR 573 approval are permanently removed and cannot be re-instated.

3. TCCA Actions

Where TCCA has reason to request the NAA to revoke the supplement approval letter, the NAA should take immediate action and inform EASA Standardisation department.

4. Communication

Each party shall immediately notify the other party of any activities related to the aforementioned certificate action.

V Appendices

Appendix 1: TCCA Supplement Contents

In accordance with the Agreement on Aviation Safety between the European Union and Canada, each AMO maintaining aircraft registered in Canada or components intended for installation thereon, shall include in its Maintenance Organisations Exposition a supplement in accordance with Annex B Appendix B1.

Appendix 2: Example TCCA Supplement

TCCA SUPPLEMENT to Part 145 Maintenance Organization Exposition

Company Name and Facility Address:

 

TCCA Approved Maintenance Organisation Number:

 

EASA Part 145 Approval Number:

 

Compliance with the TCCA approved Supplement together with the EASA Approved MOE 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 TCCA Supplement in English and provide it to TCCA upon request.

The cover page of the TCCA Supplement should include the intent of the above statement

Note: This example TCCA 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.

Table of content

Self explanatory. No example provided.

1. LIST OF EFFECTIVE PAGES

Self explanatory. No example provided.

2. AMENDMENT PROCEDURE

Self explanatory, but this paragraph should identify by title, who within the Maintenance Organization is responsible for amendment action. It should also ensure that changes to the document are submitted to the competent authority (NAA) for acceptance and approval prior to change implementation.

3. INTRODUCTION

An EASA Part-145 Maintenance Organization can be TCCA CAR 573 approved when the EASA Part-145 Maintenance Organization complies with the maintenance specific regulatory requirements set forth in this supplement in addition to complying with EASA Part 145.

This supplement is therefore intended to identify the means to comply with the agreement when performing maintenance on Canadian 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 EASA Approved MOE, the organisation and procedures upon which the TCCA CAR 573 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 TCCA 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 TCCA and notified to this organisation from time to time.

It is further understood that TCCA 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, SCOPE AND LIMITATION

This paragraph must address the approval, basis, scope and limitation of the respective Maintenance Organization.

An acceptable statement for this paragraph could be:

TCCA CAR 573 Approval is based upon compliance with EASA Part 145 except where varied by the conditions specified in the Agreement and associated MAG.

The approval of maintenance is limited to the scope of work permitted under the current Certificate issued by EASA to the Maintenance Organization in accordance with Part 145 for work carried out within the European Union unless agreed otherwise on a case by case basis by the Technical Agents of the Parties to the Agreement.

6. ACCESS BY EASA AND TCCA

This paragraph must identify the fact that TCCA staff should be allowed access to the Maintenance Organization 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 or the supervising NAA.

An acceptable statement for this paragraph could be:

TCCA staff will be allowed access to the maintenance facilities for the purpose of showing compliance with the procedures and standards as set forth in the MOE and this TCCA Supplement and also for investigation of specific cases.  In the case of a serious non-compliance with regulations or established standards Company name...... accepts that is may be subject to TCCA enforcement action to maintain its approved status with TCCA. It is also acceptable that the supervising NAA may perform such investigation on behalf of TCCA.

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 TCCA 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 TCCA, a work order/contract defining the maintenance to be performed will be established between the organization and the Canadian 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 Canadian 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. MAJOR REPAIRS AND MODIFICATIONS

This paragraph should specify that the Canadian customer must obtain or establish the process to obtain TCCA approvals prior to the incorporation of major repairs and major modifications and that the Civil Aviation Regulation's definition of "Major repair or Modification" is to be used.

An acceptable statement for this paragraph could be:

For purposes of defining ‘major modification or major repair’ CAR 101.01 will be used for Canadian products. This Part-145 Maintenance Organization will ensure that major repairs and major modifications are incorporated only when in receipt of appropriate approvals from TCCA through the Canadian customer.

9. RELEASE OF COMPONENTS AFTER MAINTENANCE

The Maintenance Release of Aircrafts/Components Other Than Complete Aircraft is to be conducted in accordance with the requirements of EASA Part 145 and the additional requirements specified in appendix B1 of the Agreement and explained further in the Maintenance Annexe Guidance (MAG).  An Authorised Release Certificate (EASA Form 1) is to be issued. This paragraph should specify the actions needed to ensure that the maintenance release is recognized as a valid CAR 571.10 maintenance release by the Canadian Customer and regulatory body.

The supplement should contain a copy of a completed example of an EASA Form 1 used by the AMO and instructions for completion by staff.

An acceptable statement for this paragraph could be:

Release to service of components maintained in accordance with this supplement will be carried out in accordance with EASA Part145 and the additional requirements specified in appendix B1 of the agreement, paragraphs 7 and 8 of this supplement will be taken into account. An Authorised Release Certificate (EASA Form 1) is to be issued.

A maintenance release made in accordance with this supplement constitutes a corporate release on behalf of the Maintenance Organization as well as being a CAR 571.10 release.

Block 12 of the EASA Form 1 will specify any overhaul, repairs, modifications, Airworthiness Directives, Service Bulletins, replacement parts and quote the issue of the approved data used. In 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 in Block 12.

Block 12 will include the TCCA Approval number e.g. "TCCA Approval No.: 8XX-XX"

Block 14a of the EASA Form 1 will display a checkmark in the "Other regulation specified in block 12" Check Box. In the case where the particular maintenance was only TCCA approved and not EASA approved the "Part-145.A.50 Release to Service" checkbox should not be checked. Example: a TCCA AD not approved by EASA.

The EASA Form 1 document will be signed by a person authorised to return the component to service on behalf of …company name.

9.1 Component eligibility for installation

The supplement should include information regarding the acceptability of components authorised for use during maintenance.

An acceptable statement for this paragraph could be:

Only the following new and used components may be fitted during maintenance:

9.1.1 New Components

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. The following new components are eligible for installation on Aircraft/Component under the jurisdiction of TCCA:

  1. New components from USA OEMs, PC holders and Part Manufacturing Approval (PMA) holders accompanied by a FAA Form 8130-3 or a Certificate of Conformity (C of C) as a new part.
  2. New components from all EU States OEMs and PC holders released in accordance with EASA Part-21 (EASA Form 1).
  3. New components from Canadian OEMs and PC holders accompanied by a TCCA Form One as a new part.
  4. New Component obtained from a manufacturer holding a type design recognized in Canada and the part is certified in accordance with the laws of the state of manufacture
  5. New Component, obtained from a manufacturer under the jurisdiction of a NAA other than Canada or an EU member state, certified pursuant to an agreement with Canada, which agreement provides for the acceptance of export airworthiness certification;
  6.  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.
9.1.2 Used Components

Used components should be traceable to a maintenance organisation approved by TCCA 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. The following used components are eligible for installation on Aircraft/Component under the jurisdiction of TCCA:

  1. Used components from a FAA repair stations located in one of the 50 States, the District of Columbia and Puerto Rico accompanied by an FAA Form 8130-3 issued as a maintenance release. Used components from a FAA repair station located outside of the USA territorial boundaries are not eligible for installation on Aircraft/Component under the jurisdiction of TCCA.
  2. Used components from a Canadian AMO should be accompanied by a TCCA Form One issued as a maintenance release.
  3. Used components from EASA Part-145 approved maintenance organisations holding a valid TCCA CAR 573 approval when accompanied by an EASA Form 1 issued as a maintenance release; the TCCA approval number shall be visible in block 12 of the EASA Form 1.
  4. Used Component, accompanied by a valid authorized release certificate issued by  a maintenance organization under the jurisdiction of a NAA other than Canada or an EU member state, certified pursuant to an agreement with Canada, which agreement provides for the acceptance of export airworthiness certification;
  5. Used components from a EU AMO that does not have an TCCA approved supplement should not be used even if accompanied by a EASA Form 1
  6. 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

Not Applicable.

11. RELEASE OF AIRCRAFT AFTER MAINTENANCE

The release of aircraft after maintenance is to be conducted in accordance with the requirements of EASA Part 145 and the additional requirements specified in appendix B1 of the agreement and explained further in the Maintenance Annexe Guidance (MAG).

An acceptable statement for this paragraph could be:

Release to service of aircraft after maintenance shall be carried out in accordance with EASA Part 145 except that paragraphs 7 and 8 of this TCCA Supplement shall also be taken into account and specify the aircraft maintenance plus any repairs, modifications, Airworthiness Directives, replacement parts together with the issue of approved data used. At the completion of maintenance the following maintenance release statement will be made in the aircraft maintenance record.

Maintenance Release in Accordance with EASA Part 145:

"Certifies that except as otherwise specified the work described was carried out in accordance with EASA Regulations 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:

  1. The case where not all of the required maintenance was carried out as agreed by the customer. The maintenance not carried out will be listed on the release.
  2. The case where the particular maintenance was only TCCA approved and not EASA approved. Example: a TCCA AD not approved by EASA.

The TCCA issued maintenance organization approval number will be entered into the technical record anytime a maintenance release for an aircraft is made.

11.1 Component eligibility for installation

The requirements regarding New and Used components eligibility for installation on Canadian Registered Aircrafts are defined in section 9.1 of this Canadian supplement.

12. AUDIT PROGRAM

The primary objective of the Quality Assurance System is to enable the organisation to satisfy itself that it can deliver a safe product and that it remains in compliance with EASA Part 145 and the Specific Regulatory Requirements.

A Quality Assurance System under EASA Part 145.A.65 is found to be equivalent to the TCCA CAR 573.09 Quality Assurance Program when the following additional items are included.

  1. The organisation must perform an internal audit within the first year of the TCCA supplement approval
  2. A product audit on one of the organisations main product lines must be performed on a yearly basis.
  3. Except for the product audit referenced in (2) the internal audit cycle may be extended to 2 years 
13. REPORTING OF UNAIRWORTHY CONDITIONS

This paragraph must address the procedures for reporting an un-airworthy Canadian registered aircraft or aeronautical product.

An acceptable statement for this paragraph could be:

When any Canadian registered aircraft or aeronautical product under the jurisdiction of TCCA is found to be un-airworthy, it must be reported to the Canadian customer by the fastest means available. The Canadian Customer will advise Transport Canada as required by the CAR’s and the SDR reporting system.

14. LINE STATIONS

Each EASA Part 145 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 the Competent Authority. Line stations located in Canada are not accepted under the Agreement i.e. you cannot exercise the privileges received under the Agreement in Canada.

Appendix 3: Application Form (Transport Canada Form 24-0093)

Transport Canada Form 24-0093

European Maintenance Organisation (MO)application for initial / continuation of a Maintenance Approval in accordance with the Bilateral Agreement between the European Union and Canada on Civil Aviation Safety.

For the Applicant:

  1. EASA Part 145  MO name:
    EASA Part 145 certificate number:
  2. Address of MO:
  3. Mailing Address (if different from 2 above):
  4. Tel:
    Fax:
    Main Contact E-mail:
  1. Please select the type of application and complete the section 6 of the Form
    1. Initial:
    2. Continuation:
    3. Change:

in case of continuation and or change) TCCA CAR 573 AMO number:

  1. Application:

I wish to apply on behalf of this MO for an approval to perform maintenance on Canadian 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 charges described in the CAR 104 and that failure to submit the applicable charge may result in the suspension or cancellation of an existing maintenance approval.

(Note processing of this application may incur additional fees from your NAA)

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 charge has been submitted

Date:

Name & Signature of the MO Accountable Executive:

Note: This application form is to be addressed to the MO’s NAA Surveyor, together with documents supporting the application, and in particular the EASA Supplement to the AMO Maintenance Policy Manual.

  1. Member State NAA Action:

Please forward this application together with the TCCA supplement approval letter to:

Transport Canada Civil Aviation
Operational Airworthiness (AARTM)
e-mail: TCCA-EASA@tc.gc.ca

Transport Canada Civil Aviation Form 24-0093

European MO application for initial / continuation of a Maintenance Approval in accordance with the Bilateral Agreement between the European Community and Canada on Civil Aviation Safety.

  1. For TCCA:
    1. Initial Application
      TCCA hereby confirms that the applicant: EASA Part 145 #___________, has paid the fees in relation with the above described application, and therefore TCCA authorises the granting by the competent authority of the TCCA CAR 573 approval: __________________ to perform maintenance on Canadian products once it has been satisfied compliance of the AMO to applicable regulatory requirements.
    2. Continuation/Change
      TCCA hereby grants continuation/accepts the change (strike through as required) submitted by EASA Part 145___________/ TCCA CAR 573 XXX-XXX.

Name:

Date:

Please forward this acknowledgement to:
The applicable EU Member State NAA

  1. To be filled by TCCA in case of non-compliance

TCCA hereby informs the competent authority that the applicant has failed to demonstrate compliance with the fees and charges and that the application/ continuation of the TCCA Approval is rendered invalid.

(This information is to be forwarded to the competent authority at the above mentioned address)

Name

Date:

Note on fees and charges

For information regarding the current fees and charges please refer to the TCCA fees and charges regulation which can be found on the TCCA web site: www.tc.gc.ca

Upon receipt of an application Form 24-0093 for initial approval, TCCA will address to the applicant an invoice containing details related to payment methods.

For continuation of TCCA approval, TCCA will invoice the applicant every two years.

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