Avionics News August 2023 - 19

THE VIEW FROM WASHINGTON
Continued from page 15
authority's certificate (authorization) to allow for a return
to service following maintenance, nor does it relieve the
domestic certificate holder from complying with the foreign
authority's requirements.
The MAGs or MIPs are developed by performing a gap
analysis of the foreign authority regulations and the domestic
authority regulations. The safety differences (a relative term) is
the basis of the MAG or MIP. A maintenance organization must
comply with its own regulations (domestic regulations) plus the
foreign authority differences in order to satisfy the requirements
for the issuance and maintenance of the foreign certificate.
Usually, the differences are required to be documented as
part of a foreign certificate supplement to the maintenance
organization's manuals (expositions).
As an example, the maintenance implementation
procedures between the Federal Aviation Administration
and Transport Canada Civil Aviation currently at Revision
1 dated June 14, 2019, contain Section B, which lists the
special conditions providing guidance for FAA-certificated
A&P mechanics and FAA-certificated repair stations. Section
C lists the special conditions providing guidance for TCCAlicensed
AMEs and TCCA AMOs. Contained within section
B are two essential paragraphs: 2 and 3.
Paragraph 2 applies to FAA-certificated repair stations
located within the United States performing work on
Canadian-registered aircraft that are not operated in
commercial air service pursuant to Part VII of the CARs and/
or aeronautical products. For these repair stations, no TCCA
supplement is required. While there is no supplement, there
are still special conditions such as:
" Technical data used to perform major repairs or
major modifications must be data approved by TCCA as
described in CAR 571.06. FAA field approvals supporting
modifications using FAA Form 337 are not acceptable on
Canadian-registered aircraft. "
Paragraph 3 is applicable to FAA-certificated repair
stations located within the United States performing work on
Canadian-registered aircraft that are operated in commercial
air service pursuant to Part VII of the CARs. For repair
stations providing maintenance on these aircraft, a TCCA
supplement is required (including line maintenance facilities
located outside the United States). While there is quite a bit of
information that must be included in the Canadian supplement
to the FAA Part 145 repair station manuals, there are three
items worth noting.
The repair station must develop (and follow):
* Procedures to ensure that work that disturbs engine
or flight controls will be subject to an independent
check, as required by CAR 571. The system that has
been disturbed needs to be inspected by at least two
persons for correct assembly and correct locking of
any parts disturbed by the maintenance performed,
including an operational check for proper sense
and range of motion of the engine or flight controls.
The technical record will contain the signatures of
both persons who performed the check. One of the
signatures required by this section may be that of the
person who has signed the maintenance release.
* Procedures to ensure that all employees working
on aircraft operated per CAR Part VII have been
trained on the TCCA supplement.
* Procedures to ensure the incorporation of portions
of the air operator's safety management system as
follows:
*
Establish the contact person within the FAAcertificated
repair station with whom the
air operator will communicate SMS-related
information;
*
Establish and maintain a reporting system
in accordance with the air operator/repair
station-established agreement;
* The reporting system should ensure the
timely collection of information related
to hazards, incidents and accidents, the
investigation, analysis and identification
of the cause or probable cause, risk
management analyses, and relevant to issues
that may adversely affect safety; and
* The reporting system should identify,
or adopt, a non-punitive reporting and
emergency response plan, in accordance
with the air operator/repair stationestablished
agreement.
These special conditions not only are required to be
documented in a repair station supplement, but they also must
be accomplished when working on Canadian-registered aircraft.
When a repair station chooses to pursue international
commerce, it commits the business to incorporating the special
conditions of the foreign authority; in return, it receives
maintenance and return to service privileges. It goes beyond the
repair station supplement. Every MIP/MAG contains special
conditions, and it is critical to know what the special conditions
are, assure they are documented in the applicable supplement
if required, but most importantly, it is the responsibility of the
repair station to comply with the special conditions.
Next month, we will continue this conversation with
a focus on the special conditions contained within the
maintenance annex guidance to the United States-European
Union BASA. q
avionics news * august 2023 19
Avionics News August 2023

Table of Contents for the Digital Edition of Avionics News August 2023
