Avionics News - September 2023 - 15

The acceptance of a foreign certificate is not without
additional responsibilities. It is the accountable
manager's responsibility to ensure the repair station
meets all of the requirements of all the certificates.
Of these 49 agreements, there are only five that
contain a flight standards agreement to include
maintenance procedures: Canada, European Union,
Singapore, Switzerland, and the United Kingdom. The
U.S., Switzerland and the U.K. guidance are all similar.
The maintenance implementation procedures highlight
the differences between the two regulatory systems,
while the maintenance agreement guidance offers a
means of compliance to hold the foreign certificate.
It is important to note that while certificated under a
bilateral agreement, the MIP/MAG are your governing
documents and not necessarily the regulations of the
foreign authority. This has recently been identified
with the implementation of safety management systems
regulations in Europe for EASA 145s based within
Europe as well as directly managed foreign repair
stations (that is, repair stations not covered under a
bilateral agreement). For those EASA repair stations
covered under a bilateral agreement, the maintenance
agreement will be amended in the future to address the
differences between the EASA regulation and the host
regulations.
For illustrative purposes, let's highlight the United
States-European Union agreement. It is important that
for anyone affected by a bilateral agreement of any
kind between your civil aviation authority and a foreign
authority granting you maintenance authority for their
aircraft, you review and comply with the requirements.
The beginning of the guidance, Section A, focuses on
authority interaction. That is, how the authorities will
work together, where they will provide direct oversight,
and how they will resolve disputes. The second section
of the United States-European Union maintenance
guidance, Section B, addresses the certification for
U.S.-based repair stations.
As expected, Section B contains the initial
certification as well as the renewal processes. While
the FAA regulations require a certificate change if the
certificate holder changes the name or location of the
repair station, EASA requires a bit more. According
to the MAG, " Any change of name; including doing
business as (d/b/a) names, a change of the address
of the approved facility (this does not include the
mailing address) or change of repair station number;
requires the EASA certificate to be reissued. " There
are also limitations to working away from their fixed
location. Notwithstanding the basic requirement for
the FAA 145 to have work away authority, under the
EASA approval, " the privilege of working away from
a base station can be used only to perform nonroutine
maintenance, defined as urgent defect rectification,
on an EU-registered aircraft or articles intended for
installation on an EU-registered aircraft. "
The next area of review is the guidance for the
EASA Supplement, Appendix 1 to Section B. The first
area of note is the accountable manager's commitment
statement. Imbedded in this section is who is intended
to be identified as the accountable manager. In this
case, EASA has a higher bar than the FAA. According
to EASA, " The accountable manager is normally
intended to mean the chief executive officer of the
organization, who, by virtue of position, has overall
responsibility (including appropriate financial
authority) for running the organization. When the
accountable manager is not the chief executive officer,
he or she must have direct access to the chief executive
officer and have a sufficiency of maintenance funding
allocation. "
Continued on page 38
avionics news * september 2023 15
Avionics News - September 2023

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