The European Union and Canadian Regulatory landscape is governed by the EASA-TCCA Bilateral Aviation Safety Agreement (BASA).
Both agencies rely on a Maintenance Agreement Guidance (MAG) document to bridge the small gaps between EASA Part 145 and TCCA CAR 573 / CAR 521
Initial Airworthiness: Design and Production
Under the BASA, the Technical Implementation Procedures (TIP) govern how EASA and TCCA recognize each other’s certifications.
Design Organization and Approval
In the EU, EASA Part 21 Subpart J requires a Design Organization Approval (DOA). In Canada, this is handled under CAR 521 through Design Approval Organizations (DAOs).
The technical procedure for cross-border design involves “Validation.” Rather than repeating the entire certification process, the importing authority (e.g., EASA) reviews the technical data of the exporting authority (e.g., TCCA). For minor changes, acceptance is often automatic; for major changes or new Type Certificates, the authorities establish a “Level of Involvement” to verify compliance with environmental and safety standards.
Production Organization (The Manufacturing Phase)
Once a design is approved, production is governed by EASA Part 21 Subpart G and TCCA CAR 561. These regulations ensure that every part produced conforms exactly to the approved design data.
When a part is manufactured in an EASA-approved facility, it is issued an EASA Form 1. Under the bilateral agreement, TCCA accepts this as a valid certificate of airworthiness for installation on Canadian aircraft, and vice versa for the TCCA Form One, provided the parts are new and traceable.
AMO Primary Oversight
- EASA Part 145: Oversight is managed by the National Aviation Authority (NAA) of the specific EU member state (e.g., LBA in Germany, DGAC in France). For organizations located outside the EU, EASA manages oversight directly.
- TCCA CAR 573: Oversight is managed by Transport Canada Civil Aviation (TCCA). They oversee Approved Maintenance Organizations (AMOs) within Canada and manage the certification of foreign shops through the bilateral agreement.
Certification Basis
- EASA Part 145: The legal basis is Regulation (EU) No 1321/2014. It is a “standardized” regulation across all EASA member states, designed to ensure a seamless “open sky” for maintenance within Europe.
- TCCA CAR 573: The legal basis is the Canadian Aviation Regulations (CARs), specifically Part V, Subpart 73. It outlines the requirements for becoming an Approved Maintenance Organization (AMO) in Canada.
Release Document
- EASA Part 145: Uses the EASA Form 1 (Authorized Release Certificate).
- TCCA CAR 573: Uses the TCCA Form One (Authorized Release Certificate).
Under the MAG, a TCCA AMO can issue a TCCA Form One that is considered equivalent to an EASA Form 1, provided they include a specific “dual release” statement in Block 12 (Remarks) noting the EASA approval number.
Accountable Manager
- EASA Part 145: Requires an Accountable Manager who has the ultimate responsibility (including financial) for ensuring all maintenance is performed to EASA standards. This person is often interviewed by the authority to ensure they understand their legal liabilities.
- TCCA CAR 573: Requires an Accountable Executive. Similar to the EASA role, this person must ensure that human and financial resources are available. Canada places a heavy emphasis on this role’s involvement in the Safety Management System (SMS).
Quality System and SMS
- EASA Part 145: Historically focused on a robust Quality System (Independent Audit). However, EASA recently integrated Safety Management Systems (SMS) requirements directly into Part 145 (Regulation 2021/1963), bringing it closer to the Canadian model.
- TCCA CAR 573: Canada was a global pioneer in Safety Management Systems (SMS). A TCCA AMO must have a fully functional SMS that includes hazard identification and risk management. For a long time, this was a “Special Condition” for EASA shops, but now both systems are very well aligned in this area.
Personnel and Licensing
- EASA Part 145: Relies on Part 66 licensed engineers (Category A, B1, B2, C). The certifying staff must be specifically authorized by the maintenance organization.
- TCCA CAR 573: Relies on AME (Aircraft Maintenance Engineer) licenses. TCCA requirements for “SCA” (Shop Certifying Authority) and “ACA” (Aircraft Certifying Authority) are used to designate who can sign the maintenance release within the AMO.
Key Difference: The “Special Conditions”
To work across the border, each must follow “Special Conditions” outlined in the MAG:
- For TCCA AMOs: To be EASA-approved, they must ensure all “major” repairs and alterations are approved by EASA-compatible data (which can be tricky, as TCCA and EASA don’t always define “major” the same way).
- For EASA Part 145: To be TCCA-approved, they must ensure their Quality Department audits the TCCA supplement at least once a year and that all parts used are documented on an EASA Form 1 or a TCCA Form One (FAA 8130-3 is also accepted under specific conditions).
Next Steps
Sofema Aviation Services (SAS) and Sofema Online (SOL) Provide Classroom, Webinar & Online training please see the websites email [email protected]
Tags:
EASA, Quality System, TCCA, sasblogs, Safety Management Systems (SMS), Bilateral Aviation Safety Agreement (BASA), Bilateral Considerations, Sofema Online (SOL), European Union, Sofema Aviation Serices (SAS), Canadian Regulatory landscape, Bilateral Aviation, Safety Agreement, Design and Production, Design Organization and Approval, The Manufacturing Phase
