Subject: Maintenance Annex Guidance – Bilateral Aviation Safety Agreement between Canada and the European Union
| Issuing Office: | Civil Aviation, Standards |
|---|---|
| Document No.: | AC 573-010 |
| File Classification No.: | Z 5000-34 |
| Issue No.: | 01 |
| RDIMS No.: | 20074129-V8 |
| Effective Date: | 2024-11-15 |
Table of contents
- 1.0 Introduction
- 2.0 References and requirements
- 3.0 Background
- 4.0 Component AMOs
- 5.0 Canadian air operators utilizing EU-aircraft AMOs
- 6.0 CAR 573 AMOs maintaining EU-registered aircraft
- 7.0 Information management
- 8.0 Document history
- 9.0 Contact us
1.0 Introduction
(1) This Advisory Circular (AC) is provided for information and guidance purposes. It describes an example of an acceptable means, but not the only means, of demonstrating compliance with regulations and standards. This AC on its own does not change, create, amend, or permit deviations from regulatory requirements, nor does it establish minimum standards.
1.1 Purpose
(1) The purpose of this AC is to provide guidance to the industry concerning the Maintenance Annex Guidance (MAG) between Transport Canada Civil Aviation (TCCA) and the European Aviation Safety Agency (EASA).
1.2 Applicability
(1) This AC is applicable to Approved Maintenance Organizations (AMOs) located in Canada performing maintenance on aeronautical products under the regulatory control of the European Union.
(2) This AC is applicable to Canadian aircraft owners and Canadian air operators requesting the services of EASA-certificated AMOs to perform maintenance on aeronautical products under the regulatory control of TCCA.
(3) This AC applies to TCCA personnel.
1.3 Description of changes
(1) Not applicable.
2.0 References and requirements
2.1 Reference documents
(1) It is intended that the following reference material be used in conjunction with this document:
- (a) Aeronautics Act (R.S.C., 1985, c. A-2)
- (b) Part V, Subpart 71 of the Canadian Aviation Regulations (CARs) – Aircraft Maintenance Requirements
- (c) Part V, Subpart 73 of the CARs – Approved Maintenance Organizations
- (d) Standard 571 of the CARs – Maintenance
- (e) Standard 573 of the CARs – Approved Maintenance Organizations
- (f) Standard 573, Division II of the CARs – Safety Management System
- (g) Advisory Circular (AC) 571-024 – Documentation Required for the Installation of Parts onto Canadian Registered Aircraft
- (h) EASA Form 17 – 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
- (i) The Agreement on Civil Aviation Safety between Canada and the European Union
- (j) The Maintenance Annex Guidance authorized by Annex B of the Bilateral Aviation Safety Agreement
2.2 Cancelled documents
(1) Not applicable.
(2) By default, it is understood that the publication of a new issue of a document automatically renders any earlier issues of the same document null and void.
2.3 Definitions and abbreviations
(1) The following definitions are used in this document:
- (a) Accountable Executive: normally intended to mean the Chief Executive Officer of the organization, who by virtue of position has overall responsibility, including in particular financial responsibility for running the organization. Within an EASA AMO this individual is referred to as the Accountable Manager.
- (b) Aircraft: any machine that can derive support in the atmosphere from the reactions of the air other than reactions of the air against the earth’s surface.
- (c) Aircraft AMO: an AMO of which its scope of ratings allow for the performance and release of work on aircraft.
- (d) Applicant: the organization applying for initial or continued recognition under the Agreement.
- (e) Approved Maintenance Organization: a natural person or a legal person entitled to maintain any aircraft and/or component for which they are approved.
- (f) Authorized Release Certificate: a document, such as a TCCA Form One or EASA Form 1, whose purpose is to detail an aeronautical part which has been manufactured or maintained by an approved organization, the data to which it conforms or was maintained to, and who manufactured or performed the maintenance on it.
- (g) Bilateral Agreement: the working arrangement between the Civil Aviation Directorate of Transport Canada Civil Aviation and the European Union Safety Agency for the promotion of aviation safety.
- (h) Civil aeronautical product: any civil aircraft, or aircraft engine, or aircraft propeller, or sub-assembly, appliance, part or component installed or to be installed thereon.
- (i) Competent Authority: a government agency or entity that is designated as a Competent Authority by a Party for the purpose of this Agreement.
- Note: TCCA, EASA and EU Member State National Aviation Authorities are Competent Authorities (CAs).
- (j) Component: any aircraft engine, aircraft propeller, part or appliance.
- (k) Component AMO: an AMO of which its scope of ratings do not include the aircraft/airframe category. It does include all or some of the remaining categories other than aircraft/airframe based on their scope of ratings and limitations issued by TCCA or EASA.
- (l) EASA approval: the recognition given by EASA to a Canadian AMO.
- (m) EASA Supplement: a supplement to an AMO’s approved Maintenance Policy Manual (MPM) required by Annex B, Appendix B1 of the Agreement.
- (n) Line station: locations where line maintenance on aircraft belonging to one Competent Authority is performed with the approval of that Competent Authority, in the other Competent Authority’s territory and are identified in the relevant approval/manual which are subject to the oversight by the approving Competent Authority.
- (o) Maintenance: the performance of inspection, overhaul, repair, preservation, and the replacement of parts, materials, appliances, or components of a civil aeronautical product to assure the continued airworthiness of that product and includes the embodiment of modifications but does not include the design of repairs and modifications.
- (p) Maintenance Annex Guidance: a document developed jointly by TCCA and EASA, authorized by the Joint Sectorial Committee on Maintenance, providing functional guidance as authorized by Annex B of the Agreement on Civil Aviation Safety between Canada and the European Union.
- (q) Operational Airworthiness: Standards Branch, Operational Airworthiness division.
- (r) Safety Management System: a systematic approach to managing safety, including the necessary organizational structures, accountabilities, polices and procedures.
- (s) TCCA approval: is the recognition given by TCCA to a European based EASA AMO.
- (t) TCCA Supplement: a supplement to a Maintenance Organization’s approved Maintenance Organization Exposition required by Annex B, Appendix B1 of the Agreement.
- (u) The Agreement: the Agreement on Civil Aviation Safety between Canada and the European Union.
(2) The following abbreviations are used in this document:
- (a) AC: Advisory Circular
- (b) AE: Accountable Executive
- (c) AMO: Approved Maintenance Organization
- (d) ARC: Authorized Release Certificate
- (e) CA: Competent Authority
- (f) CARs: Canadian Aviation Regulations
- (g) EASA: European Union Aviation Safety Agency
- (h) EU: European Union
- (i) MAG: Maintenance Annex Guidance
- (j) MPM: Maintenance Policy Manual
- (k) NAA: National Aviation Authority
- (l) OP Air: Operational Airworthiness
- (m) PMI: Principal Maintenance Inspector
- (n) SMS: Safety Management System
- (o) TCCA: Transport Canada Civil Aviation
3.0 Background
(1) Since 2011-07-26, Canadian and European based AMOs have been approved to perform maintenance on civil aeronautical products under the control of the other authority in accordance with the Agreement on Civil Aviation Safety.
3.1 General information
(1) The procedures for implementing the provisions of the Agreement are set forth in the MAG. The objective of the MAG is to specify the terms and conditions under which TCCA and EASA can accept inspections and evaluations of each other’s maintenance facilities and personnel.
(2) Canadian air operators and AMOs should be familiar with the Agreement and the MAG before contracting maintenance to an EASA aircraft AMO.
(3) Persons maintaining EU-registered aircraft and/or aeronautical products should be familiar with the Agreement and the MAG.
(4) AMOs who maintain aircraft (registered in an EU Member State) will still be required to hold an EASA approval and an approved EASA Supplement. This includes AMOs who’s scope of approval requires a maintenance release with respect to the type of work performed on the aircraft (E.g. Avionics, Structures).
- (a) New applicants must comply with the MAG, revision 3, and all supplement requirements.
- (b) Aircraft AMOs whose current approval has an expiry date before year-end will be given an extension until 2024-12-31 to have an approved EASA Supplement meeting the requirements of the MAG, revision 3.
- (c) All other existing CAR 573 AMOs with an EASA approval who are performing and certifying maintenance on EU-registered aircraft have until 2025-01-31 to submit an EASA Supplement that meets the requirements of the MAG, revision 3.
(5) AMOs who intend on maintaining only components, including complete engines or propellers, will not require an EASA approval or an EASA Supplement. Organizations are asked to surrender their approval prior to 2024-11-15 as the approval and approval number is no longer valid after this date.
(6) Canadian AMOs may encounter circumstances that require evidence of acceptance in accordance with the TCCA/EASA MAG. The following language may be used in block 12 of a TCCA Form One in accordance with Appendix J of Section 571 of the Standard:
“Accepted in accordance with Section B of the MAG between TCCA/EASA.”
(7) With respect to major modifications and major repairs to EU customer components, component AMOs shall ensure that the EU customer has obtained the approval of the responsible Competent Authority and shall ensure that the EU customer has provided the required data to support the major modification and/or major repair, in accordance with applicable EASA-TCCA TIP provisions.
(8) An EASA Form 1 is fully recognized in Canada without an additional statement or TCCA approval and a TCCA Form One is fully recognized in the EU without an additional statement or EASA approval.
(9) An EASA Form 1 with a TCCA approval number in block 12 or an EASA Form 1 with a triple release, i.e. FAA-EASA-TCCA issued by an EASA Part-145 AMO remains valid indefinitely.
(10) An EASA Form 1 with a single release is acceptable, regardless of the date the Form 1 was originally issued.
(11) A Service Difficulty Report (SDR) for a serious defect found on an EU-registered aircraft or aircraft components are to be reported to EASA using their online reporting system https://aviationreporting.eu/. There is no longer a requirement to submit a duplicate SDR to TCCA.
(12) Any line stations operated by the AMO should be described within the MPM and referenced or included in the EASA Supplement. The procedure for a line station must cover the scope of work available at each station intended for the performance of maintenance on EU-registered aircraft.
(13) Line stations located outside the territorial boundaries of Canada should be identified in the EASA Supplement as above, and notification made to the organization’s PMI for coordination with the EASA for approval on a case-by-case basis.
(14) AMOs performing and certifying maintenance on EU-registered aircraft are required to establish or identify SMS procedures that meet the provisions of Section 573, Division II – Safety Management System.
- (a) If the AMO;
- (i) Does have a SMS program in place, the EASA Supplement will have to be amended to include the program or include a document incorporated by reference (DIR). If included as a DIR, a statement stating this and the procedure for maintaining the document is to be addressed in the EASA Supplement.
- (ii) Does not have a SMS program in place, they are expected to develop a program in accordance with the above provisions. The EASA Supplement will have to include the program, or a document incorporated by reference (DIR). If included as a DIR, a statement stating this and the procedure for maintaining the document is to be addressed in the EASA Supplement.
- (b) Once the supplement is approved by your PMI, the SMS program will be validated at the organization’s next scheduled surveillance inspection.
- Note: Meeting Section 573, Division II - SMS requirements of the MAG does not render an AMO SMS compliant in accordance with Subpart 107 of the CARs.
4.0 Component AMOs
(1) Component AMOs are reciprocally accepted between TCCA and EASA to permit the acceptance of each other’s maintenance certification and do not require an EASA Supplement.
(2) A TCCA Form One and an EASA Form 1 are reciprocally accepted.
(3) A TCCA Form One and an EASA Form 1 with a single release is acceptable, regardless of the date the forms were originally issued.
(4) The ARCs issued by these organizations are acceptable in accordance with the MAG and further explained in Advisory Circular (AC) 571-024, Documentation Required for the Installation of Parts onto Canadian Registered Aircraft.
5.0 Canadian air operators utilizing EU-aircraft AMOs
(1) A Canadian air operator is required to ensure an EU-aircraft AMO has the appropriate ratings and limitations necessary for the required maintenance. This can be established through the AMO listing on the EASA website: TCCA Approved Maintenance Organizations located in the EU.
(2) EU-based aircraft AMOs performing work on Canadian registered aircraft require a TCCA Supplement to their Maintenance Organization Exposition that is approved by the Competent Authority (CA). Compliance with the TCCA Supplement forms the basis by which the AMO may exercise maintenance privileges on Canadian registered aircraft.
(3) The approved AMOs are listed by the EASA at the website mentioned above.
6.0 CAR 573 AMOs maintaining EU-registered aircraft
(1) This section details additional information as to how an aircraft AMO will implement the MAG. Compliance with both the AMO’s approved MPM and EASA Supplement forms the basis by which an AMO may exercise the maintenance privileges under the MAG.
6.1 Initial approval process
(1) The AMO is required to:
- (a) Complete EASA Form 17 (MAG, Section B, Appendix 2) indicating initial; and
- (b) Create a draft EASA Supplement that describes in detail the actual working procedures of how the AMO will comply with the MAG. The AMO may refer to the MAG, Section B, Appendix 1 – Approved MAG Supplement Contents as guidance.
- Note: Simply submitting a copy of Section B, Appendix 1 does not meet the intent of 6.1 (1)(b).
(2) When the EASA Form 17 and proposed draft EASA Supplement are complete they should be sent to the AMO’s PMI at their TCCA regional office 90 days prior to the date initial approval is required.
Note: The documents should not be sent to EASA by the applicant.
(3) EASA will provide the AMO with an invoice and payment instructions.
(4) Once payment of the invoice has been confirmed, the PMI will provide the AMO with an EASA approval number which is required to be inserted into the draft EASA Supplement and re-submitted to the PMI.
(5) The PMI will review the EASA Supplement and notify the AMO of any changes required.
(6) Once the conditions of issuance have been met, the AMO will be issued a supplement approval letter indicating the EASA approval number, expiry date, and attesting the supplement is approved.
6.2 Continuation process
(1) EASA Supplement approvals are valid for 24 months if conditions for approval continue to be met. Organizations are required to apply 60 days (minimum) prior to their EASA approval expiring in accordance with the MAG if they intend on maintaining EU-registered aircraft.
(2) The AMO is required to:
- (a) Complete EASA Form 17 (MAG, Section B, Appendix 2) indicating continuation;
- (b) Review the current EASA Supplement to ensure working procedures continue to align with MAG, Section B, Appendix 1 – Approved MAG Supplement Contents, making any necessary changes; and
- (c) Forward EASA Form 17 and the proposed draft EASA Supplement (if required) to the AMO’s PMI at their TCCA regional office 60 days (minimum) prior to their EASA approval expiring.
- Note: If no changes to the EASA Supplement are required, the supplement does not need to be forwarded to the PMI for review and approval.
(3) If necessary, the PMI will review the EASA Supplement and notify the AMO of any changes required.
(4) Once the conditions of issuance have been met, the AMO will be issued a supplement approval letter indicating the latest revision of the supplement on file and the new expiry date.
6.3 Amendment process
(1) The AMO is required to:
- (a) Complete EASA Form 17 (MAG, Section B, Appendix 2) indicating change and purpose of the amendment:
- (i) Change of address
- (ii) Change of Accountable Executive
- (iii) Change of organization’s name/or approval number
- (b) Review current EASA Supplement to ensure working procedures continue to align with MAG, Section B, Appendix 1 – Approved MAG Supplement Contents, making any necessary changes; and
- (c) Forward the EASA Form 17 and the proposed draft EASA Supplement to the AMO’s PMI at their TCCA regional office.
- Note: An EASA Form 17 is not required to be submitted for minor amendments. Minor amendments other than the ones listed above must be coordinated with the AMO’s PMI.
(2) The PMI will review the EASA Supplement and notify the AMO of any changes required.
(3) Once the conditions of issuance have been met, the AMO will be issued a supplement approval letter indicating the EASA approval number and latest expiry date.
6.4 Actions for AMOs requesting approval for line stations located outside of Canada
(1) The AMO is required to submit to the PMI:
- (a) Documentation from the EU customer that supports the work to be performed at locations outside of Canada;
- (b) Proof that line maintenance activities offered are not provided by any other EU approved AMO at those locations; and
- (c) A draft EASA Supplement with the locations and their scope clearly identified in a specific paragraph as non-Canadian locations, which will be subject to acceptance from the EASA and coordinated by TCCA, who will include such line stations in their regular oversight program.
(2) The PMI will review the documentation and notify the AMO of any changes required.
(3) If deemed satisfactory, the PMI will coordinate with Op Air, who will coordinate with EASA, indicating the location of the line stations to ensure formal acceptance. By submitting this request, the AMO understands that TCCA will perform normal surveillance of these locations on a maximum period of two (2) years.
(4) If EASA agrees, they will formalize an agreement extension to the non-Canadian locations under the bilateral agreement through a formal letter to TCCA.
(5) Op Air will provide the formal letter to the PMI, and the AMO will be issued a supplement approval letter indicating the EASA approval number and latest expiry date.
6.5 Surrender of approval
(1) AMOs must submit notification by email to their PMI indicating their intent to cancel or surrender their EASA Supplement approval.
6.6 Suspension or revocation
(1) Suspension or revocation of an approval will automatically render the EASA Supplement approval and its privileges invalid.
6.7 Late applications
(1) AMOs are expected to apply 60 days (minimum) prior to their expiry date. If notification of continuation is not received within the above specified time frame, the approval will not be continued, shall be rendered invalid, and an initial application must be initiated by the applicant.
Note: It is the responsibility of the AMO to track the expiry date of their approval.
6.8 Fee processing
(1) TCCA will forward a copy of the EASA Form 17 to the EASA for their use in directly billing the organization. For continuation of EASA Supplement approval, EASA will invoice the applicant on an annual basis.
(2) If EASA notifies TCCA that fee payment has not been made (within 90 days from the invoice date), TCCA will inform the AMO’s PMI to revoke the supplement approval letter.
7.0 Information management
(1) Not applicable.
8.0 Document history
(1) Not applicable.
9.0 Contact us
For more information, please contact:
Jeffrey Phipps
Chief, Operational Airworthiness, Standards (AARTM)
Email: jeff.phipps@tc.gc.ca
For any questions concerning procedures in this AC, please contact:
Approved Organizations, Operational Airworthiness, Standards (AARTM)
Email: EASATCCAOpAir-AESATCACNavOps@tc.gc.ca
We invite suggestions for amendment to this document. Submit your comments to:
Standards Branch Documentation Services
Email: AARTDocServices-ServicesdocAART@tc.gc.ca
Original signed by
Linda Melnyk
Director, Standards branch
Civil Aviation
