Issue Papers, Concern Papers and Certification Memoranda
| File No.: | 5009-32-2 | SI No.: | 500-019 |
| RDIMS No.: | 686971-V7 | Issue No.: | 01 |
| Issuing Branch: | Aircraft Certification | Effective Date: | 2005-11-21 |
1.1 Purpose
1.2 Guidance Applicability
1.3 Description of Changes
1.4 Termination
4.1 Issue Paper (Domestic Projects)
4.2 Issue Paper (Foreign Projects)
4.3 Concern Paper (Foreign Projects)
4.4 Certification Memoranda
5.0 Explanation of the Content of Findings Documents
5.1 Header Information
5.2 Contents of Issue Paper (Appendix 1)
5.3 Contents of Foreign Issue Paper (Appendix 2)
5.4 Contents of Concern Paper (Appendix 3)
5.5 Contents of Certification Memoranda (Appendix 4)
6.0 G-Series Issues Papers - Documenting the Basis of Certification
6.1 G-1 Issue Paper
6.2 G-2 through G-5 Issue Papers
Appendix 1 - Domestic Issue Paper
Appendix 2 - Foreign Issue Paper
Appendix 3 - Concern Paper
Appendix 4 - Certification Memoranda
1.0 Introduction
1.1 Purpose
The purpose of this SI is to provide a standardized format and procedural guideline to be used in developing Issue Papers, Concern Papers and Certification Memoranda.
1.2 Guidance Applicability
This SI is applicable to Headquarters (HQ) and Regional Aircraft Certification personnel including delegates, and HQ Maintenance and Manufacturing personnel.
1.3 Description of Changes
This document is an initial issue.
1.4 Termination
This document does not have a terminating action.
2.0 References
2.1 Reference Documents
It is intended that the following reference materials be used in conjunction with this document:
- Part V Subpart 11 of the Canadian Aviation Regulations (CAR) - Approval of the Type Design of an Aeronautical Product.
- Chapter 511 of the Airworthiness Manual (AWM) - Approval of the Type Design of an Aeronautical Product.
- Staff Instruction (SI) 511-004, issue 01, dated 2005-11-21 - Type Certification of Foreign Aeronautical Products; and
- SI 511-001, issue 01, dated 2005-11-21 - Type Certification of Foreign Aeronautical Products - Determining the Level of Airworthiness Review.
3.0 Background
During the Type Certification Process Transport Canada representatives (i.e. engineers, pilots, inspectors) will need to document a point of contention or difference of opinion that are commonly referred to as findings. TCCA and the applicant (or other civil aviation authority) require a process for clarification and resolution of issues.
4.0 Documentation of Findings
4.1 Issue Paper (Domestic Projects)
An Issue Paper (IP) documents a technical issue on a domestic certification project, which indicates the possible existence of non-compliance to one or more related elements of the basis of certification for that product. Generally speaking the closure of the IP is required prior to the issuance of the type certificate.
Although it is unusual in practice, in situations where the Applicant chooses to identify and document an issue with TCCA, the applicant may choose to raise an Issue Paper. In these cases, the roles of the Applicant and TCCA are reversed, however the closing position will always be TCCA.
Appendix 1 includes a standard template for a Domestic IP.
4.2 Issue Paper (Foreign Projects)
A foreign IP is raised against an aeronautical product whose original Type Certificate was issued by a country other than Canada, and is to be imported into Canada for use by a Canadian operator. Foreign Issue Papers are raised against requirements in the Canadian basis of certification for that product that are unique to Canada (i.e. those elements that are not common between the Canadian and foreign basis of certification).
Since a foreign Issue Paper pertains to a uniquely Canadian requirement, the applicant has likely not demonstrated compliance to the requirement previously, and as such the Issue Paper is directed initially at the applicant, seeking an applicant position. As TCCA will rely on the findings made by the foreign authority, a position from the foreign airworthiness authority is subsequently requested to endorse the position made by the applicant.
Appendix 2 includes a standard template for a Foreign IP.
4.3 Concern Paper (Foreign Projects)
A Concern Paper (CP) is only used on projects involving importation of aeronautical products whose original Type Certificate was issued by a country other than Canada and with which Canada would conduct a Level 2 Review (refer to SI 511-004 and SI 511-001). Concern Papers have the same purpose as the foreign Issue Paper, except that they are raised against requirements in the Canadian basis of certification that are common to both the Canadian and the foreign certification basis. Typically the applicant has already demonstrated compliance to the requirement and their domestic authority has already made a finding of compliance. The Concern Paper is addressed only to the foreign airworthiness authority (only the foreign airworthiness authority is asked to provide a position), seeking clarification on how they found compliance with the requirement.
Appendix 3 includes a standard template for a Concern Paper.
4.4 Certification Memoranda
A Certification Memorandum (CM) is raised when a point of clarification is required with respect to a requirement or group of requirements within the basis of certification on a domestic type certification project only. Unlike the Issue Paper, there is no perceived non-compliance, but rather a need from TCCA's perspective to document a position or an interpretation with respect to the Referenced items within the certification basis. For example, TCCA may wish to document their desire to have the applicant take certain things into account when they demonstrate compliance to the requirement(s) in question. In turn, the Applicant's Position (the formal response from the applicant) would indicate their agreement and/or terms they wish to apply when conducting the demonstration of compliance.
It is possible for a CM to be elevated to an Issue Paper if there develops an issue of contention surrounding the subject of the CM. In other words, the CM started out with the intent of documenting an agreement on an approach, but developed to reveal a disagreement between TCCA and the applicant, if not resolved would result in a TCCA opinion of non-compliance. In this case, the CM would be closed, with the final TCCA position indicating that the CM has been elevated to an IP. The CM closure would indicate and point to the new IP.
Appendix 4 contains a standard template for a Certification Memorandum.
5.0 Explanation of the Content of Findings Documents
5.1 Header Information
The following fields are common to the templates used for Issue Papers, Foreign Issue Papers, Concern Papers and Certification Memoranda (see Appendices 1 through 4).
- Project - Indicates the company name of the proposed type certificate holder, plus the name and designator for the specific product in question. In some cases, the type design examination process addresses an aircraft "Series", and as such the Finding would be applicable to all models within that series, e.g. Airbus A340 Series 500. If the subject of the Finding relates to a specific model (e.g. A340-541), the Finding should indicate this clearly.
- File Number - Indicates the 5010 file applicable to the aircraft type in question (or 5011 or 5012 files for engines and propellers, respectively), plus the RDIMs number for the MS Word file in which the Finding was created. Within RDIMs, the use of "versions" should be used to separate progressive stages of the Finding, and as such, the version number that pertains to the text that follows should be included (e.g. 456787 v2).
- NAPA Project - Indicates the NAPA project number for the project. Although the Findings may be created and filed in RDIMs, Findings shall also be filed against the appropriate project identifier (i.e. aircraft/engine/propeller model) in NAPA. If the individual processing the Findings chooses to work in RDIMs, it is recommended that titled place-holders be identified in NAPA at the start of the particular project, then when the Findings are closed the final versions may be loaded into NAPA. Conversely, if the individual chooses to create and manage the Findings in NAPA, it is recommended that the final closed versions be also saved in RDIMs.
- Specialist(s) - Indicates the technical specialist(s) to which the technical subject matter pertains. This may involve one or more specialist areas that will be involved in the signoff process.
- Subject - Indicates a brief descriptive indication of the subject of the Finding. Often the title of the design standard in question is sufficient, but not necessarily. In some cases a description of the range of affected requirements is useful (e.g. "Structural Design Criteria"). The intent is to provide enough information on the subject of the Finding in order to identify the Finding subject matter to one who may not be familiar with the numerical designation of the design requirement.
- Reference(s) - Indicates the specific numerical reference of the design standards or CARs which is/are the subject of the Finding. If a range of requirements on a given subject is affected, this can be described as such (e.g. AWM 523.331 through 523.521).
- Number
The name of a finding shall start with a two-letter designator for the Finding type:
Issue Paper: IP
Concern Paper: CP
Certification Memorandum: CM
The two-letter designator for the Finding type shall be followed by a designator indicating the technical specialty with prime ownership of the technical content of the Finding:
G Project Management
E Electronic Design Assurance
P Powerplants and Emissions
A Avionics and Electrical Systems
S Structures
M Fuel and Hydromechanical Systems
OS Occupant Safety and Environmental Systems
FT Flight Test
O Operational (Commercial and Business Aviation, AARX)
MM Maintenance and Manufacturing
CAW Continuing Airworthiness
A numerical designator shall follow the technical designator for the Finding itself. A sequential numbering system should be maintained for the Findings. This would be done on a per project, approval activity or program basis.
An example follows:
IP-OS-4
This Finding is therefore an Issue Paper, with Occupant Safety and Environmental Systems being the prime technical specialty, and it is the fourth Issue Paper raised by this technical specialty against a particular approval activity.
Although one particular specialty may have primary responsibility for the Finding, other specialties may be involved in a secondary capacity, and thus will take part in the review and signoff process. Findings that are particularly multidisciplinary (i.e. likely involving more than three specialties) such as Rotorburst, Cold Soak and Flammable Fluids will typically have one discipline taking the lead role. In these cases, the designator of the lead specialty will be used in the Finding identifier. The other specialties will be listed in the "Specialist(s)" field, explained below.
- Edition - The Edition of the Finding shall always accompany the Finding designation (e.g. IP-M-3 Edition 1). The Edition is a clear indicator of the number of iterations or stages that the Finding has progressed to. The first issuance of the Finding that does not yet contain a response from the applicant shall be designated as Edition One. Once the response from the applicant is received, a subsequent TCCA position is added, and the Finding is re-issued to the applicant as Edition 2. Each subsequent issuance of the Finding to the applicant can only occur following a response from the Applicant and a subsequent TCCA position. The final Edition of the Finding in which the Finding is closed must have the final TCCA position as the final entry.
- Date - Indicates the date of issuance of the Finding at the Edition number indicated.
- Target - Indicates the milestone by which the Finding must be closed. Closure is required prior to the issuance of the type certificate, but the Finding may relate to an optional modification or feature that may be approved after the aircraft is operational, and as such the Target would be after Type certification. In other cases, agreements may be reached which allow a Finding to remain open after certification, but that the Finding shall closed prior to entry into service, and as such the Target would be noted as previous to certificate of airworthiness (C of A).
- Status - Indicates whether the Finding is "Open" or "Closed". A Finding may go through several editions requiring multiple applicant positions and subsequent TCCA positions before it may be closed at the final Edition. Until the Finding is "Closed" at the final Edition, it shall be shown as Status "Open".
5.2 Contents of Issue Paper (Appendix 1)
- Statement of Issue - The Statement of Issue is a concise statement describing the reason why the applicant is not considered to be in compliance with the design standard(s) listed "Reference(s)" when the IP was raised. The Statement of Issue should be as brief as practical, without including background information or discussion of the subject.
An applicant may raise an issue paper (rather than by TCCA). In this case, the Statement of Issue will still relate to the issue of whether the aeronautical product is in compliance with the Reference requirement(s), but will be from the applicant's perspective. For example, an applicant may insist that their product is compliant without a design change or feature considered necessary by TCCA.
- Discussion - The Discussion section shall contain any and all information necessary to explain the background or rationale for the Statement of Issue. In many cases the Issue Paper exists due to a difference in interpretation and/or applicant of a particular design standard. It is in the Discussion section that this interpretation shall be explained with all relevant rationale provided.
- Transport Canada Position - At Edition One, the Transport Canada Position shall contain a concise statement defining what action TCCA is requesting from the applicant as a result of the Statement of Issue. As the "Issue" itself has already been defined (Statement of Issue) and explained (Discussion), there is no need to reiterate the issue itself or in any way elaborate on it. In subsequent Editions of the Issue Paper, the TCCA position shall state that the applicant's response was accepted and that the Issue Paper is closed, or it shall explain why the Applicant's response was insufficient to close the Issue Paper, and what is requested of the Applicant for their second (or subsequent) response.
- Revision Summary - The use of a Revision Summary to list the various Editions of the Issue Paper and their dates of issuance is considered optional, but in cases of a multiple-edition Issue Paper, it is a useful tool to be aware of the evolution of the issue.
- Signature Block - A signature block is required to be created and signed off at the issuance of the first and each subsequent Edition of the Issue Paper. For each technical discipline having responsibility for the design standards listed in the "Reference(s)" field, there should be a signoff location indicated with the appropriate designator. Typically the specialist and their manager will sign off within the same box, but whether the manager as well as the specialist need to sign is within the discretion of each technical specialty group. Regardless of whether the specialty group manager signs or not, the Chief of that Division is required to sign in the overhead block as indicated. Both the Project Manager and the Chief of Project Management will always have their respective signoff blocks for each Issue Paper.
5.3 Contents of Foreign Issue Paper (Appendix 2)
The explanation of the contents of the Statement of Issue, Discussion and Transport Canada Position are similar to the domestic Issue Paper as defined above. The only difference with the foreign Issue Paper is the additional requirement for the "Domestic Authority Position", where the domestic airworthiness authority is requested to add their position in response to the Applicant's Position, in effect endorsing it on behalf of TCCA
5.4 Contents of Concern Paper (Appendix 3)
Note that the sections pertaining to discussion, revision summary and signature block, are similar to the format in the issue paper sections.
- Statement of Concern - Similar to "Statement of Issue" as explained above, but in the context of a requirement common to both the Canadian and Foreign certification bases. The Statement of Concern should concisely indicate what TCCA wishes the foreign authority to do. This would typically be to clarify an interpretation of a requirement in the context of a finding of compliance made against a particular aeronautical product.
- Domestic Authority Position - Only the foreign authority is to respond to the TCCA Position, as they are in effect explaining how they made the finding of compliance to the requirement in question.
5.5 Contents of Certification Memoranda (Appendix 4)
The sections pertaining to discussion, revision summary and signature block, are similar to the format in the issue paper sections.
- Transport Canada Position - Since the Certification Memorandum does not involve a perceived non-compliance but rather a need to document an agreement or an approach to be taken with respect to a demonstration of compliance, the TCCA position simply explains the topic to be documented in respect of the demonstration of compliance.
- Applicant Position - In the Certification Memorandum the Applicant Position should indicate the concurrence and/or clarification of any aspects of the approach being proposed in the TCCA position. Should concurrence not be initially possible, the Certification Memorandum may go through multiple iterations similar to an Issue Paper.
6.0 G-Series Issues Papers - Documenting the Basis of Certification
In addition to the Findings as defined above, an administrative class of Issue Papers known as the "G" Series is used for developing and documenting the basis of certification for an aeronautical product. Documentation of the basis for domestic and foreign products shall be accomplished via the use of Issue Papers as follows:
6.1 G-1 Issue Paper
The G-1 Issue Paper contains a complete definition of the basis of certification.
The basic contents of the G-1 Issue Paper are as follows:
- Statement of Issue - The Statement of Issue shall contain a brief description of the product type, and specification of application date to TCCA The "Statement of Issue" which follows this information is simply that "the basis of certification for this aeronautical product needs to be established".
- Foreign Basis of Certification - A complete definition of the foreign basis of certification shall be identified, which consists of standards (including environmental), special conditions, findings of equivalent safety, exemptions that make up the foreign basis of certification. The definition of the foreign basis of certification is necessary as it is used as the starting point for developing the Canadian basis of certification.
- TCCA Position - The TCCA Position shall contain the proposed Canadian basis of certification expressed if possible in terms of the AWM. This is accomplished by expressing the equivalent of the foreign basis of certification by quoting the appropriate AWM Chapter and Change level, and indicating that the AWM Chapter and Change level is equivalent to the foreign basis plus a listing of unique Canadian requirements, or differences between the AWM and the foreign design standard. The Canadian basis of certification shall also include all Special Conditions, Additional Technical Conditions, Environmental Standards, Findings of Equivalent Safety, Later Amendments to the Standards and Exemptions that TCCA chooses to accept as-is from the foreign basis (TCCA may choose to not accept one or more of these elements from the Foreign basis and develop its own)
Special Conditions, Findings of Equivalent Safety, Later Amendments to the Standards and Exemptions shall be listed by identifier and title, but the full text of these elements of the basis of certification are contained in the G-2 through G-5 Issue Papers respectively. As such the G-1 Issue Paper shall reference the G2 through G-5. Despite not having the full text of these other elements of the basis, the G-1 must therefore stand-alone and define all the elements in the basis.
- Applicant's Position - The Applicant shall provide their statement of concurrence to the proposed TCCA Basis, or request changes as appropriate.
- Foreign Authority Position - The foreign authority is requested to make a finding of compliance to the TCCA basis on behalf of TCCA. This shall be accomplished only upon request from TCCA, which would come once all other findings (Issue Papers, Concern Papers) have been closed, and TCCA's involvement in the type design examination is considered complete.
6.2 G-2 through G-5 Issue Papers
- G-2 Issue Paper - The G-2 Issue Paper lists the Special Conditions included in the Canadian basis of certification (as per CAR 511.07(1)(b)). These include those adopted from the foreign basis plus those unique to TCCA. Since a Special Condition is a stand alone published document produced by AARDH, it may be included as an appendix to the Issue Paper. At the first edition of the Issue Paper, the Special Condition shall be in draft form. Upon acceptance of the Special Condition via the Applicant's position, the G-2 Issue Paper may be closed and the published version of the Special Condition be included in the closed version of the G-2 Issue Paper.
- G-3 Issue Paper - The G-3 Issue Paper lists the Findings of Equivalent Safety that are included in the TCCA basis as defined by CAR 511.11(2). Development and discussion of the Equivalent Safety Finding may be done on a separate Issue Paper, and this Issue Paper may be referenced on the G-3 (via subject, file and RDIMS number). Alternately, the discussion and background of the Finding of Equivalent Safety may be included within the G-3 Issue Paper itself. Whatever fashion is used, the objective is to have a full and traceable record.
- G-4 Issue Paper - The G-4 Issue Paper lists changes to the standards made after the date of application to the foreign authority that the Applicant elects to comply with as per CAR 511.07(2). The G-4 may include as an appendix the discussion regarding the request for and the acceptance of the later amendments to the standards, or it may reference (via subject, file and RDIMS number) a separate Issue Paper.
- G-5 Issue Paper - The G-5 Issue Paper lists Exemptions granted to the Applicant under the authority of subsection 5.9(2) of the Aeronautics Act. The request for and justification of the exemption is typically a separate Issue Paper or other document which shall be included within or referenced on the G-5 Issue Paper.
7.0 Headquarters Contact
For more information please contact:
Policy Standards Coordinator (AARDH/P)
Phone: (613) 990-5742
Facsimile: (613) 996-9178
E-mail: AARDH-P@tc.gc.ca
Original signed by Maher Khouzam
Maher Khouzam
Chief, Regulatory Standards
Aircraft Certification Branch