Airworthiness Manual Advisory (AMA) No. AC AMM-002

TCCA approved organizations, certificated by the registrar of a standards setting organization

1.0 Purpose
2.0 Background
3.0 Policy Statement
4.0 Effective Date
5.0 Expiry
6.0 Headquarters Contact

1.0 Purpose

1.1 This advisory circular is intended to establish Transport Canada’s position regarding Transport Canada Civil Aviation (TCCA) approved organizations certificated by the registrar of a standards setting organization.

2.0 Background

2.1 For the purposes of this advisory circular, a Quality System is the means by which the TCCA approved organizations measure their level of regulatory compliance and their level of aviation safety.  The term could apply to a Quality Assurance System, Quality Audit System or a Safety Management System, where required by applicable Canadian Aviation Regulations (CARs).

2.2 International acceptance of aeronautical products manufactured or maintained by Canadian organizations is based upon Transport Canada’s demonstration of an equivalent level of safety inherent to the regulations applicable to those organizations certificated by Transport Canada.

2.3 Many TCCA approved organizations, including suppliers to these approved organizations, are certificated by standards setting organizations.  These certifications issued by the registrar of standards setting organizations are not normally mandated by Civil Aviation Authorities, nor do they convey or imply evidence of airworthiness of the aeronautical products manufactured or maintained by these organizations.

3.0 Policy Statement

3.1 Certification by a registrar to standards such as ISO 9001 or AS9100, does not provide relief from having to demonstrate to the Minister, compliance to applicable CARs.

3.2 TCCA approved organizations must have a quality system in place that ensures all of the activities accomplished by the organization are in compliance with the CARs.   It is also the TCCA approved organization’s responsibility to ensure that any activity carried out by a contracted supplier, on their behalf, is in compliance with their contracted agreement and in compliance to all applicable CAR requirements. Certification of a supplier by a registrar to other standards does not provide relief from the TCCA approved organization’s need to conduct any necessary reviews to confirm compliance to all applicable CAR requirements.

3.3 Where a TCCA approved organization wishes to satisfy both TCCA and a registrar’s requirements by applying a unique quality system, the manual approved by Transport Canada must clearly delineate those policies and procedures necessary to satisfy applicable CAR requirements.  References to the registrar’s requirements could be stated within this manual, so long as these references do not create doubt as to CARs compliance. 

3.4 All procedures and forms must carry the TCCA approved organization’s distinct identity, and must be subject to the amendment requirements applicable to any document incorporated by reference in their approved manual. 

3.5 A TCCA approved organization that wishes to use registrar’s oversight audits as quality system activities carried out by an ”external agent”, must ensure the audit check sheets used are of adequate scope to satisfy CAR requirements.  The TCCA approved organization must maintain evidence of compliance and non compliance, for those functional areas audited by the registrar.  The TCCA organization must also ensure that the CAR requirements not covered by the registrar are included through additional  functional areas check sheets, verified by their own staff. The TCCA approved organization must record all non-compliance findings, accomplish and record all root cause analysis, as well as keep records of their monitoring of the results of any corrective actions taken to ensure the systemic problems were addressed and the action was effective. The quality system policy and procedures described in the TCCA approved organization`s manual must encompass all audit activities carried out by “external agents”.

3.6 Having an effective quality system in place is a condition for the TCCA approval.  Where a TCCA approved organization fails to establish and maintain an effective quality system, the result may be enforcement action or suspension of their privileges.

4.0 Effective Date

4.1 This policy comes into effect immediately.

5.0 Expiry

5.1 This policy expires on publishing revisions to applicable subparts of the CARs that describe the above policy. 

6.0 Headquarters Contact

6.1 The responsible Division for this AC is Policy Development.  For more information please contact:

Brian Whitehead,
Chief of Policy Development Division (AARPC)
E-mail: whitehb@tc.gc.ca
Phone: (613) 941-8371
Facsimile: (613) 952-3298

D.B. Sherritt
Director
Maintenance and Manufacturing Branch