Maintenance and Manufacturing Staff Instructions (MSI) No. 12

Subject: Number: MSI 12
Regulatory Services Outside of Canada Revision No: 0
  Number of Pages:  
File No:  AARP-5009-3-12 Issue Date: May 25, 1998

1. Purpose

1.1 The purpose is to provide information related to the preparation, conduct and post visit activities of regulatory services performed outside of Canada, and for the recovery of costs of providing Non-Fee services outside Canada. These procedures also apply to all activities of Canadian air operators outside Canada.

2.  Background

2.1  The increasing number of companies utilizing services outside of Canada to conduct various activities, has resulted in an increased requirement for regional and headquarters personnel to travel abroad. Regulatory services outside of the country has caused additional expenses to the Department. Very often costs associated with these visits were recovered, although the procedure was not standard across the country.

2.2  Civil Aviation Directive No. 3 contains the standardized approach for the recovery of costs of providing services outside Canada for which there is no charge (Fee).

2.3  The Air Operator Certification Manual (TP4711E) also contains Cost Recovery requirements for Air Operators planning to operate between points abroad.

3.  Regulatory Services

3.1 To ensure consistency in the application of policy and procedures relating to activities outside Canada, all travel must be coordinated with the applicable Regional Manager. In addition, the Director, Maintenance and Manufacturing in Headquarters shall be notified prior to the trip taking place. The following must be taken into account prior to the proposed trip:

  1. Purpose of the requested services, e.g., audit, aircraft or sub-base inspection, etc.;
  2. proposed date for requested services;
  3. estimated number of work days required for the requested services;
  4. inspector to perform requested services;
  5. brief cost benefit analysis;
  6. consequences of not performing the requested services;
  7. signed statement by the applicant indicating agreement to reimburse Transport Canada; and
  8. alternate methods to perform the requested services, such as requesting the foreign Civil Airworthiness Authority to perform such services, under Bilateral Agreement, etc.

4.  Responsibilities

4.1  The Director, Maintenance and Manufacturing will as required:

  1. Coordinate related correspondence between headquarters and the regions;
  2. notify the foreign Civil Airworthiness Authority of the pending visit and its purpose, and as required invite a representative to be present during the visit;
  3. notify any other Canadian government agency, Canadian representative or representative of that country as protocol or requirements dictate, and obtain related information;
  4. provide the region with names, addresses and phone numbers of persons or organizations to contact in the foreign country;
  5. obtain trip reports from the regional inspector(s) following their visit, complete with the follow-on correspondence to the air operator for whom the inspection was conducted;
  6. determine if there are other regulatory services which may be accomplished in the same country, or in countries that can be conveniently visited during the same trip, if feasible. Expenses will be shared by organizations involved; and
  7. arrange for an alternate method of performing the services should the responsible region lack the required expertise and resources.

4.2  The Regional Manager, or his delegated representative will as required:

  1. Arrange for passport, visa, immunization, travel arrangements;
  2. maintain liaison with the applicant, and coordinate all arrangements;
  3. inform the applicant of the cost recovery policy, and obtain a statement of agreement. (Reference Directive No. 3);
  4. inform his designated inspector (s) to contact the foreign regulatory authority;
  5. arrange for collection of Non-Fee expenses.

5. Inspection Outside Canada - General

5.1  The following criteria applies to inspections accomplished by inspectors in countries other than Canada:

  1. When an AMO establishes a maintenance base outside Canada, or when an Air Operator enters into a maintenance arrangement outside Canada, arrangements shall be made, prior to commencement of operations, to inspect the maintenance facilities and aircraft, as applicable;
  2. when a change to the scope of maintenance performed at a base outside of Canada occurs, such as the addition of a new aircraft type rating, new maintenance arrangements or additional privileges , a base inspection should be conducted within ninety days of the date of the effective change; This also applies to seasonal bases.
  3. if the operation is located in a country having a Bilateral Airworthiness Agreement or Technical Arrangement with Canada, arrangements with the Foreign Airworthiness Authority should be made for subsequent annual surveillance and reporting;
  4. where an agreement or arrangement such as that described in paragraph c) exists, audits of the facility should nevertheless be made by Transport Canada at appropriate intervals dependent on the scope of work performed and risk indicators such as CADORs ; and
  5. where no agreement exists with the Foreign Authority, or if the Authority is unable to comply with the surveillance request, inspections should be conducted by Regional Inspectors, in consultation with the Regional Manager and the Director, Maintenance and Manufacturing as required.

6. Effective Date

6.1  This instruction comes into effect on June 25, 1998.

7.  HQ Contact

7.1  The responsible officer indicated below may be contacted for information regarding this MSI:

Brian Whitehead, AARPC
Aircraft Maintenance & Manufacturing Branch
Phone: (613) 941-8371
Facsimile: (613) 952-3298

7.2  This staff instruction is available on the internet at the following address:

D.B. Sherritt
Director, Maintenance and Manufacturing