EASA maintenance supplement requirements
In 2011, a new Civil Aviation Safety Agreement was put into force between Canada and the European Union. It detailed new requirements regarding the maintenance of aircraft registered to the other party. Specifically, it detailed the new elements that were required in a supplement approved and added to the maintenance policy manual to cover work on the other party's registered aircraft. This included:
- A statement of commitment signed by the current accountable manager that the organization shall comply with the manual and its supplement.
- The organization shall comply with the customer work order, taking particular note of requested airworthiness directives, modifications and repairs and of the requirement that any parts used were manufactured or maintained by organizations acceptable to the other party.
- The customer issuing the work order has established the approval of the appropriate competent authority for any design data for modifications and repairs.
- The release of civil aeronautical products is in conformity with applicable legislative and regulatory requirements.
- Any civil aeronautical product under the jurisdiction of the other party found in an unairworthy condition shall be reported to the other party and customer.
As part of this process, a maintenance annex guide was prepared and signed by Transport Canada Civil Aviation and the European Aviation Safety Agency in 2012 and subsequently revised in 2014. The MAG provided guidance on what the supplement should contain, and it provided a sample manual.
Since the update of the MAG, there has been some confusion in what was required in the supplement due to the elements described in each document. Some of this may be attributed to process inspections or program validation inspections being carried out by the TCCA. In some cases, the inspection being carried out only reviewed the elements of the agreement, and in others, it would be the elements of the MAG. So if the inspection being carried out was only on the five elements, why is there a need for further detail in the supplement, and would added detail complicate the inspections
The answer is that, in many cases, a PI is carried out specifically on the EASA supplement. The PI is less in-depth than the PVI and can be easily carried out within the two-year commitment that the TCCA has made to audit the EASA supplement process. Therefore, the focus is on the agreement requirements and evidence that it is being carried out. Also, the agreement requirements are the minimum and, depending on your business, there may be a need for added elements to capture the intent.
From another perspective, the MAG provides guidance on how to word the supplement and what items to include, and ensuring that the five agreement requirements are met. Your supplement should identify a little more detail on your procedures used to meet these requirements. In a PVI, these details would be reviewed in-depth, whereas in the PI, a higher level review would take place.
If during an inspection or other conversations with the TCCA this issue arises, please send the details to Kevin Bruce, AEA regulatory consultant for Canada, at email@example.com. This will help in getting the policy applied consistently across the country.
FOR MORE INFORMATION:
Contact Ric Peri, vice president of government & industry affairs for AEA, by email at firstname.lastname@example.org or by phone at 202-589-1144.