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ARSA Works with Quadrilateral Group Towards “Practical Compliance”

On Nov. 9 and 10, the quadrilateral Maintenance Management Team (MMT), which is comprised of the FAA, Transport Canada, EASA and Brazil’s ANAC, met in Ottawa to discuss issues affecting existing bilateral maintenance agreements. The MMT is similar to the almost 10-year-old Certification Management Team (CMT), and the four authorities used this first official meeting to present governance plans including annual meetings and associated industry days. The group’s official charter will likely be finalized by the end of the year.

In preparation for the event, ARSA worked with several other industry trade associations to develop and execute the agenda for the Nov. 10 industry day:

Industry Day – Nov. 10 – Review 

Participants were briefed on ICAO’s efforts to minimize duplication associated with the certification and surveillance (i.e., audits) of Approved Maintenance Organizations (AMOs). As most ARSA members know, most States of Registry require their own AMO certificates instead of approving or accepting those issued by other authorities. Although ICAO’s efforts will not affect the State of Registry’s authority over continued airworthiness it will, by developing more robust AMO guidance, encourage States to strongly consider approving or accepting the certificates issued by other authorities or, at the very least, rely on audits performed by other civil aviation authorities. This is clearly a step in the right direction although the results of the effort will not be known for many years.

Not surprisingly, parts documentation was discussed again – the participating groups (except for Transport Canada) addressed this topic during an unofficial meeting in June 2016 under the auspices of the FAA-EASA Joint Maintenance Coordination Board after the agencies’ International Safety Conference – including commercial and commercial off-the-shelf parts (COTS) parts and the current requirement in the Maintenance Annex Guidance (MAG) that they be accompanied by a Form 1 or 8130-3 when installed in maintenance subject to that agreement. Although EASA will soon issue a Notice of Proposed Amendment (NPA) to reduce the number of parts that will require Form 1 (perhaps setting the stage for subsequent MAG changes), the rulemaking process will take more time and is fraught with uncertainty.

In the meantime, industry reminded the two agencies that certificate holders have no practical compliance path because the vast majority of commercial and COTS parts are not traceable to a production approval holder and consequently are not accompanied by Form 1 or 8130-3 as required by the MAG (except for standard and fabricated parts). An ARSA-led industry coalition recommended a solution earlier this year (i.e., that the parts not require a Form 1 or 8130-3 if they are traceable to an approved design; a C of C would suffice). Unfortunately, the issue remains open although discussions between the two authorities are continuing.

More progress was made in the area of parts documentation associated with single releases for maintenance performed on aircraft. The issue is whether parts installed on a U.S.-registered aircraft in the European Union must have Form 8130-3 if only a single release is to be issued, which is normally the case for aircraft maintenance. Such parts should not require Form 8130-3, although the MAG states otherwise. ARSA is hopeful this will be addressed in MAG change 7.

Finally, Transport Canada is working to develop guidelines to accept work performed by appropriately-certificated maintenance facilities outside the geographical borders of the United States or Canada (or another country that does not have a maintenance agreement with Canada). The theory is that if Transport Canada or the FAA would accept work from an appropriately certificated organization inside the United States or Canada, why would they not recognize the same maintenance when performed by an FAA or TCCA certificate holder outside either country? The problem arises due to the geographic limitations inherent in most bilateral agreements although there are ways to address it if the authorities are willing to do so. The FAA and EASA have issued numerous “foreign” AMO certificates compared to a much smaller number for Canada and Brazil. If a maintenance facility in Mexico, for example, held an EASA Part-145 certificate but wanted to work on U.S. State of Registry articles, the FAA would require that it obtain an FAA foreign repair station certificate instead of recognizing its EASA certificate. EASA would do the same. Perhaps the two authorities should rethink this.

Industry is hoping the MMT will lead by example and eventually adopt mutual recognition of each other’s maintenance certificates without special conditions. It would set a positive example for the rest of the world and would not adversely affect the industry’s excellent safety record.

The next MMT meeting will be in Brazil in October 2018 in an as-yet undisclosed location – the most likely candidates are Sao Paulo or Brasilia.

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