Aircraft Maintenance in a

Global Framework

PRESENTED BY:

Jeffrey Phipps

Chief Operational Airworthiness

Standards Branch

Transport Canada Civil Aviation (TCCA)

Tuesday, May 5, 2015| 1:30pm – 2:30pm

Maintenance Management Conference | Portland, OR | May 5 – 7, 2015

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TC Civil Aviation Program

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A/Director Standards

Jacqueline Booth

A/Chief

TPEC John Glavind

Chief Flight Standards

Pierre Ruel

Chief Aviation Enforcement

Jean-François Mathieu

Chief Operational Airworthiness

Jeffrey Phipps

Chief Commercial Flight

Standards

Deborah Martin

Chief Aircraft Certification

Standards

Blake Cheney

Chief Environmental

Protection/STDs

Gilles Bourgeois

Standards Branch

Operational Airworthiness

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Chief, Operational Airworthiness

Jeffrey Phipps

A/PM, Maintenance Performance Standards

Ryan Hennigar

CASI

Kent Goulding

CASI

Ganesh Pandey

CASI

Daniel Haughton

CASI

Daniel Haughton

CASI

Vacant

PM, Approved Organization Standards

Mark Trainor

CASI

Marcel Gauthier

CASI

Mathieu Pare

CASI

Martin Truman

CASI

Dean Barrett

CASI

Vacant

PM, Aircraft Requirements Standards

Brian Clarke

CASI

Craig Dennis

Registration Specialist

Christopher McCue

CASI

Ian Sturgeon

CASI

Vacant

Canada’s First Flight

23rd February 1909, Baddeck NS

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No Regulations = No Jobs

“The Good Old Days”

Safety

• With industry growth ICAO member states must adapt.

• Continuous improvement required to effectively conduct critical

oversight functions.

• Auditing is a critical aspect of safety oversight, a multitude of additional

audits do not necessarily increase the level of safety.

• Civil aviation authorities must be more effective in the application of their

resources.

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The condition to which risks are managed to an acceptable level; where acceptable level from a TCCA perspective is on-going compliance with

regulatory requirements.

Red Tape

• Bureaucratic practice of hair splitting or foot dragging, blamed by its

practitioners on the system that forces them to follow prescribed

procedures to the letter.

• It gets its name from the colour of the ribbon used in tying government

documents.

• TCCA is trying to reduce “red tape” and better utilize our resources.

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Colloquial Term

Over Regulate = No Jobs

Surveillance

• TCCA’s surveillance has evolved beyond compliance auditing.

• Systems based approach to determine if an enterprise is effective at

achieving compliance.

• Assessments, program validation inspections (PVI) and process

inspections (PI) are now conducted based on risk.

• An enterprise’s systems reviewed to determine if they are effective.

• Currently and on an on-going basis.

• Change in surveillance methodology has eliminated duplication in

surveillance activities.

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TCCA Service & Certification Review

• TCCA is launching a review of our Service and Certification activities.

• Consider taking a more risk-based approach.

• Making greater use of sampling and possibly increased delegation.

• Regulatory requirements must contribute to safety and be enforceable.

• Documentation framework is being redefined to improve TCCA

guidance and remove regulatory burden.

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Globalization

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Manufacturing and Maintenance Organizations - Transnational

Requires multiple regulatory certificates and surveillance.

International Agreements

• TCCA has focused on developing International Agreements versus

Foreign Approved Maintenance Organization (FAMO) approvals.

• Full Bilateral with the United States and the European Union;

Certification/Manufacturing/Maintenance.

• Technical Arrangement Maintenance (TAM) with;

Brazil, Hong Kong, Singapore, New Zealand, Israel

• Certification Agreements with;

China, Japan

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International Agreements cont’d

• TAM’s currently being developed with Japan and Australia.

• Once in place an International Agreements is more effective than a

FAMO.

• Development is a lengthy process. Typically 2-4 years.

• Agreements need to be treated as a “living document”.

• Accommodate organizational changes, regulatory changes, and

improved processes based on confidence building.

• TCCA now meeting with EASA and the FAA on a annual basis.

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TCCA/EASA Confidence Building

• Sampling Inspection System (SIS) to start in 2015.

• On site inspections performed by TCCA in the EU and by EASA in

Canada.

• Results will validate the current approval process and determine which

steps are required.

• Similar confidence building may be included in other International

Agreements.

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•Submits a written request

to PMI 90 days before the

Approval is required

•Provides:

-Section B of the MAG

-EASA Form 17

•Provides the PMI with:

-2 copies of EASA Form 17

-EASA Supplement

EASA 145 Approval of a CAR 573 AMO (SIS Results will validate required steps)

AMO TCCA AMO

TCCA •Notifies EASA of the

approval request •Invoices Applicant

AMO

•Pays the fee

EASA EASA •Confirms fee

Payment to TC

•Reserve approval

number for AMO

TCCA •Approves EASA Supplement

•Issues the Approval Letter

•Publishes the approval on the TC Web Site

Sole Source Repair

• Becoming a common practice for third party manufacturers.

• Facilities located outside of the territorial boundaries of our International

Agreements are not recognized.

• Development of new International Agreements are now not always

possible based on length of time required for the development of such

agreements.

• Issuance of a TCCA FAMO approval required when the maintenance is

not provided by any other organization within our International

Agreements.

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FAMOs • Some of our Regulatory Partners have hundreds of globally approved

maintenance facilities.

• Currently TCCA has no FAMO’s.

• Three applications are currently being proceed from South Africa,

Indonesia and the Philippines.

• All of these organizations are sole source repair organizations, issuance

of a FAMO is required to meet Canadian regulatory requirements.

• All three organizations have multiple regulatory approvals.

• Repair Station may reside in countries that are not fully ICAO compliant.

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Manufacturing

• Canadian manufacturers are located outside of Canada as a supplier or

under their TCCA manufacturing approval.

• Canadian Aviation Regulations (CARs) allow for the extension a TCCA

manufacturing approval outside of Canada.

• Supplier control of multinational third party manufacturing has always

been an organizational and regulatory challenge.

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Shared Surveillance Methodology

• Agenda item at the ICAO High Level Safety Conference.

• AMOs and third party manufactures identified as possible candidates.

• TCCA FAMO approvals will be shared with regulatory partners.

• Foreign maintenance approvals may become part of future agreements.

• Processes need to be developed to share surveillance responsibilities.

• Validation principals maybe possible.

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Surveillance Methodology cont’d

• Third party manufacturing and supplier control present even greater

challenges with regards to documentation, conformity, and surveillance.

• The responsibility to maintain a system that ensures a compliant

aviation product lies with the State of Design and manufacturer of the

main product.

• A Major manufacturer for a complete aircraft may have up to 4000

suppliers.

• TCCA will work with ICAO member states on the development of a

framework that will reduce surveillance duplication.

New and Emerging Technologies

• TCCA maintenance performance rules unchanged in 15 years.

• Basic training curriculum not subjected to frequent amendments.

• Type training will encompass new and emerging technologies.

• TCCA approved type training is required for all turbine helicopters and

transport category aircraft.

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MRB Process

• MRB process ensures the development of maintenance requirements

are up to date with new and emerging technology.

• Uses the MSG-3 process to derive scheduled maintenance tasks.

• Used by all manufacturers of transport category aircraft.

• Standardization and harmonization of the MRB process, under the

International MRB Policy Board (IMRBPB).

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Basic MRB Process

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STRUCTURES

WORKING

GROUP

POWERPLANTS

WORKING

GROUP

SYSTEMS

WORKING

GROUP

AVIONICS

WORKING

GROUP

ZONAL

WORKING

GROUP

INDUSTRY

STEERING

COMMITTEE

MAINTENANCE

REVIEW

BOARD

DRAFT MRB

MRB

REPORT

Airworthiness

Limitations

ICAs

OPERATOR

MAINTENANCE

PROGRAM

INDUSTRY REGULATORY

REPORT

Instructions

IMRBPB

• Formed in 1995.

• Meets annually to review changes to MSG-3 and the MRB process.

• Nine member authorities and all manufacturers using the MSG-3

process.

• Advocates harmonization and standardization.

• Reviews all changes to ATA MSG-3 and revised every two years.

• Formal Governance being introduced with the Certification Management

Team (CMT) to establish co-ordination at a bilateral and multi-lateral

level.

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IMRBPB cont’d

• During the past five years the IMRBPB has approved;

-Two revisions to MSG-3.

-2013 MSG-3 revision includes Volume I and II.

-Approved 46 Issue Papers affecting the MRB process and/or MSG-3.

-Development a new MRB process standard, completion end 2015.

• MRB process standard will enable future validation of the MRB report as

part of the Type Design validation process.

• Enabling a more effective use of regulatory resources.

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We’re All In This Together

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Manufacturers/Operators/Maintainers/Regulators

Partnership and Balance = Safety

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