By Mike Whissell
Discussions between the Federal Aviation Administration (FAA) and Transport Canada Civil Aviation (TCCA) regarding mutual recognition of design approvals resulted in changes to the Bilateral Aviation Safety Agreement (BASA). This revised agreement signed on June 12, 2000 now has specific provisions for the reciprocal acceptance of replacement parts without explicit review and approval by the importing authority.
The FAA agreed to accept "replacement parts" whose design has been approved under a TCCA "Part Design Approval" (PDA), and produced by the holder of a TCCA (Standard) 561 manufacturer certificate, for installation on U.S. registered aircraft or on other aeronautical products to be installed thereon. In return, TCCA agreed to remove the existing limitation in Standard 571 on FAA Parts Manufacturer Approval (PMA) usage on Canadian registered aircraft or on other aeronautical products to be installed thereon. Specifically, the change introduced a new reciprocal agreement for acceptance of "replacement parts" intended for installation on aeronautical products.
In Canada, when it comes to the installation of "replacement parts" in an aircraft the final decision rests with the AME who will be signing the maintenance release for the maintenance accomplished. The certification statement stipulates, "The described maintenance has been performed in accordance with the applicable airworthiness requirements." Applicable airworthiness requirements include Canadian Aviation Regulation (CAR) 571.13 and Section (Standard) 571.13 of the Airworthiness Manual which provides eligibility criteria that must be satisfied, each time a part is installed on a Canadian registered aircraft, or on an aeronautical product intended for installation on a Canadian registered aircraft. Eligibility criteria include proper documentation and certification for these FAA PMA "replacement parts."
So, what is a TCCA PDA part?
A TCCA PDA is a design approval means for Canadian-designed replacement parts that replaces the TCCA historically used approval means of issuing an STC or RDC, under Chapter 513 of the Airworthiness Manual (AWM). As a result, the PDA system is fundamentally a new approval document added to the existing process for STCs and RDCs set out in subpart 513 of the CARs and Chapter 513 of the Airworthiness Manual, augmented by some elements of the FAA PMA system governed by FAR Part 21, Subpart K and FAA Order 8110-42A. The significant PDA system elements are:
- The TCCA PDA system addresses only the design approval aspects of a given replacement part and only has a "test and computation" design methodology, whereas the FAA also allows PMA by "identicality." An applicant for a PDA must have its own design data approved by TCCA, or have legally acquired the rights to use TCCA approved data which may be proprietary to other parties;
- TCCA PDA replacement parts can only be manufactured under a manufacturer certificate issued under subpart 561 of the CARs or Chapter (Standard) 561 of the Airworthiness Manual; and
- The holder of both the PDA design approval and the 561 manufacturer certificate for a replacement part must be the same.
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