Recognition of Airworthiness Authorities

Effective Date: 15 August 2016

Version in effect: 6 (revised 12 March 2024)

Reference: TAM Part 1, Chapter 4

OPI / Telephone: DTAES 2-2 / 613-808-3408

1. Purpose

1.1. This Technical Airworthiness Authority (TAA) Advisory provides guidance and information on the recognition of Airworthiness Authorities (AAs), by:

1. defining what is meant by “recognition”;
2. explaining why the TAA undertakes recognition of AAs;
3. describing how recognition of an AA is achieved and maintained; and
4. providing a list of AAs that are currently recognized by the TAA, as well as those who have recognized the Department of National Defence/Canadian Armed Forces (DND/CAF) Airworthiness Program and its Authorities.

2. Applicability

2.1. This TAA Advisory is applicable to TAA regulatory staff and TAA-accredited organizations, as well as TAA Authorized Individuals (AIs) who wish to leverage airworthiness artefacts from other AAs.

3. Related Material

3.1. Definitions:

1. Airworthiness Authority (AA). The generic term for any of the following: aviation regulatory agency (or authority), aviation safety authority, National Aviation (or Airworthiness) Authority (NAA), Civil Aviation Authority (CAA), or Military Aviation (or Airworthiness) Authority (MAA).
2. Civil Aviation Authority (CAA). The government statutory authority in each country that oversees the approval and regulation of civil aviation. Depending on how it is structured within the state, the airworthiness authority may be established as a sub-component of the larger Civil Aviation Authority. The CAA may also be referred to as the National Aviation (or Airworthiness) Authority (NAA).
3. Military Airworthiness Authority (MAA). The national military airworthiness authority of a state responsible for the airworthiness of the military aircraft of that state. The Canadian MAA (CA MAA) is headed by an AA supported by an Operational Airworthiness Authority (OAA), an Airworthiness Investigative Authority (AIA) and a Technical Airworthiness Authority (TAA). Other military regulators may be organized differently. 
4. Recognition. The term “Recognition” can have different meanings within the airworthiness context. For the purposes of this advisory, recognition is defined as the process by which an AA assesses and acknowledges another AA as being a competent regulator, empowered with the necessary authority, infrastructure, resources, and mechanisms to ensure aviation safety. The scope of recognition is limited to those airworthiness functions that fall within the assigned responsibility of the respective AA. For the DND/CAF TAA and the Technical Airworthiness Program, this relates to airworthiness certification, production oversight and airworthiness inspection (continuing airworthiness). Recognition can be unilateral, bilateral, or multilateral.
5. Airworthiness Artefacts. For the purpose of this advisory, an airworthiness artefact is a regulatory output from a military or civil airworthiness authority. Normally, these regulatory outputs will take the form of an airworthiness approval, or other form of authorization, from an AA. Examples may include any of the following:

(1) Type Design approvals;

(2) Type Certificates;

(3) design change approvals;

(4) design data approvals;

(5) organization accreditations/approvals; and

(6) individual and organizational assignments of authority.

3.2. References:

1. A-GA-005-000/AG-001 – Department of National Defence/Canadian Forces (DND/CF) Airworthiness Program.
2. C-05-005-001/AG-001 – Technical Airworthiness Manual (TAM)
3. Transport Canada Civil Aviation (TCCA) Staff Instruction 511-001 Type Certification of Foreign Aeronautical Products – Determining the Level of Airworthiness Review
4. North Atlantic Treaty Organization (NATO) Airworthiness Policy (internally, within DND, available in the AEPM library, RDIMS #1724729)
5. European Defence Agency (EDA) publication – European Military Airworthiness Document – Recognition (EMAD-R), Edition 3.1, 21 April 2023 (internally, within DND, available in the AEPM library, RDIMS #1559486)
6. Air Force Interoperability Council (AFIC) Air Standard AW 2003, Ed2, v1, 16 July 2021 – Process for Recognition of Military Aviation Authorities (internally, within DND, available in the AEPM library, RDIMS #1558748)
7. International Civil Aviation Organization (ICAO) Doc 9734 – Safety Oversight Manual, Second Edition 2011
8. ICAO Doc 9760 – Airworthiness Manual, Third Edition, 2014
9. Military Authorities Recognition Question Set (MARQ) Template (internally, within DND, available in the AEPM library, RDIMS #1634944)
10. AF9000 Procedure TAA09.006-05 Technical Airworthiness Oversight – Industry Recognition Process
11. AF9000 Procedure TAA09.019 Type Design Examination (TDE)

4. Discussion

4.1. Overview

4.1.1. One of the responsibilities delegated to the TAA under the DND/CAF Airworthiness Program (reference 3.2.a.) is to provide oversight of individuals and organizations that are performing technical airworthiness functions. The following sections of the Technical Airworthiness Manual (TAM) (reference 3.2.b.) describe how this responsibility is regulated for organization, or design certification, approvals that have been issued by another civil or military airworthiness authority:

1. TAM Part 1, Chapter 4 – Assignment of Technical Airworthiness Authority describes the rules and standards for determining the acceptability of organizations that have been assigned airworthiness management roles or airworthiness functions by a regulatory authority other than the TAA.
2. TAM Part 2, Chapter 5 – Type Design Examination (TDE) describes the rules and standards for the acceptance of work performed, and airworthiness artefacts issued, by other airworthiness authorities in relation to initial type certification or major design change approval.

4.1.2. To enable the provisions of these two TAM chapters, there is a requirement to identify the other regulatory authorities that are acceptable to the TAA and detail the methodology used to establish acceptability. Recognition is the primary process used by the TAA for establishing acceptability of the work and artefacts of another airworthiness regulatory authority.

4.2. Benefits

4.2.1 Recognition of other AAs facilitating compliance with various provisions within the TAM.

4.2.2 Recognition allows the TAA to exploit opportunities arising from the adoption of another AAs' assurance activity, leveraging existing airworthiness artefacts, and realizing economies (e.g., adopting organizational approvals or aircraft certification evidence, or conducting joint organizational approvals or aircraft certification activities associated with a common aircraft type on a cooperative program basis).

4.2.3 The recognition assessment process exposes the TAA to other AAs’ program structure, methodologies and best practices, which can be adopted to improve the Technical Airworthiness Program and enhance aviation safety within the DND/CAF.

4.2.4 In the context of TDE, recognition can be used to support determinations of Acceptability and will influence the level of Type Design Review required (Level 1 – Minimal, Level 2 – Limited, or Level 3 –Comprehensive).

4.2.5 In those cases in which TDE is used in support of the airworthiness approval of a major design change managed by a fleet’s Type Certificate Holder, the TAA-approved Engineering Process Manual will detail the role of the recognized AA and the scope of authority that the TAA has approved.

4.2.6 In the military context, recognition can enhance interoperability (i.e., informing decisions or formal agreements for the employment of another nation’s maintenance technicians (First Line), or being supported by their approved maintenance organization (Second Line)).

4.3. Limitations and Constraints

4.3.1. Safety and airworthiness are sovereign responsibilities. Recognition, therefore, does not transfer any legal responsibilities from the TAA to the recognized AA. Even if the TAA has concluded, based on AA recognition, that the outputs of a MAA-regulated system are acceptable, the TAA continues to remain fully accountable for the airworthiness of CAF aircraft.

4.3.2. TAA recognition of another AA neither implies, nor requires, that the authority must make any changes to their airworthiness management systems as a result of the recognition. It remains the responsibility of the TAA to account for any differences in standards and processes, and to decide how any identified gaps are to be managed.

4.4. Recognition – Civil Aviation Authorities

4.4.1. The DND/CAF Airworthiness Program has provisions for the recognition, by the TAA, of Civil Aviation Authorities (CAAs) based on their regulatory experience and reputation, without requiring a formal recognition process. The TAA has extended this recognition to the following CAAs:

1. Transport Canada Civil Aviation (TCCA) – the TAA accepts certification work approved by TCCA that applies to civil pattern aircraft on the DND military aircraft register. This also includes acceptance of TCCA organizational approvals related to maintenance, design, manufacturing and materiel support services for civil-derived aeronautical products;
2. U.S. Federal Aviation Administration (FAA) – the TAA accepts certification work approved by the FAA that applies to civil pattern aircraft on the DND military aircraft register. This also includes acceptance of FAA organizational approvals related to maintenance, design, manufacturing and materiel support services for civil-derived aeronautical products;
3. European Union Aviation Safety Agency (EASA) - the TAA accepts certification work approved by EASA and its member states that applies to civil pattern aircraft on the DND military aircraft register. This also includes acceptance of EASA and EASA member state organizational approvals related to maintenance, design, manufacturing and materiel support services for civil-derived aeronautical products.

4.5. Recognition – Military Airworthiness Authorities

4.5.1. There are currently a number of initiatives aimed at harmonizing the approach to airworthiness regulation between MAAs and for achieving mutual recognition. Key coordinated efforts have been sponsored by:

1. the North Atlantic Treaty Organization (NATO) (reference 3.2.d.);
2. the European Defence Agency (EDA) (reference 3.2.e.); and
3. the Air Force Interoperabiity Council (AFIC) (reference 3.2.f).

4.5.2. Common to the efforts between these agencies is the use of a standardized assessment tool, based on International Civil Aviation Organization (ICAO) documents (references 3.2.g. and 3.2.h.), which outline the duties and responsibilities of MAAs with regards to the certification and continuing airworthiness of aircraft, and airworthiness safety oversight. This standardized assessment tool has been tailored for the military context and takes the form of a question set called the Military Authorities Recognition Question set (MARQ) (reference 3.2.i.), which is a controlled document that is managed by the EDA Military Airworthiness Authorities (MAWA) Forum.

4.5.3. Unlike ICAO in the civil context, there is no single, internationally-recognized organization that sets airworthiness or aviation requirements for MAAs. It is through the military fora noted above that Canada and other nations are working to promote harmonization, and have adopted the process of recognition through the use of the MARQ.

Note: Within a military organization, airworthiness and aviation responsibility may be spread across a number of organizations, and enforcement may only be possible through internal regulations, rules and contracts. While MAAs may closely align with many of the international civilian airworthiness processes, by necessity, military aviation has a different risk context and will employ military design standards. For example, for most military organizations, operational effectiveness is paramount and, therefore, aviation safety objectives must be balanced against the need to accept higher levels of risk wherever operational circumstances dictate.

4.5.4. Military Authorities Recognition Question Set. The MARQ is structured in two layers: 'Organizational Goals' and 'Assurance Goals'. Between them, there are over 150 safety goals or protocol questions, distributed over four sections that allow an AA (MAA or CAA) to provide evidence on how it satisfies the safety goals through the conduct of its national airworthiness assurance responsibilities. The four sections are:

1. Airworthiness Regulator. This section identifies regulatory Organizational Goals and critical elements associated with the code, structure and organization of the authority;
2. Airworthiness Inspection. This section identifies Assurance Goals for the authority’s regulation of continuing airworthiness;
3. Production Oversight. This section identifies Assurance Goals for the authority's regulation of production organizations; and
4. Aircraft Certification. This section identifies Assurance Goals for the authority’s regulation of certification activities.

4.6. Recognition Process

4.6.1. The TAA (through the Directorate of Technical Airworthiness and Engineering Support (DTAES) 2 staff) is responsible for the overall coordination of an AA recognition event. The recognition process follows four basic phases:

1. planning;
2. review (desktop and onsite);
3. granting of recognition; and
4. recognition sustainment.

4.6.2. While the review process includes both a desktop and an onsite review, the output of the desktop review can be sufficiently comprehensive to preclude the requirement for the onsite review. When granting recognition, the TAA will specify any associated terms or condition. Sustainment usually relates to the requirement to communicate any change to the conditions under which the recognition was originally issued. Terms, conditions and sustainment requirements are normally articulated in a recognition certificate and the supporting documentation.

Note: The recognition process primarily addresses those aspects of another AA’s regulatory program that equate to those found within the DND/CAF Technical Airworthiness Program. For this reason, it is the DND/CAF TAA that undertakes and issues recognition on behalf of the CA MAA.

4.6.3. Planning Phase

4.6.3.1. The planning phase is used to review the rationale for the AA recognition and establish the recognition plan. The TAA will normally support recognition of a MAA or CAA to leverage certification information developed by an MAA/CAA for an aircraft type being operated or procured by the DND/CAF. The TAA may also support recognition of a MAA or CAA that has regulatory responsibilities for organizations that perform design, maintenance, manufacture, or material support activities on aircraft types or aeronautical products that are similar to those operated by the CAF.

4.6.3.2. The recognition plan will identify:

1. the rationale for the recognition activity taking place;
2. points of contact within the MAA or CAA organization that will be facilitating the review;
3. a schedule identifying MARQ completion by the respective MAA/CAA, desktop review, onsite review and close-out activities; and
4. the TAA staff assigned to perform the reviews and documentation requirements.

Note: When the TCCA or FAA has a bilateral or similar agreement in place with a CAA that the TAA is planning on recognizing, a reduced review can be applied. The recognition plan can be used to provide the rationale for a direct recognition, without completion of the MARQ or an onsite evaluation. The reduced review could include the assessment of relevant open-source documentation, information provided by the CAA being recognized, and/or releasable third party information applicable to the recognition. There may still be a requirement for TAA staff to meet with the CAA to understand how the CAAs’ regulatory system will be used to support the fleet that is on the DND military aircraft register. It may be necessary to develop limitations and conditions associated with the recognition, based upon risk assessment of any gaps in documentation or information.

4.6.4. Desktop Review

4.6.4.1. Once the MAA/CAA has completed the MARQ and provided core MARQ reference documents, the TAA (DTAES 2 staff) will coordinate its review by its authorized representatives (DTAES regulatory Section Heads), as follows:

1. DTAES 2 is responsible for the “Airworthiness Regulator” sub-section;
2. DTAES 4 is responsible for “Airworthiness Inspection” and “Production Oversight”; and
3. DTAES 3 is responsible for “Aircraft Certification”.

4.6.4.2. The objective of the TAA staff review is to establish “acceptability” of the MAA/CAA’s airworthiness system based on their responses to the MARQ. It is essential that only experienced TAA staff members conduct this assessment, since the goal is not to measure a MAA/CAA against the TAA’s system, but rather to understand its authorities, policies, procedures and outputs, and identify possible gaps in the way the MAA/CAA is measured against the standardized AA “template” as defined by the MARQ.

4.6.4.3. Once the regulatory Section Heads have completed their reviews, they provide a summary of their findings to DTAES 2, who collates them into a preliminary report. The report provides an overall assessment of acceptability and identifies any areas that require clarification through an onsite review. DTAES 2 maintains a record of individual evaluator findings and coordinates with the AA being assessed to build a schedule for the onsite review.

4.6.5. Onsite Review

4.6.5.1. The onsite review will normally be led by the TAA’s authorized representative (DTAES Director or a regulatory Section Head). The onsite review team will include representatives from the TAA staff that have the subject matter expertise to conduct the follow-up with the MAA/CAA for the areas identified as requiring additional onsite review.

4.6.5.2. It is important that the schedule created for the onsite review include all questions and/or areas for additional review, as this, combined with the subsequent record of responses or findings and the report from the Desktop Review, will constitute the basis for the TAA supporting or rejecting a MAA/CAA recognition.

4.6.6. Granting Recognition

4.6.6.1. After the onsite review has been completed, the TAA (DTAES 2 staff) will complete the recognition file by preparing a final justification report, a Recognition Letter and a Certificate for the TAA’s signature.

4.6.6.2. The recognition letter will include references to:

1. this TAA Advisory;
2. the final justification report and the RDIMS number of the project file that contains the completed MARQ sub-sections; and
3. any reference material provided by the MAA/CAA.

4.6.6.3. DTAES 2 staff will then update the Annex A to this Advisory, which lists the AAs recognized by the TAA, as well as any associated limitations or restrictions.

4.6.7. Recognition Sustainment

4.6.7.1. The AA recognition process established by the TAA does not require a scheduled review and renewal of a MAA/CAA. A TAA recognition does not expire; however, its ongoing validity is dependent on the TAA being cognisant of any updates to the MAA's/CAA's MARQ responses as a result of changes to their assigned authority or responsibility, organizational construct, or their associated regulations, policies or procedures. Although this can be facilitated through the “regulator-to-regulator” relationship that the recognition process establishes, the TAA remains responsible for determining whether the extant recognition is current and valid, when it is to be leveraged to accept artefacts or approvals, or otherwise inform interoperability decisions and/or arrangements.

5. Recognized Airworthiness Authorities

5.1 Recognized AAs

5.1.1 Annex A to this Advisory lists those AAs that have been recognized by the TAA. Information is provided related to:

1. nationality;
2. whether it is a CAA or MAA;
3. organizational title and relevant composition details;
4. recognition reference documentation; and
5. the scope and conditions associated with the recognition.

5.1.2 Annex B to this Advisory lists those AAs that have recognized the DND/CAF Airworthiness Program.

5.1.3 These lists will be updated any time:

1. there is a change to an existing recognition;
2. new AAs are added; or
3. an AA’s recognition is revoked.

5.2. Recognized Organizations

5.2.1. As stated in para 4.1.1.a. of this advisory, Part 1, Chapter 4 – Assignment of Technical Airworthiness Authority of reference 3.2.b. describes the rules and standards for determining acceptability of organizations that have been assigned airworthiness management roles or airworthiness functions by a regulatory authority other than the TAA.

5.2.2. Organizations working within an airworthiness system approved by another AA that has been assessed, deemed acceptable, and recognized by the TAA are called “recognized organizations”. Reference 3.2.j represents a TAA staff instruction describing how companies providing services under contract to DND are recognized by the TAA.

5.2.3. TAA-recognized organizations are listed on the TAA internet and DTAES intranet websites.