Application to Waive Specific Eligibility Requirements for Technicians Being Authorized to Perform Airworthiness-Related Tasks and Airworthiness Functions

Effective Date: 16 March 2020

Version in Effect:  2 (Revised 15 March 2024)

Reference:  Technical Airworthiness Manual, Part 1, Chapter 4, Section 1.4.2.S2, Paragraphs c. and d.

OPI / Telephone: DTAES 4-6 / 819-939-4082

1. Purpose

1.1 This Technical Airworthiness Authority (TAA) Advisory provides guidance to Maintenance Organizations seeking TAA authorization to waive specific knowledge, skills or experience “eligibility” requirements for maintainers being authorized to perform airworthiness-related tasks and airworthiness functions. This may include the execution and signing for work performed and/or Maintenance Release Authority (MRA) and Aircraft Release Authority (ARA).

2. Applicability

2.1 This TAA Advisory applies to Acceptable Maintenance Organizations (AMOs) who are seeking relief from technical airworthiness requirements in assigning authority to their technicians to perform maintenance, as well as sign for maintenance and/or execute MRA or ARA on Department of Defence and the Canadian Armed Forces (DND/CAF) aircraft. This TAA Advisory may be used when a waiver request, submitted to the TAA, can demonstrate that the assignment will not affect safety or reduce it below a level that is acceptable to the TAA.

3. Related Materials

3.1 Regulatory References:

3.1.1 C-05-005-001/AG-001 –Technical Airworthiness Manual (TAM):

1. Part 1, Chapter 4 (1.4.2.S1 – Organizational Authority and 1.4.2.S2 – Individual Technical Authority)
2. Part 5, Chapter 9 (5.9.2.S1– Exemption or Deviation Request)
3. Part 3, Chapter 1 (3.1.2.S8 – Verification of Maintenance), and 3.1.2.S2 (Performance of Maintenance)

3.1.2 TAA Advisory 2016-04 – Recognition of Airworthiness Authorities

3.1.3 TAA Advisory 2015-01 – Basic Airworthiness Exam Requirements for MRA Candidates within a TAA-Accredited Organization

4. Discussion

4.1 According to the DND Technical Airworthiness Manual (reference 3.1.1), an  AMO’s Maintenance Process Manual (MPM) shall define the eligibility requirements, in terms of knowledge, skills and experience that an individual must meet prior to being authorized to perform and sign for maintenance, and/or execute MRA (i.e., Aircraft Certification Authority (ACA) and Shop Certification Authority (SCA)), or ARA. While the AMO is expected to adhere to these rules, there may be occasions when a Senior Maintenance Manager (SMM) may need to consider granting authorization to an existing individual within the AMO, or hiring a new employee, who does not fully meet the defined eligibility requirements for the intended role. In this case, the SMM may submit a waiver request to the TAA for approval, providing that the SMM can demonstrate that it will not affect safety, or reduce safety below a level that is acceptable to the TAA. In accordance with reference 3.1.1.b, a waiver submission should include:

1. Identification and description of the airworthiness deficiency for which the exemption is requested;
2. Background to the request;
3. Rationale and supporting arguments to substantiate the request, including alternate airworthiness requirements and/or demonstrating equivalency;
4. Identification of any reduction to the level of safety, or airworthiness risks, arising from the request;
5. Identification and proposed conditions that could mitigate or eliminate any risks;
6. Duration of the exemption, if applicable, with associated mitigation plans; and
7. Supporting Documentation.

4.2 The following paragraphs provide guidance and considerations that may be taken into account while assessing an individual’s knowledge, skills and experience requirements against the AMO policy defined within their MPM.

4.2.1 Knowledge

4.2.1.1 In general terms, and in compliance with reference 3.1.1.a, the organization’s MPM will define knowledge in terms of trades training, specialty training, on-type training, initial training, and airworthiness training. Any individual responsible for the conduct and/or certification of maintenance shall have completed a basic avionics, mechanical/structures or specialty maintenance course by a training organization acceptable to the TAA. This may include training by an approved Royal Canadian Air Force (RCAF) training facility, or a training facility approved by another civil or military airworthiness authority. Reference 3.1.2 provides information on civil or military airworthiness authorities that have been recognized by the TAA. A waiver request would have to present a strong case, with objective evidence, demonstrating equivalent training gained through formal courses or On-the-Job-Training (OJT) and work experience.

4.2.1.2 While the TAM does not specifically define the eligibility requirements for an individual to perform and sign for maintenance, hereinafter referred to as a Journeyperson, it does recognize that incorrectly performed maintenance can have a significant effect on the continuing airworthiness of an aeronautical product. For this reason, it is expected that the organization’s MPM will define the training and authorization requirements for a Journeyperson. Additionally, the MPM should list the Journeyperson’s responsibilities associated with Verification of Maintenance, as defined in reference 3.1.1.c. For a one-time deviation from the training and authorization requirements defined in the MPM, the SMM/Person Responsible for Assignment of Authority (PRAA) will be expected to submit a waiver request, as detailed in this TAA Advisory.

4.2.1.3 An ACA can be granted once the individual has met basic knowledge pre-requisites (i.e., Aircraft Maintenance Engineer (AME) licence holder or completion of TAA-approved apprenticeship program) and completed an on-type course. Generally a request to waive the on-type course for ACA would not be supported, unless the organization can demonstrate that the individual has received equivalent training through other means (i.e., a combination of defined OJT program and experience within the organization).

4.2.1.4 For the SCA authorization, the individual would normally need to obtain a diploma or certificate in the appropriate field for the work that the SCA is being assigned. This can also be satisfied through an OJT program and/or work experience if it is defined in the organization’s MPM.

4.2.1.5 Individuals considered for ARA are normally selected from the organization’s most experienced ACAs, provided they have a good understanding of their MPM and their airworthiness responsibilities. While rare, any deviation from the requirements for ARA must be well substantiated within the waiver request.

4.2.1.6 Initial training normally covers non-trade specific training that applies to all staff within the organization. This would include (but is not limited to) Indoctrination, Quality System, Electronic Record Keeping Systems (ERKS), Human Factors, Workplace Hazardous Materials Information System (WHMIS), Tool Control and First Aid Training. The requirements for initial training should be described within the organization’s MPM. The TAA would not expect to see a waiver request in this area.

4.2.1.7 For any individual who will hold MRA, Technical Airworthiness Training is mandatory and is not usually part of initial training. This is normally met through the in-house training of the TAA-approved MPM and associated procedures, followed by a Basic Airworthiness Exam. Details on the requirements for a Basic Airworthiness Exam may be found at reference 3.1.3. Appropriate Airworthiness Training and exam may not be waived.

4.2.2 Skills

4.2.2.1 This requirement refers to the need to provide evidence that the individual under consideration has completed a selection of maintenance tasks related to the roles and airworthiness authorization being assigned. In general, the organization’s MPM should define the required skills and how they are achieved (e.g., OJT). While basic skills are gained through the individual's apprenticeship program, this does not negate the need to further develop their skills through a systematic performance of the task and evidence that the individual has satisfactorily completed the task to the satisfaction of the SMM and/or PRAA must be documented. In some cases, this hands-on training may be acquired during the aircraft type course. Any deviation from the skills eligibility requirements defined in the MPM will require a waiver.

4.2.2.2 If the organization’s scope includes the requirement for granting ARA, the MPM will need to describe how the individual will gain the skills required to execute ARA. This would include exposure to all the scenarios covering Aircraft Release responsibilities (i.e., Aircraft Release for Flight versus Aircraft Release to Flight-line operations following a significant Maintenance Event, as applicable), demonstrated through OJT to the satisfaction of the SMM or PRAA. Any deviation from the requirements defined in the organization’s TAA-approved MPM would require a waiver.

4.2.3 Experience

4.2.3.1 Depending on the roles and authorizations being assigned, experience requirements may vary from the completion of an apprenticeship program to minimum defined criteria based on experience working within an AMO and experience working on similar aircraft types or components. For ACAs, reference 3.1.1.a, standard 1.4.2.S2 includes experience gained through the individual’s apprenticeship program, experience working within a TAA-AMO and experience on aircraft that have been issued type certificates by an airworthiness authority acceptable to the TAA. SCA experience is expressed in hours working on relevant components, under the direct supervision of a SCA. For ARA assignment, additional experience requirements are imposed on top of the ACA requirements.

4.2.3.2 Requests for a waiver of experience requirements are the most common waivers received by the TAA. As with all eligibility requirements, any deviation from the experience requirements defined in the organizations MPM will require a waiver approval.

4.2.3.3 Organizations requesting a waiver for their personnel must submit the Request for Technical Airworthiness Function Waiver provided in Annex A to this advisory. Once the waiver has been approved, and any mitigating actions completed, the individual may be formally authorized in accordance with the organization's MPM. A copy of the waiver should be held on the member’s file throughout the individual’s employment with the organization, or until the requirement in the MPM has been met, thereby nullifying the waiver.

Note:  It should be noted that, if an organization is planning on hiring a number of individuals with similar backgrounds, it may be more efficient to approach the TAA for an amendment to the MPM to cover off this scenario.