Recording Major Repairs on Canadian Products

ARSA recently requested that Transport Canada, Civil Aviation Directorate (TCCA) adopt a uniform policy for recording major repairs performed in the U.S. on Canadian aeronautical products. Under the Maintenance Implementation Procedures (MIP) to the Agreement for the Promotion of Aviation Safety between the U.S. and Canada a major repair to a Canadian product is recorded on FAA Form 337 or "an equivalent method acceptable to the TCCA."

In a letter to TCCA, ARSA proposed that U.S. repair stations be allowed to use the work order exception in 14 CFR Part 43, Appendix B, paragraph b as “an equivalent method acceptable to the TCCA” for recording major repairs.

TCCA sent a formal response, agreeing that if a U.S. repair station were to "follow an FAA accepted procedure in its manual that provides the owner of the aircraft with a copy of the work order, and retains a copy in its records for two years" this constitutes compliance with the MIP.

Further, the TCCA stated that the Canadian major repair reporting requirement applies to complete aircraft only. It does not apply to "products" (as that term is defined by the TCCA) other than aircraft.

The formal confirmation of this policy from TCCA may be found here.

A copy of ARSA’s letter requesting the policy to TCCA may be found here.