TCCA Issues Undocumented Parts Rule Exemption

[Widow]

This rubs me the wrong way. Anyone else feel the same?

Transport Canada Issues Exemption to Undocumented Parts Rule


DATE: 07/09/2010
SUMMARY:
On July 2, 2010, Transport Canada Civil Aviation (TCCA) issued an exemption to relieve AMOs with avionics, instrument and component ratings from the requirements of CAR STD 573.02(11). Click here to view Exemption 573.020001

MAJOR HIGHLIGHTS:
CAR Standard 573.02(11) states that an AMO with ratings in the aircraft avionics, engine, propeller, structure, or component categories may evaluate undocumented parts of the kinds listed on the pertinent ratings, provided that:

a.the AMO establishes applicable procedures, in its MPM, to perform the process outlined in Standard 571, Appendix H,
b.the AMO obtains approval for the procedures required in paragraph (a) in accordance with section 573.01 of the CARs, and
c.the performance of such service is authorized in the limitations set out in the AMO certificate.
The exemption applies specifically to holders of an AMO certificate with applicable avionics, instrument and component rating, issued pursuant to CAR 573.

The exemption is subject to the conditions that the person holding an AMO certificate with the above ratings shall ensure that:

1.the parts certified are within the applicable scope of these ratings,
2.the necessary instructions for continued airworthiness are available to maintain these products, and
3.all other applicable CARs shall be complied with.
AEA COMMENTARY:
The AEA has been discussing this issue with TCCA for some time, and we are extremely pleased with TCCA’s recognition that AMOs with the above-stated ratings need not follow the procedures of CAR 571, Appendix H to re-certify undocumented parts. AEA member AMOs in Canada with these ratings may now amend their MPM in accordance with the provisions of the exemption.

http://www.aea.net/governmentaffairs/re ... .asp?ID=44

[Brewguy]

Nope, this doesn't bother me in the least. In fact, I say it's a good call on TC's part.

Let's use an analogy: Say you want to take out life insurance - but the insurer first want to make sure you're in perfect health. You should be able to go to a doctors office, be tested (blood tests, x-rays, etc. ... whatever is necessary) and examined by a competent person (a doctor) and be given a clean bill of health. The doctor shouldn't necessarily need your complete medical history back to your birth to determine that you're okay.

[AME 283]

Very scary, TC has dumbed down the rules too far already that we need only minimal traceability on parts. Now TC is allowing un documented parts into service with out due process As an AME who wears the ultimate responsibility when installing the part this gives me grave concern.

I see lots of parts that fail on install, I expect this will increase this rate of failure

By allowing this type of exemption TC is ducking their responsibility

Are there any other countries that allow un documented parts ?? I know that you are not allowed to install un documented parts in EASA aircraft, but this type of exemption is going to increase the use of un documented parts in Canada

Oh well should increase work for lawyers during the next incident

[Heliian]

Good Idea in theory,

just because a part is undocumented doesn't mean its bogus and the legal responsibility is on the AMO not the AME. This will particularly help the owners of more vintage a/c who have a hard time finding parts. The rule is being applied to avionics and instrumentation, not lifelimited parts. Just because a part has lost it's history shouldn't make it garbage, a good green initiative if you ask me, I'm surprised the avionics manufacturers didn't lobby against this, means less new sales.

[2R]

Does this apply to all those nice parts on the healing shelf

[AME 283]

Suggest you read the CARs, and talk to a lawyer, just because one is working for an AMO it does relieve the AME from responsibility The AME bears the ultimate responsibility for installing a part.

And since the American justice system seems to be heading north, a lot of lawyers are using the shot gun approach, they sue every one.

I agree an un documented part my not be "bogus" but how do you know ?? How do you know the part was not rejected as it did not meet the applicable standards ??

Be careful and be safe

[Heliian]

As an AME, when I install a part, I check the cert first, then the part to make sure it belongs to the cert and then i check the part for any obvious defects, install and test it to ensure proper functionality. If the part has been re-certified and I do my due-diligence and all the proper paperwork, then my end of it is complete. If the part catastrophically fails after the fact there will be traceablility right back to the person who re-certified it, if he/she did their job correctly you then have to look at the re-certifying procedures from the AMO. You can't get sued for doing your job properly and I would like to know if a canadian AME has ever been sued successfully for nothing. You can sue all you want but it doesn't mean you'll win.

If the AMO is properly rated for recertification then there is no issue, it's not like every AMO across the country will get carte blanche to recertify anything.

[twistedoldwrench]

If you think you can't be sued for doing your job properly and within the rules- think again. Anytime someone is killed or even hurt in an accident the shotgun approach by lawyers will implicate you on some level. Lawyers seam to be able to hire "experts" to support any point of view they wish to take. It has absolutely nothing to do with the truth of a matter, just how much portion of blame your insurance company is willing to cover. (you do have insurance for working on aircraft don't you?) Just keep in mind what kind of lawyer advertizing do you see on TV-"hurt in an accident? call 1-800-xxx-xxxx" Like previous poster sayes- American style justice not only is moving- but has moved North of the 49th.

Not to hi-jack this thread- if a component is within the scope of an AMO to be certified- that means they have the manuals and experise to verify the correct parts in a component- resistors, drive gears in a starter, an armautre, etc. Components are not "aircraft parts" until the whole unit is overhauled, repaired, tested and certifed as an assembled part.
Specifically a part such as a starter can be a lot of pieces, gears, housings, armatures, brushes, etc. If these peices measure, fit, perform to meet overhaul criteria, then why not use them just because they are NOS or used serviceable and don't have good paper trail. A lot of old stock for older aircraft componets fall into this category, as rules were not always as stringent as they are today- doesnt mean they are bad parts.

I think my next job will be a greeter at Walmart! Too much BS in this racket! Thanks for the oportunity to rant.