FAA to TCCA transition
FAA to TCCA Airworthiness Directive status transition review
This review reads an aircraft's AD compliance status for a move onto the Canadian register and asks whether each position will hold up on import. It is run for the receiving side, or the seller preparing the handover, before the AD status list transfers. The work traces each applicable directive to its accomplishment evidence, checks the method of compliance recorded, and identifies where the applicable directive set itself changes on crossing to the Canadian system. You receive an evidence map keyed to the import questions, a gap list of positions taken without support, and a request set for the accomplishment records still missing.
When this review is needed
- A US-registered aircraft is importing into Canada and its AD status has to satisfy TCCA on arrival.
- The applicable AD set changes on the Canadian side and the importer needs the delta identified.
- A directive is shown complied but the accomplishment record behind it has not been located.
- A method of compliance used under the FAA system has to be legible to the receiving authority.
The problem
An AD status list is a set of assertions, and each one is only as strong as the accomplishment record behind it. On a US to Canadian import the applicable set does not simply copy over: the Canadian system carries its own directives and may mandate items the FAA list never showed, while a position recorded as complied under one authority has to be evidenced in a way the other reads. A status list that closed clean on the US side can still leave the importer with directives to prove and directives it did not know applied.
What gets reviewed
- Each applicable directive traced to the accomplishment record that closes it
- Method of compliance checked for whether it is recorded and legible to the receiving side
- The applicable AD set reassessed for what changes on crossing to the Canadian system
- Recurring directives checked for the next due point and its basis
- Alternative methods of compliance identified and their acceptance on import considered
- Positions taken without support flagged for evidence recovery
Scope this review
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What gets validated
- Every directive shown complied has an accomplishment record that supports the claim
- The method of compliance is recorded and does not rely on unstated assumptions
- The applicable set reflects directives the Canadian system adds beyond the FAA list
- Recurring items show a next due point consistent with the utilization history
- Any alternative method of compliance is identified with its basis, not assumed accepted
Evidence normally required
- The current AD status list and its accomplishment references
- Accomplishment records, work orders, and sign-offs behind the closed items
- The applicable directive set for the aircraft on the Canadian side
- Utilization history for recurring-directive due points
- Any alternative-method-of-compliance approvals in the file
Common discrepancies
- A directive shown complied with no accomplishment record located
- A directive that applies on the Canadian side but never appeared on the FAA list
- A recurring item whose next due point does not agree with the utilization history
- An alternative method of compliance relied on without its approval in the file
What is at stake
A directive shown complied without its accomplishment record becomes an open compliance question at import, and one the importer cannot close by asserting it again. Directives that apply on the Canadian side but were never on the FAA list surface as unaddressed work, sometimes with a due point already passed, which can ground the aircraft until the position is evidenced or the task is done.
How the work runs
Reassess applicability
Establish the directive set applicable on the Canadian side and mark what the FAA list did not carry.
Trace closures to evidence
Tie each complied directive to its accomplishment record and method of compliance.
Check recurring due points
Confirm next due points against the utilization history for recurring items.
List gaps and additions
Flag unsupported positions and newly applicable directives and request the missing records.
What the buyer receives
- An evidence map linking each directive to its accomplishment record
- A gap list of unsupported positions and directives newly applicable on import
- A request set for the accomplishment records and approvals still to be recovered
Who uses the output
- Continuing-airworthiness teams clearing the AD position for the Canadian register
- Acquisition teams sizing the compliance work an import implies
- Records staff recovering the accomplishment evidence the import will require
How the work fits into the transaction or program
The review reads the AD position before the import, so unsupported closures and newly applicable directives are known while there is time to evidence or accomplish them. Its gap list drives the recovery and planning, and its evidence map forms the AD section of the Canadian import package.
Start with a single asset
Confirm the status list matches the underlying evidence.
Jurisdiction-specific considerations
The applicable directive set on the Canadian side is not a copy of the FAA list: it can add mandatory items and can treat an alternative method of compliance differently. The review identifies the delta so the importer sees directives that only become applicable on crossing, rather than assuming the US status carries over intact.
Regulatory limits
The review assesses the AD records and reports the gaps and the applicability delta. It does not accomplish a directive, approve a method of compliance, or make an airworthiness determination. Acceptance of the AD position rests with the receiving operator and TCCA.
What this review does not cover
- Accomplishing or signing off any airworthiness directive
- Approving an alternative method of compliance
- Any airworthiness determination on the aircraft's AD position
Specific to this review
- The applicable AD set changes on a US to Canadian import, so a clean FAA status list can still leave directives that only become applicable once the aircraft crosses.
- A compliance claim with no accomplishment record cannot be closed by restating it, so evidence recovery is the real work on the AD position.
- A recurring directive's next due point is a frequent discrepancy, because the interval basis and the utilization history are recorded in different places and can drift apart.
Sources
U.S. Government (eCFR). The legal basis for issuing and enforcing Airworthiness Directives on U.S.-registered products.
U.S. Government (eCFR). Records an owner or operator must keep, including total time in service, current status of life-limited parts, and AD compliance.
European Union / EASA. Continuing airworthiness, maintenance records, CAMO responsibilities, and the airworthiness review process in the EASA system.
U.S. Government (eCFR). Export airworthiness approval requirements and special requirements of an importing authority.
European Union / EASA. EASA design and production certification, STCs, ETSO authorizations, and EASA Form 1 release.
Frequently asked questions
Does the FAA AD status carry over unchanged to the Canadian register?
No. The Canadian system maintains its own applicable set and can mandate directives that never appeared on the FAA list, and it can treat an alternative method of compliance differently. The review identifies that delta so nothing is assumed to carry over that does not.
Relevant glossary terms
Related pages
Where this fits
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