Signing of the Technical Implementation Procedure – some highlights

ADS briefing on the UK CAA / EASA TIP – Industry Outreach Webinar – written by Ashanti Basu, ADS Aerospace Regulatory Manager.

 

On 17 May 2021 the Certification Oversight Board approved the Technical Implementation Procedure (TIP) in Aviation Safety between the UK and the EU.

This was thankfully delivered in record time, with much credit to DfT/CAA and EASA/EU council. The TIP formulating a small part of the overall UK-EU trade and cooperation agreement, will continue the strong relationship and ideals between UK and European aerospace and will be a pragmatic and welcome reduction in unnecessary effort in recognising each others’ approvals in aviation safety.

Although not totally reciprocal there is significant coherence on recognition of most regulatory procedures, as DfT and the UK CAA had previously intimated to industry. The TIP also sets out the measures the aerospace sector must take in order to design and produce new aerospace parts moving between the UK and the EU.

This BASA will recognise CAA approval in the EU member states and also Switzerland and Iceland.

TIP – KEY ISSUES

All previously approved design certificates prior to 1 Jan 2021 will be valid for either the CAA or EASA and will not require further approval (Article 15).

The Certification Oversight Board has been established in accordance with Article 3 of the Aviation Safety Annexe. This is the technical coordination body for the responsible implementation of the Annexe. They will propose amendments to the Specialized Committee on Aviation Safety (SCAS), define procedures and report unresolved issues to the SCAS.

Acceptance not requiring oversight by the validating authority (VA)

  • When the previously certified/validated aeronautical product, EASA will accept minor changes to products and TSOA articles approved by the CAA and also design data for minor repairs.
  • When the previously certified/validated aeronautical product, CAA will accept minor changes to products and TSOA articles approved by the EASA and also design data for minor and major repairs, ETSOA and non-significant STC and major changes in the EASA system.
  • ETSO – The CAA will automatically accept all EASA approved ETSO but EASA will validate UKTSO, however EASA expect streamlined resolution.

The following table outlines the equivalencies and differences. (Courtesy of CAA).

Procedures requiring validation

The initial application process for Streamlined or technical is similar whereby application to VA made via the CA and the VA acknowledges and advises the CA of missing data within 20 days.

Technical validation in line with level of involvement procedures (LOI) Process 1

  • An application is required to the VA.
  • Technical assessment by the VA – involvement will be as per LOI procedures
  • Validation certificate will be issued by the VA.

Other issues

  • There will be a transfer of STC and TC – although the volume and timeline have not been discussed as yet.
  • No UK organization should release on a EASA Form 1 from 1 Jan 2021.
  • Likewise UK companies should use UKPA part marking not EPA from 1 Jan 2021.
  • There is currently no provision for VTOL in either UK CAA or EASA regulations.
  • The lack of reciprocity in some areas means that EASA may validate significant work for UK industry, causing additional delay and expense.

EASA have offered that they aim to minimise undue expense as best they can. Consequently ADS considers that further work is needed to develop full cooperative equivalency in the near future to best aid UK industry.

ADS would like to offer our gratitude on behalf of industry members to DfT/CAA and EASA/EU council for there considerable efforts in the prompt delivery of the TIP agreement.

A further note disseminating the detail of the TIP will be presented by ADS at a later date.

For further discussion contact Ashanti Basu ADS Aerospace Regulatory Manager

CAA links to TIP and presentation