For a SPO to be assessed as a MTCH, DASA will rely extensively on a TCAE that provides confidence that the organisation has the necessary processes/systems and arrangements in place to undertake the holder obligations as well as some additional DASR specific requirements associated with MTC holder duties.
The information in this appendix provides an overview of the requirements of the TCAE for a MTCH; further information can be found in Acceptable Means of Compliance (AMC) to DASR 21.A.14(c). Additionally, DASA is currently developing a system for evaluating TCAEs that will underpin the MTCH authorisation.
The TCAE should describe the MTC holder’s management system and arrangements for executing their continued airworthiness obligations for the platform type. The TCAE should broadly cover the following areas11:
Introduction. The TCAE shall provide some context covering platform, certification history/genesis, certification basis, description of relevant foreign frameworks/operators and any other platform nuances that contextualises the ADF type.
Organisational Structure. The TCAE shall outline the organisational structure of the MTCH and the key support organisations (e.g. the MDO), how the MTCH interfaces with supporting organisations and eligibility requirements under DASR 21.A.14. This section should also describe the interfaces with foreign framework arrangements and how access to type design data is secured. This is further described in DASPMAN Volume 3 Section 7.
Assigned Responsibilities. The TCAE shall describe key responsibilities associated with the MTCH functioning including those of their design support network. Where partner organisations and/or subcontractors are utilised, the TCAE shall describe how the MTCH organisation proposes to collaborate with their design organisation(s).
Procedures. The TCAE shall document key procedures for a range of functions covering how the MTCH intends to carry out the holder obligations under DASR 21.A.44. This should include any processes that propose an Alternative Means of Compliance (AltMoC) to meeting the holder obligations or privileges the MTCH may be eligible for under DASR 21.A.263.
Resources The TCAE shall describe the available resources through a supporting design service that has access to type design data. This can be either local MDOA support and/or through to a foreign OEM or service.
Compliance Matrix. As a means to detail how the MTCH organisation meets the applicable DASR obligations, a compliance matrix may be presented clearly outlining the regulatory requirements of the MTCH organisation and how the organisation complies with or proposes to meet each requirement (e.g. by referring to the
Internal Governance. The TCAE shall describe internal governance arrangements within the MTCH, and external arrangements between the MTCH and any support organisations.
Hazard Management. The TCAE shall describe the internal communication channels, regular safety forums, working groups and systems in place across the broader platform enterprise to manage and communicate ongoing hazards and risks.
Finally, documents constituting TCAEs are not “approved” by DASA. Rather, they are MTC holder’s document(s), and are intended to be working documents that could be expanded to reflect arrangements for subsequent MTC changes, MSTC issues, and major repair design approvals.