时间：2011-08-31 13:49来源：蓝天飞行翻译 作者：航空 点击：次
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One non-JAA NAA (Canada) pointed out that their legal system makes no differentiation between the two types of data. Other JAA–NAAs concurred. In addition, Accepted is also used to indicate when another authority’s approval is recognised in Canada. Any mention of liability should be deleted according to one commentor, as that is strictly a matter for national law in each State. It was not the intention to replace that law, but to draw attention to the issue, that the IEM was added. It is however deleted, and the matter will be raised to the attention of the JAAC instead. Another point that will be highlighted at JAAC level is that relating to the fact that, once adopted, these proposals will mean that the existing JARs that use the term (e.g. JAR–21, JAR–145 and a number of airworthiness JARs) will have to be reviewed for consistency. One affected group commented that this would involve a ‘huge amount’ of work. A number of comments asked for clarification as to whether or not Acceptable and Approval were synonymous with the two proposals. The DEFWG felt that Acceptable was, but Approval should only be used as a noun; i.e. the Approval is the document stating that something or someone is Approved. Some commentors proposed wording to indicate specific actions that would have to be taken for the NAA’s recognition to be either Approved or Accepted. For example, phrases such as ‘..following thorough review..’ and ‘..following cursory review..’, respectively. These were reviewed and the final wording reflects the intent of these comments. The use of the two terms, and thus two systems, was supported by some, as being a flexible way to do business. However, the comment stating that Accepted implies that an applicant need not wholly comply with a requirement is incorrect. Whether Approved or Accepted, the applicant must comply with all of the relevant requirements. The DEFWG has retained two terms, has revised Approved from a single word to the phrase Approved by the Authority (this is to address the point about indirect approval), and has included the word ‘documented’. |
