NAVIGATING THE CANADIAN AVIATION REGULATIONS (CARs)
In reviewing other log books, I noticed that there are some elements of logbook keeping that are either missed or not fully understood. It struck me that this is as good a time as any to review some of the requirements of the CARs, particularly those pertaining to maintenance and logbook entries. These requirements are found mostly in Part V and Part VI of the CARs. The following discussion will centre on small, private, piston-powered aircraft.
The first point is where to find the CARs. They are all free and online through the Transport Canada web site. https://tc.canada.ca/en/corporate-services/acts-regulations/list-regulations/canadian-aviation-regulations-sor-96-433
If you do not have internet access, you will have to either go to a library, or phone TC and ask for a paper copy of the CARs Parts that you want (for which they will charge you).
Each of the lines on the online page is a link that expands the Table of Contents of that Part. The column on the left is the Regulations. They tell you what you have to do. The numbers of the Regs have a “0” in the centre digit, for example 605.84. The right column in the Table of Contents is the Standards. They tell you how to meet the regulatory requirement. In CARs Part VI, the numbers of the Standards have a “2” in the centre, eg. 625.84. Note that the two numbers correlate. In this example, Standard 625.84 is the standard you must achieve to meet the regulatory requirement of CAR 605.84. The numbering convention is similar in CAR Part V. In any case, you have to meet the standard to be compliant.
In CAR Part VI, section 605.86, it says that no pilot or owner shall take off or permit a takeoff of an airplane not maintained in accordance with an approved maintenance schedule.
Developing an “approved maintenance schedule” is the stuff of commercial operators and transport category aircraft. What are simple, humble, private owners to do? This is where Standard 625 comes in. It provides the “what to do” and the “how to do it” in order to achieve compliance.
Standard 625.86 begins by saying that it is the owner’s responsibility to ensure that the operator (pilot) knows what maintenance is due on the airplane.
It goes on to say that Standard 625, Appendix B, Part I is an approved, blanket maintenance schedule for non-commercial, privately owned, piston engine aircraft other than balloons. It further says that you must also comply with Appendix C.
Simply put, these three paragraphs together mean that you
make an entry in the front of the journey log book stating that the airplane is
maintained according to CAR Standard 625, Appendix B, Part I, and Appendix C.
Now we get into the “nitty-gritty” details.
Breaking it down further, Appendix B, Part I is a generic list of tasks to carry out in order to complete an annual inspection. It is applicable only to small, unpressurized, piston engine fixed-wing and rotor-wing aircraft privately owned and not used in a flight training service. You simply pick out the tasks on the list that are applicable to your aircraft.
Standard 625 Appendix C
In addition to Appendix B, CAR 625.86 states that you must also carry out the applicable items of Appendix C. These are the “Out of Phase” items.
The annual inspection is valid until the last day of the 12th month following the last inspection. For example, if your last inspection was signed off on January 6 2022, it is valid until January 31, 2023. After doing the next annual inspection, you may not get it done and signed off until, say, February 3, 2023. Your latest annual inspection is valid until February 29, 2024. Conversely, there is nothing to stop you doing your annual inspection early for the sake of weather or scheduling. The same rule still applies on the new sign-off date.
The Appendix C Out of Phase items have no such “slippage”. They are hard calendar time items.
For example, if your last compass swing was signed off on January 6 at the same time as your annual inspection, then you are grounded on January 6 unless you do a compass swing. You still have to do the full annual inspection before January 31 to avoid being grounded.
Listed below are some of the most notable—for different reasons—Appendix C items.
8. Tachometers – The accuracy of mechanical drag cup type tachometers has to be checked annually, and be accurate to within the tolerances established by the aircraft manufacturer or, to within +\- 4% of engine RPM at mid-point of the cruise range. The easiest way to do this is with a hand-held optical tachometer while you are doing your leak-check ground run.
10. Non-stabilized Magnetic Direction Indicators (MDIs) – The compass has to be swung and a correction card completed, dated and installed at the compass. A copy must also be entered into the journey log.
12. Emergency Locator Transmitters (ELTs) – ELT’s transmitting only on 121.5 MHz have to have a “Performance test” annually. That means they have to be sent to an approved shop for testing. ELT’s transmitting on 121.5 MHz and 406 MHz require an “Operational test” annually. This is simply pushing the self-test button within the first 5 minutes of each hour for no more than 3 seconds while listening on 121.5. You should hear the “siren” sound of the 121.5 function, and get an email notification from the 406 MHz function. The 406 ELT’s have to go to a shop for a “Performance test” every 2 years. CAR 605.39 allows flying an aircraft for up to 30 days without an ELT. There is no distance restriction.
13. Altimetry Devices – This includes air data computers, altimeters, altitude encoders, auto pilot and any other device that is intended to sense altitude. If you intend to fly in Class B, Class C, or Class D transponder airspace, you must have your “altimetry devices” calibrated every 2 years to ensure accuracy of both the reading on the instruments and reporting to ATC.
The allowable leak rates are contained in CAR Standard 571, Appendix B. By first ensuring that there are no pitot/static system leaks before taking your airplane in, you can eliminate costly troubleshooting and ensure that the visit is only for testing. DO NOT BLOW INTO THE PITOT TUBE OR STATIC PORT. You will damage the airspeed indicator and altimeter, maybe worse if someone left the pitot heat on.
14. Air Traffic Control (ATC) Transponders – ATC Transponders, including altitude encoder, where installed, shall be tested every 24 months. This is typically done at the same time and is part of the same test as the item 13. Altimetry Devices above.
In addition to those items listed in Standard 625 Appendix C, there are also a few other recurring hard time tasks to be carried out.
· Engine Oil and filter change
· ELT battery (mfr’s time limit)
· Magneto overhaul after 500 hrs (Bendix) or 400 hrs (Slick) in service (for Bendix, see Continental Motors Service Bulletin SB643C; for Slick, see Slick Service Bulletin SB2-19A)*
· Airworthiness Directive CF90-03R2 – Exhaust-type heater inspection. This is a rare instance in which an AD is applicable to amateur-built and O-M aircraft. The inspection must be carried out annually or every 150 hours, whichever occurs first.
· Prop bolt re-torque on wood propellers
*Service Bulletins are not legally required. However, magnetos generally fail at ~700 hours.
All of these items must be tracked in the log book. One way of doing that is to make a list of the applicable items and their due dates on your computer. Each time that you write a snag in the log book, you could then update the list as required, print it, cut it out and paste it into the log book.
The exact same print-cut-and-paste method could be done with the answer to the snag and the Maintenance Release, as in the example illustrated.
Maintenance Release
Whenever “elementary” or “maintenance” work is carried out on an aircraft, CAR 571.03 holds that it must be entered into the “technical record”. For an amateur-built, that could still be the journey log.
A Maintenance Release is not required following elementary work. The list of elementary tasks can be found in Standard 625, Appendix A. If the task is not on the list, it is not elementary work and requires a Maintenance Release. Elementary work does not require the release statement below and can be signed for by the pilot, even on a certificated airplane—only if the task is on the list contained in Standard 625 Appendix A. All other work is considered “maintenance” and must have a Maintenance Release.
A Maintenance Release “is a declaration that, with respect to the maintenance performed, the performance rules of section 571.02 of the CARs have been complied with and the applicable standards of airworthiness have been met.”
Who, then, is allowed to sign a Maintenance Release for maintenance work?
There are several answers:
1. In the case of certificated airplanes, it has to be an appropriately rated AME (see CAR 571.11(1)).
2. In the case of an amateur-built, it is an owner. (see CAR 571.11(2)(b))
3. In the case of an aircraft operating under a Special Certificate of Airworthiness in the Owner-Maintenance classification, it has to be someone who is a pilot and an owner (see CAR 571.11(2)(d)).
A Maintenance Release, following maintenance, must say something along the line of,
“The described maintenance has been performed in accordance with the applicable airworthiness requirements.”
or a similarly worded statement.(see CAR 571.10(2)).
This statement with the phrase “…in accordance with the applicable airworthiness requirements ” includes the “Types of Work” that was performed on the airplane. The “Types of Work” list is found in Schedule III at the end of CARs 571. While you are there, you will want to look over Schedule I and Schedule II as well. https://lois-laws.justice.gc.ca/eng/regulations/SOR-96-433/FullText.html#s-571.01.