Safe Aircraft Operations and Maintenance Starts with Understanding Aircraft Owners' Responsibilities

by Nathalie Fortin, Civil Aviation Safety Inspector, Pilot Training and Licensing, Standards, Civil Aviation, Transport Canada

You have completed your flight training and have now jumped into the world of aircraft ownership to expand your horizon with exciting new flying adventures. Congratulations! Throughout your training, on one of the school's aircraft, your instructor provided valuable information on how to ascertain an aircraft is airworthy before going flying. But do you know enough to shoulder the responsibilities that come with owning an aircraft? There is more to it than just relying on your aircraft maintenance engineer (AME). We will explore some of the aircraft owner responsibilities and offer guidance on where to find information. (This article is not aimed as a complete guide to aircraft ownership, but as an overview of some things to consider for the safe continued operation of your private aircraft.)

When you buy an aircraft, it is the seller's, or registered owner’s, responsibility to notify Transport Canada in writing no more than seven days after the change of ownership (Transport Canada Aeronautical Manual (TC AIM)-LRA 4.4). For more information, visit the Web site, Registering and leasing aircraft.

Although there is only limited elementary maintenance work on a certified Canadian aircraft that can be performed by the owner, and most of the work has to be performed by an AME (CAR 571.02(3)), it is the responsibility of the owner to ensure the proper maintenance is done which includes looking up airworthiness directives (TC AIM-LRA 5.6.1).

Approximately 27% of CADORS events associated to Recreational Aviation occurrences between 2018 and May 2024 were related to maintenance (Source: CADORS).

Maintenance release

No person shall conduct a takeoff in an aircraft, or permit a takeoff to be conducted in an aircraft that is in the legal custody and control of the person, where that aircraft has undergone maintenance, unless the maintenance has been certified by the signing of a maintenance release. (TC AIM-LRA 5.4.1, CAR 605.85)

This means that as an owner and pilot of an aircraft, you are responsible for ensuring that when work has been done on your aircraft, the proper maintenance release has been signed by someone who is qualified. Unless it is elementary work, which does not require a maintenance release by an AME, but pursuant to CAR 571.03, any elementary work performed on a certified aircraft must be detailed in the technical records and accompanied by the signature of the person who performed the work.

Owners should periodically review the maintenance schedule to ensure that it meets the requirements.

Maintenance schedules

CAR 605.86 prescribes, in part, that all Canadian aircraft except ultralight aeroplanes or hang gliders shall be maintained in accordance with a maintenance schedule that has been approved by the Minister and that conforms to CAR Standard 625.

Appendices B, C and D to CAR Standard 625 are applicable to the development of maintenance schedules. Owners of non-commercially operated small aircraft and balloons may choose to comply with Part I or II of Appendix B, as applicable, and Appendix C to CAR Standard 625. They need not submit any documents to the Minister for formal approval. The maintenance schedule is considered to be approved for their use by the Minister. Owners need only make an entry in the aircraft technical records indicating that the aircraft is maintained pursuant to the maintenance schedule. Owners should periodically review the maintenance schedule to ensure that it meets the requirements. (TC AIM-LRA 5.6.2 Maintenance Schedules)

CAR Standard 625—Appendix B is for maintenance schedules and is of particular interest for private aircraft owners. It lists inspection items to be included, a supplement to any guidance from your aircraft's Pilot Operating Handbook (POH) or aircraft flight manual (AFM) and the manufacturer.

Elementary work

What is considered elementary work? See CAR Standard 625, Appendix A here: Standard 625 Appendix A: Elementary Work—Canadian Aviation Regulations (CARs) (canada.ca)

Group aircraft ownership

When an aircraft is owned by multiple individuals, or a corporation with multiple directors, the same applies as to a single-owner aircraft. There are no specific regulations on who can perform elementary work on privately registered aircraft, only how the work shall be done and how to record it. The owner of the aircraft, however, is responsible for who may perform elementary work on their aircraft. They should also ensure that those persons are knowledgeable of the work being performed and that it is performed to the correct standard.

What are the technical records?

Technical records for an aircraft are comprehensive logs that include a journey log, records for the airframe, engine, and propeller, and an empty weight and balance report, ensuring compliance with maintenance standards (CAR 605.92).

There are significant differences from a certified to an owner-maintenance, amateur-build or ultralight aircraft. For example, when an aircraft is operated under a special certificate of airworthiness in the owner-maintenance or amateur-build classification, all entries in respect of the technical records may be kept in the journey log (CAR 605.92(3)).

Airworthiness Directives and Service Bulletins

TC endeavours to notify owners of Canadian registered aircraft of the issuance of any applicable Airworthiness Directives (ADs) or mandatory Service Bulletins (SBs). Aircraft owners are responsible for obtaining the relevant continuing airworthiness information applicable to the type and model of aircraft—including installed equipment, engine, propeller(s) (if any)—that they own. You may look them up here, if you own a certified aircraft (TC AIM-LRA 5.7.2).

ADs are issued by Transport Canada and are mandatory, whereas SBs are issued by manufacturers and are generally recommendations rather than requirements. In aviation, both ADs and SBs are important for maintaining the safety and reliability of aircraft, but they serve different purposes and come from different sources. Here’s a breakdown of each:

AD in Canada:

1. Issuing authority: In Canada, ADs are issued by Transport Canada, the Canadian aviation regulatory authority.

2. Purpose: Like in other jurisdictions, Canadian ADs are mandatory and address safety issues that need to be corrected to ensure the safety of aircraft, engines or components.

3. Content: Canadian ADs detail the problem, the required corrective actions and the compliance timeline. They are legally enforceable, and aircraft operators must comply to maintain airworthiness.

4. Enforcement: Transport Canada enforces compliance with ADs, and failure to comply can lead to penalties or grounding of the aircraft.

SB in Canada:

1. Issuing authority: SBs in Canada are issued by the aircraft or component manufacturer, just as in other countries.

2. Purpose: SBs are recommendations or suggestions for improvements, maintenance or repairs that are not mandated but are intended to enhance safety, performance or reliability.

3. Content: SBs from manufacturers provide guidance on actions such as inspections, modifications or other updates. They are generally recommended but not compulsory.

4. Enforcement: Compliance with SBs is usually voluntary in Canada, though operators may choose to follow them to prevent issues or improve performance.

Finding SBs typically involves accessing information directly from aircraft or component manufacturers or through various aviation resources. Here are some common ways to locate SBs:

1. Manufacturer's website:
   • - Aircraft manufacturers: Visit the official website of the aircraft manufacturer.
   • - Component manufacturers: If you're looking for SBs related to specific components (e.g., engines, avionics), check the manufacturer's website for those components.
2. Customer support portal:
   • - Many manufacturers offer customer support portals or online services where registered users can access technical documents, including SBs. You may need to log in with credentials or be an authorized customer to access certain documents.
3. Aviation maintenance and operations manuals:
   • - Some SBs are included in maintenance manuals or operational handbooks provided by manufacturers. These documents may be available through subscription services or on manufacturer websites.
4. Aviation regulatory authorities:
   • - While SBs themselves are not issued by regulatory authorities, they may be referenced or summarized in publications or databases managed by agencies like Transport Canada, the FAA or the European Union Aviation Safety Agency (EASA).
5. Third-party aviation information providers:
   • - Services like aviation software platforms (e.g., Jeppesen, Aviall or FlightSafety) may provide access to a wide range of technical documents, including SBs.
6. Aviation industry forums and networks:
   • - Sometimes, industry forums, professional networks or user groups may share or discuss SBs. However, for official and up-to-date information, always refer to the manufacturer's direct sources.
7. Contact the manufacturer directly:
   • - If you are having trouble finding a specific SB, contacting the manufacturer directly via email or phone can often provide you with the document or direct you to where it can be accessed.

By using these resources, you should be able to locate the relevant SBs for your aircraft or components.

You can also subscribe to e-news on the Transport Canada Web site to keep up to date on what’s new in transportation from the Government of Canada. You can choose the topics that are important to you. Visit e-news.

Clean aircraft concept

Part of the maintenance work is to clean the aircraft. Dirt might foul the controls but also hide defects that will not be visible with your regular pre-flight inspection. It also affects flying performance as it disturbs the flow of air in flight. Cleaning your aircraft regularly is part of a healthy maintenance schedule (CAR Standard 625, Appendix B, Part I).

Conclusion

Just as staying informed about your aircraft's performance, airspace changes and checking NOTAMs are essential, regular recurrent training is equally valuable. This same principle applies to maintaining your aircraft, ensuring countless safe and event-free hours in the air with friends and family.