Many aircraft owners are keen to learn more about being a pilot beyond the basics of ground school. The opportunities for new ratings, aircraft upgrades and places to go are often the focus of excitement and adventure. Then there is the responsibility of maintaining an aircraft with much of the focus on “passing” the annual inspection. The strict requirements and attention to detail demonstrated by the signing AME usually represents the most costly part of ownership. While the AME is your primary resource on the technical and regulatory status of the aircraft, the reasons for having to do certain items is not always clear. Sometimes the recommendations by the AME are just accepted whereas other times they are challenged (mainly due to cost). As an AME, I want to encourage you to learn more about the airworthiness requirements of your aircraft as they are your responsibility as the aircraft owner (ref. CAR 605.86).
The Certificate of Airworthiness
Each new aircraft is manufactured according to a type design that meets the airworthiness design standards. Upon completion and final inspection, it is then issued a Certificate of Airworthiness (C of A) which remains with the aircraft throughout its time in service. The actual certificate must be kept on board the aircraft although it never needs to be replaced as long as the aircraft continues to be maintained and operated according to airworthiness requirements.
The C of A is a type of flight authority with the expectation that the aircraft will continue to be operated in an airworthy condition. Operating an aircraft that is known to not be airworthy requires another type of flight authority called a flight permit. The C of A document remains in force on an aircraft until something happens that compromises its airworthiness. This could be the findings from an annual inspection, a known defect, outstanding AD, unapproved method of repair, out-of-phase compliance time exceeded, or operating outside the limitations set out in the POH. In each of these cases the C of A is considered to be temporarily invalid until corrected and released by an AME.
Serviceable, Unserviceable and Airworthy
These terms are frequently used to describe the condition of the aircraft or one of its components. The term serviceable describes an aircraft, part or component as being in a fit and safe condition for flight meaning that it has been maintained to acceptable limits. When something is considered to be serviceable it can be counted upon to function as intended.
The term unserviceable describes any aircraft, part or component that does not meet the criteria for being fit or safe. The item must either be replaced with a serviceable item or be repaired according to the accepted standards of airworthiness.
Now, Airworthy describes an aircraft, part or component that is not only serviceable but also conforms to its type design. This means that you cannot just make it work any way you decide. The rectification must reflect a specific standard set out by the manufacturer or a regulation.
Besides the C of A, the aircraft document package must also include the Certificate of Registration (C of R) which is issued to the owner/ operator of the aircraft. The Pilot’s Operating Handbook (POH) contains the “instructions” for operating a specific model of aircraft. It must also contain the updated Weight & Balance information including equipment list and amendments. Modifications to the aircraft by STC may require a POH supplement to be added describing the new system and any effect it may have on operation.
The Annual Airworthiness Information Report (AAIR) is sent to registered owners/ operators annually. The reporting form is for statistical purposes and requests information about the aircraft as well as hours flown. While the report does not affect airworthiness and does not need to be carried on board, the duty of returning the completed report back to Transport Canada may be subject to a fine if not sent.
The Owner and the AME
Aircraft owners who do not take responsibility for the airworthiness of their aircraft are often at the mercy of the AME and his practices (for better or for worse). With some exceptions, it has been the norm for most owners to bring the aircraft in for the annual (or repair) and leave everything up to the AME as long as everything works the way it should when it’s done. There is a high level of trust by assuming that the AME is familiar with all of the necessary requirements for your aircraft. Trust your instincts to find a shop or AME that you feel comfortable with.
If you simply prefer to not get involved in the tracking of these requirements but trust the AME that your aircraft will continue to be maintained as airworthy then this intention must be made clear. When nothing is said, Many AME’s will still assume the role of technical and regulatory advisor (as they have for years) with the only difference being that it is not their responsibility to see that all required items are completed unless asked to do so. The AME however, is always bound to Part V of the CARs concerning the performance of all maintenance work. The time taken to research ADs and Bulletins has long been a gray area with the AME, who will often notify the owner of any applicable items that he may have come across or researched. This task really ought to be requested by the owner while expecting to pay the AME for any time spent on even the research of these documents. Most AMEs will undoubtedly still make the owner aware of any technical or regulatory concerns that may be new or previously overlooked simply because they are used to traditionally taking the lead in this area.
Certification of work completed
Any work carried out on the aircraft that is considered maintenance work, must be released by an appropriately rated AME. Other forms of work (not covered at this time) include elementary work and servicing which may be completed by unlicensed but trained personnel. Scheduled work is done according to a maintenance schedule for the aircraft. The aircraft records must identify the type of schedule as being from the manufacturer or from CAR Standard 625.
The old system used to expect an AME performing a repair to sign for and release the entire aircraft back into service. Due to the concern for other work completed on the aircraft, the improved format required the AME to only sign for the work that he/she did. This makes the AME accountable only for the performance of his/her own work. The AME can also be responsible for the entire aircraft when signing out an annual or 100 hour inspection according to the scope of that inspection. This is the same way things are done today under the authority of the CARs. Performing an annual requires that the inspecting AME compile a list of findings from the inspection and to address the severity of each with the owner. Only the owner can ultimately decide what work is to be completed on his/her aircraft. The AME’s job is to perform work only as directed by the owner. Any outstanding findings known to affect the airworthiness of the aircraft are also entered into the technical records thus putting the onus of non-conformance back on the owner. This action in itself may cause the owner to reconsider getting the required work done.
Won’t get fooled again
It is in the owner’s best interest to learn enough about the airworthiness of their aircraft that they can ask the right questions when talking to an AME or shop about doing work for them.
Shops that do not concern themselves with regulations specific to the performance of maintenance or do not involve the owner in the maintenance process are doing a disservice to themselves and their customer. Any AME should be able to answer most regulatory concerns presented by the customer for his/her aircraft.
An aircraft that has been found to not be airworthy after an accident or incident may also raise concerns with the insurance company and Transport Canada.
Shops that operate as an AMO usually maintain both private and commercially operated aircraft. Using an AMO is one of the requirements for commercial aircraft because these shops are recognized by Transport Canada as having met specific quality guidelines. Any other shop or AME are not subject to this regulatory oversight yet are still bound by the regulations to perform maintenance according to the same performance standards.
While aircraft ownership affords the owner to call the shots, the responsibility for maintaining an airworthy aircraft remains paramount.