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Annual inspection requirements

Many aircraft owners are well aware that they are required to have an annual inspection carried out on their aircraft. The expectation is that the owner will establish a relationship with a shop or a particular AME (Aircraft Maintenance Engineer) and basically hand over the aircraft for its annual check up. This is often where the responsibility supposedly ends for the owner until its time to get out their cheque book at the end of the inspection process.

The CARs (Canadian Aviation Regulations) actually make it clear that the aircraft owner has more responsibilities than just leaving things in the care of the all knowing AME. Many aircraft owners need to be reminded of the pertinent regulations that clearly put the onus on them when considering the state of airworthiness for their aircraft. Even the requirement to have the annual done within 12 months is to be monitored by the owner unless previous arrangements have been made clear with the shop performing the work.

The AME should be able to inform the owner of applicable SBs (Service Bulletins), ADs (Airworthiness Directives) and various out-of-phase items that apply to their aircraft at the annual inspection. The responsibility for these items however does not rest with the AME but with the owner. The owner must also establish a maintenance schedule applicable to the aircraft which forms the basis for how the aircraft is to be maintained. All of these areas can be addressed in consultation with their shop AME in order to ensure that the aircraft will continue to meet the regulations once the annual has been completed. CAR Standard 625 Appendix B outlines the basis of maintenance schedule requirements for small aircraft. The result is usually a one-time statement in the journey log regarding the type of schedule to be followed. This is also described in further detail below.

Maintenance personnel are usually willing to provide the above information concerning airworthiness to the owner, however it is not their responsibility should something be missed. This is why it is necessary for the owner to understand his/ her obligation to the airworthiness process and knowingly hire the AME to perform this research over and above doing the annual inspection. The expectation must be clear so that either way, someone is tasked with this research before the work is completed. It has long been assumed that the AME is expected to just take care of all these details, but the current regulations indicate otherwise.

In reality, Owners doput their trust in the ability of the AME to perform his duties in accordance with the Maintenance Manual and other ICAs (Instructions for Continued Airworthiness) pertaining to the aircraft. This is what AMEs are trained for however, they are not responsible for tracking inspections, SB or AD compliance, out-of-phase items or any airworthiness limitations unless formally requested to do so on behalf of the aircraft owner. All of these areas are addressed in Part V and VI of the CARs. At the end of the day, it might make more sense for the AME to do this research using his resources but the time spent doing this is not necessarily a freebee. Many in the general aviation sector still adhere to outdated expectations that are not consistent with the current requirements. Let me make it clear that aviation safety is less concerned with tradition and more dependent upon continuous improvement.

Every aircraft must be maintained to an appropriate maintenance schedule whether they are privately or commercially operated. The type and scope of the maintenance schedule is determined by the aircraft model as checked against the content of CAR Standard 625 Appendix B and C. The maintenance schedule is like a timetable used to track when scheduled events like inspections or certification of altimetry devices will be required on the aircraft. Many private aircraft schedules are based on reference to a generic check list in Appendix B and a common list of out-of-phase tasks in Appendix C. These out-of-phase tasks common to all aircraft include (but are not limited to) a compass calibration, ELT certification, testing of altimetry devices and propeller overhaul limits. These are considered as some of the primary regulatory requirements for items affecting aircraft airworthiness. Other requirements are found in the manufacturer’s publications.

The persistent myth of maintaining an aircraft to either private or commercial standards is not exactly accurate. All aircraft are subject to any and all regulations pertaining to that aircraft type. The only difference may be that commercial operators are bound to the specific content of their approved maintenance schedule relevant to the nature of their operation. They are also regularly audited to ensure continued compliance with the conditions of their operating certificate. Private aircraft are bound to many of the same regulations but are not normally audited as part of a mandated quality process.

The documentation required for the implementation of a maintenance schedule consists of a simple entry in the journey log stating the type of schedule used such as “This aircraft is being maintained in accordance with CAR Standard 625 Appendix B Part I and Appendix C as applicable”. Both private and commercially operated aircraft should display this type of statement in the front of the journey log.

The Annual inspection is considered the minimum requirement for private aircraft and entails opening up the aircraft panels and covers to inspect the items contained on the applicable check list. Servicing of the aircraft is also done at this time in the form of lubrication points, adjusting tire pressures, or checking fluid levels. As each area of the aircraft is inspected according to the check sheets, any additional work (aka snags or defects) should be noted for assessment before subsequent rectification or deferral. Other check list items include the need to check cable tensions, inspect for structural integrity, clean spark plugs and perform a differential compression test on the cylinders. These are all key functions in determining the health of the airframe and engine. As long as the required maintenance is completed within the established time frames (by hours flown or calendar time) then the aircraft C of A (Certificate of Airworthiness) remains in force.

Maintenance people also have regulatory responsibilities when performing the type of work that is required to complete the annual inspection properly. The depth of inspection will be first based upon the requirements of the aircraft manufacturer then upon the knowledge and ability of the maintainer to perform that work using the proper tools, test equipment and procedures. A prime consideration when selecting a shop or AME is dependent upon whether the maintainer has a good reputation in customer relations and familiarity with your type of aircraft. Ineffective communication will surely lead to somebody dropping the ball, so to speak, over a required item. This can certainly lead to frustration and mistrust. A healthy respect within the owner - maintainer relationship tends to also generate a mutual trust built over time. While there is no harm in the maintainer exploring new aircraft types to maintain, make sure that you have a good feeling that your AME is the type to seek the necessary technical information when it is beyond arms reach. Reputable shops will usually have what they need or have prompt access to it, since this is also a regulatory requirement.

Another great debate is fueled over the decision to entrust your aircraft with an individual freelanceAME, smaller one man shop or a larger AMO (Approved Maintenance Organization). There are pros and cons of each just as there are exceptions to the rule when coffee shop banter can easily incite suspicion within these three choices in some way or another. Some aircraft owners that you meet may raise suspicions about price or quality based on one or two rumored experiences. I encourage you to check out any possibilities based upon your own preferences (along with your circle of influence) to make an educated decision that is best for you. Regardless of what needs done, as the aircraft owner, you are also the customer who is spending your money the way you see fit. Just remember that the only responsible outcome should always be an airworthy aircraft. In most cases, you get what you pay for!

There are also three significant considerations when determining how your money is to be spent on your aircraft. First of all, the aircraft owner has committed to a significant investment into their passion to fly. Ownership provides that unique opportunity to boast about and care for a flying machine that will carry you to the next fly out breakfast or planned getaway. Secondly is the governing Regulations which provide the airworthiness parameters to be followed in the interest of safety. Thirdly is the AME who stands in the middle of the two attempting to make the best informed compromise between treating the customer fairly and ensuring that his own regulatory responsibilities are also met when he signs the maintenance release attesting to the work completed. It can often be a delicate balance between cheque book, compliance and signature. Even interpretation of the rules may lead to relevant questions depending on who offers their opinion. Sorting it all out may not be an easy task but the regulations are always available in black and white whereas most opinions are based on some grey area. It’s important to work with the facts of compliance before considering convenience as an easy out.

It is also of some concern that many of the airworthiness requirements for small aircraft are taken too lightly. The regulations exist based on careful review and input from industry partners through the CARAC process (Canadian Aviation Regulatory Advisory Committee) or from other worthy Associations such as COPA (Canadian Owners and Pilots Association). Unfortunately, it seems that money speaks louder than rule books for certain people because after all, this aviation thing is merely a hobby for some of us. The reality check here is that the weekend flier as well as the charter company with a busy schedule both have ethical and safety obligations towards themselves and that of the general public. A certain lack of respect for the rules may be due to casual ignorance or may even be spiteful in the name of sticking it to the man. Either way, our respect of the regulations needs to remain intact as we sort through some of our collective issues concerning the cost of flying. We have all had selective frustrations with having to comply with (what seem like) unrealistic conditions or having to account for a bunch of unlikely “what if” scenarios in an effort to cover all the bases. We have also learned some things the hard way and learned that the best thing to do is also the right thing to do.

The only way to really maintain due diligence is through education and compliance. Get informed and look for alternative means of ownership if the financial burden of maintenance is beyond what you are willing to invest. Seek out some new perspectives on the responsibility of aircraft ownership and strive to raise awareness among your peers. This all gets back to putting safety first and if a hundred dollar hamburger makes sense to you then so should a properly maintained aircraft to get you there.

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