Photo courtesy Zenair
|
|
Zenair aircraft kit designer
Chris Heintz (right) conducts a workshop on aircraft homebuilding. Soon
homebuilders will be able to include assistance in aircraft construction but
their kits will still have to meet the 51 per cent rule. Photo courtesy Zenair |
By Adam Hunt, COPA manager Membership Services and
Representation
Being active on the eight technical committees within the Canadian Aviation
Regulations Advisory Committee (CARAC) is one of the ways that COPA represents
its members to the government. CARAC is part of the process of formulation and
amendment of the CARs. February 20-21, 2002 saw meetings for the CARAC Part V
Maintenance and Manufacturing Technical Committee. COPA was the only
organization at these meetings representing recreational pilots of fixed wing
aircraft to address items on the agenda that affected light aircraft and
amateur-built aircraft. The Canadian Balloon Association was also present.
STC RECORDS
One of the most contentious issues dealt with “Instructions for Continued
Airworthiness” particularly as they apply to aircraft modified with
Supplementary Type Certificates. There have been some notable accidents due to
aircraft being modified with STCed mods and then the new STCed parts not being
inspected or maintained as needed.
Many STCs come with maintenance instructions (ICAs) and this issue dealt with
how to most effectively make sure that aircraft owners incorporate those ICAs
into their maintenance schedule and aircraft documentation. The proposed
amendment to CAR 605.92 will require aircraft owners to identify the existence
of ICA information in the aircraft Technical Record, so that AMEs working on the
aircraft will be aware of the modification and the maintenance requirements for
it.
The change to CAR 605.92 was passed as written by the committee, but there will
be dissents by some AME associations.
COPA supports the requirement that these ICAs be entered in the Technical Record
for the aircraft. They need to be recorded somewhere for each aircraft to ensure
safety and COPA opposes adding a new requirement for a third record for each
aircraft on top of the Journey Log and Technical Record already required. COPA
believes that each owner should ensure that they are then entered in the
aircraft’s maintenance schedule. Maintenance schedules do not follow the
aircraft once it is sold. They belong to the owner and may contain proprietary
information.
51 PER CENT checklist
Amateur-built aircraft rules came up for changes. These were mainly to
incorporate the old requirements of Airworthiness Manual Advisory 549.5 into the
CARs. The committee was asked to approve the incorporation of a checklist to
determine compliance with the “major portion” requirement (the 51 per cent rule)
into the new CAR Standard 507. When the other changes in the works for the
amateur-built regulations allow professional assistance, a kit will still need
to
meet the 51 per cent rule. A builder’s 51 per cent checklist will be required.
The Technical Committee approved the amendment as it was proposed, without
changes, a position supported by COPA.
Elementary tasks by owners
Changes were also proposed to CAR 625 Appendix A in the area of what is
considered as “Elementary Work” on all certified aircraft. This is the rule that
allows aircraft owners and pilots to carry out tasks, such as inflating tires,
replacing spark plugs and changing oil on small private airplanes. The new list
of acceptable tasks actually combines several previous lists into one and
expands the privileges that owners and pilots have in carrying out elementary
work. COPA is in favour of this and supported the proposal.
AME Hours of Work
The Technical Committee was presented with a study on AME hours of work that was
prepared by an outside consulting company. The study was designed to find out if
there is a problem with fatigue levels among AMEs. Some of the findings were
rather surprising – it highlighted that a significant number of AMEs report
working regular shifts of more than 25 hours! The report highlighted the need to
examine whether there needs to be regulation within the aircraft maintenance
industry for AMEs and other maintenance workers. After much debate, the
committee decided that the full technical committee, rather than a working
group, would consider the issue at a series of meetings later on this year. This
process will result in recommendations to Transport Canada before year-end. COPA
will participate in this debate to ensure that the best interests of private
aircraft owners are represented.
Parts distribution
The committee also received the final report of the Working Group on
Distributors of Aeronautical Products. Canada has a unique system in the world
whereby the distributors certify the aircraft parts received individually or in
batches and retain the manufacturer’s certification paperwork. This system has
been in use in Canada for many years and has generally worked well. The Working
Group considered whether changes were needed to accommodate the new realities of
global trade and large aircraft mobility between operators internationally. The
Working Group recommended that the current system be retained in their report
and the Technical Committee accepted the report as it was written.
COPA represented to the committee that the current system works well for private
airplane owners in Canada. This system, whereby the distributor certifies the
product, saves time and keeps costs down for private owners without compromising
safety.