March 9-10, 2004 marked the first meeting of the
Canadian Aviation Regulations Advisory Committee’s (CARAC) Part V Maintenance
and Manufacturing Technical Committee for 2004. As is usually the case, COPA’s
delegate to this committee, Adam Hunt, was the only representative present from
any of the organizations that claim to represent recreational aviation in
Canada.
The first day of the meeting was taken up in discussions on Notices of Proposed
Amendment (NPAs) regarding AME Fatigue and the proposal to introduce a
requirement for Approved Maintenance Organizations to have a Fatigue Risk
Management plan in place.
COPA is monitoring this issue to make sure that it doesn’t result in further
costs to AMOs which in turn would result in higher costs for maintenance to
privately owned aircraft. The NPAs proposed were sent back to Transport Canada
for some further work before proceeding further.
Much of the second day was taken up with review of first drafts of what will
become NPAs introducing Safety Management System (SMS) requirements into the
maintenance and manufacturing world. All operating certificate holders in
aviation will be required to have an SMS in place in the near future.
Maintenance and manufacturing organizations were the first to be subject to SMS
under the CARs, but it was done under the banner of “Quality Assurance.”
Because the rest of the aviation certificate holders are going to be working
under SMS, Part V has to adjust its rules to make them fit closer to the SMS
model.
TC received extensive input from the members of the Part V Technical Committee
and will be writing NPAs based on these consultations, for presentation later on
this year.
The changes made to the O-M Category of aircraft were discussed near the end of
the second day of meetings. Since the inception of the O-M Category in the CARs,
putting a new aircraft on the list has required an amendment to CAR Standard 507
Appendix H, which contains the list of eligible aircraft. This involved TC
assessing an application to add an aircraft to ensure that it qualifies and then
presenting an NPA to the CARAC Part V Technical Committee to approve the
amendment. This meant that the process of adding a new aircraft to the list
could take up to a year. COPA has been working with TC to find a simpler and
faster way of doing it. To streamline the process TC had proposed in 2002 to
remove the list from CAR Standard 507 Appendix H and put it into an
Airworthiness Notice. At this CARAC meeting, TC proposed withdrawing the NPA and
instead administratively amend the CAR Standard to add the new aircraft.
This means that new aircraft can be added to the list at the completion of the
TC internal assessment process, without bringing the matter to the Part V
Technical Committee and without mailing out an Airworthiness Notice.
COPA supported this move as it will greatly speed up the addition of new
aircraft to the O-M list and help keep older aircraft flying!
COPA participates in all nine CARAC Technical Committees to represent COPA
members to Transport Canada in the CAR rulemaking process. COPA is the only
association that represents non-commercial aircraft owners and pilots that
participates on all CARAC Technical Committees, ensuring that COPA members’
interests are heard in Ottawa.