What to know about installing parts

By Adam Hunt

Installing parts on your plane is a subject that confuses many of people.

What parts are you allowed to install and what paperwork is required for which parts?

As usual the answer varies a lot depending on the category of aircraft you own.

Let’s start with the easy categories.

In the case of basic ultralights the answer is easy – you can install any parts from any source, aeronautical or otherwise. There is no standard, which is why you can’t carry passengers in BULAs!

There is no requirement to document, certify or sign for parts installed on a BULA either, although keeping a record of parts installed is certainly recommended.

In the case of advanced ultralights (AULA) you are permitted to only install parts that are approved by the manufacturer, as explained in the TC Ultra-Light Transition Strategy. Non-manufacturer approved parts would be a modification and would thus require manufacturer approval! While AULAs are not required to have logbooks, maintenance records are required and so a record of the installation of all parts, new or used is required.

Amateur-built and owner-maintenance aircraft are authorized in CAR 571.07 to have non-certified parts installed. In the case of those categories of aircraft, it is recommended that aviation quality parts be installed, but it is not required. The decision is left to the owner as to the choice of parts.

No certification document is required for new parts installed on these aircraft. A used part that has undergone maintenance will need a document releasing that work. The release can, of course, be signed by the owner of the aircraft.

It is in the case of certified aircraft the situation gets complex, of course! The rules are contained in CAR 571.07 for new parts and CAR 571.08 for used parts.

Let’s look at each class of parts in turn.

1. A new part manufactured in Canada by the holder of the type certificate (TC) or a Supplemental Type Certificate (STC) can be installed, but requires a certification tag under Airworthiness Manual Chapter 561.

2. A new part manufactured by the holder of the TC or an STC in a country with which Canada has a bilateral agreement to accept their export certification can be installed without a certification tag as long as you have the export paperwork.

Transport Canada no longer requires specific "export documents" for anything other than complete aircraft and this CAR is likely to be amended soon. In the meantime, CAR 571.07(2)(b) will also apply to these parts. That section reads:

"...a foreign-manufactured part that is obtained from a manufacturer holding a type design recognized in Canada and the part is certified in accordance with the laws of the state of manufacture." 

In the case of parts originating in the United States, Transport Canada has said that they interpret 571.07(2)(b) to include new parts received with any documentation (not necessarily a formal release) issued by the appropriate manufacturer, indicating that the part came from them. That could include invoices, packing slips, etc.

This puts our access to US parts on the same footing as US users, and ensures Canadians do not suffer financial disadvantage by requiring additional paperwork.

3. A standard part can be installed without a certification tag as long as it is specified in the type design. A standard part is one that is produced to an aviation industry accepted standard, such as AN bolts, Mil-Spec wiring etc.

4. A commercial part can be installed without a certification tag as long as it is specified in the type design. Commercial parts are non-aeronautical parts that an aircraft TC or STC holder specifies as being part of the aircraft type design, such as a commercial automobile-type door seal, for instance.

5. An FAA approved “Parts Manufacturing Authority” new part (PMA) can be installed without a certification tag provided it is specified in the aircraft type design. For more information on acceptance of PMA parts see CAR Standard 571.07

6.  A part that is made under CAR 571.06(4) must be installed without a certification tag, as long as it complies with the specification of the original type certification documents. Airworthiness Manual 571.06 provides additional information on these parts.

7. Used parts can be installed provided that it is an airworthy part that has been removed from an aircraft for immediate installation on another aircraft, or it is an airworthy part that has undergone maintenance for which a maintenance release has been signed as required by CAR 571.11(2)(c), or the part has been inspected and tested to ensure that the part conforms to its type design, is in a safe condition and a maintenance release has been signed to that effect.

Making sure that the parts you install on your plane are “legal parts” and are properly documented can be confusing. If in doubt check the CARs.