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5. Special Inspections to Assess Air Operators' Degree of Compliance with the Canadian Aviation Regulations

Special Inspections to Assess Air Operators' Degree of Compliance with the Canadian Aviation Regulations

Directive No. 23
Revision 1

Revision objective:

To clarify the role of Regional Managers, Maintenance and Manufacturing with respect to Special CARs compliance inspections.

Since promulgation of the Canadian Aviation Regulations (CARs) on October 10, 1996, most of our energies have been devoted to re-certifying all Canadian air operators to CARs standards, and to correcting deficiencies revealed in the original CARs through the issuance of exemptions and development of Notices of Proposed Amendments to bring about amendments to the CARs. This has been a tremendous task, of which we can be justifiably proud; however, in order to accomplish it, we have had to defer some activities, the most significant of which is audits.

All Regions are planning to resume audits during this and the upcoming fiscal year. Notwithstanding, for reasons explained below, we see the need for an additional focused inspection program to assess the level of compliance with CARs requirements of all air operators.

As you are well aware, the CARs contain many provisions that did not exist under the regime of the Air Regulations and Air Navigation Orders. In Part VII these include enhanced requirements for training programs, expanded use of Standard Operating Procedures and Minimum Equipment Lists, aircraft performance operating limitations, and new training/checking requirements such as introduction of the Pilot Competency Check in CARs 702 and 703, and Line Indoctrination in CAR 704. While the regulatory changes impacting upon air operator maintenance departments are not as extensive, they too are subject to some new requirements.

We have evidence that, while all approved documents reflect CARs requirements, operators may not have fully understood the implications and implemented all of them. I believe it is essential that we confirm this on a national basis as soon as possible. We cannot wait until completion of a full audit cycle to determine if air operators are or are not in full compliance with the CARs.

Accordingly, at NCAMX we agreed that Regional Managers, Commercial & Business Aviation would develop plans to conduct special CARs compliance inspections of all air operators operating pursuant to CARs 703, 704, and 705, and private operators operating pursuant to CAR 604, while Maintenance and Manufacturing would conduct special CARs compliance inspections on air operators operating pursuant to CARs 703. The inspections should take place in conjunction with annual visits to operators, and sample certain high risk areas of the operation, utilizing selected Maintenance and Operations checklists from the Manual of Regulatory Audits, as listed below.

Where these checklists have been modified for purposes of this inspection, a copy of the amended checklist is attached with this directive. When large numbers of records are involved, inspectors will make use of random sampling techniques.

Inspection Priorities for Commercial & Business Aviation:

Operations subject to oversight from Commercial & Business Aviation will be inspected according to the following priorities: Priority 1 — CAR 703, Priority 2 — CAR 704, Priority 3 — CAR 604, and Priority 4 — CAR 705. CAR 705 operations are accorded lower priority because they have more infrastructure to begin with, and are generally subject to a higher level of surveillance. It is understood that implementation of these inspections will have an impact on a Region’s capability to achieve the inspections and audits called for by the Frequency of Inspection Policy.

Maintenance Checklists:

3.4	Pre-Audit Activities
3.5.1	Maintenance Procedures Manual/Maintenance Control Manual
3.5.3	Personnel
3.5.9	Defect Control (Deferral)
3.5.12	Sample Aircraft for Conformance
3.5.14	Company Quality Audits
3.5.21	Control of Parts/Material
3.5.23	Maintenance Contracts
3.5.24	Airworthiness Directives

Operations Checklists:

OP-7	Flight Crew Training Program
OP-8	Flight Crew Training Records
OP-9	Operational Control System
OP-10	Flight Documentation
OP-14	Cabin Safety (as applicable to operation)
OP-15	Flight Attendant Training Program (as applicable)
OP-16	Flight Attendant Training Records (as applicable)

Implementation Plans and Reporting:

Regions will prepare a CARs Compliance Inspection Plan for the period January 1, 1999, to December 31, 1999, and submit their plans to the appropriate functional director, Maintenance and Manufacturing or Commercial and Business Aviation, by December 18, 1998. In addition, Regions will report quarterly to DGCA on the progress of their plans, and the results of inspections completed to date. Depending on the results obtained, the focus and scope of the inspections may be changed. While it may not be possible that all operators can be inspected within this time frame, I ask Regions to inspect as representative a sample as possible.

Art LaFlamme
Director General
Civil Aviation

Revision date: July 1999
Expiry date: October 1, 2003

Date modified:

2010-06-22

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