Aviation Safety Letter 1/2003
COPA Corner - Who Needs a Maintenance Schedule?
by Adam Hunt, Canadian Owners and Pilots Association (COPA)
If you own any type of aircraft then the answer is - you do! A maintenance schedule is the way you keep track of the work that needs to be done on your aircraft. In fact, unless you own a basic ultralight, advanced ultralight, paraglider or a hang glider, then the law requires you to have a maintenance schedule.
Looking at the rules
When the CARs were introduced in 1996, they included a new requirement for all aircraft to have a maintenance schedule, except hang gliders and ultralights. CAR 605.86 spells it out clearly - a maintenance schedule is required for all certified and amateur-built aircraft, including airplanes, balloons, helicopters, gliders, airships and gyrocopters. The accompanying CAR Standard 625 tells you how to accomplish that. That Standard even contains a Transport Canada pre-approved maintenance schedule that private aircraft owners can use. It is all in CAR 625: "Owners of non-commercially operated small aircraft and balloons who choose to comply with Parts I or II of Appendix B as applicable, and Appendix C, need not submit any documents to the Minister for formal approval. Owners need only to make an entry in the aircraft technical records that the aircraft is maintained pursuant to the maintenance schedule."
Well, reading that, it looks like all you have to do is make a logbook entry specifying that you will use CAR 625 Appendix B and C and you can forget about maintenance schedules for as long as you own the airplane, right?
What do the aircraft maintenance engineers (AMEs) say? Making a logbook entry does not necessarily make an airplane legal to fly, as it does not give assurance that maintenance was performed as per the requirements. Just making that required logbook entry won't tell your AME when that fire extinguisher in the plane needs replacing or whether there are any outstanding airworthiness directives (AD) the maintenance and/or replacement due date of all time-limited components. CAR 625 Appendix B and C are a great place to start in making up a functional schedule, as they list all the items that need to be covered in the annual inspection (Appendix B) and those items which are "out of phase" with the annual inspection (Appendix C).
What items need to be included? The approach many owners take is to have columns for the item to be completed, the date or airframe hours last done, the periodicity or time between inspection or replacement and the date or hours next due. Some items will specify a date when they are due and others will be an airframe or engine time. Some specify both a calendar date and airframe hours, so your system will need some flexibility.
What things should be on the maintenance schedule? One of the items that should definitely be on your maintenance schedule is the date of your annual inspection. This is specified in CAR 625 as being not more than 12 months following the date of the last annual inspection. That means if the last one was May 1, 2002, your next one will have to be signed off no later than May 1, 2003, if you want to fly on May 2.
Oil changes at 25- or 50-hour intervals, as applicable, are good to include, as are any recurring ADs or Service Bulletins that have calendar times or airframe hours, or both, when they have to be completed. A good example is the well-known Canadian AD CF 90-03R2 that requires an inspection of the aircraft muffler on all Canadian aircraft that have heaters which use muffler heat to operate. This AD requires an inspection every 150 hr or annually, whichever comes first. You will need to use a system to track both the calendar and airframe hour limits on those types of inspections. One way to do that is to use two lines on your table.
Another area to think about is supplement type certificate (STC). Do any of the modifications with STCs on your aircraft have special inspections or maintenance action required? These STCs "Instructions for Continued Airworthiness" (ICA) are important to keep your plane airworthy and will soon be required to be entered in your technical record, through an upcoming CAR amendment.
The rest of the items will come from a quick read through CAR 625 Appendix C -- the "out of phase items" list. Do you have a fixed pitch propeller? They need to be removed and inspected every five years. Variable pitch props are generally required to be sent for overhaul every ten years. Once you have thought about the annual inspection date, recurring ADs and Service Bulletins, STC ICA and CAR 625 Appendix C "out of phase items," you will probably have a complete maintenance schedule. A complete maintenance schedule will keep your plane well maintained and give you and your AME confidence that everything is taken care of! For more information on COPA, have a look at http://www.copanational.org/.
- Date modified: