Maintenance and Certification
- Issue 1/2013
- Copyright and Credits
- Guest Editorial
- To The Letter
- Flight Operations
- Maintenance and Certification
- Recently Released TSB Reports
- Accident Synopses
- The Civil Aviation Medical Examiner and You
- Take Five: Flying near Power Lines
- Know Where to Hold Short (poster)
- Full HTML Version
- PDF Version
- Canadian Approved Maintenance Organizations (AMO) and Maintenance on United States (U.S.) Registered Aircraft
- Aircraft Fuel System: Water Contamination of Fuel Tank Systems
Canadian Approved Maintenance Organizations (AMO) and Maintenance on United States (U.S.) Registered Aircraft
Dean Barrett, Civil Aviation Safety Inspector, Operational Airworthiness, Standards Branch, Civil Aviation
Did you know that Canadian AMOs can perform maintenance on U.S. registered aircraft?
Canadian AMOs can also perform maintenance on components meant for installation on U.S. registered aircraft.
Canada and the U.S. entered into a safety agreement entitled The Agreement for the Promotion of Aviation Safety dated June 12, 2000. This led to the creation of guidance material to help organizations in implementing the maintenance and alteration or modification provisions of the Agreement. These new procedures are entitled The Maintenance Implementation Procedures (MIP) and were signed on March 14, 2011.
The objective of the MIP is to assist in the understanding of the requirements and conditions that need to be met for U.S. repair stations and Canadian AMOs along with Federal Aviation Administration (FAA) certificated mechanics and Canadian Aircraft Maintenance Engineers (AME).
What does this mean for Canadian AMOs?
Canadian AMOs can use these implementation procedures to their advantage to perform maintenance on U.S. registered aircraft and components for installation thereon.
There is some leg work that has to be accomplished before AMOs or AMEs can perform maintenance on U.S. registered aircraft, however this can be accomplished in a relatively short time frame should all the conditions be met.
An AMO or AME that has been approved or rated for maintenance and modification work by Transport Canada Civil Aviation (TCCA) in the form of a certificate or license, and complies with the special conditions of the MIP, will be eligible to perform maintenance, preventive maintenance, and alteration work on aeronautical products under the regulatory authority of the FAA (with the exception of annual inspections).
Some of the most notable, but not all, conditions an AMO or AME must address before they are able to take advantage of the MIP are the following:
An AMO must establish procedures to ensure they are able to comply with FAA requirements. This is usually a supplement to the Maintenance Policy Manual (MPM). This supplement must be submitted to your local Transport Canada Centre (TCC) or the TCCA regional office for approval (Note: An FAA supplement is only required when an AMO is performing maintenance on a Part 121/135 U.S. registered aircraft. No supplement or additional requirements are necessary for parts or private aircraft.);
The AMO or AME must hold a valid AMO certificate or AME license issued by TCCA;
The person responsible for supervision or final inspection and approval for return to service of a civil aeronautical product must be able to read, write, and understand English;
All repairs and alterations as defined by FAA regulations must be accomplished in accordance with data approved by or acceptable to the FAA;
In the case of work performed by an AMO, the work will not exceed the scope of the ratings and limitations contained in their AMO certificate and MPM;
- In the case of work performed and certified by an AME, the work will not exceed the AME’s privileges pertaining to their AME license. <
To assist in the clarification of the MIP below, we have highlighted some of the more frequently asked questions:
Can an appropriately rated Canadian AMO located in Canada perform maintenance on a U.S. registered aircraft located in the U.S.?
The answer to this question is NO. The reference can be found in section 2.0 of the MIP. It stipulates:
An AMO or AME can only perform maintenance and alterations on FAA-controlled aeronautical products and return said product to service when the product is located in Canada.
Who can perform maintenance on a privately operated U.S. registered aircraft located in Canada?
The answer can be found in section 2.0 of the MIP. It stipulates:
A Canadian AMO or AME can perform maintenance on a privately operated U.S. registered aircraft located in Canada and return it to service.
Can a Canadian AME perform and sign off on an Annual Inspection on a U.S. registered aircraft?
The answer to this question is NO. The reference can be found in section 3.5.1. of the MIP. It stipulates:
A Canadian AME cannot perform annual inspections on aeronautical products under the regulatory control of the FAA.
What is the required content of a Canadian supplement?
The content that is required in a Canadian supplement varies depending on the type of operation involved and how your AMO intends on utilizing the MIP. It can be found in, but is not limited to, Chapter 3 of the MIP. Consultation with your local TCC or TCCA regional office is recommended.
Can an FAA-approved repair station located outside the continental U.S. perform maintenance on a Canadian registered aircraft?
The answer to this question is NO, the reference can be found in two parts, first in section 1.7 and second in section 2.0:
An FAA-certified repair station or FAA-certificated mechanic can only perform work on Canadian aeronautical products when the product is located in the U.S.
The geographical definition of the U.S. is found in section 1.7 of the MIP. It stipulates:
United States. In a geographical sense, (1) the States, the District of Columbia, Puerto Rico, and the possessions including the territorial waters, and (2) the airspace of those areas.
TCCA recommends that persons or organizations that intend on or currently maintain U.S. registered aircraft and components for installation thereon become familiar with the Agreement and the associated “NEW” MIP.
Canadian AMO are encouraged to contact their local TCC or TCCA regional office regarding the procedures and requirements of the MIP should they be looking to perform maintenance on U.S. registered aircraft or components meant for installation thereon.
The MIP can found at the following web address:
The following is based on FAA Special Airworthiness Information Bulletin CE-12-06, and is reproduced in the ASL for the benefit of our stakeholders. These are recommendations only and are therefore not mandatory.
This Special Airworthiness Information Bulletin (SAIB) is to inform pilots, owners, operators, and maintenance and service personnel of general aviation aircraft of the hazards associated with water contamination of fuel tank systems. The fuel tank system consists of all tanks, components, lines, fittings, etc., from the fuel tank to the engine.
This SAIB is similar to SAIB CE-10-40R1, dated July 30, 2010, which addresses specific Cessna aircraft models, and is meant to cover general aviation aircraft not included in SAIB CE-10-40R1.
Water may enter the fuel tank system via any penetration in the wing fuel tank and from moisture condensation inside the tank. Water in the fuel may come out of solution, settle and make its way to a drain location in the form of a blob, pea, or BB-shaped translucent mass found at the bottom of the sampler cup.
Water suspended in the fuel may lead to a cloudy or hazy appearance in the sampler cup. Water may have dissolved in the fuel, but the conditions have not yet occurred to cause the water to come out of solution and perhaps adhere to the dry tank upper surface or walls (similar to condensation). Understanding this, all pilots, owners, operators, maintenance, and service personnel should assume some water exists in the fuel tank system on the airplane.
We recommend you do the following:
Become familiar with all drain locations on a specific model of airplane. From model to model in a series of airplanes, the number, type, and location of drains may not be the same. There is no single point of drainage that can be used to check for all fuel system contaminants simultaneously. Take the time to properly check all drain locations before each flight.
With the airplane in the normal ground attitude and starting at the highest drain location, check all drain locations for contaminants before every flight, whether or not refueling has occurred. Have fuel sample disposal provisions and proper lighting at your disposal to properly check for fuel tank system contamination.
- Drain at least one cup of fuel (using a clear sampler cup) from each drain location.
- Drain the fuel strainer as required to completely flush its contents in each of the fuel selector positions
- Check for water, clarity, cloudiness, haze, proper fuel type/grade (i.e. 100LL is light blue in tint, jet fuel is clear or yellowish), odour, or other contaminants.
- Allow time between fueling and draining. It takes time for any contaminates to settle to sump area prior to draining tanks.
- If any contamination is detected in the fuel tank system, thoroughly drain all drain locations again.
- If contamination is observed, take further samples until the fuel appears clear, and gently rock the airplane in both the roll and pitch axis to move any additional contaminants to the drain points.
- Take repeated samples from all drain locations until all contamination has been removed.
- If contaminants are still present, do not fly the airplane. Have qualified maintenance personnel drain and purge the fuel tank system. Remove all evidence of contamination prior to further flight.
Take proper precautions to preclude water from entering into your fuel tank system from an external source (washing, rain, snow, sleet, etc.). Regularly check all external entry sites (caps, access panels, etc.) for evidence of water ingress into the fuel tank system. When possible, store the airplane indoors. If stored outdoors or exposed to wet conditions (washing, rain, snow, sleet, etc.), examine the fuel tank system drains for contamination more frequently.
- Pay particular attention to airplanes that have been externally cleaned and/or refinished.
- Avoid using pressure washers near fuel system caps/filler areas when washing the aircraft.
- It is a good idea to remove accumulated snow/ice from the fuel tank entry sites to prevent ingress of water during melting.
During annual or 100-hr inspections, do the following:
- Check fuel caps, cap gaskets, cap adaptors, cap adaptor gaskets, fuel filler neck to adaptor sealer, fuel gage transmitter gaskets, gage transmitter access covers, and upper surface inspection covers for condition, proper sealing, security, alignment, etc. Ensure to service and clean these areas, replacing parts as necessary.
- Drain and flush the fuel strainer and carburetor bowl completely.
- Inspect the interior of metal fuel tanks for signs of corrosion, which may indicate water contamination.
- Inspect the interior of bladder tanks for wrinkles, broken or missing hangers, etc.
- If signs of contamination are found, alert the owner and fuel supplier of your findings for corrective action.
If the aircraft has a fuel drain valve replaced with a cap or plug, you should suspect water contamination in the respective tank. Strongly consider having a qualified maintenance technician install the proper drain valve prior to flight.
Take precautions to preclude water migration in the fuel tank system from an internal source (free water coming out of solution). Keep fuel tanks full when the airplane will not be operated regularly to minimize moisture condensation within the tanks. Keep fuel tanks full between flights, provided weight and balance limitations permit. Limit the fuel tank’s exposure to large temperature fluctuations as much as possible. If the airplane has been exposed to sustained wing low or unusual attitudes or a fuel tank has been run dry, sump contaminants may have migrated throughout the fuel tank system.
Know your fuel supplier. Regularly check and verify quality controls are in place to ensure you receive only dry, uncontaminated fuel from a supplier. Have on-field checks and verify to ensure continued supply of dry uncontaminated fuel to an operator. Gain assurance that the fuel supply has been checked for contamination and is properly filtered before allowing the airplane to be serviced. When ordering fuel, specifically state the exact fuel grade and quantity needed. Be present at each and every refueling and observe the fueling process.
Collect all sampled fuel in a safe container and dispose of properly.
Replace all safety items removed during contamination checks. Correct all unsatisfactory conditions found during any examination prior to further flight.
Additional background and reference materials are listed in the FAA SAIB link above. For further information, you can discuss with any of your local Transport Canada inspectors, or email us at email@example.com.
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