Advanced Ultra-Light Aeroplane - Manufacturers' Responsibilities

If you are the manufacturer of any model of advanced ultra-light aeroplane, there are some things that you need to know and some things you need to do:

  • before you ask to have your model listed as one of those eligible to be registered as an advanced ultra-light aeroplane
  • as you ask Transport Canada to list your model, and
  • after you begin selling aeroplanes you produce (whether they are fully-assembled aeroplanes or kits).

Although some of the requirements for advanced ultra-light aeroplanes are similar to those for other categories of aircraft, there are some significant differences. Services such as after-market support and the distribution of ongoing safety information are the sole responsibility of the manufacturers of advanced ultra-light aeroplanes.

Before joining the group of advanced ultra-light aeroplane manufacturers, you will need to decide if you are able to manage the technical side of aircraft design, manufacturing and continuing fitness for flight. You also will need to satisfy yourself that you are willing and able to maintain the required records, not only of your aeroplane model, but also of those who purchase aeroplanes from you as well as the subsequent owners of those aeroplanes. You will also need to ensure that you are willing and able to provide the after-market support to ensure continued fitness for flight of the aeroplanes that you produce. You need to decide if you are prepared to approve (or reject) owner-proposed modifications to your aeroplanes and you’ll need to have a system for notifying owners of needed safety actions as your fleet of aeroplanes ages.

Your responsibilities are the same, whether you sell finished aeroplanes or kits. Liability and responsibility for the aeroplanes you manufacture rests with you, under the advanced ultra-light aeroplane programme - and that includes the provision of after-market support to ensure the continued fitness for flight of the aeroplanes for as long as your model continue to fly.

The following text contains important information for manufacturers of advanced ultra-light aeroplanes. It is intended to help you become clearly aware of the responsibilities and liabilities that are borne by advanced ultra-light aeroplane manufacturers.

Before you ask to have your model listed as one of those eligible to be registered as an advanced ultra-light aeroplane ...

You will need to develop and compile all of the technical specifications, drawings, calculations, assembly instructions and other technical material pertaining to each model of advanced ultra-light aeroplane that you produce. As you develop these materials, it is important for you to keep in mind that all of this information must be kept by the manufacturer and be made available to Transport Canada upon request. Therefore, it is important that early in the process you develop a system for documenting all the technical information about each of your models. The technical specifications, drawings, calculations, assembly instructions and other documented material are called the Type Definition for each model of advanced ultra-light aeroplane.

Once you have developed all of the technical information for your aeroplane model, you will need to confirm that your type definition actually does comply in all respects to the requirements outlined in a document entitled “Design Standards for Advanced Ultra-light Aeroplanes”. The Light Aircraft Manufacturers’ Association of Canada (LAMAC) developed this document; the Minister has accepted these design standards as the requirements for advanced ultra-light aeroplanes in Canada. You can contact LAMAC on the Internet at http://www.lamac.info/ for the current edition of the design standards. As a manufacturer of an advanced ultra-light aeroplane, you are responsible for determining that your type definition conforms to these design standards.

You will need to establish a maintenance program comprising a schedule of inspections and procedures required to maintain the aeroplane in a “fit for flight” condition. You will be required to provide each purchaser with a copy of this maintenance programme. You will need to submit a copy of this maintenance programme to Transport Canada before aeroplanes of your model will be eligible for registration as advanced ultra-light aeroplanes.

You also need to establish procedures to ensure that the Type Definition of your model of advanced ultra-light aeroplane continues to comply with the standards specified in the manual entitled Design Standards for Advanced Ultra-light Aeroplanes, as long as you continue to manufacture that model of aeroplane as an advanced ultra-light aeroplane.

It is important that you establish the procedures whereby you will have the information needed to make certain certifications required of you as the manufacturer of an advanced ultra-light aeroplane. As the manufacturer, you are responsible for determining and certifying that each of your assembled ultra-light aeroplanes (whether it is assembled by you at your factory or assembled by a customer who purchases a kit) conforms to both:

  • your Type Definition, and
  • the Design Standards for Advanced Ultra-light Aeroplanes

In order to register their aircraft, owners must obtain your certification that the assembled aeroplane conforms to your Type Definition and that you consider it to be fit for flight. This document is called a Statement of Conformity.

As you ask Transport Canada to list your model as being eligible for registration as an advanced ultra-light aeroplane

Before Transport Canada will include your model on the Listing of Models Eligible to be Registered as an Advanced Ultra-light Aeroplane, you must provide Transport Canada with the following documentation for each model of aeroplane:

  • are approved by the manufacturer and the type of undercarriage that is approved by the manufacturer;
     
  • maximum empty weight, maximum take-off weight, maximum stalling speed in the landing configuration and the minimum useful load for each approved engine and type of undercarriage;
     
  • a Declaration of Compliance, which is a written declaration that
     
    • the type definition for your model of advanced ultra-light aeroplane complies with the standards specified in the most current version of the manual entitled the Design Standards for Advanced Ultra-light Aeroplanes;
    • the type definition for that model of advanced ultra-light aeroplane will continue to comply with the standards specified in the manual entitled Design Standards for Advanced Ultra-light Aeroplanes, as long as you continue to manufacture that model of aeroplane as an advanced ultra-light aeroplane;
       
  • a copy of your Specified Maintenance Program, including the inspection schedule and the maintenance procedures to maintain the aeroplane in a “fit for flight” condition;
     
  • a copy of the procedures that you have established for:
     
    • confirming that each assembled aeroplane conforms with your type definition for that particular model of advanced ultra-light aeroplane,
    • confirming that the assembled aeroplane complies with the standards specified in the Design Standards for Advanced Ultra-light Aeroplanes, and
    • confirming that the assembled aeroplane is fit for flight,
       
  • any other documents or information pertinent to establishing the aeroplane as an advanced ultra-light aeroplane as requested by Transport Canada.

After you begin selling aeroplanes you produce

For each aeroplane you sell, you must provide to each aeroplane owner a copy of your maintenance program (including inspection schedule and maintenance procedures) applicable to the aeroplane model.

As the manufacturer of an advanced ultra-light aeroplane, you are responsible for ensuring and certifying that each assembled aeroplane conforms to your Type Definition for that model and that the aeroplane continues to do so for the life of the aeroplane. This responsibility for “after market” support for the continuing “fit for flight” condition of your aeroplanes brings the requirement for you to identify any maintenance or other action that is needed with respect to your model of advanced ultra-light aeroplane to keep the aircraft safe. These actions are called “Mandatory Actions”. As the manufacturer, you are required to issue a Mandatory Action whenever you become aware of any action that if not taken would result in an unsafe or potentially unsafe condition for one of your models of advanced ultra-light aeroplanes. You must advise the owners of all of your aeroplanes of each Mandatory Action you issue applicable to their aeroplane and you must maintain a record of each Mandatory Action you issue. You should advise Transport Canada of each Mandatory Action

So that you can provide the required information to aeroplane owners, you are required to maintain a current record of all owners of your aeroplanes.

In addition, you must make available to Transport Canada upon request:

  • a current record of all owners of your models of advanced ultra-light aeroplanes;
  • all mandatory actions that have been issued for your models of advanced ultra-light aeroplanes; and
  • a copy of the type definition for each model of advanced ultra-light aeroplane.

From time to time owners of advanced ultra-light aeroplane may decide that they would like to make certain changes to their aeroplanes. Any change that results in an aeroplane deviating from your Type Definition is a “modification” to that aircraft. As manufacturer, you are the only one able to approve or reject modifications. There is no provision for you to delegate the responsibility for determining whether or not the modified aeroplane continues to comply in all respects to the requirements outlined in your type definition or in the “Design Standards for Advanced Ultra-light Aeroplanes”. Therefore, it is important that you have a process in place for considering and acting on such requests from owners.

The Ultra-light Aeroplane Transition Strategy is a document that outlines in more detail the requirements imposed on ultra-light aeroplanes in Canada. Section 3 of this document outlines requirements for advanced ultra-light aeroplanes. You can find the Ultra-light Aeroplane Transition Strategy on the Internet at http://www.tc.gc.ca/eng/civilaviation/standards/general-recavi-ultralight-ultransitionstrategy-menu-3434.htm

You will also find other useful information about advanced ultra-light aeroplanes on the Internet at http://www.tc.gc.ca/eng/civilaviation/standards/general-recavi-ultralight-menu-2457.htm

More detailed information regarding a manufacturer’s perspective about modifications to advanced ultra-light aeroplanes can be found at http://www.tc.gc.ca/eng/civilaviation/standards/general-recavi-ultralight-modsadulmanufacturer-524.htm

More detailed information regarding an owner’s perspective about modifications to advanced ultra-light aeroplanes can be found at http://www.tc.gc.ca/eng/civilaviation/standards/general-recavi-ultralight-modsadulowner-2458.htm

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