Operational Airworthiness
Privileges of Performing Maintenance or Elementary Work When Instructed by Sources other than the Canadian Aviation Regulations
Purpose
This airworthiness notice is issued to provide information and guidance regarding maintenance privileges contained in documentation other than the Canadian Aviation Regulations (CARs). Such instructions are typically found in Master Minimum Equipment Lists (MMEL), Minimum Equipment Lists (MEL), Service Bulletins (SB), Airworthiness Directives (ADs), Limited Supplemental Type Certificates (LSTC) and Supplemental Type Certificates (STC).
Background
Regulatory or manufacturer approved instructions are often prepared under the control of a foreign regulatory authority and accepted by Transport Canada in accordance with bilateral/technical agreements. Such instructions sometimes make reference to the persons authorized to perform or certify the work under the foreign regulations. The authority to perform maintenance and release aircraft to service varies from country to country.
The Maintenance and Manufacturing Branch has received several inquiries relating to instructions directly approved or validated by Transport Canada, that include references to the persons who may perform maintenance and/or return aircraft to service following maintenance.
Privileges
When considering who may perform or certify a given maintenance task, the requirements of the CARs take precedence over statements contained in such documents as MMEL/MELs, SB/ADs, and LSTC/STCs.
Elementary work is not subject to a maintenance release, however, all other maintenance is subject to the maintenance release requirements of CAR 571.10. Tasks that are considered elementary work can be found in the Aircraft Equipment and Maintenance Standards 625 Appendix A. If a task is not listed in Appendix A, it is not elementary work. Additionally, elementary work need not be performed by a holder of an Aircraft Maintenance Engineer (AME) licence, or persons working under an Approved Maintenance Organization (AMO) certificate.
Aircraft owners and operators are responsible for authorizing persons to perform elementary work. All tasks designated as elementary work shall be entered in the Journey Logbook, pursuant to CAR 605.94 - Journey Log Requirements, which is separate and distinct from the maintenance release requirements required by CAR 571.10.
For Minister of Transport
D.B. Sherritt
Director, Maintenance and Manufacturing