Bits and Pieces
Annual Maintenance Inspection and Sign-out on your Homebuilt
By Jack Dueck
Ask yourself the following question:
After three years of flying my homebuilt, what should my maintenance records look like?
With the privilege of building and flying our own aircraft in Canada, we have each of us, signed a logbook entry in our Journey Log that states: "This aircraft will be maintained in compliance with CAR 625, appendices B & C." What does this entail?
We find this information under the rules and regulations relating to amateur-built aircraft. 'EXEMPTION FROM SECTION 549.01 CANADIAN AVIATION REGULATIONS AND CHAPTER 549 AIRWORTHINESS MANUAL AIRWORTHINESS STANDARDS AMATEUR-BUILT AIRCRAFT PART VII - CONTINUING AIRWORTHINESS, PARA (71).
Except where specifically stated to the contrary, amateur-built aircraft are subject to the same operating and maintenance regulations as type certified aircraft. Some of the applicable regulations, and their practical effects are summarized in the following information notes:
- The details of all maintenance and elementary work performed on an amateur-built aircraft must be entered in the aircraft's technical record.
This would suggest that the logs should list ALL maintenance work carried out.
- All maintenance activities require a maintenance release
- The owner of an amateur-built aircraft may sign the release for the maintenance of his or her own aircraft.
- Elementary work does not require a maintenance release; however, it must be recorded in the aircraft technical record, together with the signature of the person who performed the work.
So the owner/operator must list all maintenance work, and any maintenance work that is not ‘elementary’ requires a signature.
What is ‘Elementary or Minor’, and what is Major?
- A “minor change” is one that has no appreciable effect on the weight, balance, structural strength, reliability, operational characteristics, or other characteristics affecting the airworthiness of the product
- All other changes are “Major Changes”
- Examples of major changes:
- New propeller with a different pitch/diameter
- New engine of greater or lesser horsepower
- Installing floats
- Examples of minor changes:
- Overhaul of the engine
- Replacement of engine with same make/model
- Adding additional instruments
- The maintenance schedule requirements detailed in STD 625 Appendix B are approved by the Minister for use with Amateur-built aircraft, at intervals not exceeding 12 months. STD 625 specifies that Appendix B must be supplemented by the applicable requirements of STD 625 Appendix C, for out of phase tasks and equipment maintenance requirements.
If the annual inspection is signed off in the appropriate logbook on June 1, the next annual must be signed out no later than June 1 the following year. No ‘float’ allowed.
- A weight-and-balance report is required for each aircraft configuration.
- Amateur-built aircraft are not required to comply with Airworthiness Directives; however, operators are strongly urged to review applicable airworthiness directives to determine if they wish to comply voluntarily, in order to enhance the safety of the aircraft.
- Repairs and modifications to amateur-built aircraft must conform to technical data acceptable to the Minister; sources of acceptable data include, but are not limited to:
- Drawings and methods recommended by the manufacturer of the aircraft kit, component, or appliance;
- Transport Canada advisory documents;
- FAA Advisory Circular 43.13.1 and 2, UK CAA Aircraft Inspection Procedures (CAIP), JAA Advisory Circulars, (ACJ) and publications issued by recognized authorities on the subject matter concerned.
- All entries in respect of the technical records for the airframe, engine and propeller for an amateur-built aircraft may be kept in the journey log, provided the requirements with respect to the technical records are met
Owners/operators of amateur-built aircraft may log all of the maintenance activities in the Journey log. You do not need to maintain and keep an Airframe, Engine, or Propeller log. However, I wonder what happens to the log and its records if the aircraft is destroyed in a fire. I keep separate logs for the airframe and engine in the hangar for that very reason.
- Owners may devise their own data, which need not be approved, but must be subject to all appropriate level or review or analysis, or be shown to comply with recognized industry standards, or commonly accepted practice.
- Changes that affect the structural strength, performance, power plant operation, or flight characteristics of an amateur-built aircraft must be reported to the Minister before further flight of the aircraft; such changes may require re-evaluation to confirm that the aircraft continues to comply with the acceptable standards.
You will need to go through a new test-flight period after any such changes are made. The number of hours will be assigned by the Minister, and depend on the extent of the change.
- The Minister is the final authority for determining the acceptability of data.
If we review item 8 above, we see a hierarchy of acceptable repairs and modifications. The first and foremost is data generated and supplied by the manufacturer of the kit. Next is data produced by Transport Canada documents. And third is acceptable authoritative literature such as AC 43.13, 1 and 2.
If we further review item 10 above, we see that we can also, in absence of the above, devise our own data, which does not need to be approved, but that must be subject to all appropriate levels, reviews, or analyses or which can be shown to comply with industry standards or accepted practice.
Our logs should show:
- all maintenance entries
- accompanied by data that qualifies the maintenance or repair
- signature and license of the person carrying out the work
An example would be:
June 1, 2008; Annual Maintenance Inspection and all repairs carried out as per aircraft inspection check list attached. All work performed in accordance with AC 43.13B.
PPL # 12345