The Government Approved List;
As the owner of small privately operated aircraft have you ever been tempted to work on your own airplane? Well you can!
Transport Canada re-wrote the rules in 2004 and the new list is surprisingly realistic (as written). They list 29 items the private owner can do, or authorize someone else to do, so long as you enter it in your technical logs. They call these items “elementary work” and they are listed in “The Canadian Aviation Regulations (CARS), Standard 625 APPENDIX A - ELEMENTARY WORK”.
For isolated locations up here this can be really important. I have paraphrased this list below, and put in one Yukoner's recomendations (mine, in blue) for when doing the work. If you have questions or need clarification I suggest you reference;
- the above document,
- your aircraft manuals sometimes have good detail,
- check out AC.43.13, or
- discuss it with your favorite AME.
(1) fabric patches measuring not more than 15 cm (6 in) in any direction and not requiring rib stitching or the removal of control surfaces or structural parts;
Small Fabric Patches are not as difficult as you might imagine. (Check out AC.47.13 from a friend, the library, or Amazon) Do them in the open on warm days. Clean the area well using MEK (uck!) or failing that, Isopropyl Alcohol or in a pinch, white gas. Use pinking shears to cut your patch an inch or two bigger than your damage. If you use MEK no other prep is needed. If alcohol or gas then you might want to use Buto-Solv to soften the dope on the wing. Then place your patch and work it down using a small brush or your fingers (uck!). Once it is set into place and bonded lightly, use coats of Butyrate dope with aluminum powder in it, or pigment that can block ultraviolet, and brush on until the finish is satisfactory. The result will be much more airworthy, and esthetically pleasing too.
(2) removal and replacement of tires, wheels, landing skids or skid shoes, not requiring separation of any hydraulic lines;
For us, most of the time we can change wheels / skis without disconnecting any hydraulic lines. Biggest risk I have seen is from damage from trying to jack the aircraft up. Borrow or make proper jacks. Watch out when lifting, the c of g changes as the aircraft comes off the ground, many land on their nose.
Keep track of each bolt, nut, part as you remove it so you can put it back in the right place. If you need to replace tire and/or tube, take air out before unbolting wheel halves. Now is good time to clean out the bearings and put in new grease into the rollers. Don't put in extra grease. Use talcum owder on tubes and allign the red "DOT" on tire with the stem of the tube. Reinflate to recommended pressure after bolting together (For most of us thats about 25 psi).
(3) removal and replacement of skis on fixed landing gear, not requiring separation of any hydraulic lines;
As in number 2. above, but pay attention to your skis, cables, fittings and bungees. If they are worn, damaged, or look questionable stop and arrange for new parts. (Imagine the result of a failed safety cable?) Keep everything safety-wired together in a bundle if this is a seasonal change.
(4) repair of non-structural fairings, cover plates and cowlings;
This can be done with a little care and practice. But remember they repair must be to "CODE". Look at AC.43.13 for standards or check out on of the excellent home-builders sites for completely professional riveting and sheetmetal work skills. But don't guess about rivet spacing and edge distances! Get the proper materials and rivets, borrow or buy the proper tools, and practice a bit first.
(5) cleaning and replacement of spark plugs;
Do this once and you will be surprised by the ease and the improved performance. You need a 7/16" and a 3/4" wrench to remove the wire leads. they don't need much torque so be careful. Make a box with a hole for each plug marked to hold them safely as they are removed so you do not mix up where each plug came from. Don't drop these guys...ever!
Use a socket wrench to remove each plug. Inspect it (Gap should be uniform on each, and no bits of stuff between electrodes. Measure with a guage and adjust gently but firmly.) Look for"clinkers" down inside that you can remove GENTLY with a steel pick. Do not scratch the electrodes. The top plugs should all be a uniform grey-brown color. The bottom plugs may be darker than the top and slightly oily. You can rotate top for bottom in each cylinder, but not between cyinders. When you replace the plugs use new copper washers, or anneal the old ones. A very tiny bit of anti-seize lubricant on the threads is a good idea, until you get it on the electrode, then your plug is useless. Torque your plugs with a torque wrench. Re-attach the wires after checking each "cigarette" end is clean and intact. Don't tighten very tight. Test run it, then go.
(6) checking of cylinder compression;
To do this right you need to borrow or buy a "leak-down" tester. This work is not difficult but I prefer having an AME there when I do this because their experience in diagnosing the results are usually invaluable. I will complete more later.
(7) cleaning or changing of fuel, oil, and air filters;
Find out what filters are on your airplane and where they are. Most are safety-wired in place so have wire and pliers ready before you remove them. Fuel bowls are removed, emptied, examined, and replaced. If your aircraft has screens, locate them, remove safety-wire, and watch the location and sequence of washers or parts as you remove them. Clean them in a small tin bread pan in avgas and look in the residue for bits, colors, magnetic pieces, etc. You can dump the solvent on a clean piece of paper towell and allow to dry so you can take it to an expert if in doubt. Look at lines and fittings for leaks or damage too. Replace, torque, and safety-wire as original
(8) draining and replenishing engine oil;
This is the best insurance you can buy. (See above (7) for filters and screens) Drain all lines and coolers if possible. Collect oil in a container, it is likely toxic waste in most jurisdctions. Replace and safety-wire plugs or drains. Refill with seasonal oil, test run, and check for leaks and levels. Top up, and go.
(9) checking the electrolyte level and specific gravity of lead acid batteries;
Remove each cap and top up to bottom of colar with distilled water. If your battery is more than 3 years old, buy one of the new approved "gel-cell" type. They last years longer, maintain a charge better, are smaller and lighter (?? a W&B isue ??) And, they are same price and you can send them by mail.
(10) adjustment of generator or alternator drive belt tension;
There are usually at least two bolts to loosen, then a lever is needed to pull the belt tight, but not too tight, and hold it while you re-tighten the bolts. You should be able to deflect the middle of the belt about 1/4 to 1/2 inch by pushing very hard with your index finger. Too tight and you can take out the alternator bearing. Too loose can cause considerable vibrations, lack of charging, and undiagnosed electrical issues? The prop needs to be removed to replace belts, so consider buying two and safety-wiring the second in place out of harms way until needed?
(11) cleaning of balloon burner nozzles;
I need an expert here.
(12) removal and replacement of balloon baskets, burners and gas tanks that are designed for rapid change in service;
Here too!
(13) removal and replacement of glider wings and tail surfaces that are designed for quick assembly;
And here, but I would love to learn.
(14) repair of upholstery, trim and cabin furnishings;
An issue close to my heart. TC traditionally disallowed anything but original equipment, so most of us were sitting on rags and looking at exposed wires. I imagine that TC inspectors will still demand an FAA certificate of flame testing if you do very much here. One way around it might be to use leather...it is tough to flame test a cow. Cows are not made of foam though, time will tell. There are fire retardent sprays for fabric, but I anticipate TC would want a flame test after using it. (See my closing comments). In the mean time keep it as clean as possible.
(15) removal and replacement of role equipment designed for rapid removal and replacement;
This appears to be things like external antenaes for tracking, or brackets etc for approved STC's.
(16) removal and replacement of passenger seat belts and harnesses;
"Passenger" NOT pilot for some reason, knock yourself out. Buy certified ones of course. I am sure your AME will look after the Pilots one?
(17) removal and replacement of fuses, light bulbs and reflectors;
Use the approved size and type and there is not much room to go wrong. Don't go "oversize" without fire insurance.
(18) removal and replacement of avionics components that are rack mounted or otherwise designed for rapid removal and replacement, where the work does not require testing other than an operational check;"
This appears to allow only removal of item from a tray, and not modification to the panel, rack or tray in any way. My comments here are similar to the upholstry comment.....a lack of technicians here in the North has resulted in a lot of old radios, poor quality radios, and even the odd non-fuctioning one. Fortunately they are still not mandatory, unless you are talking about ELTs, and I won't even start with that....
(19) removal and replacement of aircraft batteries;
Check out my comments in number 9, above, get a GEL-CELL.
(20) removal and replacement of co-pilot control levers, wheels, pedals and pedal guard plates that are designed for rapid removal and replacement;
A few aircraft have co-pilot controls "designed for rapid removal and replacement". (My own co-pilot does not come with any levers, wheels or pedals, but she would be hard to replace in any event.).
(21) opening and closing of non-structural access panels
They are there to allow insection/service. My advice is to use a good quality tool, if you strip a fastener replace it, and keep track of location and orientation of each panel you remove. If you have had any panels off, your next pre-flight should be very dilligent.
(22) removal and replacement of cabin doors on unpressurized aircraft, where the door is designed for rapid removal and replacement;
If you have doors"...designed for rapid removal and replacement..." it should be obvious, but it may not be clear cut. (Check out my closing remarks for explanation.) I would pull a pin, or key, but I would be reluctant (legally) to start removing any bolt or nuts. This is not about flight with the doors removed, that is not always allowed.
(23) removal, replacement and repositioning of non structural partitions in the passenger cabin;
Most of us private guys don't have these, if you do, here you go, you are legal to move them.
(24) inspection and continuity checking of self-sealing chip detectors;
Since pulling the PT-6 out of my Aeronca Champ I have not been bothered by nuisance chip-lights.
(25) removal and replacement of induction system anti-icing baffles, scoops and deflectors that are designed for rapid removal and replacement;
It would be nice to belive this includes winterization kits that are STC'd, but it doesn't say this.
(26) removal, cleaning, replacement and adjustment of external components of chemical dispersal systems that are designed for rapid removal and replacement;
Agriculture types, or perhaps private Fire Bombers would benefit from this.
(27) deactivating or securing inoperative systems in accordance with sections 605.09 or 605.10 of the CARs, including the installation of devices specifically intended for system deactivation, where the work does not involve disassembly, the installation of parts, or testing other than operational checks;
If you have a system that fails (avionics, fuel pumps,etc.) you may pull a breaker or switch....Duhh !..this is likely for more complex and commercial guys.
(28) checking and adjusAgricultureting air pressure in helicopter floats, and aircraft tires having an operating pressure below 100 psi, except on aircraft operated under CAR 704 and CAR 705.
Here too, limited application for us private guys.
29) repetitive visual inspections or operational checks (including inspections and tests required by airworthiness directives) not involving disassembly or the use of visual aids, performed out of phase with the aircraft’s scheduled check cycle at intervals of less than 100 hours air time, provided the tasks are also included in the most frequent scheduled maintenance check.There is repetitive visual inspections or operational checks (including inspections and tests required by airworthiness directives) not involving disassembly or the use of visual aids, performed out of phase with the aircraft’s scheduled check cycle at intervals of less than 100 hours air time, provided the tasks are also included in the most frequent scheduled
This wasn't written by a lawyer, nor anyone with a high shool education. I called the local TC to ask what this meant, but unfortunately I am still not sure. My guess is, if you do any of this work your aircraft still needs inspections and anuals by qualified AME. And,
If there are AD's involved, since TC has ruled that the compliance with an AD is the owners responsibility, research your AD's. If you can verify compliance without disassembly of any parts I would enter that in the Technical logs. If there are any questions, involve your favorite AME.
Remember, this is my interpretation;
FINAL CAUTION: As with any situation the government inspector you encounter might be having a bad day, so I urge common sense, applied at the time, in your location, and perhaps not widely announced. The test should be; "Would I take my daughter for a ride in this aircraft, as it now is?" NOT "What would the Transport Canada Inspector say?".
REMEMBER TO ENTER THE WORK INTO YOUR LOG BOOKS PROPERLY (Date, Work Done, Compliant with what standard....,by who, your name, signature and licenses number). This is where they will focus thier attention. I base this on the fact that Transport Canada trained me to enforce the Canadian Air Regulations a few years ago. (The irony of that won't be lost on those of you who know me.) Following this training they even provided me, and selected RCMP officers, with certification of our knowledge. At that course the TC instructors made jokes about what issues were to be pursued and that they weren't any controversial ones. The approach is one of policy and not law. The difference between policy and law is fundamental in Canadian Jurisprudence, but is lost on most Transport Canada officials I greatly fear.
If you have any additional helpful information please send it along to me to help other Northern Pilots.