Is S.I.D. compliance required for A/C certification.

[Widgeon Guy]

On the Cessna 300 series the SID came out as part of the Maintenance Manual. I have been told to sign off the annual as per 625 appendix and all will be good. But 625 is a standard and in CAR 605 it says that some manufactures publications need to be done for the A/C to meet the Type Certificate. This seems a little gray to me, that you would be aloud to use 625 as away around doing a structures inspection even on a non commercial registered a/c.
Any ideas before i go to my regional transport office.

[Big Pistons Forever]

Cessna says that completing the SID is required to ensure continued airworthiness. If you sign off the aircraft under 625 as airworthy and the aircraft then sheds a wing..... well I would not want to be you. The bottom line is when Cessna built all those aircraft in the 60's and 70's I don't think they ever envisioned that so many would still be flying 40 years later and have accumulated over 10,000 hrs. Owners of this class of aircraft have to be prepared to spend some money to properly inspect and reinforce the known weaknesses in their aircraft.

[impress]

simple, non gray answer. What is your annual referenced to? Car 625? or the Maintenance Manual? if its Car 625 then no SID "REQUIRED". I am not saying no SID needed, just not REQUIRED. When you use CARS as the reference you avoid the requirement of SIDS because you are not using the statement "maintained IAW manufacturers recommendations" as you are with all commercial Maintenance Schedules. A decision needs to be made by the signing AME, some factors to consider are corrosion, cycles/hours, operating environment, type of flying.

[Widgeon Guy]

Aircraft Maintenance - General

605.84 (1) Subject to subsections (3) and (4), no person shall conduct a take-off or permit a take-off to be conducted in an aircraft that is in the legal custody and control of the person, other than an aircraft operated under a special certificate of airworthiness in the owner-maintenance or amateur-built classification, unless the aircraft
(amended 2002/03/01; previous version)

(a) is maintained in accordance with any airworthiness limitations applicable to the aircraft type design;
(amended 2002/03/01; previous version)

(b)meets the requirements of any airworthiness directive issued under section 521.427; and
(amended 2009/12/01; previous version)

(c) except as provided in subsection (2), meets the requirements of any notices that are equivalent to airworthiness directives and that are issued by
(amended 2002/03/01; previous version)

(i) the competent authority of the foreign state that, at the time the notice was issued, is responsible for the type certification of the aircraft, engine, propeller or appliance, or

(ii) for an aeronautical product in respect of which no type certificate has been issued, the competent authority of the foreign state that manufactured the aeronautical product.



625.84 Aircraft Maintenance - General

Information Note:

(i) Details regarding the approval of maintenance schedules are given in 625.86 of these standards.

(ii) Airworthiness Limitations are those requirements that result when the design analysis of the aircraft shows that certain tasks are required to ensure the aircraft remains in compliance with the design standards contained in the certification basis shown on the type certificate.
(amended 2009/12/01; previous version)

(iii) Airworthiness Limitations may be in the form of:

(A) life-limited parts;

(B) an inspection task required by any supplemental inspection document (SID) which has been published by the manufacturer for that aircraft;

(C) Certification Maintenance Requirements (CMRs), either issued by the manufacturer, or by a person holding the design certification for a modification that has been embodied into an aircraft; and
(amended 2009/12/01; previous version)

(D) any other limitation issued by a manufacturer when set out in the instructions for continued airworthiness, issued pursuant to the basis of certification basis.
(amended 2009/12/01; previous version)

Standard 625 Appendix B - Maintenance Schedules
Content last revised: 2007/12/30

General Procedures

(1) The Maintenance Schedule includes:

(i) Part I - Scheduled Inspections for Aircraft other than Balloons;

(ii) Part II - Scheduled Inspections for Balloons.

It must be supplemented by the applicable requirements of Appendix C, for out of phase tasks and equipment maintenance requirements.

(2) Each person performing inspections required by the maintenance schedule shall record the inspections in the aircraft technical record, using a check list that includes all items in Parts I or II that are applicable to the aircraft concerned. Additionally, all tasks required by Appendix C shall be recorded in the aircraft technical record.

Information Note:

Aircraft manufacturers' check lists can be used, provided that they include all the applicable items listed herein.

(3) The tasks listed in the maintenance schedule are described in general terms only, as the specific items applicable to particular aircraft will vary according to aircraft type.

(4) The method of inspection for each item on the maintenance schedule shall be in accordance with the manufacturer's recommendations or standard industry practice.

Information Note:

The following is provided as a quick reference chart. The specifIic details are contained in: Section 625.86; the relevant paragraphs of this Appendix B; Appendix C; and Appendix D of these standards.

Maintenance Schedules - Quick Reference Chart

(5) The depth of inspection of each item on the schedule shall be determined by the person performing the inspection, and shall be consistent with the general condition and operating role of the aircraft.

(6) Pursuant to CAR 605.86(2), the schedule is considered to be approved for use by owners of small non-commercial operation aircraft and all balloons. Owners need only to make an entry in the aircraft technical records that the aircraft is maintained pursuant to the maintenance schedule.

(7) Pursuant to CAR 605.86(2), the maintenance schedule can be used as the basis for a commercial air operator's maintenance schedule. With the exception of a balloon inspection schedule, commercial air operator's maintenance schedules based on this document are subject to approval by the Minister in accordance with Appendix D. Schedules for aircraft operated in commercial air service (including balloons pursuant to CAR) shall include an inspection of the items listed in Part I or II of this appendix, as applicable, and the accomplishment of out of phase tasks and equipment maintenance requirements specified in Appendix C.

(8) Pursuant to CAR 605.86(2), where the aircraft utilization is sufficient to ensure that all items listed in Parts I or II of this appendix are performed within a 12 month period, an owner can request that inspections under this maintenance schedule be performed progressively. In this case, a revised maintenance schedule shall be submitted for the Minister's approval in accordance with the procedures outlined in subsection 625.86(2) of these standards.

(9) Pursuant to CAR 605.86(2), where a flight training unit operating aeroplanes and helicopters pursuant to CAR 406 chooses to use Part I of this appendix as a basis for inspections to be carried out at 100 hour intervals, it must be approved in accordance with the procedures outlined in Appendix D of these standards.

(10) This maintenance schedule is not an inspection checklist. Prior to performing the inspections tabled herein, an appropriate checklist containing these requirements must be developed.

Information Note:

(i) Many aircraft manufacturers produce detailed inspection checklists. In many cases the location of system components is clearly identified on those documents. In the interest of efficiency an owner may wish to use a manufacturers checklist in order to accomplish this inspection. Manufacturer's checklists may be used, provided they include at least the items listed in Part I or Part II of this appendix, as applicable. Where an owner has chosen to use a manufacturer's checklist, it should be clearly marked to indicate that the check is following the general maintenance schedule. In addition, any references in those checklists concerning compliance with Airworthiness Directives must be stricken out as not applicable, as it is the owner's responsibility to advise the AME of any outstanding Airworthiness Directives or airworthiness limitations.

[palebird]

A little grey?? The last post spells it all out. Whoever is giving you advice is leading you astray.

[iflyforpie]

Every AME doing CAR 625 inspections should read what Widgeon Guy posted. I was going to write the same thing to reply to impress's post.

CAR 625 App B doesn't replace the manufacturer's maintenance requirements, it incorporates them.

[Widgeon Guy]

So i did ask the question on the TC web based question and answer site and was treated very well, It took a lot longer to answer then the guy working on it thought it would take. But that tells me that he had lots of input form other standards people in Ottawa. The short answer is a private a/c does not need the SID completed to have the annual sighed off as per standard 625 you still reference the Cessna inspection sheet and the items you did not do in the log entry. And all TC guys should give you and same answer as it is in the Data base now. The CARs are very convoluted.

[Gord Tessier]

Hi. I am having the same problem. Is there a letter or document that I could place in my maintenance manual from TC to satisfy my AME.
I assume they would have given you a written reply. If you do have something could I trouble you to fax it to 18663034180 or attach it here. I would be most grateful
Thanks,
Gord.

[impress]

well, i feel better now.

I had gone through this with TC several times before my previous post.

[Gord Tessier]

OK, so my AME calls me this morning. His man at TC inicated to him that SID's (supplemental Inspection Dcouments) are in fact mandatory as per 625.84.
Can someone please post the letter from TC Ottawa that settles this nonsence once and for all before I have a heart attack.
The cost to do these are over $60k. It would ground the entire fleet at annual if it were true.
Help!

[crazy_aviator]

+1 on the TC letter that testifies to the fact that SID s are MANDATORY on a -625 annual !!
Most AME s have been doing annuals WITHOUT referencing the SIDS IMHO and this "gray" area aught to be cleaned up.

[iflyforpie]

OK, so my AME calls me this morning. His man at TC inicated to him that SID's (supplemental Inspection Dcouments) are in fact mandatory as per 625.84.
Can someone please post the letter from TC Ottawa that settles this nonsence once and for all before I have a heart attack.
The cost to do these are over $60k. It would ground the entire fleet at annual if it were true.
Help!

Wow, $60K per aircraft? What are you operating?

[Gord Tessier]

337G Skymaster

[iflyforpie]

We have a Skymaster too (337A) and are looking at doing the SID over the winter, but some estimates were closer to $25K. Still waiting for the paperwork to arrive so I can see what I am up against...

[Gord Tessier]

SID inspections are NOT mandatory for Canadian registered, small, privately owned aircraft.

From Transport Canada

"For non-commercial owner/operators of small piston aircraft who are operating under Standard 625 Appendix B however the ability to operate to the general annual inspection requirements of this appendix removes the requirement to perform the SID inspections.The Regulations state only the minimum requirements in order to comply however Transport Canada encourages all owners to assess manufacturer’s recommendations for their aircraft".

That is the answer to the million dollar question. Thank you very much to COPA for helping me out on this one. You guys are awesome.