Aircraft Painting

[GottaFly]

I was curious about aircraft painting. What and where are the regs? Does a paint shop need to be an AMO? Who can paint aircraft (certification)? Where are the paint shops in western Canada?

Thanks for your answers!

[crazy_aviator]

An AME needs to sign off the paint job on an aircraft with a C of A An ultralight, for example can be painted by the owner etc.,,,, beware of flight control balance and paint and stripper plugging critical ports and surfaces like the pitot - static etc

[CamAero]

Crazy Aviator, by "Sign Off", you mean a "Maintenance Release"?

The following is from Part 1 of the CARs:

"maintenance release" - means a certification made following the maintenance of an aeronautical product, indicating that the maintenance was performed in accordance with the applicable provisions of these Regulations and the standards of airworthiness; (certification après maintenance)

Now, a Maintenance Release is required where actual maintenance has been performed.

Also from Part 1 of the Regs:

"maintenance" - means the overhaul, repair, required inspection or modification of an aeronautical product, or the removal of a component from or its installation on an aeronautical product, but does not include
(amended 2003/06/01; previous version)

(a) elementary work,

(b) servicing; or

(c) any work performed on an aircraft by the manufacturer prior to the issuance of whichever of the following documents is issued first
(amended 2007/12/01; previous version)

(i) a certificate of airworthiness,
(amended 2007/12/01; previous version)

(ii) a special certificate of airworthiness, or
(amended 2007/12/01; previous version)

(iii) an export airworthiness certificate; (maintenance)
(amended 2007/12/01; previous version)

So, it could be debated as to whether or not painting is by definition, maintenance. In a case where control surfaces are balanced after a paint-job, that alone certainly would constitute maintenance and would require a maintenance release and would require a dual inspection if the controls were disturbed but I do not think that that is necessarily what the OP was getting at.

Also, the O.P. has asked if a paint shop need be an AMO?

No, Non-Specialized Maintenance on private aircraft does not need to be accomplished by an AMO.

All maintenance on commercial aircraft and Specialized Maintenance (see CAR 571 Schedule II, http://www.tc.gc.ca/eng/civilaviation/r ... 2-1769.htm) on all aircraft does need to be accomplished (or, at the very least, the maintenance release must be made by), an AMO.

C.A.

[Colonel Sanders]

Personally, I think that re-painting a small, non-movable
section of a private aircraft (with a certified C of A) is
elementary maintenance, but I could be wrong.

Forgetting about flight controls for a moment (too easy) ...

A complete strip and repaint of an aircraft might reasonably
result in a measurable change in it's empty weight (unlike a
small touch-up).

Would changing the empty weight of an aircraft still be
considered elementary maintenance, or would it require
a maintenance release?

Personally, I would recommend a re-weigh of an aircraft
that had been completely re-painted, but I was repeatedly
dropped on my head as a small child.

[CamAero]

Would changing the empty weight of an aircraft still be
considered elementary maintenance, or would it require
a maintenance release?

The list of what constitutes Elementary Work, ~ (Note: they do not call it Maintenance) ,is found here:

http://www.tc.gc.ca/eng/civilaviation/r ... a-2458.htm

The list is "exhaustive", meaning that anything not on the list but that does appear in the definition of "Maintenance" in Part 1 of the Regs, does constitute Maintenance, does not fall under "Elementary Work" and would require a Maintenance Release.

Changing the empty weight is a good point point Colonel, though I doubt actually, particularly with a complete strip and repaint that the change would be measurable. I cannot think of anybody I know who has weighed an airplane just because they painted it. However, that said, the regulatory requirement for weight and balance is that it is amended "Every time that there is a change". Being though that there is no way to know the exact weight and moment-arm of a paint job, strictly speaking, weighing the aircraft would be the only means of determining if or what the change has been.

The use of "precision measuring or test equipment" (ie weigh scales), does constitute Maintenance, however, the requirement to keep the aircraft's weight and balance up to date is the Owner's.

C.A.

[iflyforpie]

It paint touch up listed in CAR 625 APP A CS? Remember, that list is exhaustive. Maybe repainting counts as servicing?


Having been involve in the repainting of several small aircraft, I can say that there is no formal certification to paint planes, but the process involved to do it properly (disassembly, balancing/re-rigging of flight controls/airframe, and reweighing) required a facility specialized in the process and an AME on contract or staff.

[CamAero]

Pie, the word "Servicing", unless the specific tasks listed fall under the Elementary Work definitions list in 625 Appendix A, will still be maintenance. Nothing about ATA Chapter 12 makes it holy. Unfortunately.

CA

[GottaFly]

Thank you for your replies. I am speaking about painting in the commercial world so gathering from the responses, a commercial paint facility needs to be an AMO. I suppose most commercial operators probably convert their hangars into makeshift spray booths, hire auomotive painters and have them supervised by AMEs. There are very few stand alone paint companies in Canada that I can find.

[CamAero]

Thank you for your replies. I am speaking about painting in the commercial world so gathering from the responses, a commercial paint facility needs to be an AMO. I suppose most commercial operators probably convert their hangars into makeshift spray booths, hire auomotive painters and have them supervised by AMEs. There are very few stand alone paint companies in Canada that I can find.

What size bird are you painting?

[GottaFly]

Considering building a booth to handle up to and including a q400

[crazy_aviator]

2 things, W and B amendment and flight controls must have a maintenance release by an AME. IF the A/C has a C of A it will also have maint. and parts manuals and in the maint. manual, flight controls MUST be checked for balance when repainted

[CamAero]

Crazy Aviator, could you please show me in the regulations where a maintenance release is required for a weight and balance amendment.
CA

[crazy_aviator]

Weight and Balance Reports

(a) The empty weight of an aircraft stated in a weight and balance report shall include all items required by the basis of the aircraft type certification, and all additional items of installed equipment. Any item not forming part of the type design shall be entered in an equipment list with its associated weight and moment. This list constitutes a part of the weight and balance report.

(b) Weight and Balance reports shall be certified by signing a maintenance release.

(2) Amendments to Weight and Balance
(amended 2002/09/01; previous version)

(a) Following a modification or a major repair that involves a change to the empty weight or centre of gravity of an aircraft, the person who made the change shall make an entry into the journey log or approved alternative system as soon as practicable after the change but, at the latest, before the next flight, which shall include:
(amended 2007/12/30; previous version)

(i) a description of the change;
(amended 2002/09/01; previous version)

(ii) the effective date of the change; and

(iii) the weight and moment arm of each item installed or removed.
(amended 2002/09/01; previous version)

(b) Subject to the requirements of section (1), the particulars in respect of changes to the empty weight or centre of gravity shall be transcribed in the empty weight and balance report, or, if an approved fleet emtpy weight and balance control program is in effect, in the empty weight and balance data for the aircraft, in accordance with the requirements applicable to the transfer of data from the journey log, set out in section 605.96 of the CARs.
(amended 2002/09/01; no previous version)

Information Notes:
(amended 2002/09/01; no previous version)

(i) Paragraph (2)(a) above allows for the temporary removal of aircraft equipment for repair, or incorporation of a modification or repair, without the need to immediately amend the empty weight and balance report.

(ii) When the pertinent changes are transcribed from the journey log, pursuant to paragraph (2)(b), the amended empty weight and balance report will indicate the actual empty weight, as stated in section (1) of this appendix.

(iii) Pursuant to section 605.85 of the CARs, a maintenance release is to be signed in respect of the maintenance performed, when applicable.

(c) Following any change to installed equipment, the weight and balance report equipment list shall be amended to reflect the change.
(amended 2007/12/30; no previous version)



For a report you need a release,, for an amendment IF maint. work was done you need a release ,,this is what i gather in the CARS

[helicopterray]

Anyone can paint an aircraft, there is no certification requirement.

However, individual aircraft manufacturers may have some very specific requirements in their Standard Practices manual as to what you can use to prep the aircraft for paint, what Mil-Spec paint you can use, and in some cases, how thick the applied paint can be.

An AME will have to certify that the paint job was in accordance with those specifications.

[photofly]

Regrettably, you are all wrong.

Painting an aircraft is maintenance and requires a release from an AME. For a commercial aircraft it must be by an AMO.

See the following judgement by the Civil Aviation Tribunal (denied) on appeal against an enforcement decision by Transport Canada on that basis:

http://www.tatc.gc.ca/decision/decision ... &dc_id=665

[GottaFly]

Regrettably, you are all wrong.

Painting an aircraft is maintenance and requires a release from an AME. For a commercial aircraft it must be by an AMO.

See the following judgement by the Civil Aviation Tribunal (denied) on appeal against an enforcement decision by Transport Canada on that basis:

http://www.tatc.gc.ca/decision/decision ... &dc_id=665

Perfect! This is exactly what I needed. It pretty much sums it all up. Thank you!

[Colonel Sanders]

It paint touch up listed in CAR 625 APP A CS?

Yes, in two different sections, no less. I am quite happy to
talk about this at the Tribunal. Again.

Remember various people here threatened me with reporting
me to Enforcement a couple years back, because I (gasp)
admitted to touching up paint chips with a hobby brush?

I laughed, and the Mods deleted the thread in it's entirety.

You people really need to get a grip. Touchup is elementary
maintenance. Painting an entire airplane is not. If you can't
see the difference between the two, well ...

[SeptRepair]

Learned something new with this thread. But for the life of me I cant find the area in the CARs that says Maintenance includes repainting. The definition of Maintenance in Part 1 is the only one I can find. Yet when you read the tribunal report it uses a separate definition of maintenance and doesn't back it up with a link in the Cars, just a reference to a page. Anyone know where THEIR definition of maintenance is located?

[crazy_aviator]

Most A/C have balanced control surfaces and those surfaces MUST be checked by an AME ( post strip and paint) prior to flight, therefore necessitating a maint. release. Most owners have their A/C weighed after a complete repaint ( only makes sense) and that W and B must also be signed off. MANY accidents have been caused by paint shops doing a paint job and things being covered, removed etc and no AME to spot it!!!

[black hole]

As a point of interest only. Cessna at the factory: Builds the aircaft at one facility and then on the test flight flies them to another facility were they are painted.( that's not safe. Is it?). If the AC is stripped of paint( no surfaces removed) and then repainted: what is the weight change?
I read in an equipment list years ago that the all over paint on a C180 was 11 lbs.

I think that the overall issue was something deeper here and that TC was flaunting CARS and not common sense. Where is the common sense secion in CARS? I couldn't find it!

BH

[CamAero]

Crazy_aviator, I learned something there with the Regs you posted. I did not realize that a W&B amendment required a maintenance release. It is a contradictory requirement when you look at the definition of "maintenance" in Part 1; however, it won't be the first or last time that the CARs contradict themselves but thank you for pointing it out.

Sept Repair, I'm with ya;

But for the life of me I cant find the area in the CARs that says Maintenance includes repainting.

Colonel Sanders, in my opinion, your 'touching up with a hobby brush' is not maintenance of any sort. It is not "maintenance" under the definition of the CARs, nor is it Elementary Work. It is simply cosmetic-care, no different in my estimation to wiping the belly or vacuuming the carpet.

Crazy Aviator, you have failed to explain why painting is maintenance. You have cited that painted controls need to be rebalanced; OK, in some cases they do, in some cases they do not. Lets say I take the cowling off my Cessna 180, paint strip one layer of paint and one layer of primer. Then I repaint it with the same combination and same materials. Now, I go ahead as an owner can, under the "Elementary Work" allowance and reinstall the cowling. The re & re of the cowling as per the requirement is recorded in the J-Log and transcribed to the technical records. The weight and balance change was negligible. Can you explain to me how what I have done, bearing in mind the definition of "maintenance" in the CARs, constitutes maintenance and / or would require a Maintenance Release?

The point that masking tape etc could plug a pitot tube or static vent is a hollow argument. If you cover same said ports with tape while you wash your aircraft, do you need an AME to inspect it, see that you did indeed remove the tape and then sign a Maintenance Release before the aircraft can fly again?

The Tribunal case brought up by photofly is a good one but TC had those guys in a barrel for doing maintenance and subsequently operating the aircraft without a Maintenance Release. Hypothetically, if they had only painted the wings and fuselage, no control surfaces and no other work {maintenance}, (the thing arrived there on a trailer in pieces for Christ' sake), this would have been well worth fighting T.C. tooth and nail over. The accused in this instance did not have a case, plain and simple. As a point of interest, at the last of the Tribunal report, in the section "The Law", the definition of "maintenance" is notably absent.

C.A.

[crazy_aviator]

Cam,

Ive never mentioned that painting an aircraft was considered maintenance IAW the CARS. I DID mention that IF you do maintenance whilst doing the painting operation (like balance the controls , weight and balance etc) THEN you will need a release

[crazy_aviator]

Another thing, like ive mentioned before, Im getting TIRED of reading accident reports of planes coming out of paint shops and having accidents. Any idea WHY this is happening ? Sure you can put a pitot cover on a pitot and go wash the plane but leave the technical stuff to the AME s

[CamAero]

OK Crazy_Aviator, point taken.

Black Hole - with regard to your point about the Cessna aircraft being 'test-flown' to the paint shop from the factory, interestingly, in Canada, (I am not sure about the US), nothing done to an aircraft before its Certificate of Airworthiness is issued is considered maintenance.

In this country, the flight your talking about could be done without a maintenance release.

C.A.

[Beefitarian]

As a point of interest only. Cessna at the factory: Builds the aircaft at one facility and then on the test flight flies them to another facility were they are painted.( that's not safe. Is it?). If the AC is stripped of paint( no surfaces removed) and then repainted: what is the weight change?
I read in an equipment list years ago that the all over paint on a C180 was 11 lbs.

I think that the overall issue was something deeper here and that TC was flaunting CARS and not common sense. Where is the common sense secion in CARS? I couldn't find it!

BH

I'm guessing here but.. Does Cessna paint with robots making the amounts applied the same every time? Even a highly skilled painter might apply a heavier coat on one area.

Also is there a final W&B done later after the last options are installed for the customer?

For sure TC is using cars across the board here. Applying the rules needed to prevent problems painting an Airbus 380 to painting a cub.