Annual Inspection Interval: 12 months or 365 days?

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Colonel Sanders
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Annual Inspection Interval: 12 months or 365 days?

Post by Colonel Sanders »

This might have been discussed here before ...

Simple question. If we look at CAR 625 App B we find
the following:

http://www.tc.gc.ca/eng/civilaviation/r ... 1-3008.htm

which says:

-- cut --

Type: Non-commercial Small aircraft - Excluding pressurized turbine-powered aircraft and balloon.

Interval: Appendix B, Part I @ 12 months + Appendix C

-- cut --

Note that the above does NOT say 365 days for the interval. It
says 12 months.

Let's say the annual was performed 7 Sep 2010. Is the next
annual due 7 sep 2011, 8 sep 2011, or 1 oct 2011.

I think the correct answer is 1 oct 2011. Am I full of sh1t as
usual?

Now onto out-of-phase CAR 625 App C for a similar discussion.
Picking compass randomly, look at CAR 625 App C(10) which
says:

-- cut --

(a) Except as provided in (b) and (c), non-stabilized magnetic direction indicators shall be calibrated, and a dated correction card installed for each indicator, at at intervals not exceeding 12 months;

-- cut --

Same question applies as to annual inspection on 7 sep 2010.

Is the compass due 7 sep 2011, 8 sep 2011 or 1 oct 2011?

Obviously the same question could be asked of any other
out-of-phase item with similar "12 month" interval (not 365
day interval) specification.

This isn't really an AME question. Every private light aircraft
operator/pilot in Canada should know the answer to this
question, and I am embarrassed to say that I only have
an opinion on this - not surprisingly, the longest interval.
Does anyone have an interpretation from TC on this?

PS In the USA, the FAA clearly uses the "1st day of the
following 13 month" interpretation.
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Big Pistons Forever
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Re: Annual Inspection Interval: 12 months or 365 days?

Post by Big Pistons Forever »

625.86(2)

(a) As applicable to the type of aircraft, at intervals not to expire later than the last day of the 12th month, following the preceding inspection, Part I and Part II of the Maintenance Schedule detailed in Appendix B of these standards are approved by the Minister for use on other than large aircraft, turbine-powered pressurized aeroplanes, airships, any aeroplane or helicopter operated by a flight training unit under CAR 406, or any aircraft operated by air operators under CAR Part VII.
(amended 2007/12/30; previous version)
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crazy_aviator
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Re: Annual Inspection Interval: 12 months or 365 days?

Post by crazy_aviator »

if my inspection was done jan 5 2010 then it is due jan 31 2011 many AME s dont know that
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Re: Annual Inspection Interval: 12 months or 365 days?

Post by Big Pistons Forever »

crazy_aviator wrote:if my inspection was done jan 5 2010 then it is due jan 31 2011 many AME s dont know that
To be completely correct it is due 1 Feb. Your current inspection expires at midnight on the 31 Jan
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Re: Annual Inspection Interval: 12 months or 365 days?

Post by Colonel Sanders »

625.86(2)(a)
Thx BPF! That clears it up nicely.
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Re: Annual Inspection Interval: 12 months or 365 days?

Post by Hornblower »

Actually that standard is informational only and has no legislative authority. I would belive that it was defined in the standard because of section 28 of the Interpretation Act which states:

Where there is a reference to a period of time consisting of a number of months after or before a specified day, the period is calculated by

(a) counting forward or backward from the specified day the number of months, without including the month in which that day falls;


(b) excluding the specified day; and


(c) including in the last month counted under paragraph (a) the day that has the same calendar number as the specified day or, if that month has no day with that number, the last day of that month


Kinda surprised you wouldn't be up on all that legal stuff what with your litigious experience and all.
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Re: Annual Inspection Interval: 12 months or 365 days?

Post by Colonel Sanders »

My apologies - I had an opinion on it, but no reference to back it up.

Thanks!
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Re: Annual Inspection Interval: 12 months or 365 days?

Post by Big Pistons Forever »

Hornblower wrote:Actually that standard is informational only and has no legislative authority. I would belive that it was defined in the standard because of section 28 of the Interpretation Act which states:

Where there is a reference to a period of time consisting of a number of months after or before a specified day, the period is calculated by

(a) counting forward or backward from the specified day the number of months, without including the month in which that day falls;


(b) excluding the specified day; and


(c) including in the last month counted under paragraph (a) the day that has the same calendar number as the specified day or, if that month has no day with that number, the last day of that month


Kinda surprised you wouldn't be up on all that legal stuff what with your litigious experience and all.
Well you learn something new every day ! Thanks Hornblower
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Re: Annual Inspection Interval: 12 months or 365 days?

Post by hangarline »

Big Pistons Forever wrote:To be completely correct it is due 1 Feb. Your current inspection expires at midnight on the 31 Jan
This is true, however be careful of any AD's that are carried out at the same time as the annual inspection as they expire before the annual does.
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Re: Annual Inspection Interval: 12 months or 365 days?

Post by Colonel Sanders »

Correct - theoretically AD's are really out-of-phase maintenance items.

An AD might be due before next flight, or after the next 10 hrs in service,
or every 25 hours.

Given that the exhaust muff AD CF-90-03R2 applies to virtually every
light aircraft in Canada (except mine, which don't have cabin heat):

http://wwwapps3.tc.gc.ca/Saf-Sec-Sur/2/ ... CF-90-03_2

And it specifies the following interval:
at intervals not to exceed one year or 150 flight hours, whichever occurs first
What is the definition of "one year" with respect to CF-90-03R2 ? Is it 365 days,
or the 1st day of the 13th month, like the annual?

I think it's 365 days, so you're pooched on taking the annual out to the end of the month
if you have cabin heat.

Interesting that US 2011-10-09 (Cessna seat rail) says "12 calendar months". I presume
they really mean 365 days, not until the 1st of the following 13th month.
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Re: Annual Inspection Interval: 12 months or 365 days?

Post by Big Pistons Forever »

The exhaust muff AD is unusual as it specifies a 10 hour tolerance for the 150 hour interval. Normally you can't exceed the AD calendar or time limits under any circumstances. BTW my AME treats the "annual" requirement for the AD the same way as the whole annual inspection (this is for my Grumman AA1B operated under CAR 602). That is the inspection gets doen as part of he annual and so there may be more than 365 days between inspections but it will still be inside the same month.
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Re: Annual Inspection Interval: 12 months or 365 days?

Post by rahre »

When your AD,s are done has nothing to do with how your AME treats them ,it is completly up to the owner of the aircraft to make sure that all AD,s and inspections are done on time. Your AME has no authority to "sign out" AD,s
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Re: Annual Inspection Interval: 12 months or 365 days?

Post by Hornblower »

I guess what you are saying Rahre, is that in fact there is no need to ever "sign out" an AD. Where an AD requires maintenance, the maintenance will need to be released as per the 605.85 requirement, or if elementary work is involved, the details of that will have to be entered in the tech log IAW the 571.03 requirement. If the AD does not apply, or if it involves something like a AFM or maintenance schedule amendment/revision, nothing other than compliance is required.
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Re: Annual Inspection Interval: 12 months or 365 days?

Post by tiggermoth »

When your AD,s are done has nothing to do with how your AME treats them ,it is completly up to the owner of the aircraft to make sure that all AD,s and inspections are done on time. Your AME has no authority to "sign out" AD,s
Oh, thats neat. So if an AD comes out on my C-172 that says "remove the vertical stabilizer to check for corrosion" I can go ahead and do it myself, as the AME can not sign it out anyway :mrgreen: :mrgreen: :roll: (okay, I am a bad example because in my airplanes case, I am the owner, but I am also an AME M1)

Rahre, yes AME's can "sign out" the AD's. They always have, and always will. In fact there are many AD's that require an AME sign out due to the scope of work involved in performing said AD. Where your confusion is coming from is the fact that it is the owners responsibiity to ensure that the AD has been performed. If you take your airplane in for an annual, and the AME does not do the shroud heater AD, it will come back on you, not the AME, because you did not ask or make sure that they did it. Now, if you go in and say "hey man, when you do my annual, make sure you look after all the AD's", then they will do, and sign out, the applicable AD's.

Thats the difference:

-you, as the owner, make sure the AD's have been carried out.
-the individual (AME) who performed said AD is the one who signs it out.
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Re: Annual Inspection Interval: 12 months or 365 days?

Post by CpnCrunch »

Hornblower wrote: Tue Dec 06, 2011 6:46 pm Actually that standard is informational only and has no legislative authority. I would belive that it was defined in the standard because of section 28 of the Interpretation Act which states:

Where there is a reference to a period of time consisting of a number of months after or before a specified day, the period is calculated by

(a) counting forward or backward from the specified day the number of months, without including the month in which that day falls;


(b) excluding the specified day; and


(c) including in the last month counted under paragraph (a) the day that has the same calendar number as the specified day or, if that month has no day with that number, the last day of that month


Kinda surprised you wouldn't be up on all that legal stuff what with your litigious experience and all.
Just to clear up a misconception here, Section 28 of the interpretation act is day-for-day, so if it say 12 months then it means 12 months to the same day (unless that day doesn't exist, in which case it's the end of the month).

BPF was correct, it is Standard 625.86(2) that applies here, and means the annual inspection doesn't need to be done until the end of the month. Those standards are referenced from CAR 605.86 (1):
605.86 (1) Subject to subsection (3), no person shall conduct a take-off in an aircraft, or permit a take-off to be conducted in an aircraft that is in the person’s legal custody and control, unless the aircraft is maintained in accordance with

(a) a maintenance schedule that conforms to the Aircraft Equipment and Maintenance Standards;
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Re: Annual Inspection Interval: 12 months or 365 days?

Post by ant_321 »

CpnCrunch wrote: Mon Apr 03, 2023 7:50 am
Hornblower wrote: Tue Dec 06, 2011 6:46 pm Actually that standard is informational only and has no legislative authority. I would belive that it was defined in the standard because of section 28 of the Interpretation Act which states:

Where there is a reference to a period of time consisting of a number of months after or before a specified day, the period is calculated by

(a) counting forward or backward from the specified day the number of months, without including the month in which that day falls;


(b) excluding the specified day; and


(c) including in the last month counted under paragraph (a) the day that has the same calendar number as the specified day or, if that month has no day with that number, the last day of that month


Kinda surprised you wouldn't be up on all that legal stuff what with your litigious experience and all.
Just to clear up a misconception here, Section 28 of the interpretation act is day-for-day, so if it say 12 months then it means 12 months to the same day (unless that day doesn't exist, in which case it's the end of the month).

BPF was correct, it is Standard 625.86(2) that applies here, and means the annual inspection doesn't need to be done until the end of the month. Those standards are referenced from CAR 605.86 (1):
605.86 (1) Subject to subsection (3), no person shall conduct a take-off in an aircraft, or permit a take-off to be conducted in an aircraft that is in the person’s legal custody and control, unless the aircraft is maintained in accordance with

(a) a maintenance schedule that conforms to the Aircraft Equipment and Maintenance Standards;
Thanks for sorting that all out 11 years later. Haha
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Re: Annual Inspection Interval: 12 months or 365 days?

Post by Bug_Stomper_01 »

ant_321 wrote: Mon Apr 03, 2023 7:57 am
CpnCrunch wrote: Mon Apr 03, 2023 7:50 am
Hornblower wrote: Tue Dec 06, 2011 6:46 pm Actually that standard is informational only and has no legislative authority. I would belive that it was defined in the standard because of section 28 of the Interpretation Act which states:

Where there is a reference to a period of time consisting of a number of months after or before a specified day, the period is calculated by

(a) counting forward or backward from the specified day the number of months, without including the month in which that day falls;


(b) excluding the specified day; and


(c) including in the last month counted under paragraph (a) the day that has the same calendar number as the specified day or, if that month has no day with that number, the last day of that month


Kinda surprised you wouldn't be up on all that legal stuff what with your litigious experience and all.
Just to clear up a misconception here, Section 28 of the interpretation act is day-for-day, so if it say 12 months then it means 12 months to the same day (unless that day doesn't exist, in which case it's the end of the month).

BPF was correct, it is Standard 625.86(2) that applies here, and means the annual inspection doesn't need to be done until the end of the month. Those standards are referenced from CAR 605.86 (1):
605.86 (1) Subject to subsection (3), no person shall conduct a take-off in an aircraft, or permit a take-off to be conducted in an aircraft that is in the person’s legal custody and control, unless the aircraft is maintained in accordance with

(a) a maintenance schedule that conforms to the Aircraft Equipment and Maintenance Standards;
Thanks for sorting that all out 11 years later. Haha
I love me a necropost lol. Here is an update to the CAR

625.86(2)
2)
(a) As applicable to the type of aircraft, at intervals not to expire later than the last day of the 12th month, following the preceding inspection, Part I (https://tc.canada.ca/en/corporate-servi ... cars#part1) and Part II (https://tc.canada.ca/en/corporate-servi ... cars#part2)
of the Maintenance Schedule detailed in
Appendix B (https://tc.canada.ca/en/corporate-servi ... tions-cars)
of these standards are approved by the Minister for use on other than large aircraft, turbine-powered pressurized aeroplanes, airships, any aeroplane or helicopter operated by a flight training unit under CAR 406, or any aircraft operated by air operators under CAR Part VII.
(amended 2007/12/30)
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