Used Parts from Foreign Aircraft

[CamAero]

The requirement for the installation of a used part on an airworthy aircraft in Canada is that that part be traceable back to its last "airworthy installation".

(Airworthy: "Fit and safe for flight and in conformity with its type design.")

Lets say in my hypothetical world, I have a DHC-6 airframe registered, 8Q-MZP. (A country with which Canada has no Bilateral Agreement and no 'Memorandum of Understanding'.)

Now lets say that I wish to use parts from 8Q-MZP on my Canadian registered DHC-6.

I have spent some time trying to decipher Airworthiness Notice AN BO-73. Here is a link to it: http://www.tc.gc.ca/eng/civilaviation/s ... 3-2642.htm

The following is an excerpt from BO-73:

If the aircraft was not a Canadian aircraft, the part may require additional maintenance prior to being accepted. The part must be inspected for condition and a maintenance release signed prior to installation. Ref. CAR 571.08.

Oddly in a way, BO-73 does not say "If the aircraft does not have a Canadian Certificate of Airworthiness.."

While I think I recognise the intent, "Canadian Aircraft" infers to me that simply a Canadian C of R would fit the bill.

And, the following is from CAR 571.08(2):

No maintenance release document is required where the part is an airworthy part that has been removed from an aircraft and installed on another aircraft with no intervening storage period. The identification of the aircraft from which the part was removed, and any other details necessary to establish the technical history of the part, shall be entered in the recipient aircraft’s technical record.

So, my question is, is there a significant advantage to registering the aircraft in Canada prior to using any parts from it on a Canadian registered one?

Can anybody here cite examples of where they have seen operators run into trouble in this regard?




Thanks in advance.

C.A.

[photofly]

I'm afraid I can't address your direct question, but have you considered the difficulties involved in registering a foreign-registered aircraft as Canadian?

[CamAero]

AFAIK, all you do is fill out this form and send it in or bring it by your regional T.C. office, along with a bill of sale.

http://www.tc.gc.ca/media/documents/ca- ... -02_bo.pdf

A Canadian Certificate of Airworthiness is an entirely different matter, however.

C.A.

[Valkyrie_XB70]

I am in no way an expert on the CARs but I would interpret that to mean the part you want to install must be re-certified or have NDT testing to verify that it is airworthy. However you might be able to submit the associated paperwork to TC and get it approved. Myself I would be very wary of installing a part from a foreign aircraft without doing a lot of fact checking. For all you know it could have be "ridden hard and put away wet".

[Colonel Sanders]

TC is going to get very angry at you, when they discover
this loophole of registering an aircraft with no intent to
get a C of A, to use as a parts donor.

In fact, they may deny you a C of R if you tell them you
have no intention of ever getting a C of A.

PS If you're going to pull this trick, you must first de-register
the aircraft with the foreign nation, which must notify TC. An
aircraft cannot be registered in more than one country at any
one time.

[photofly]

I hope you're right; but this page entitled "how do I Register My Imported Aircraft in Canada?"
http://www.tc.gc.ca/eng/civilaviation/s ... t-2037.htm
lists, as the very first you "must" do:

meet airworthiness requirements for importation into Canada

[Colonel Sanders]

that would seem to imply that you get a C of A
before a C of R, which is not the case.

[GyvAir]

meet airworthiness requirements for importation into Canada

Are they referring to type certificate, rather than CofA?

[photofly]

I believe that an MD-M needs to certify that it complies with its type certificate, yes - but that's not a trivial process for an aircraft that's airworthy; hard to see that it would be easier for one that isn't.

[Colonel Sanders]

I think it means that the aircraft is eligible
for a C of A in Canada.

Many aircraft are not.

[CID]

This has a very simple answer. First, the language used in Airworthiness Notices is not perfect. The CARS are the authoritative documents. In this case I think the intent is clear. No loophole, especially since it's an AN.

An aircraft with a C of R and no C of A isn't a good parts source. Is the C of A out of force because some or all of the parts are worn (not safe) or have no airworthiness documentation that is acceptable to TC? (non-conforming)

The international agreements are in place to ensure that aircraft and their parts meet a level of safety acceptable to the signatories. Aircraft from countries who do not have a formal agreement in place with TC (BASA, MOU, TA etc) therefore do not have "airworthy" parts in the eyes of TC.

So...no. You can't take parts removed from foreign aircraft and legally install them on Canadian registered aircraft and maintain your C of A unless that country has an airworthiness agreement with Canada or you have the part certified in a shop with the authority to issue the proper maintenance release.

[CamAero]

I hope you're right; but this page entitled "how do I Register My Imported Aircraft in Canada?"
http://www.tc.gc.ca/eng/civilaviation/s ... t-2037.htm
lists, as the very first you "must" do:

meet airworthiness requirements for importation into Canada

One of the inevitable convolutions to this discussion is C of A requirements being confused with C of R.

Photofly, the link you provided, and as Hedley points out, seems to be talking about importing an aircraft. In a way, its title puts the cart before the horse, as you can have an aircraft with a Canadian C of R which has not been "imported"; ie. (does not have a Canadian C of A).

CID, I hear what you are saying, however, one of my quotes in my first post was:

CAR 571.08(2)
No maintenance release document is required where the part is an airworthy part that has been removed from an aircraft and installed on another aircraft with no intervening storage period. The identification of the aircraft from which the part was removed, and any other details necessary to establish the technical history of the part, shall be entered in the recipient aircraft’s technical record.

So, by your take on it, if I grabbed the pilot's seat cushion out of DHC-6, 8Q-MZP and installed it in my Twatter, C-GMPJ, with no intervening storage period and a log entry to the effect; "Pilot's seat cushion P/N XXXXX installed as removed from 8Q-MZP. The described maintenance has been performed in accordance with the applicable standards of airworthiness.", what CAR would I be charged under?

Valkyrie, you have raised a good point as well. I do hope that said cushion was not; "ridden hard and put away wet" as people in foreign countries, particularly warm, moist ones are wont to do.


CA

[CID]

CamAero, you can't take the CARS out of the context of aircraft that have a Canadian C of A or operate under an airworthiness authority that is formally recognized by The government of Canada.

So you're not removing an "airworthy part". In the context of the CARS, a part removed from an airplane that isn't eligible for a Canadian C of A or a foreign flight authority that is formally recognized by the government of Canada is not "airworthy". It's almost the same as taking parts off a car in a junk yard and installing them on your airplane. Transport Canada doesn't recognize those as airworthy parts either.

What CAR would you be in violation of? For starters, 571.08(2). The exact paragraph you are referring to.

[CamAero]

OK CID, I see what you're getting at. What would be a legal means of installing that cushion? What would you do?

[SeptRepair]

Do an undocumented parts procedure. Here is a snippet of Standard 571 appendix H.

"5. Part considered authentic: Consider the following factors when evaluating the authenticity of the part:

(a) the origin of the part (i.e. was the part received from a reliable source?);

(b) documentation such as packing slip, manufacturer’s identification tag, identity of component from which the part was removed; and

(c) part nomenclature, part number, serial number, manufacturer’s identification marks or stamps found on the part."

[Heliian]

You would need to re-certify the part before installation. Re-certifying a part could be as simple as a visual inspection or as much as a full overhaul depending on what it is. To re-certify a part one must be an AMO appropriately rated by TC.

Otherwise, everyone and their brother would be buying undocumented junk from the far corners of the earth and putting it on their a/c. Not that it doesn't happen, it's just against the law.

[CID]

What they said!

(Which is basically what I said in my first post on this topic)

[CamAero]

With DHC-6 on my AMO ratings Certificate, and following SeptRepair's instructions from STD 571 Appendix H for Undocumented Parts , could I "recertify" my seat cushion?

There's nothing to say that the parts I have are undocumented though>?

8Q-MZP has impeccable records.

CA

[SeptRepair]

Sure you can. use due diligence and ITRAN it. Make sure your AMO has the procedure for undocumented parts approval. All you would be doing is giving that part a maintenance release, thus certifying it.

[CamAero]

OK - thanks SeptRepair, CID et al.

Appreciate.

CA

[CID]

Basically, see if you can establish where the part originated (should be no problem if the records are "impeccable") then inspect it to see if it can be traced to those records and if it's serviceable and if its ever been modified.

That should do it for a seat cushion.

Other components may need to go through a certified repair shop depending on what it is.