Regulations and Exemptions

Q9.  The recent update to Standard (Std) 573.06 of the Canadian Aviation Regulations (CARs) introduces training requirements related to safety management systems (SMS) (Std 573.06 (8)). While some of the training requirements were in place previously (e.g. Human Factors), there are some more specific requirements now being identified.

CAR 107 specifies that SMS only applies to AMOs that can perform maintenance accomplished on aircraft operated under Subpart 705 of the CARs.

The exemption only applies to AMOs that can perform maintenance accomplished on aircraft operated under Subpart 705 of the CARs.

Is Std 573.06(8) applicable to all AMOs?

Standard 573.06 (8) states:

"(8)  Training of maintenance safety personnel

The person responsible for maintenance and all personnel assigned duties under the safety management system established pursuant to section 573.30 of the CARs shall successfully complete a safety related initial training course that includes the following subjects:

(a)  maintenance and flight safety philosophy;

...; and

(g)  incident investigation."

The training requirement apply to:  (a) The person responsible for the maintenance (of an organization that has an SMS mandated by CAR 573.30); and (b) personnel assigned safety management system duties (of an organization that has an SMS, mandated by CAR 573.30)...

CAR 573.30 mandates an SMS “... in respect of an applicant for, or a holder of, an approved maintenance organization (AMO) certificate authorizing the holder to perform maintenance on an aircraft operated under Subpart 5 of Part VII ...”

Therefore, Std 573.06 (8) does not apply to all AMOs. It applies to “applicant for, or a holder of, an approved maintenance organization (AMO) certificate authorizing the holder to perform maintenance on an aircraft operated under Subpart 5 of Part VII”. There are no new requirements as suggested in the question above.

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